1. U.S. Coast Guard Homeland Security Applicability of International Regulations to Uninspected Towing Vessels (UTV) Towing Vessel National Center of Expertise

2. U.S. Coast Guard Homeland Security Objectives Towing Vessel National Center of Expertise Identify key international reference materials for UTVs Determine when a UTV engages in international/foreign voyages Determine international requirement applicability for a UTV based on build date/Gross Register Tons/Gross Tonnage, International Tonnage Convention

3. U.S. Coast Guard Homeland Security References Towing Vessel National Center of Expertise SOLAS (various) MARPOL (Annex I - III and V – VI) STCW ILLC ISPS ILO NVIC 11-93 (Applicability of Tonnage Systems) Various CFRs. For example: 46 CFR Part 69 (Measurement of Vessels) 33 CFR Part 169 Subpart C (LRIT) 33 CFR Subchapter O (MARPOL Annex I, II, V) 33 CFR Subchapter H (MTSA)

4. U.S. Coast Guard Homeland Security Foreign/Domestic Voyage (Per 46 CFR 69.9 and NVIC 11-93 Ch-3) Towing Vessel National Center of Expertise Foreign Voyage: Foreign port to US port Foreign port to Foreign port US port to Foreign port US territory/possession to/from other port w/in US jurisdiction Great Lakes Voyage: A voyage on the Great Lakes Domestic Voyage: Not a foreign voyage Not a Great Lakes voyage All “international voyages” are “foreign voyages” but…not all foreign voyages are international voyages.

5. U.S. Coast Guard Homeland Security Ton/Tonnage (History) Towing Vessel National Center of Expertise 1 Tun = 1 cask of wine 252 gallons 57 cubic feet

6. U.S. Coast Guard Homeland Security 1969 – International Tonnage Convention A replacement for the different global systems More accurate measurement of a vessels hull & superstructure Gross tonnage Net tonnage Ton/Tonnage (History) Towing Vessel National Center of Expertise 1849 - Moorsom System: Fees charged based on potential earning capacity Gross tons Net tons

7. U.S. Coast Guard Homeland Security Tons/Tonnage Towing Vessel National Center of Expertise Tons/Tonnage: Volume of a vessel’s enclosed spaces Based on tons of 100 cubic feet Space’s Length X Width X Height / 100 What is it??

8. U.S. Coast Guard Homeland Security Gross Tonnage Systems Towing Vessel National Center of Expertise GRT (Gross Register Tons) US Regulatory measurement system (standard, dual, simplified) US tonnage system with a historical basis – prior to 1983 this was the only measurement system AKA: GT, national tonnage, gross tons, regulatory tonnage GT ITC (Gross Tonnage, International Tonnage Convention) US tonnage measurement system to comply with International Convention on Tonnage Measurement of Ships, 1969 AKA: ITC, convention tonnage, gross tonnage

9. U.S. Coast Guard Homeland Security Gross Tons/Tonnage Towing Vessel National Center of Expertise A vessel’s approximate volume based on tons GRT: Standard, dual measurement systems: GT = Volume of enclosed spaces (tons) – exempted spaces per regulation (46 CFR Part 69) Simplified measurement systems: Length, depth, breadth modified by a coefficient: For example…GT = 0.67 LDB/100 (depends on hull shape) GT - ITC: All enclosed spaces modified by a coefficient: GT = K 1 V V = total volume of all enclosed spaces in cubic meters K 1 = 0.2+0.2 log 10 V What is it??

10. U.S. Coast Guard Homeland Security Net Tons/Tonnage Towing Vessel National Center of Expertise Net tonnage (NT) = A vessel’s earning capacity NRT: Standard, duel measurement systems = NRT = Gross tonnage – deducted spaces Simplified measurement systems = Gross tonnage modified by a coefficient: NT for self-propelled non-sailing vessel = (GT)(0.80) NT – ITC: Volume of passenger and cargo spaces modified by a formula based on the vessel’s volume: NT – ITC = K 2 V C (4d/3D) 2 +K 3 (N 1 +(N 2 /10)) What is it??

