Does anyone remember the citation for the rule that the lowest tonnage limitation possible is 2000grt / 4000gt?
46 CFR Subpart D 11.402 deals with tonnage limitations. I don’t recall ever reading anywhere where a minimum tonnage limitation was spelled out.
I had a eureka moment 30 minutes ago. It isn’t in the CFRs but in a policy letter…
If you ever wind up with an evaluator claiming that your tonnage limit on an AGT license would be only 1000 grt so there is no point in getting it because your 1600 grt license is bigger, direct them to [B][I]policy letter 11-12, section 4 (d)[/I][/B].
Policy Letter 15-02 spells it out quite clearly, including the formula for calculating the tonnage restriction.
I believe the most significant difference is the old policy letter did not make any stipulations for itc tonnage so your limit was 2000grt, period, not also 4000 gt itc.
As Diesel pointed out, there is a formula for tonnage, but the lowest tonnage I have heard anyone having was 2,000 tons. I am sure there could go lower, but all the people I have crossed paths with, that was the restriction I have heard.
That is the lowest grt they are supposed to issue. Not all evaluators are aware of that though, some have tried to issue 1,000 grt restrictions and had to be pointed to the policy letter saying 2,000 grt is the lowest. There is also supposed to be an itc equivalent tonnage on there, not to be lower than 4,000 gt itc.
[QUOTE=Capt. Phoenix;67843]That is the lowest grt they are supposed to issue. Not all evaluators are aware of that though, some have tried to issue 1,000 grt restrictions and had to be pointed to the policy letter saying 2,000 grt is the lowest. There is also supposed to be an itc equivalent tonnage on there, not to be lower than 4,000 gt itc.[/QUOTE]
Yup exactly right, and Policy Letter 11-12 just came out superseding 15-02, and as was stated the biggest change was adding the ITC equivalency. Which is a huge factor on lots of today’s vessels. Most of the new OSV’s don’t even have domestic tonnages.
Despite what we may think from reading policy letter 11-12, the nmc is not endorsing restricted agt licenses for itc tonnage. Apparently this has gone to cg hq for clarification with no answer yet. I an going to try the appeals process. If I succeed, I hope future applicants won’t need to deal with this problem.
What is the point of posting the policy letter without any explanation? We know what it says…
[QUOTE=Capt. Phoenix;69280]Despite what we may think from reading policy letter 11-12, the nmc is not endorsing restricted agt licenses for itc tonnage. Apparently this has gone to cg hq for clarification with no answer yet. I an going to try the appeals process. If I succeed, I hope future applicants won’t need to deal with this problem.[/QUOTE]
Keep us in the loop, I’m about to fight he same battle…
Anyone have an update on this yet? I have a AB that just upgraded to a 3/M with a GRT only tonnage limitation. I am trying to help him figure out how this his license would qualify him (or not) to sail on a vessel that is only measured under ITC. When he talked to the folks at 888 I ASK NMC (for as little as that is typically worth) they said no ITC tonnage would be endorsed period. I recommended that he try and talk to an evaluator (read roll the dice), but it sounds as if this issue is above that level as well. PM me if you prefer.
[QUOTE=Capt. Phoenix;69427]What is the point of posting the policy letter without any explanation? We know what it says…[/QUOTE]
uhhh so we can read it…
Try this one Policy Letter 11-12
Removed post.