Here are what the changes contained in USCG 2006-26202 represent.

   Current USCG Regulations for a "Mate of Towing License" require 24 months ONBOARD a tugboat.
   The Proposed USCG Regulations for a "Mate of Towing License" require 1 month ONBOARD a tug.
   The TOAR (Towing Officer Assessment Record), is already required for both so exactly what these "additional   requirements" consist of remains a mystery. If we are talking about the "Towing Vessel License (Apprentice Mate) Exam", than someone needs to demonstrate how or why it replaces 23 months of actual experience onboard a tug. The content of that exam is nothing new or different than that of the current Apprentice Mate/Steersman now in place. Below is an expansion on the subject. 
Towing License Sea Service Requirements
Apprentice Mate / Steersman of Towing Vessels: total service of 18 months on deck, 12 of which must have been aboard towing vessels.
Mate / Pilot of Towing Vessels: total service of 30 months, 12 of which must have been as apprentice mate / steersman of towing vessels.
Master of Towing Vessels: total service of 48 months, 18 of which must have been as mate of towing vessels (not limited to harbor assist work).
Note: Steersman and Pilot are the traditional regional terms used for an apprentice mate and mate on the Western Rivers.
For calculating sea service, the C.G. considers a day to be 8 hours of work (in the 3-watch system), a month to be 30 days and a year to be 360 days. Working in the 2-watch system, which applies to the vast majority of towing vessels, crews work a 12-hour day while typically standing an alternating 6-hours on / 6-hours off rotation (sometimes 12-hours on / 12-hours off). The Coast Guard credits this sea service at a 1.5 factor, or a day and a half of sea time for each day worked, because of the extra 4 hours each day.
Many, but not all, tug and towboat mariners work an equal time schedule, with a total of 6 months spent at work each year. Assuming that this is the case, it would take the following time periods of calendar years to gain the required experience to qualify to test for these licenses.
1. Apprentice Mate / Steersman: 2 years
2. Mate / Pilot: 3 years 4 months
3. Master: 5 years
There is a notable exception to this. In the Gulf of Mexico it is common for mariners to work for 8 months a year in a 4-week on / 2-week off rotation. This is a longstanding practice that has its roots in the traditionally low pay that was typically paid in the region, and mariners had to work this schedule to make even a marginal living. Wages, in most cases, have significantly improved compared to the old days, but the practice lingers on at most companies for one simple reason: it reduces their manning needs by 33%, and it also saves them a lot of money in benefits such as health insurance. Working the 2-on / 1-off schedule, the times work out as follows.
1. Apprentice Mate / Steersman: 1 year 6 months
2. Mate / Pilot: 2 years 6 months
3. Master: 4 years
In all cases, up to 6 of the 18 months of required service to qualify for the apprentice mate / steersman license may have been acquired on vessels other than towing vessels. When applied, this means that the minimum amount of sea time experience (based on the C.G.'s 8-hour day system, which is how the regulations are written) actually gained on board towing vessels that is possible under this route of advancement for Mates and Masters is as follows.
1. Mate / Pilot: 2 years
2. Master: 3 years 6 months
This compares to just 30 days or 1 month of towing vessel experience required for anyone already holding a Master's or Mate's license of greater than 200 G.R.T. to "lateral" over to the towing industry from another sector of the Merchant Marine. The proposal contained in docket number USCG-2006-26202 would extend this loophole to those holding licenses less than 200 well.
Congress acknowledged the need for Masters and Mates to have very specialized skills in order to safely operate towing vessels when they called for the revamping of the towing vessel license structure just a few years ago. The "30-day loophole", however, was a political / regulatory compromise made at the time to quell the complaints of the upper-level (unlimited tonnage) and 500 / 1,600 G.R.T. license holders who did not want any restrictions as to what kind of vessel they could operate, period.
Congress' instinct and decision to require more specialized experience of mariners operating towing vessels was a good one. It's time to do away with this dangerous shortcut for all licensed mariners and come to an agreement on what constitutes a proper and, above all, safe minimum experience level. Thank you for your interest,
                   Captain Jordan May
                   Captain Joel Milton,
                   Master of Towing Vessels Association Members
For those of you who want to know more about this proposed Towing Vessel licensing change, go to , go to the views column to the right of the various people or organizations that submitted comments, and click the icon for the Word or .pdf document to download and read. I've been told unofficially that, although the comment period is officially closed, the C.G. is still accepting our comments. I strongly urge you to consider doing so, or at least lending your name to a petition. Contact me if you need help in this process. We are trying to get them to officially re-open the comment period before writing the final rule on this.
Thanks for your time.
Joel Milton

The important points are as follows:

