Licensing Appeal Process

[lonewinds]

Looking to renew an out-of-grace license from OUTV to the new Master of Towing Vessels - Western Rivers. Told by the NMC today that although I can retest the written portion of my License, I will be required to be examined by a "Towing Officer Assessment Report (TOAR)" that could take months. Even tho I safely operated heavy tows for 15 years on the Lower Miss.

The catch is, I can't legally operate a towboat to be examined for the Assessment Report without a License, but I can't get that License without an Assessment Report. This straight from the NMC's representative.

Any suggestions? Can an appeal be lodged successfully with the NMC? Does anone have firsthand appeal knowledge?

Thanks in advance for your help

[dougpine]

Unless I'm mistaken, you're in the "oops I wish I never let my license expire" category. Do you qualify for a 200 ton Master of Inspected vessels? I believe if you hold that, you can do the "30 day wonder" route: 30 days on a tug, a completed TOAR, and you're good to go. I may have missed something there but I'm sure someone else will chime in.

Otherwise, you have to start from scratch by testing and trying to get a TOAR signed off.

[jdcavo]

Your first level of appeal is to request a reconsideration from NMC. If they upohold their original decision, you can then appeal to the Commandant of the Coast Guard. That appeal has to be sent to the NMC, but they forward it to Coast Guard HQ where it is decided. I can't speculate as to your chances of success, partly because appeals on this issue are very subjective and the decision is based on the unique circumstances of each marienr, and also because my office will be involved in any appeal to CG HQ. I would be remiss if I didn not warn that this entire process could also take months.