🔍 Key Concepts

• 46 CFR requirements for officer citizenship on U.S.-flag towing vessels • Difference between "not readily available" and a formal regulatory waiver • Who has the authority to waive citizenship requirements and under what conditions

💭 Think About

• Ask yourself: Does the Coast Guard allow the Master of a U.S.-flag towing vessel to be a non‑U.S. citizen just because it is hard to find someone, or are waivers tightly limited by regulation? • Consider whether operating location (inside vs. outside the boundary line) affects citizenship, or mainly affects inspection and route requirements. • Think about whether economic reasons (cost of hiring a U.S. Master) are ever listed in the CFR as a valid basis for a waiver of citizenship requirements.

✅ Before You Answer

• Check 46 CFR parts that address manning and citizenship (for example, those tied to 46 U.S.C. 8103) to see if any exception for Masters of towing vessels is actually written. • Verify whether any waiver provisions talk about the Master specifically, or only about a percentage of crew positions below Master. • Confirm whether the regulations ever mention cost or availability as a valid reason to waive a U.S. citizenship requirement for the Master.