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    Acting As Pilotage 2010 PDF

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    JillF.Russell

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    US. Deparment of i Crore, Meine napecten 90-808 25517 Homeland Security ‘cd Sai Bn oa Showa ome 517 ‘Soir Basa Bie! Gon s63 200 Yrited States Foe pcr aas eet Chast Guard Elta Notes Setevacgnt SECIUNINST 16712.1 December 23, 2009 SECTOR JUNEAU INSTRUCTION 16712.1 Subj: SOUTHEAST ALASKA “ACTING-AS” PILOTAGE POLICY Ref: (a) Title 46, Code of Federal Regulations, Part 15.812(b)2) (@) Title 46, Code of Federal Regulations, Part 15.812(b\3) (@) Title 46, Code of Federal Regulations, Part 15.301 () Title 46, Code of Federal Regulations, Part 7 (6) FirstClass Pilotage Package for Southeast Alaska |. PURPOSE, This policy clarifies expectations for licensed masters and mates who wish to serve as “acting as” pilots under references (a) and (b). An “acting as" pilot is licensed deck officer who meets the requirements spelled out within these cites. Because the waters of ‘Southeast Alaska are designated pilotage waters defined in reference (c, this policy does not discuss the self-ertfication requirements for thase who wish to operate in waters that are non designated pilotage waters. This policy does not supersede existing regulation or guidance, but rather attempts to provide additional guidance for how mariners in Southeast Alaska (SEAK) can meet the regulation. Please reference enclosure (2), Navigation and Vessel Inspection Circular VIC) 94, for an in-depth discussion of federal pilotage issues. 2. ACTION, Owners and operators of vessels operating in SEAK that require “acting- as pilotage should familiarize themselves with this policy and with federal regulation to ensure that their vessels’ crews are in full compliance. Failure to mest regulatory requirements may result in Coast Guard enforcement action against vessel owners and/or operators. 3. DIRECTIVES AFFECTED, This policy supersedes and cancels the OCMI SEAK’s leter 16711 of April 20, 2008, 4. BACKGROUND. In 2006, a US-flagged passenger vessel grounded in Icy Suit, causing millions of dollars of damage tothe vessel and requiring all passengers and most of the crew to abandon ship inthe middle of the night. The offcer in charge ofthe navigational watch atthe tine of the grounding did not have the route familiarity required by regulation, had the officer met existing “acting as pilotage requirements, the casualty may have been averted 5. DISCUSSION, When sailing in designated pilotage waters while not on Register, certain vessels (inspected self-propelled vessels and seagoing tank barges), which are authorized by their ‘Certificates of Inspection to proceed beyond the Boundary Line, defined in reference (d), require sone form of pilot Depending on gross tonnage, some vessels must cary first class pilot; ‘others may forgo carrying a frst class pilot ifthe officer who controls a navigational watch isan acting as pilot Subj: SECTOR JUNEAU INSTRUCTION 16712.1 December 23, 2009 The requirements for “acting as" plotage on a self-propelled vessel under 1600 GRT, ‘described in reference (a, stipulate that a licensed master or mate must (1) Be at least 21 years old; (2) Have made four round trips over the route as a watchstander or observer inthe ‘Wheelhouse, at least one of which was made within the previous 60 months, and at least one of which was made in darkness, ifthe route is tobe transited in darkness, b, More stringent standards, described in reference (b), exist for “acting as” pilotage for the master or mate in control ofa seagoing tank barge of up to 10,000 GRT. e.The standards in references (a) and (b) are similar in that both require route familiarization trips. NVIC 8-94 notes that routes that must be transited for “acting 3s" pilotage “should parallel the route requirements fr licensed frst lass pilots.” A list of these routes in SEAK is provided in enclosure (1); the routes are identical to those in, reference (). 