[jdcavo]

[quote=stevefoster;17777]...I want my 1000 ton Freight and Towing license back............I asked for that in a letter to my evaluator and have not received any response to that issue....[/quote]

The change to the freight and towing license circa 1987 increased the authority of your license, from 1000 GRT to 1600 GRT. However, even if we kept this license, it would have been changed in the same rulemaking that created the towing vessel licenses that was part of the fallout from the Mauvilla/Amtrak Sunset Limited casualty in 1993. Part of the intent of that rulemaking was to make all mariners on towing vessels, regardless of the specific license they hold perform practical demonstrations of their ability to operate a towing vessel. Asking for the long-gone Master of Freight and Towing Vessels license is not going to lead to anything but a diminution of your credibility, it will make it easier to dismiss any valid comments you have.

The above notwithstanding, you could have been grandfathered to the license when you renewed between 2001 and 2006. But your opportunity to do so has since passed. One of the reasons you cannot avail yourself of the grandfathering now is the general intent of the current regulations, and for the grandfathering. The grandfathering was intended solely to allow working mariners on towing vessels to transition to the new license with minimal disruption (hence the timing based on the renewal of the existing license). However, the long-term intent was clearly that if you don’t use it, you lose it, as evidenced by the requirements to renew the license in 46 CFR 10.227(d)(8)(D)(vi)(A) [formerly 46 CFR 10.205(c)(iv)(6)(i)]. This regulation requires a mariner who already holds Mate or Master of towing vessels renewing their license to complete the maneuvering and handling section of the TOAR (section D) if they do not have towing experience in the past 5 years. Clearly, if a mariner who got the “new” license but doesn’t have recent experience has to re-do the TOAR, someone who hasn’t been on a towing vessel for 20+ years should be subject to the same requirement. So even if you were grandfathered, you couldn't renew without towing experience or re-doing the manuevering part of the TOAR.

[EDITED TO CORRECT TYPOS]