For the past year (plus) I have been working AHTS vessels and not using my unlimited Ch. Mate or my DP certs, but I figured I would take the opportunity to get my MOTV while I was taking a bit of a break from twelve hour DP watches.
My licence is up for renewal and I went through the entire TOAR thoroughly, and submitted it along with explanations of how, when, and where each was completed. There were two assessments however that were legitimately “Not Applicable” and I noted them as such with explanations:
- Transition from inland rules to international - The vessels I am working on never enter waters where inland rules apply - they work mostly in S.E. Asia and never in the U.S.
- Operate “Pushing Gear” - These are AHTS with no pushing gear.
They replied saying these “were not optional” and must be completed.
I was considering filing an appeal (including an essay type reply to each of the above demonstrating a knowledge of both pushing gear and what all is involved with an inland/intl transition) but didn’t want to risk a delay of my renewal.
Anyone have any experience with this particular issue?
They also made a comment that my service thus far “may be outside the scope of my present license”. It is a foreign flagged vessel working outside the US, and the endorsing flag state has no problems with my current credentials - the USCG could choose not to recognize this time for sea service credit I guess - any experience with this one?
Thanks in advance for any assistance. I am not too concerned with anyone’s advice on “how it should be” but prefer any experience on “how it is”, since we all know when dealing with the USCG that reason, logic, and “how it should be” rarely reflect the reality of the bureaucracy.