4. NVIC 8-94 also provides several definitions useful for understanding “acting-a¢" pilotage requirements, Selected definitions are expanded upon in enclosure (3) 6. IMPLEMENTATION ‘Vessel owners and operators must comply with federal regulations governing “acting- 3" pilotage. This policy mandates no additional requirements beyond what is already requited by federal regulation, ». Occasionally, vessel (such as seasonal passenger vessels) may arrive in SEAK and be unable to fully meet these requirements. Prior to commencing passenger operations, vessel operators must submit variation requests, in writing to the OCML. These requests ‘must include a transition plan detailing timeline and means for bringing personnel into compliance. ‘The plan should suggest interim measures o provide equivalent level ot safety (by adding additional lookouts, for example) during the transition period. Sector Juneau will evaluate and grant these requests on a case-by-case basis 7. DISCLAIMER, This policy is nota substitute for applicable legal requirements, nor is it, in itself, a rule. Where federal statutes, regulations, or the Maine Safety Manual have left discretion to the OCMI and Capiain of the Port, this policy clarifies and ses local requirements for the SEAK maritime industry. 8, CHANGES, This policy lever will be posted on HOMEPORT at hup:itomeportuscg.miluneau. Changes will be issued as necessary. Suggestions for improvements should be submitted, in writing, to Sector Juneau at the address specified in the header onthe first page. Subj: SECTOR JUNEAU INSTRUCTION 167121 December 23, 2009 5. QUESTIONS, If you have any further questions or concems regarding this matter feel free ‘© contact the Sector Juneau Vessel Inspections Division at (907) 463-2444 or DI7-PF- SectorJuneaulnspections@ useg. mil 10, ENVIRONMENTAL ASPECT AND IMPACT. CONSIDERATIONS. Environmental considerations were examined inthe development of this policy and have been determined to be 01 applicable. 11. FORMS/REPORTS. Federal regulations do not require masters and mates to submit records -ef their route familiarization rips to the Coast Guard for review o: approval prior to serving as “acting as” plots. However, Sector Juneau strongly encourages “sctng a5” pilots to document these trips and carry the documentation with them so that a Coast Guard Inspector or Investigator ray review the record if the occasion aries. The documentation may take any form, but should include the route, the date, the vessel, the name of a witness, and whether the route Was taversed in darkness. Enclosure (4) is sample log. [fan “acting as” pilot works on a vessel that sutinely transits only one section ofan established SEAK pilotage route, the individual need ‘nly attain the four ound trips on that section of the route, not onthe whole route. Web sR MELISSA BERT Captain, United States Coact Gard Enclosures: (1) SEAK Pilotage Routes (2) Navigation and Vessel Inspection Circular (NVIC) 8-94 G) Selected Pilotage Definitions (4) Sample Route Log SOUTHEAST ALASKA DESIGNATED AREAS Designated res otge waters for which ist Cas Pils ceases o endorsements rad unde ite AG CER, Pat 10 bythe OCM. The ‘ea or wich Pst Cas nes or endorsemens are ised apd requ wife Souths Alaa Marin Inspeion owe co elle Core Pilotage Areas Geographic Boundaries ‘Teip Sheet Reference Points Geogra D (N/S~B/W=0/D, fine a Caps Rouben o Cape Fo NER Moun fecal “-- souter tip of May Ind intaes fsuancest Behm Ca and Fie Seat TR Carel PP of Kalan Rave rio the Kalan Rp i Bai Chel (Entre area) ina ain Pe NGand ‘Rican Ap Guar Te Ene ‘8 Ghacai or Bre Recikas”> 7) Grease Sait ‘Nees Ree, Seamer Pr ‘orb of Goard rand SouoF 7560, 17020) Samer Ptand Eas of 192-20, Incas Kaan By. ‘seaanig Consists