[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.
[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.
[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.
[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.