Towing questions.

[coastal0423]

I hold a 1600 ton Inland Master, and 200 ton Near Coastal Master. Have been working on inland, and near coastal tugs for a few years now, gaining time and experiene on tugs. Question how do I get towing added to my credentials? I have been working on Toar's. Should I first submit a inland Toar since that license is over 200 ton, or will it make any difference? I take it I would receive a mate of towing once appropriate Toar's are complete? If anyone can help answer these questions it would certainly be appreciated. I have asked the NMC these same questions, they tell me to just submit what I have, and they will then review what I can get. I personally don't like wasting my time trying to get something if I'm not completely qualified.

[captbbrucato]

If I'm not mistaken, a completed TOAR is all you need to get the endorsement with your level of license. See highlighted text below.

[Code of Federal Regulations]
[Title 46, Volume 1]
[Revised as of October 1, 2010]
From the U.S. Government Printing Office via GPO Access
[CITE: 46CFR11.464]

[Page 159-160]

TITLE 46--SHIPPING

CHAPTER I--COAST GUARD, DEPARTMENT OF HOMELAND SECURITY

PART 11_REQUIREMENTS FOR OFFICER ENDORSEMENTS--Table of Contents

Subpart D_Professional Requirements for Deck Officers

Sec. 11.464 Requirements for endorsements as master of towing vessels.

(a) If you would like to obtain an endorsement as master of towing
vessels with a route listed in column 1 of table 11.464(a) of this
section, then you must complete the service requirements indicated in
columns 2 through 5. You may serve on the subordinate routes listed in
column 6 without further endorsement.

Table 11.464(a)--Requirements for Endorsement as Master of Towing Vessels \1\
----------------------------------------------------------------------------------------------------------------
Total TOS \3\ on T/V as TOS \3\ on Subordinate
Route endorsed service TOS \3\ on T/V as mate (pilot) not particular route
\2\ mate (pilot) as harbor assist route authorized
1 2 3................. 4................ 5............. 6
----------------------------------------------------------------------------------------------------------------
(1) OCEANS (O)................ 48 18 of 48.......... 12 of 18......... 3 of 18....... NC, GL-I
(2) NEAR-COASTAL (NC)......... 48 18 of 48.......... 12 of 18......... 3 of 18....... GL-I
(3) GREAT LAKES--INLAND (GL-I) 48 18 of 48.......... 12 of 18......... 3 of 18.......
(4) WESTERN RIVERS (WR)....... 48 18 of 48.......... 12 of 18......... 3 of 18.......
----------------------------------------------------------------------------------------------------------------
\1\ If you hold an endorsement as master of towing vessels you may have an endorsement-as mate (pilot) of towing
vessels for a route superior to your current route on which you have no operating experience--placed on your
MMC after passing an examination for that additional route. After you complete 90 days of experience and
complete a Towing Officer's Assessment Record on that route, we will add it to your endorsement as master of
towing vessels and remove the one for mate (pilot) of towing vessels.
\2\ Service is in months.
\3\ TOS is time of service.


[[Page 160]]

(b) If you would like to obtain an endorsement as master of towing
vessels (limited), then you must complete the requirements listed in
columns 2 through 5 of table 11.464(b) of this section.

Table 11.464(b)--Requirements for Endorsement as Master of Towing Vessels
[Limited]
----------------------------------------------------------------------------------------------------------------
TOS \2\ on T/V as
Route endorsed Total service limited apprentice TOAR or an approved TOS \2\ on
\1\ mate (steersman) course particular route
1 2 3.................... 4................... 5
----------------------------------------------------------------------------------------------------------------
LIMITED LOCAL AREA (LLA)..... 36 18 of 48............. 12 of 18............ 3 of 18.
----------------------------------------------------------------------------------------------------------------
\1\ Service is in months.
\2\ TOS is time of service.

(c) If you hold a license or MMC endorsement as mate (pilot) of
towing vessels, you may have master of towing vessels (limited) added to
your MMC for a limited local area within the scope of your current
route.
(d) Before you serve as master of towing vessels on the Western
Rivers, you must possess 90 days of observation and training and have
your MMC include an endorsement for Western Rivers.
(e) Each company must maintain evidence that every vessel it
operates is under the direction and control of a mariner with the
appropriate endorsement and experience, including 30 days of observation
and training on the intended route other than Western Rivers.
(f) If you hold a license or MMC endorsement as a master of steam or
motor vessels of greater than 200 gross register tons, you may operate
towing vessels within any restrictions on your endorsement if you:
(1) Have a minimum of 30 days of training and observation on towing
vessels for the route being assessed, except as noted in paragraph (e)
of this section; and
(2) Either--
(i) Hold a completed Towing Officer's Assessment Record (TOAR)
described in Sec. 11.304(h) that shows evidence of assessment of
practical demonstration of skills; or
(ii) Complete an approved training course.
(3) Your license or MMC does not need to include a towing
endorsement if you hold a TOAR or complete an approved training course.
(g) If you began your service or training in the towing industry
before May 21, 2001, you may receive a license as master of towing
vessels if before May 21, 2004, you complete the examination required by
46 CFR 10.903(a)(18)(i) and meet either of the following two
requirements:
(1) Three years of service, including--
(i) Two years on deck aboard a vessel 8 meters (26 feet) or more in
length;
(ii) One year on deck aboard a towing vessel, with at least 6 months
of training or duty in the wheelhouse of the towing vessel; and
(iii) Three months in each particular geographic area for which you
are seeking authority; or
(2) Three years of service aboard towing vessels, including--
(i) One year on deck, with at least 6 months of training or duty in
the wheelhouse of the towing vessel; and
(ii) Three months in each particular geographic area for which you
are seeking authority.
Your license does not need a towing endorsement if you hold a TOAR
or a course completion certificate.