of2 charts, dawn none ‘Samper Sai Rat Ni Alsade 780, We Meartir Reef ‘ia eof Wrage “S Bicar Wrangell Narrows RWioy, ‘Noho PF Aeeader w5 Via Beat Becaba’"T WH bay. Cons oS charts, eWiteae (Enareareo) Feeleak Sond RP ‘Nah of Cape Bendel, Soulof Pr | rin ‘HE ica Hh and Wet Pe Agua ‘Wie ‘Keka Seale Newiot hiamiton, Soakorm® | 7555) Mesrny, and Bact of Payne I 1 Enclosure (1) Rev. December 2008 SOUTHEAST ALASKA DESIGNATED AREAS. Tip Sheet Reference Points Geographic Boundaries (W/S~E/W-0/D, ‘Seah of i om Neva Bt Pa of and Non of SN Reva om. i Tom Neva Pr Pav oT RE Tor of Reva Pant Soa oF Serie, igcombe and Cape Cross. West of ie tom ata 0) to Sig Pt SW of ne fom P Kak “Pec Sire Sergi ‘SW af aie om Pogiba Pte Foun Gove, NEcfaline —N-Porooal Tori af Kata nd Suto Narrow from Pr Kakul © Rovnd ‘SW Rakal overs Is incldes 85% Fish Bay 72) Pert Stic / Moonah Sound! Nora ie 70 dress te Tom Vast and South W Povo ‘and Mid Chatham om Noth Passage Pinto Admiay Ina. fener. G2) ine rom Pogbshi tt Poison Cove ‘Soot Chatham Sanit —Novin fine at 0 fom Cape Onanay Soa ofan 17360) 270 degrees tre fram Yash ead ae a line om Po (Gardner to Kgs “Slapiens Passage South Northota Te om Po aghis (175017360) from Bishop Peto Tataon PEt me South fai “Stephens Fasage North NW of ine fom Pt Ardea oPUTaialon Wan oa ee 700) from Outer Pt Porton Is Li. South ie fom v-see Fran Ligh Tey Svat Bast and Upper East oF ia Pra Chatham Couverden. (Enire are) 7300, Port of Hoonah - | seta Etat Parana Ts ge Ete as ea) ‘Tyan Canad 5 Seiason Port Torta ine fom Symonds Ponto 7300) “Va Sgimvarrogia ued — tiem Ratings | ‘for Lynn Canal SW Lt. South of Seduction Pot. Poids jaw Cao Hn Staaf ne 180 fom ~ 2 - Enclosure (1) Rev. December 2008 SOUTHEAST ALASKA DESIGNATED AREAS ‘fom Pook toPoriaod lx Nori ofa Ne Fe of Fines o Skagway ‘Nah of Seioson For land Is Lo Symopds rand Nonhofatine §: Sahasian Pu = Non-Core Piotage Areas (Chart) Nichot Passe a) Wiest Const Prince of Wales Nort of daond Pt and Est oft Sania ‘And Klwock net. Port of Klawockor Cre, aie -MacnamraP Nonth of lis 250 fom Nesbit Reef. ay South of Pe Colpoys, (Ente ara) E:RCobpeys MoArturRest Noho Cpe Pole, West oF Pt Coopys, tad 1. Ware ls, Cape Decision ae (©: The Bol, Od Sitka Rocks NB of Vist I and West of Eaty Pt 1: Port of Ske ‘Noth of Tantalon Pe ad South ofthe Sone Doulas Bride: (Ente are) Inches Listen Te. Does W Cape Spencer, Coat Pe ya a. a5, ey Strat Coa Send a) stank net N:Colunn Pt 5: Pet of Pelican 3 Enclosure (1) Rev. December 2008 SOUTHEAST ALASKA DESIGNATED AREAS Non-Core Pilotage Areas las Geographic Boundaries Ghai Bay ori Tlie fom Pr Caran oP Gas, ray, ‘Wan Osan Cape wed Soot ‘lizbn Pe 2a (Entre area) ‘The order ofthe routes for each grouping is ftom the southernmost route tothe northernmost route. This order plicated on the licens, Enclosure (1) | Rev. December 2008 Southeast Alaska “Acting As” Pilot Definitions ‘OCMI Area of Responsibility: (33 CFR 3.85-10) The Southeast Alaska Marine Inspection Zone and Captain ofthe Port Zone comprise the area within the boundary which starts at 6 01.3" N x 142" 007 W thence proceeds northeasterly to the Canadian border at 60° 18.7'N x 141° 00! W: thence southerly and easterly along the United States-Canadian shore side boundary to 54” 40°; thence westerly along the United States-Canadian maritime boundary to the outermost extent ofthe Exclusive Economic, Zone (EEZ); thence northerly along the outer boundary of the EZ to 142° 00’ W; thence due north to the point of origin Pilotage Waters: (46 CFR 15.301) Federal pilotage waters are the navigable waters ofthe United. Stats, including al inland waters and offshore waters toa distance of theee nautical miles from the baseline from which the Teritorial Sea is measured. Designated areas ae all areas within the Archipelago of Southeast Alaska, The baseline to three nautical miles is considered non-designated ‘waters in Southeast