500GRT NC NMC seatime question? Mr.Cavo?

[coldcreepin]

I have applied for my 500GRT master NC. I got a letter back from NMC stating I have fulfilled my over all sea time requirement, but need 180 more days as master/mate/ equivalent over 50GRT while holding a license as master/mate/equivalent. True I have 750 days as mate over 50GRT, but only 180 days as a licensed mate over 50GRT.


"720 days of service MUST have been as a master, mate; master ormate (pilot) of towing vessels, or equivalent supervisory positionwhile holding an endorsement as master, mate, master or mate (pilot)of towing vessels, or operator of uninspected passenger vessels

360 days of the service as Master, Mate, or equivalent supervisoryposition, must have been on vessels over 50 GRT; " from 500GRT check list.

I meet the over all 1080 days, over 540 NC days, over 720 days as mate while holding license, "360 days of the service as Master, Mate, or equivalent supervisoryposition, must have been on vessels over 50 GRT" I have over 360 days as mate over 50GRT "but not 360 as mate over 50GRT while holding license.

I read this as the 360days as master/mate/equivelant doesn't need to been while holding license. The 720 requirements states while holding license, but the 360 over 50GRT says nothing about holding a license.

I have hundreds of sea time as mate from working inland "with out license, but as approved mate training program from the USCG" 99GRT passenger vessel, where a licensed mate wasn't required and hundreds of days as master under 50GRT while holding a license. Am I sadly wrong or is the evaluated at the NMC wrong?

Thank you, I hope I'm right, I have studied my ass off and , know i could pass my exam if i had the letter to test. I currently hold a 200GRT NC master.

[jdcavo]

I have applied for my 500GRT master NC. I got a letter back from NMC stating I have fulfilled my over all sea time requirement, but need 180 more days as master/mate/ equivalent over 50GRT while holding a license as master/mate/equivalent. True I have 750 days as mate over 50GRT, but only 180 days as a licensed mate over 50GRT.


"720 days of service MUST have been as a master, mate; master ormate (pilot) of towing vessels, or equivalent supervisory positionwhile holding an endorsement as master, mate, master or mate (pilot)of towing vessels, or operator of uninspected passenger vessels

360 days of the service as Master, Mate, or equivalent supervisoryposition, must have been on vessels over 50 GRT; " from 500GRT check list.

I meet the over all 1080 days, over 540 NC days, over 720 days as mate while holding license, "360 days of the service as Master, Mate, or equivalent supervisoryposition, must have been on vessels over 50 GRT" I have over 360 days as mate over 50GRT "but not 360 as mate over 50GRT while holding license.

I read this as the 360days as master/mate/equivelant doesn't need to been while holding license. The 720 requirements states while holding license, but the 360 over 50GRT says nothing about holding a license.

I have hundreds of sea time as mate from working inland "with out license, but as approved mate training program from the USCG" 99GRT passenger vessel, where a licensed mate wasn't required and hundreds of days as master under 50GRT while holding a license. Am I sadly wrong or is the evaluated at the NMC wrong?

Thank you, I hope I'm right, I have studied my ass off and , know i could pass my exam if i had the letter to test. I currently hold a 200GRT NC master.

I can't get directly involved with your specifics as it reelates to an open application at NMC, and you're asking about an appealable decision by the NMC. As my office handles appeals of NMC decisions, I cannot get involved as it may end up in my office fon appeal.

Im general, "equivalent supervisory position" means you were doing almost exactly the same things, including standing watches as the officer in charge of the watch. The relevant facts are not whether a licensed mate is required, but whether an unlicensed person is allowed to serve as the person incharge of the watch. It is usually applied to military service, the only instance I have seen it applied to commercial sewrvice was on a towing vessel in the oil service in the Gulf at a time in the recent past when the crews of those vessels were not required to have licenses or MMDs. I have never seen it applied to an inspected vessel required to have licensed officer(s).

[coldcreepin]

Thank Mr.Cavo,
Can you clairify 46 CFR 11.418, according to the CFR/500GRT check list the 720days as master/mate/equivalent must be as licensed master/mate/equivalent, but does the 360days over 50GRTas master/mate/equivalent have to be while holding a license?

If YES, I can appeal using my service as "Mate unlicensed" inspected vessel, as our vessel was approved and was issued a COI, to operate with a Licensed master and Company certified mate, who went thru the company uscg approved mate training program. The mate stood watch "solo" and took command of the vessel and her 499guest in the situation the master became inconpasitated . "I have over 400days in this role"

If NO, Just appeal quoting CFR 11.418, doesnt state 360days as mate is while holding a license.

Any thoughts are greatly appreciated!

[jdcavo]

Thank Mr.Cavo,
Can you clairify 46 CFR 11.418, according to the CFR/500GRT check list the 720days as master/mate/equivalent must be as licensed master/mate/equivalent, but does the 360days over 50GRTas master/mate/equivalent have to be while holding a license?

If YES, I can appeal using my service as "Mate unlicensed" inspected vessel, as our vessel was approved and was issued a COI, to operate with a Licensed master and Company certified mate, who went thru the company uscg approved mate training program. The mate stood watch "solo" and took command of the vessel and her 499guest in the situation the master became inconpasitated . "I have over 400days in this role"

If NO, Just appeal quoting CFR 11.418, doesnt state 360days as mate is while holding a license.

Any thoughts are greatly appreciated!

Yes. It says "one year of THE required service..." By using "the" it is referring to the previously mentioned two years of service while holding a license.

[Tcaptain]

I have worked on several passenger vessel where the COI allowed a "senior deckhand designated in writing" to fill the Mate position , including the 96 GRT 500 pass riverboat I was Captain of as well as her sister ship.

[jdcavo]

I have worked on several passenger vessel where the COI allowed a "senior deckhand designated in writing" to fill the Mate position , including the 96 GRT 500 pass riverboat I was Captain of as well as her sister ship.

I think you're misreading the COI. In every such COI I've seen, it required a senior deckhand to be designated in writing who can maintain "positive control" of the vessel. It's because there is only one licensed officer and it's so someone can steer the vessel and make sure it doesn't hit something in the event the one officer is incapacitated. That in no way authorizes them to serve in "the mate position."