1. The petition from Delta Towing of Galliano, La. (a subsidiary of Edison Chouest Offshore, a large oilfield vessel operator) was originally intended to solve their own problem of being short on qualified wheelhouse personnel for their tugs by being able to use experienced captains from their oilfield supply vessels and crewboats after they met the following conditions: pass the written exam for apprentice mate or attend an approved course, get a TOAR signed off, and complete 30 days of training and observation aboard a tug. Although they do mention in passing the potential added benefit to the industry-at-large of helping to reduce the overall manning shortages, it appears clear that they meant that this advancement path was to apply primarily to their own oilfield mariners. For those of you unaware of it, the oilfields are just as short, if not even shorter, on qualified mariners as we are. This is, for now at least, simply an in-house fix for Delta Towing. It won't help the rest of the towing industry any time soon, if ever. It would, however, set a very bad precedent.
2. I think that using experienced oilfield captains is an idea that has considerable merit. As I stated in my letter to the federal rulemaking docket, these are the kind of mariners that would have the least problem making the transition out of anyone I can think of. However, 30 days is just too short of a time frame, and no one is going to legitimately complete a TOAR in 30 days, period. I feel perfectly comfortable stating that it is flat-out impossible. I would, however, fully support a provision that limited this path to oilfield mariners with adequate experience, as long as the training and observation period was long enough. I proposed a minimum of 90-120 days in my letter to the docket, and even then I think I was being generous. That is the absolute lowest end of the range that I feel it would be possible to do it in without compromising safety unnecessarily.
3. American Waterways Operators (A.W.O.), the towing industry's lobbying organization, in their comments to the docket, went well beyond what Delta Towing proposed. They suggested that the Coast Guard also extend this path of advancement to <200 GRT Mates as well, and also that the proposed 3-years of experience on the license need not be served in a licensed capacity at all, or even on a towing vessel. This is foolishness of the highest order.
4. A.W.O. has claimed that this was endorsed by the Towing Safety Advisory Committee (TSAC), the implication being that TSAC as a whole is a real authority on marine towing safety issues and if they give it their stamp of approval then it must be okay. But the only working mariner on TSAC at the time this was being worked on, Capt. Joe Dady, was not a member of the TSAC working group that came up with this, nor did he vote for it. In fact, no actual working mariner has ever gone on the record to endorse this at all. Look at the comments on the docket. Two Coast Guard-certified Designated Examiners, among other mariners, have stated that it is a bad idea and will make our industry less safe.
5. The proposal as published by the Coast Guard, and endorsed by A.W.O., would not restrict this path of advancement to only experienced oilfield seamen. Rather, it would be open to any holder of a 200/150/100 GRT Master's license (AWO wants the mates included, too) with three years on the license, no matter how and where they got the sea time to qualify for that license in the first place, or how/where they got the proposed three years on the license to qualify for this advancement path. This would include operators of charter boats, commercial fishing vessels, small passenger vessels and ferries, excursion vessels, dinner boats, etc. In the vast majority of cases these people are completely unqualified to serve as anything but an apprentice mate for at least a few months, if not years. Creating a route by which these licensed captains and mates could be fast-tracked into the wheelhouse of a tug means that, sooner or later, one way or another, they will be. This will undoubtedly lead to accidents that would have otherwise been avoidable. Given the times, and the disposition of the public and Congress, another major accident attributed to our industry will very likely unleash even more training requirements and hardships that we don't need or want.
6. Since everyone agrees that no reputable company would hire and place in such a position of authority and responsibility a person with only 30 days experience on tugs, that leaves only the disreputable companies to do it. Without a doubt, a few will always do what they want anyway, regardless of the law, and hope they don't get caught at it and/or get in a huge accident causing multiple fatalities, especially innocent civilian fatalities, such as occurred in the I-40 bridge strike and collapse in Oklahoma. Such is life. But to prevent them from being able to legally get away with an unsafe practice the 30-day provision should be removed altogether and replaced with a much more realistic period of time, as I outlined in my comments to the docket.
6. To leave it at just 30 days would be, in essence, giving the Coast Guard's full endorsement to an obviously dangerous practice. I'll also add that the Coast Guard simply lacks the in-house, professional expertise to make a judgement call on something like this. TSAC should but doesn't, mostly due to the fact that working mariners are way under-represented on the committee and don't appear to be seriously listened to in any case. Since the Coast Guard relies on TSAC for the towing safety expertise they (the C.G.) don't have, and since TSAC appears to be unable to offer sound safety advice untainted by other agendas or the inexperience of its non-mariner members (the large majority), the Coast Guard is simply left with generally poor advice to work with. TSAC's members may mean well, at least most of the time, but they will never overcome this big shortcoming until working mariners become a majority whose advice is heeded. This is the root of the overall problem.
Joel Milton
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