Wow, Tim, you may be sorry you asked this question here -- there is some pretty bad advice above! As a licensed Master, I'm sure you understand more about the regs for Subchapter T small passenger vessels than most of those who weighed in.
Some clarifications:
Bottom line is that you need to jump through quite a few hoops to get any boat certified -- new or used. The Coast Guard needs to confirm that the hull is built to a classification standard such as ABS or Lloyds Rules (doesn't have to be CLASSED, just built to a standard.) All mechanical, electrical, and plumbing systems need to meet either the Coast Guard regulations in Subchapter T, or if the passenger count and vessel length are smaller, ABYC standards. She needs to pass an intact stability standard, which usually requires physical testing (even if there are near sister vessels operating that have passed.) (A Damage Stability standard is not required if under 65 feet.) A collision bulkhead is required if operating on Exposed or Partially Protected waters. (It must be located between 5 and 15% of the waterline length aft of the stem, so even if you have one, it's gotta be in the right place.)
- You cannot bareboat charter a boat and then hire yourself back as captain -- that used to be the case some years ago, but it is expressly prohibited now.
- Just because a boat is well built doesn't mean it will be no problem getting certified. You still have to a.) Prove it (with plans, tests, and calculations), and b.) meet the letter of all requirements, not just be good marine practice. (Are the handrails 39.5" high? No, they're only 39"? You have to raise them! Do you have 32" wide exit doors? Of course not -- better get the sawsall out!)
- The Subchapter T construction and arrangement regulations apply to all boats carrying more than 6 passengers for hire (or more than 12 if the boat is over 100 Gross Tons (domestic)). Generally the boat must be US built though, which means Willards are certainly eligible.
And all of the above needs to be documented to the satisfaction of the Coast Guard, which means accurate plans need to be drawn up and calculations submitted for approval. It can certainly be done, and is done all the time, but you need to be aware that it can take time and money to get that COI in your hands. Lots more to it than just being "seaworthy and not leaking fluids"!
My experience with the Coast Guard is that they are there to help you through the process, and they generally are very helpful in outlining the requirements and explaining the reasoning. However they do have a huge and varied mission, so there's definitely a limit to the amount of hand-holding they can do. So it's good to do a little homework before proceeding. The first step is to review the Regs (see the links below) and make a list of questions. Then contact your local Coast Guard Inspections office (OCMI, Officer in Charge Marine Inspection). They will assign an Inspector for the boat only if you can convince them you are serious -- i.e. you actually own the boat and are actively planning to make the necessary changes to put her into service. Then you can work closely with your inspector to work out what needs to be done and what documentation the Coast Guard will need. (My advice: don't try to fight them - it's worth developing a friendly, cooperative rapport with them.)
References:
-Rick Etsell, P.E., naval architect
- SubChapter T Small Passenger Vessels: 46 CFR Parts 175-185 ONLINE
- Small Passenger Vessel Information Package (pdf file) (This one's from Sector Upper Mississippi River, but other CG offices usually have a very similar guide.)
- Marine Safety Center (USCG Technical Review Authority): MSC Homepage
- USCG Small Passenger Vessel Safety Program Website
When did they stop the bareboat/Hired Captain deal?
They haven't.
The regulations are just more strict and better defined since there are or were so many people violating the rules through ignorance or by choice.
Again, don't rely on internet forums for that kind of information. Go to the source, learn to read the CFRs and ask the USCG for specific information regarding your own situation.
Just because your document is endorsed for coastwise trade doesn't make it or you a commercial operator or operation ... contrary to what at least one member here believes and promotes.
thanks
Not sure what the original poster had in mind ...
Uh, read the thread title, that pretty much narrows it down to a fine point.
If you are still confused, look up COI.
I guess you didn't bother to look up "COI."
No point in going any further with this conversation.
Whether you think he needs one or not is quite irrelevant.
He started the thread, he titled it, he asked about getting a COI.
He didn't ask you if you thought he needed one.