Alaska, Designated Areas: (46 CFR 15.301) Designated areas are those areas within pilotage waters for ‘hich First Clas Pilot licenses or endorsements ar issued under 46 CFR 10 by the OCMI, The areas {or which First Class Pilot licenses or endorsements ae issued and required within the Southeast ‘Alaska Marine Inspection Zone are listed in Enclosure (2). Designated areas are also referred tas, Pilotage routes Round Trip: (46 CFR 15.812) A round trip consists of vessel traveling from the one of the geographical boundaries listed in Enclosure (2), inbound/northbound to the dock facility where a pilot ‘would normally depart the vessel and outbound/southbound to the designated water's boundary, or a round trip may consist of transit of the waterway berween boundary reference points and back the ‘opposite direction. Whe:e applicable, a round trip for a port must include the main ship channe] approaches. Partial trip segments may be combined to achieve a rip requirement. For vessels traveling solely in one direction “sctng as" pilots in training are not required to transit in the opposite direction {o attain a route qualification. In other words, for “acting as” pilotage purposes, fur tips in one litection are acceptable if that i the only route the vessel transits. Note: If for some reason the vessel ‘must transit inthe “opposite direction” the vessels’ navigation must in controlled by a pilot or “acting as" pilot Recency: (46 CFR 15.812) One round trip must have been made within the past 60 months after achieving the inital 4 tips requited in order to maintain eceney for purposes of “acting as” pilot. Darkness: (46 CFR 15.812) If the vessel makes the transit in darkness atleast one ofthe qualifying trips must be made in darkness. Darkness for these purposes is defined as the period between evening civil wilight and morning civil twilight. Reduced visibility (not durin the period defined above) does not constitute darkness for qualifying nighttime trips. Additionally, fora trp to qualify as during darkness, over half of the time for the transit ofthe waterway must be made during the authorized period defined above (ie, in the dark) Enclosure 3 “ACTING AS” ROUTE VERIFICATION LOG Names ‘Start Reference Points Depart Date/Time Dark Stop Reference Points ‘Arrival Date/Time Signature: Capacity Vessel Name & Official Number USGT ‘Signature, Printed Name, & License # of PiloUMaster Enclosure 4 ‘Vrited States ‘Coast Guard ‘ComDTPUB P167008 NvICS-94 |4 October 1998 NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 64 tecronic Version for Distribution onthe World Wide Web Subj: ISSUES REGARDING FEDERAL PILOTAGE |. PURPOSE. ‘This Circular provides Coast Guard Captains ofthe Por (COPS) and members of| ‘ndstry wih answers to various questions reptrding Federal iloiage requirements [DIRECTIVES AFFECTED. Inepreatons of Various Issues Regarding Plots and the Potage Regulations, NVIC 39, is hereby canceled, 3. DISCUSSION. Regulations concerning piles have been under revision since about 1980. There have been aumereds changes to the regulations, and consequently, there ate areas where interpretations and guance are necessary. The pit icensing regulations ae Jocated at 46 CFR §10.701 though §10:713. The pilot manning regulations are located at 46 CFR 615.812 Enclosure (1) 5 mean to answer some oie commen quesbons asked about opis related to Federal ploage requirements Ee Ch frear anizal, U.S. Coast Guard Chief, Office of Marine Safety, Security ‘and Environmental Protection ENCLOSURE A Enclosure (I) to NVIC 8.94 ‘sues Regading Federal Piotae Requirements ‘Seas questions ‘Question - What vesslerquin plots? Anus - tachment () is a summary of US. plotage requirements which apply everywhere in the US. except the Great Lakes and Sant Lawrence Seaway. Aitachment (2) is summary of US. pilotage requirements for US. vessel on the Great Lakes and Sant Lawrence