[USCG-1999-6224, 64 FR 63228, Nov. 19, 1999, as amended at 66 FR 20937,
Apr. 26, 2001; 68 FR 35812, June 17, 2003; USCG-2008-0906, 73 FR 56508,
Sept. 29, 2008; USCG-2006-26202, 73 FR 52794, Sept. 11, 2008; USCG-2006-
24371, 74 FR 11244, Mar. 16, 2009]

[Capt. Phoenix]

Since your coastal license is only 200 tons you need to do apprentice mate to get a towing license for coastal. If you have the time offshore then get your 500/1600 ton coastal or ocean mate and submit a toar nc/ocean toar. You should have gotten an apprentice mate a while back so you could have time logged under it already...

[cappy208]

Huh? The bluesuits won't give you a straight answer. Or a commitment? Hmmm. Never heard that before.

If I was in your shoes, first find out what it would take to raise your 1600 to NC. It's a whale of a lot easier to 'get' it down, than trying to go 'up' to the towing endorsement.

When did you sit for your 1600? Since 2002? If so, all you need is more seatime to upgrade (I believe). Maybe RR again.

Then once you have a 'greater than 200 ton license'. You become eligible to qualify under the 30 day wonder clause. ( merry Christmas!)

Also (just got more confusing). How much time do you have as Master or Mate on either license? There is a process for individuals with 5 years ON your license. (as opposed to seatime while holding a license) this requires a limited exam, a completed TOAR and you're good to go too.

[Capt. Phoenix]

Captbbrucato: All he needs is a toar to get his inland mate of towing. He would need to do apprentice mate to get it on his near coastal since it is only a 200 ton license.

Cappy: The testing difference between mate inland and mate nc is quite big.

Coastal0423: Bite the bullet and upgrade.

[cappy208]

Cappy: The testing difference between mate inland and mate nc is quite big.

I looked it over. I didn't realize there was such a huge difference. But the OP already has a 1600 masters license,inland and already qualifies ( with a TOAR and 30 days on a tug) to get an inland MOTV endorsement. I would imagine NMC would have to divine what is next for the ocean part. It has been dealt with to get a apprentice steersman license is for guys with NO license. I don't recall seeing anyone with an inland license doing this trying for NC MOTV upgrade.

[coastal0423]

Cappy208. This is the understanding I got. The testing I completed for master 1600 inland, would keep me from having to complete the apprentice steersman. I have been told I need to submit inland Tour have it applied to my license, then I would need 90 days of training on near coastal route and a completed near coastal Toar to receive near coastal towing. That did not come from the nmc so that may not hold true at all.

[Capt. Phoenix]

I don't recall seeing anyone with an inland license doing this trying for NC MOTV upgrade.

It is completely possible that there is an easy way to go from inland mate of towing to nc/ocean mate of towing. I will do some digging when I get to an actual computer. He should definitely start with his inland mate of towing though.

[Capt. Phoenix]

I just reread the OP and realized I misread it all the times I double checked what licenses he has and that he has masters licenses, not mates licenses. With a masters license iit is rather simple, complete an Inland TOAR, if you work offshore currently complete both a NC/Ocean and an Inland TOAR. Submit the inland TOAR and get master of towing inland and request a mate of towing NC/Ocean. Once you have 90 days coastal time and a NC/Ocean TOAR done you can upgrade the Mate of Towing to Master of Towing. (You might be able to complete and submit the NC/Ocean TOAR initially then not have to submit another one later but that would make sense and this is the government we are dealing with.)

Footnote 1 to table a in section 11.464 (shown below).

46 CFR § 11.464

Table 11.464(a)

1) If you hold an endorsement as master of towing vessels you may have an endorsement-as mate (pilot) of towing vessels for a route superior to your current route on which you have no operating experience—placed on your MMC after passing an examination for that additional route. After you complete 90 days of experience and complete a Towing Officer's Assessment Record on that route, we will add it to your endorsement as master of towing vessels and remove the one for mate (pilot) of towing vessels.


http://ecfr.gpoaccess.gov/cgi/t/text...4.7.39&idno=46

[Capt. Phoenix]

Captbbrucato: All he needs is a toar to get his inland mate of towing. He would need to do apprentice mate to get it on his near coastal since it is only a 200 ton license.

Sorry captbbrucato, you were more right because even after multiple readings I still thought he had mate licenses. You bolded the wrong section of that citation though... The tricky part is getting a NC/Oceans towing license when he only has a 200 ton NC license so does not qualify for the TOAR plus 30 days observation path to that MOTV. He only qualifies as a 30-day-wonder for inland routes.

[cappy208]

I haven't been able to find it on my phone, but there is a mechanism for holder of less than 200 ton to get a MOTV. But the key was to have several years ON your license as operator. As opposed to just being a deckhand WHILE HOLDING a license. Do you have several years serving ON your license?