Tug & Barge Seatime under new rules?

The new USCG rules allow for using the combined tonnage of the tug and barge for unlimited tonnage seatime on a 2 for 1 basis upto 50 percent of the required seatime.

However, most of us will not have any seatime letters including the barges that we have towed for various companies over the last 30 years. Many of the old employers are now out of business, or will not have records of the barges that we towed years ago. This will be especially true of customer owned barges.

As a practical matter, how are we supposed to document this combined tug and barge seatime?

Can we self certify it?

I thought this was already set up under 46 CFR Part 11.211 (d)? Are these new regulations similar but somehow different? 11.211 (d) has been around for years. Also, are you sure these new regulations are supposed to apply to any and all barges or tows? The “rigidly connected composite unit” thing makes sense, but getting unlimited sea time for towing an unlimited-tonnage barge astern doesn’t add up in quite the same way.

So…does this mean we will have a new 719S on the way that will have a space for that information? Can I retroactively go back to my previously submitted seatime letters and edit/modify the information to the new allowable tonnage…Do I need all new seatime letters from all my past employers with the new tonnage data? For signed seatime letters I haven’t yet submitted, can I just add the tonnage to the 719S or does this have to be re-verified through the company? What ancillary issues will pop up when our seatime tonnage goes from <200 to >1600 ?
Any info on how this might be implemented?
I hope JD Cavo chimes in on this…

[QUOTE The “rigidly connected composite unit” thing makes sense, but getting unlimited sea time for towing an unlimited-tonnage barge astern doesn’t add up in quite the same way.[/QUOTE]

[I]Why not? Does the barge go away or something?[/I]

[QUOTE=highseasharry;131021]

Why not? Does the barge go away or something?[/QUOTE]

I understand your point, when you’re towing no matter what the case may be you still have to maneuver the giant hunk of steel but the handle characteristics of towing a barge astern are vastly different from pushing one ahead or towing on the hip. Even pushing one ahead on wires is vastly different than pushing one ahead on pins. A rigidly connected composite unit handles a lot more like a ship but with the added advantage of the fact that the tug and barge units can become separate if need-be. Towing or pushing on the wire is just too different to justify counting combined sea time.

[QUOTE=highseasharry;131021]

[I]Why not? Does the barge go away or something?[/I][/QUOTE]

To be logically consistent if towing a barge with a 199 ton tug is good for unlimited time shouldn’t you have to have a unlimited tonnage license to do it?

Now that would truly suck.

[QUOTE=Kennebec Captain;131043]To be logically consistent if towing a barge with a 199 ton tug is good for unlimited time shouldn’t you have to have a unlimited tonnage license to do it?[/QUOTE]

no. It’s just a reasonable upgrade path to third mate which is the entry level unlimited license.

[QUOTE=tugsailor;131055]no. It’s just a reasonable upgrade path to third mate which is the entry level unlimited license.[/QUOTE]

2 for 1 up to 50% makes sense.

[QUOTE=captjamied;130773]So…does this mean we will have a new 719S on the way that will have a space for that information? Can I retroactively go back to my previously submitted seatime letters and edit/modify the information to the new allowable tonnage…Do I need all new seatime letters from all my past employers with the new tonnage data? For signed seatime letters I haven’t yet submitted, can I just add the tonnage to the 719S or does this have to be re-verified through the company? What ancillary issues will pop up when our seatime tonnage goes from <200 to >1600 ?
Any info on how this might be implemented?
I hope JD Cavo chimes in on this…[/QUOTE]

I’m mostly avoiding this as I have no idea how you’re going to document the aggregate tonnage for any given day during your time on the boat. It’s not the form of the document, it’s how you’re going to get the specific tonnages on a day by day basis. That obstacle is going to make it extremely difficult to do this retroactively. Going forward, I’d suggest getting and/or keeping daily documentation. It’s likely you will need to identify the specific barges in the tow so their tonnages can be verified.

You can’t “change” the 719S, you can’t use the 719S unless the vessel (or in this case, vessels) are less than 200 GRT (in this case, aggregate) and the form is signed by the owner and operator. I doubt that is the case here.