Seaway. Aachen (3 is Surnmary of US. pleage requrements fe foreign merchant vessel on the Great Lakes and Saint Lawrence Seaway. ‘Question - Who way serve as Federal plo? Answer - There ae wo types individuals who may serve a pilot. One i an individual holding a Federal rst lass pilot's iense wit endorsement forthe rout, in accordance with 6 CFR $15.8120X0). ‘The other individual who may serve asa plo is generally referred to a5 an “ating as" pilot. An acting as plot isan individual who ia licensed member ofthe vss crew and who alo safes the qualification requirements found at 46 CFR $15.812(0)2) and (0X3) 1h 46 CFR §15.812(0)2), the phrase “employed aboard a vesiel”isincxpeted by the Coast (Guard wo mean that the individual ea Hcensed member ofthe vesel'serew, or an appropriately licensed permanent employe ofthe vse owner or operator, Serving sboard the vessel, ‘Question - What is mean by “plotage routes” fr licensed ist clas pilots and for “ating 2" pilots? ‘Answer ~ Federal first clas piles Heenses are sued with endorsements which desribe the geographic limits ofthe waters upon whichthe holder suthoriad ta serve, m accordance with SCR §15.8120K1). “Acting "plots, musteomplete specified amber of round rps over the route abe traversed in accordance with 46 CFR §1581200)2) These individuals slfceriy sto thei qualifications for route ie dey are not sued a ilo’ lense or endorsement that describes the speiic Wales upon Which they are authorized to see as pio i class pil’ licens and endorsements may be issued with incsive rote descriptions to ppticans who have not made familiarization rips on every Section of every waterway included within the described route Applicants ae not always required © aban familiarization rps on each ibutary along te route being applied fr, or ar they alvays equted to present evidence of having docked at ach Facity within the route. Inadition, in many zones, applicants are nt reqused vo oval round ips im the minor prs included inthe rote." For acting as pilos, th requirements concerning routes should parallel te route requirements for licensed first clas pilots. A description of the route requirements fra icensd fst class pt and an “aeting as" plot may te obtaine fom the OCMI concemed. It's incumbent upon the mariner whe will “act a" apilot to determine in advance whether helshe meets te local plotage requirement “The specific requirements oe qualiying io acta pilot on those waters may heobtined fom the OCMI concemed. For purposes of establishing the requisite nuber of round tripe in given pilrage route segment, the local knowlelge requirements may be satisfied when the lensed individual is tranied the length of he segment ori the local pilotage requirements permit has made trips 1 one oF ‘ore facilis within the segment ‘OCMIs will ake availibe to interested persons, a deserpton of the pilotagerowesiroue segments within tele respective zones, Enclosure (I) to NVIC 8-94 Mariners who willbe completing routes, route segments and round trips to qualify s pilot both “acting as" and applicants for a first class plo licens) should verify in advance with the appropriate ‘OCMI, what consis qualiying trp. ‘Question - May observer experience sats rouefamiirizaion requirements? ‘Answer - Yes. "Observer" experience hasbeen acceptable or many year in satisfying the ound trip requirements for rose familiarization (46 CFR 810.7050) (Questan- What are Federal piltage waters? Ansuee- Federal plage wats include all navigable waters ofthe United Stats ott the cuter limits ofthe Tetra Sea the 3 mile limi) ‘Tagand bases Question - To qualify as an “acting a" tak barge pilot, most the tug havea barge in tow during the required weve round ips? ‘Ansier~No. Coast Gust policy requires that only 25 ofthe required roundtrips be mae withthe barge in ow. An OCMI may, however, further reduce or eliminate the numberof ound rps required