Upgrading unlimited license on ATB

I hold a 3rd Mate’s unlimited. So far I have a sea service letter documenting 120 days on a vessel <1600 GT. From what I’ve read in the CFRs, 50% of seatime for an unlimited license upgrade can come from service on such a vessel.

I’ve currently have the rest of the 365 done, but it was on a coastwise ATB (w. Intercon pins). The tug itself is <500GT, but with the barge is well over 1600GT. All of the work is done pushing, we don’t even have a winch, we’re married to the same barge all the time, and frequently go offshore. I met a federal MS River pilot that claimed he upgraded an unlimited license from time on push boats and that all he had to do was provide documentation of the barge tonnages and the trips.

So the question is, is this actually possible? And if so, what route do I take to get it done… submit the paperwork as usual and debate it through the inevitable appeal process?


sorry, found another thread on this. admins feel free to delete this thread. thanks.