Whenever I see “…the Coast Guard” I cringe because there are so many parts and one section may decide one thing, tell your company one thing and then in another port, they decide another and tell you something else. I have gotten to the point now, being on the comm’l side, that if they tell me something I make sure it is recorded or request a copy in writing.
On this issue specifically, I think someone got lazy and did not update their AIS and the USCG noticed it. From reading your post, I think you would naturally err on the side of caution and I would do the same especially since if I was meeting you, I would want your overall size not the size of just the tug.
The director of the VTS in NYC is a close friend. I will ask his opinion which will be just that, not policy and maybe he will tell me why this is becoming an issue.
Which Coast Guard office contacted your company?