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[QUOTE=Kennebec Captain;131043]To be logically consistent if towing a barge with a 199 ton tug is good for unlimited time shouldn’t you have to have a unlimited tonnage license to do it?[/QUOTE]

That would mean the only way to get an unlimited license would be to work on an “unlimited” vessel on deck. You wouldn’t be able to use time as Mate or Master on a vessel of lesser tonnage to upgrade to the next tonnage increment.

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[QUOTE=tugsailor;131055]no. It’s just a reasonable upgrade path to third mate which is the entry level unlimited license.[/QUOTE]

With the new change lowering the minimum tonnage from 200 GRT to 100 GRT, yo can probably qualify for 3rd Mate at the same time as Mate 1600, and before you have enough time for Master 1600.

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[QUOTE=PaddyWest2012;130772]I thought this was already set up under 46 CFR Part 11.211 (d)? Are these new regulations similar but somehow different? 11.211 (d) has been around for years. Also, are you sure these new regulations are supposed to apply to any and all barges or tows? The “rigidly connected composite unit” thing makes sense, but getting unlimited sea time for towing an unlimited-tonnage barge astern doesn’t add up in quite the same way.[/QUOTE]

The regulation you cite is for ATBs/ITBs, and has been around a long time. The one that was the subject of the original post is a new regulation and applies to tows that are not part of an ATB or ITB. The issue is how you are going to document the aggregate tonnage of the entire tow when the barges in the tow change often, sometimes several times in a single day (think of the math “word problem” about the bus, “…at the next stop, 2 passengers get on and 3 get off…”). If the documentation issue can be overcome, it mostly benefits inland and river push boats.

The change from over 200 to over 100 makes it possibly for those of us with a lot of 199 ton tug time to sit for third mate but only with a 2000 ton limitation

I can’t image what a master 1600 might do with a third mate 2000.

To have a useful third mate license it would be necessary to have at least authority for 6000

Some of us tow the same barge for weeks if not months at a time. The largest barge that I have towed was 17,000 GRT. It would be nice to get some credit for that to help bump my tonnage limit up. There have been quite a few 5000 ton barges.

If you’re keeping track of things for recency, shouldn’t be an issue.

[QUOTE=z-drive;131102]If you’re keeping track of things for recency, shouldn’t be an issue.[/QUOTE]

Needless to say. I’m keeping track of all barges now. Years ago is the issue

The USCG should allow self certification for old barge seatime when the companies are out of business or no longer in business. It’s obvious that if we have documented old seatime on tugs, those tugs must have been towing something. The HP of the tug should help determine the legitimacy of the claimed barge size

Does anybody know if this combined tonnage seatime will work for lower license upgrade? I need time on vessels over 100 grt to upgrade to a 1600 ton master.

[QUOTE=Sharknado;143194]Does anybody know if this combined tonnage seatime will work for lower license upgrade? I need time on vessels over 100 grt to upgrade to a 1600 ton master.[/QUOTE]

The first sentence of 46 CFR Part 11.211-(d) reads: “Service on ATB or Dual Mode ITB units is creditable for an original deck officer endorsement or raise of grade of [B][U]any deck officer endorsement[/U][/B].” Therefor I would argue that combined tonnage is good for more than just unlimited tonnage upgrades.

It’s a giant load of horse crap! Academy folks want a freebie , they don’t want to ride a real ship and upgrade correctly so let’s get on a freaking tug and change the rules to call it a ship. A tugboat is a tugboat. (Articulated TUG and Barge)That’s it! You wanted that big license now go use it. Anybody who enters the towing industry with a unlimited license does it for experience or a lifestyle change so leave it like that. If you want a fight that makes a difference get some ship made back in the USA. Quit dumbing the system down. A tugboat and a OSV is not what you went to a prestigious academy for.

2000GRT will give you 4000 GT (ITC). Plenty of Large OSV’s out there you could serve on and keep bumping your tonnage up.

Go get on a ship. See yah.

I went to an academy specifically to work on workboats. Of course that’s what my major was centered around. I’ll just keep dumbing the system down while I’m here. So sorry…