with te barge in tw i hele determines that is appropiate for any routes or Segments With the ‘Question - Wil an individual seeking a Federal first clas pilot’ license or endorsement, who obtains his ‘rer qbaifying experience exclusively on tug and barge combinations be limite to piloting nly sd barge combinations? ‘Answer In genera, pplicans who aba thee qualifying experience on tug and barge combinations of ‘over 1,60 gros ons shoud be issued an unrestricted it cla pil’ license or endorsement of any foes tons" without a "tug and barge combination" imitation, However, tere ae routes where, du 0 the nature ofthe wales, an OCMI could reasonably conclude hat is sppropiate co require an applicant, imespctive of other licenses hel, to obtain experince on self-propelled vessels grater than 1,600 gross tons on those pancular waters inorder to qualify for an untescted fist clas pilot Hcense ce ‘endorsement for that route. Accordingly, when appropriate, and in tbe OCMIs Sole discretion, the OCME ‘may place a Fimitation on suc license or endorsement "Those cases where the restive endorsement is warranted ae expected tbe relatively few in ‘omber, and limited primarily to those individuals who have litle orn sll-propelled deep draft vesel experience and who have performed ter round tps primarily on tg and barge combinations ‘OCMIs will deny and potty the Regional Exam Centers (RECS) ofall waters in thes zones that are of amature such thatthe "tg and barge combination esition may be warranted Docking Plot/Masiers and Mooring Masters ‘Question » What isthe official status of docking ples and docking masters, and are they required to be oensed? Enclosure (1) to NVIC 8.94 Answer - In some pots, particulary on the East and Gulf Coasts individuals frequently referred to as docking ples or docking masters duet the docking and undocking of vessels. In most cass, these Individual are employes of tug boat companies, (Coast Guar icensing epaltions (46 CFR Part 10) donot address docking plots or docking ‘masters an, to our knowledge, the sates also do not istve these licenses. Therefore, “docking pilot” and “docking mister” ae unofficial employer trade designation, rather than types of eases, Inspecied,coastvise seagoing vessels, ot sing on reser, when underay and not onthe high seas, most be under the direction and consol of «Federal plo (46 U.S.C. 98502) (46 CFR $15,812), With respect these vessels, the law and regulations are clear, Ifa vessel meets the above description, it mst be operated under the diection and contol ofa federally licensed plot all imes when itis underway in U.S. navigable waters. Any individual directing the navigation of soc a vescel (a docking pilaster, oran individual called by anyother name) must have the appropiate Fist class pilot's Hicense issued by ‘he Coast Guard forthe particular route in question. Vesel sling on 4 registry {endorsement are subject state plage requirements. Under 46 U.S.C. §8903, the Coast Guard may require a Federal pilot inthose instances where the states donot requie a pio. Ths is geverally ‘accomplished trough th regulatory proces. In emergency situations, however, it may be accomplished through a Cepuin ofthe Po Order. ‘Question - Wha are the requirements for mooring masters Aautsr- The regulations concerning mooring masters ae found a 33 CFR §150.211, These regulations have no bearing on piltge requirements. Under 46 US.C. $8502, if US, coastwise seagoing vessel i within U.S. pilotage waters a mooring master or anyone ele directing the movernents of he vesel mast have the appropriate platage credentials for that ves. Licensing questions ‘Question - Do trips made by cg operators prior 10 June 1985, when the operator was not an observer oF der instruction, count ards filment ofthe round wip requirements found in 46 CER SIS8I27 ‘Answer- Yes. Round tris made bah rir to and alr June 24, 1983, while the