ITB Sea Time for Upgrade

[MateMatt]

I'm trying to upgrade my license from 3rd AGT to 2nd AGT. I've been doing research in the CFRs and can't really find any concrete information about if ITBs qualify as unlimited tonnage vessels. The only thing I've found is:

46 CFR 10.211
"(d) Service on a Dual Mode Integrated Tug Barge (ITB) unit is
creditable for original or raise of grade of any deck licenses. Service
on a Dual Mode ITB with an aggregate tonnage of over 1600 gross tons is
creditable on a two-for-one basis (two days experience equals one day of
creditable service) for up to 50 percent of the total service on vessels
over 1600 gross tons required for an unlimited license. The remaining
required service on vessels of over 1600 gross tons must be obtained on
conventional vessels or Push Mode ITBs."

What about ITBs that are not "dual mode"? The ITB that I work only comes out of the notch for inspections during yard periods. Otherwise, it never comes out. The combined gross tonnage for the tug and barge is 9336 tons. The tonnage for the tug is only 1218 gross tons. Should I get unlimited tonnage time for the time I spent on this? If not all of it, do I at least get 90 days toward my unlimited tonnage time?

Any insight or information about the matter would be greatly appreciated.

[jdcavo]

ITBs are considered dual mode ITBs for the purposes of applying 46 CFR 10.211.

[50thState]

ITBs are considered dual mode ITBs for the purposes of applying 46 CFR 10.211.

I'm confused, if his vessel doesn't count as a push mode ITB, then what does?

[MateMatt]

Does this mean that, if I spent over 180 days on this ITB, I should get 90 days unlimited time toward my upgrade?

[cappy208]

Read the COI. It should have a paragraph that tells everyone what type, construction the vessel is.

I would be willing to bet it is listed as a 'dual mode' ITB. Even though it is incapable of operating out of the ITB framework, this is part of the 'loophole' that these ITB's operate under.

Sorta 'tupid if you ask me!

Your CFR only applies to Dual Mode ITBs. The previous 3 paragraphs do NOT mention any other type of ITB. You may have to argue the point, that your ITB is NOT a "Dual Mode" ITB and back it up with creditable info. But I am sure you will need to go the extra mile to prove your case. This is one problem when dealing with NMC from afar, versus dealing with your local REC. But hey.... aiin't progress grand?!

[jdcavo]

cappy208 is right. For more info on the differences, see NVIC 2-81 . Push-mode are regulated as a single vessel, and dual-mode are regulated as a tug and barge. Note the differences in manning on pages 7 and 8 of the NVIC.