Avoiding 10.407(c) tonnage restriction 3d AGT

[dap7777]

For years I've thought 10.407(c) would be a great way to get my 3d AGT since I'm driving in the Gulf. So that's how I applied. However, now I realize that an initial tonnage restriction is all but mandatory. See 10.402(b) ("under 10.407(c) a tonnage restriction is placed on the license based on applicant's qualifying experience"). What if, however, I show that I've been driving 1600+ ton boats on my 1600 Master Ocean - like for months and months? Can I avoid the 407(c) tonnage restriction (which seems like an endless process to get out of once in) ??? How much heavy time would I need to show up front for unlimited 3d Mate application under 407(c) i.e. one half of 1 year or one half of 3 years?

Evaluator says she's ready to approve; I said wait and I'll show you heavy sea time. She says "Why wait?" like the restriction is inevitable. Seems like maybe others have avoided the restriction. How'd you do it? Comments welcomed. Thanks. DAP

[Capt Leigh]

My Understanding is that 1/2 of all sea time when applying up front,but only 180 days when holding the Third Mate ticket and acting as Third Mate on a Vessel over 1600GT. I have always assumed that someone would use their 3000 ITC tonnage on a Vessel over 1600 GT to qualify to operate the Vessel and a carefully worded Sea time letter from their employer,but should defer this answer to someone more knowledgeable.

Out of curiousity were you approved to test or allowed to cross with no testing or assesments per Policy letter 01-02.
Did you hold a Mates ticket prior to 2002?
Did You complete STCW Courses?

Thanks for your thread,Good luck.....

[dap7777]

[quote=Capt Leigh;23694]

Out of curiousity were you approved to test or allowed to cross with no testing or assesments per Policy letter 01-02. Finished and submitted assessments-all 100 or so of them, which were required. And I will have to test.
Did you hold a Mates ticket prior to 2002? Yes. Never sailed on it however.
Did You complete STCW Courses? Yes and no. I got a partial waiver to skip some of them; I have GMDSS, FL, MP, BM and a bunch of others; don't have meteorology, stability, cargo etc... . Had to fight for the waiver. I posted on that issue several months ago. Thanks. DAP

[Capt. Fran]

What if, however, I show that I've been driving 1600+ ton boats on my 1600 Master Ocean - like for months and months?

Hey DAP,
I think you might have mis-typed here or something. If you have a 1600 Master, what you really have is Master of any vessels LESS than 1600 tons, i.e. 1599, not 1600+. So, I'm assuming your months and months of time will not help remove the tonnage restrictions.

[dap7777]

Hey DAP,
I think you might have mis-typed here or something. If you have a 1600 Master, what you really have is Master of any vessels LESS than 1600 tons, i.e. 1599, not 1600+. So, I'm assuming your months and months of time will not help remove the tonnage restrictions.

Interesting point. My thinking is that the statutory langauge cites "qualifying experience" and since I've been driving vessels I believe are over 1600 Tons (on my 1600 tons or less license) then I could make the argument that the 407(c) tonnage limitation ought to be set aside for cause. But I'm understanding that you don't buy that. I'm hoping you might expand on your reasoning and explain the assumption(s) you make. Appreciate it. DAP

[CaptAndrew]

since I've been driving vessels I believe are over 1600 Tons (on my 1600 tons or less license)

Sounds to me as if you were breaking the law. I am sure that you were not so maybe you can explain. You cannot use time that you were not legally doing.

I use to drive a ship which was under 100GRT but 1400GT and I could only use the time based on domestic tonnage as I did not have a 1600ton license. I asked just for the hell of it and was refused.

[dap7777]

[quote=CaptAndrew;23793]Sounds to me as if you were breaking the law. I am sure that you were not so maybe you can explain. You cannot use time that you were not legally doing.


Looks like I've been misreading the COI on this vessel, which under Gross Tons reads "I-1875" and then Net Tons 560. Evidently this is the international tonnage (not gross tons) and is accordingly under my license's 3000 ITC restriction.

It that's the case, then it looks like I'm gonna be stuck with a tonnage restriction unless anyone has any suggestions(?)... Oh well. Always better to know the score.

[Diesel]

[QUOTE=dap7777;23794]

Sounds to me as if you were breaking the law. I am sure that you were not so maybe you can explain. You cannot use time that you were not legally doing.


Looks like I've been misreading the COI on this vessel, which under Gross Tons reads "I-1875" and then Net Tons 560. Evidently this is the international tonnage (not gross tons) and is accordingly under my license's 3000 ITC restriction.

It that's the case, then it looks like I'm gonna be stuck with a tonnage restriction unless anyone has any suggestions(?)... Oh well. Always better to know the score.

Seems pretty clear cut to me...Go to a company with large OSV's. Either do time on deck or get your assessments done to get a Large OSV license. You will accrue time towards a third mate either way.

[eesmith4]

I have always assumed that someone would use their 3000 ITC tonnage on a Vessel over 1600 GT to qualify to operate the Vessel and a carefully worded Sea time letter from their employer,but should defer this answer to someone more knowledgeable.

That's how I got my 3rd Mate AGT, boat was 2217 ITC and I sailed on it with a 3000 ITC Mate, upgraded from 3000 ITC Mate to 3000 ITC Master/3rd Mate AGT without any tonnage restriction.

[Diesel]

That's how I got my 3rd Mate AGT, boat was 2217 ITC and I sailed on it with a 3000 ITC Mate, upgraded from 3000 ITC Mate to 3000 ITC Master/3rd Mate AGT without any tonnage restriction.

CG got wise to this and came out with Policy letter 15-02

[Windjammer]

I had time as master on a 99GRT/2600GT vessel while holding a 1600GRT/3000GT Master license. When I upgraded to add 3rd Mate Unlimited, they gave me a 4000GT limitation and a letter stating that the tonnage limitation would be removed after 180 days over 3000GT. I then worked as mate on a 3800GT vessel (hard to find) for 180 days and the limitation was removed.

I know two other guys who had virtually identical sea time and were able to do the same upgrade from 1600/3000 master to add 3rd mate unlimited without any tonnage limitation. The bottom line: it seems to depend on the individual reviewer (or the moon phase!).

[dap7777]

So NMC West Virginia did give me approval to test for 3d Mate - - Limited to 3000GRT. Seems like a cranky, stingy result, but I don't know of any way to challenge it. So I'm moving into a studying/test prep phase now-- if anyone has any surefire studying techniques or materials they want to recommend, please do. (planning on meandering through Bowditch; my company has eliminated funding for license upgrades so I'm not going to be attending any fancy course prep; I do have a Hawsepipe DVD). Hey thanks. DAP.