operator was directing ineavigaton ofthe tind barge, count towards the requisite numberof round tps ‘Question - Does» dy-exgo barge qualify forthe ips required with a barge in tow, or mus the bare in tow be a tank barge? Answer - Round tips mate with drycargo barges qualify forthe round tip requirement ‘Question - What documentation mus the towing vessel operator produce to denonsrate compliance with the round wp requirement? ‘Answer - Any method of recording round wp i acceptable. The dae, out, ime of day, and the name nd gross tonnage ofthe vessel on which the round ips were made must be included inthe documentation. It is expected that mos individuals Would use a personal log book, ‘Question - Must tis round trip documentation be kept on the vessel? Ansster -No it snot requirement to have round trip documentation aboard the vesel, Should the information be pecessiry for nvestigation i must be provided within reasonable period of time 3 Enclosure (I) to NVIC 894 However ifn OCMUCOTP has reson to doubt sn individuals qualifications to “act as" plo in accordance with 46 CFR §15812(b)2), the vessels departure could be delayed pending receipt of sausfctory evidence that equred round rps have been made ‘Question - How does an opertor document trips made in the employ of companies that no longer exis oF for which records are no longer available? ‘Answer - By sel-cerifiction, however, the individual could be asked to provi ation! information ‘hat would corroborate the sel-ertston. ‘Question - What documentation must te towing vesel operator produce to demonstrate compliance with ‘he requiement fran anaval physical? ‘Answer In accordance with 46 CFR 153812), documentation proving compliance wih applicable portions ofthe regulations including the resus ofthe operator’ core physical examination, must be Produced within a reasonable period of ime, if quired by the Coast Guar, ‘Question - Most this annwl physical exam documentation be kept on the vesel? Anse -No, ‘Question - Different Coast Guard dre use different forms for phys examinations. Coast Guard ‘offers may pt accep forms with which they are unfamiliar. What form mus be wed? ‘Answer - The epuatons (46 CFR §10.205(d) state thatthe ess ofthe physical exam most be ‘recorded on Coast Guard physical exam form (CG-719K:) or equivalent. However, should be “ndersiod that any form s acceptable provided i contains the equted formation contained in 46 CFR 1020s ‘Quastan - Sections 15.8124) and 15.812(eKt)requte round tips, among oer hings, to serve as plo, ‘What size vessel mus chese round tps be mde on? Ansuie- Wit egurd tank barges, least 2/3 of the round wp must be made witha barge in tow (unless educed by the OCMI), and te remaining 1/3 roundtrips may be mace on any vesel of reasonable size. An outboard moterboa! snot a vessel of reasonable siz, but tow is reasonable Regarding self-propelled vessels, again, any vessel of reasonable size i accerable, however, an ouboard motorboat snot reasonable Federal ve Site Plouge ‘Question - When is a vessel subject oplotage requirements? How sit determined wheter state or Federal plotage law applies in any given case? ‘Answr~ The sates regulate plouge on foreign tade vessels (foreign vessels and U.S. vessels operating ‘on register inthe bays, rivers, harbors and pons ofthe United States (46 U.S. $8501). The ‘esponsibily for exablshing plage roglremenss resis withthe tats in thas cases and isto the law fof the stat in whose waters & pacar vessels fund that one must lok to determine those equremens. Any U.S. documened vessel with only arity endorsement on its cerfcae of documentation (COD) would be subject to sate pilotage laws. Al foreign vesels are subject to state pilotage laws Enclosure (1) to NVIC 894 ‘Coastwise seagoing vessels are subject o Federal pilotage requirements and are 1 be under the

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