Read the entire thread. Is seems others brought up other information that created new discussion that I responded to as did others. I didn't know we couldn't respond without permission from the thread starter. You being a Guru, please forward me the rules of of discussion.
Hi Rick, Good advice and I contacted the CG and set up a meeting .They were more than happy to meet with me on this project. The CG in Boston does have that Small vessel package,it's titled (I have a dream) ..Thanks all.Wow, Tim, you may be sorry you asked this question here -- there is some pretty bad advice above! As a licensed Master, I'm sure you understand more about the regs for Subchapter T small passenger vessels than most of those who weighed in.
Some clarifications:
Bottom line is that you need to jump through quite a few hoops to get any boat certified -- new or used. The Coast Guard needs to confirm that the hull is built to a classification standard such as ABS or Lloyds Rules (doesn't have to be CLASSED, just built to a standard.) All mechanical, electrical, and plumbing systems need to meet either the Coast Guard regulations in Subchapter T, or if the passenger count and vessel length are smaller, ABYC standards. She needs to pass an intact stability standard, which usually requires physical testing (even if there are near sister vessels operating that have passed.) (A Damage Stability standard is not required if under 65 feet.) A collision bulkhead is required if operating on Exposed or Partially Protected waters. (It must be located between 5 and 15% of the waterline length aft of the stem, so even if you have one, it's gotta be in the right place.)
- You cannot bareboat charter a boat and then hire yourself back as captain -- that used to be the case some years ago, but it is expressly prohibited now.
- Just because a boat is well built doesn't mean it will be no problem getting certified. You still have to a.) Prove it (with plans, tests, and calculations), and b.) meet the letter of all requirements, not just be good marine practice. (Are the handrails 39.5" high? No, they're only 39"? You have to raise them! Do you have 32" wide exit doors? Of course not -- better get the sawsall out!)
- The Subchapter T construction and arrangement regulations apply to all boats carrying more than 6 passengers for hire (or more than 12 if the boat is over 100 Gross Tons (domestic)). Generally the boat must be US built though, which means Willards are certainly eligible.
And all of the above needs to be documented to the satisfaction of the Coast Guard, which means accurate plans need to be drawn up and calculations submitted for approval. It can certainly be done, and is done all the time, but you need to be aware that it can take time and money to get that COI in your hands. Lots more to it than just being "seaworthy and not leaking fluids"!
My experience with the Coast Guard is that they are there to help you through the process, and they generally are very helpful in outlining the requirements and explaining the reasoning. However they do have a huge and varied mission, so there's definitely a limit to the amount of hand-holding they can do. So it's good to do a little homework before proceeding. The first step is to review the Regs (see the links below) and make a list of questions. Then contact your local Coast Guard Inspections office (OCMI, Officer in Charge Marine Inspection). They will assign an Inspector for the boat only if you can convince them you are serious -- i.e. you actually own the boat and are actively planning to make the necessary changes to put her into service. Then you can work closely with your inspector to work out what needs to be done and what documentation the Coast Guard will need. (My advice: don't try to fight them - it's worth developing a friendly, cooperative rapport with them.)
References:
-Rick Etsell, P.E., naval architect
- SubChapter T Small Passenger Vessels: 46 CFR Parts 175-185 ONLINE
- Small Passenger Vessel Information Package (pdf file) (This one's from Sector Upper Mississippi River, but other CG offices usually have a very similar guide.)
- Marine Safety Center (USCG Technical Review Authority): MSC Homepage
- USCG Small Passenger Vessel Safety Program Website
After reading this from CG regulations, I would say you cannot bareboat and get hired back as the Captain.
After reading more deeply into USCG interpretations and actions, I see that I was mistaken and you are correct.
While there appears to be no specific regulation that prohibits the owner from serving as master, the CG interpretation and its enforcement history supports the practical fact that an owner who serves as master under a "bareboat" charter agreement will not succeed in a defence against the violation.
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