11. U.S. Coast Guard Homeland Security Sea (Lake) Story Towing Vessel National Center of Expertise Keel laid: Sep 1993 Delivered: March 1995 Passengers allowed: 750 Length: 195 ft GT-ITC: 3974 GRT: 94 From 46 CFR Part 69 (Measurement of vessels): Structures...on or above the line of the uppermost complete deck...open to the weather are exempt from gross tonnage. An interior or exterior opening that is temporarily closed by cover plates or boards held in place only by hook bolts is considered “open to the weather”.

12. U.S. Coast Guard Homeland Security Applicable Tonnage System Towing Vessel National Center of Expertise A vessel-specific determination Key document - NVIC 11-93 Ch-3 Tonnage questions unanswered by the NVIC should be directed your TVNCOE rep Some questions may be more appropriately answered by CVC-1 and/or the Tonnage Division at the Marine Safety Center (MSC-4) Requests for formal vessel specific determinations go through MSC-4 which is similar to plan review process

13. U.S. Coast Guard Homeland Security Key Points Towing Vessel National Center of Expertise UTVs that engage in foreign voyages must be in compliance w/all applicable international requirements Each vessel is evaluated on a case by case basis: Build date Applicable tonnage system When international requirements became effective

14. U.S. Coast Guard Homeland Security Build Date Towing Vessel National Center of Expertise Build date is: The date the keel was laid – no substantial alteration or The date the vessel was substantially altered: A change of more than 1% in GRT or GT ITC for vessels built before 18JUL82 A change of more than 5% in GRT or GT ITC for all vessels built on or after 18JUL82 Use the most recently altered date as the build date Existing Vessels 18JUL1982 Interim Scheme Vessels 31DEC8518JUL1994 All VesselsVessel’s <1600 GT New Vessels

15. U.S. Coast Guard Homeland Security General Tonnage System Applicability Towing Vessel National Center of Expertise UTVs with a build date on or after July 18, 1994, must comply with ALL international requirements using their GT ITC UTVs with a build date before July 18, 1994 can use their GRT for some international requirements; however, for certain international requirements they must use GT ITC. Gross tonnage does not always mean gross tons, it could be telling you which tonnage measurement system is to be used. Be sure to check definitions!! Existing Vessels 18JUL1982 Interim Scheme Vessels 31DEC8518JUL1994 All VesselsVessel’s <1600 GT New Vessels GT ITCGRT/GT ITC

16. U.S. Coast Guard Homeland Security General Tonnage System Applicability for Vessels With Build Dates Before 18JUL94 Towing Vessel National Center of Expertise Can use GRT for: GMDSS MARPOL (except Annex VI) SOLAS (some exceptions) Safe Manning Document Must use GT ITC for: LRIT ISM ISPS MARPOL Annex VI STCW

17. U.S. Coast Guard Homeland Security Towing Vessel National Center of Expertise UTV International Addendum (Unofficial)

18. U.S. Coast Guard Homeland Security Example Towing Vessel National Center of Expertise Built in 1978 GRT is 198 and GT ITC is 858 NRT is 135 and NT ITC is 257 Length overall 123 ft Convention length 118 ft Vessel goes international (foreign) No substantial alterations Do they have to comply with: MARPOL Annex VI (IAPP)? LRIT? GMDSS? YES NO

19. U.S. Coast Guard Homeland Security Example Towing Vessel National Center of Expertise Built in 1978 GRT is 198 and GT ITC is 832 NRT is 135 and NT ITC is 257 Length overall 123 ft Convention length 118 ft Vessel goes international (foreign) New construction GT ITC was 858 (alteration date 01NOV1996) Do they have to comply with: MARPOL Annex VI (IAPP)? LRIT? GMDSS? YES

20. U.S. Coast Guard Homeland Security Issuing Certificates to UTVs Not Subject to Certain Requirements Towing Vessel National Center of Expertise Reason…facilitate the operation of the US maritime industry Upon request, the CG can issue certificates even though an international convention does not apply to the vessel - i.e. ISSC and SMD (or SML) Examiners should encourage owners and operators to take advantage of this opportunity to avoid delays while conducting business in a foreign port

21. U.S. Coast Guard Homeland Security Questions Towing Vessel National Center of Expertise