RAM Towing lights Question

[Meme.Lord]

Realistically, I fully understand I’m splitting hairs here. However;

Rule 27 (c) has a divergence between International and Inland rules, technically.

International:

(c) A power-driven vessel engaged in a towing operation such as severely restricts the towing vessel and her tow in their ability to deviate from their course shall, in addition to the lights or shapes prescribed in Rule 24(a), exhibit the lights or shapes prescribed in subparagraphs (b)(i) and (ii) of this Rule.

Inland:

(c) A vessel engaged in a towing operation which severely restricts the towing vessel and her tow in their ability to deviate from their course shall, in addition to the lights or shapes prescribed in subparagraphs (b)(i) and (ii) of this Rule, exhibit the lights or shape prescribed in Rule 24 (§ 83.24).

The conflict:

• LAPWARE has questions indicating there is a difference, saying Towing vessels under COLREGS can only show RAM while towing astern, and Inland they can be RAM in any orientation. (Questions USCG 10057 vs USCG 10961 if you’re able to follow along a home)
• Nautical Rules of the Road, 5th Edition- Browne, on page 119, Says there is a difference
• Nautical Rules of the Road, 4th Edition- B.A Farnsworth, on page 91 says there is substantially no difference
• Farwell’s 9th edition says there is no difference here, as far as I can find, (Page 21, 411)
• US NAVCEN’s Amalgamated Rules of the road does not highlight a difference. When I had emailed them previously highlighting both this discrepancy, and that someone had somehow italicized everything after rule 23, the formatting issues were fixed, and the discrepancy remains unhighlighted.

LAPWARE Questions:

USCG 10961
INTERNATIONAL ONLY: If a towing vessel and her tow are severely restricted in their ability to deviate from their course, the towing vessel shall show lights in addition to her towing identification lights. When shall these additional lights be shown?
A. If the vessel is towed alongside
B. If the vessel is towed astern
C. If the vessel is pushed ahead
D. All of the above

USCG 10057
INLAND ONLY: If a towing vessel and her tow are severely restricted in their ability to deviate from their course, lights in addition to the towing identification lights must be shown. These additional lights shall be shown if the tow is which of the following?
A. towed astern
B. pushed ahead
C. towed alongside
D. All of the above

Nautical Rules of the Road, 5th Edition- Browne, P.119:

Nautical Rules of the Road, 4th Edition- B.A Farnsworth, P.91:

Farwell's 9th edition:

P. 21:

P. 411:

The Question:

Before I go bother NAVCEN again, I thought I’d ask my colleagues who match my nerdiness, but exceeded my experience, is there a definitive answer here somewhere? Is Lapware and Captain Browne wrong, Are Farwell’s and NAVCEN wrong, or am I misunderstanding?

Or D. All the Above.

[requiem]

Yes, NAVCEN appears to be incorrect. I believe the '81 amendments flipped the order of the clauses in the International Rules, but will need to verify. An authoritative reference source should be identified before suggesting corrections. As to the interpretation…

27(b) does not carve out an exception for vessels engaged in a towing operation. In contrast, it does carve out an exception for those engaged in minesweeping operations. Thus, a towing vessel that qualifies as RAM is clearly obligated to display RAM lights.

27(c) appears to be a clarifying rule, indicating that a RAM towing vessel must also display appropriate towing lights. A strictly literal interpretation would be that such a vessel must comply with all three of 24(a), 27(b)(i), and 27(b)(ii).

Thus, a vessel towing alongside, displaying both RAM lights and appropriate tow lights, is compliant with all three: 24(a) is satisfied by not displaying lights for towing astern and 27(b) is satisfied by displaying RAM lights. Additionally the other parts of rule 24 are satisfied by displaying the appropriate lights for towing alongside. This does not contravene any of the rules.

In contrast, a vessel towing alongside that eschews display of towing lights in favor of RAM lights violates the relevant sections of Rule 24, and a vessel that does the opposite is failing to comply with Rule 27(b).

The LAPWARE interpretation could just as easily claim that a RAM vessel towing alongside is obligated to display the lights for a vessel towing astern, which is clearly nonsensical.

[tugsailor]

The most definite answer would be from the cases. It’s up to the courts, particularly appellate courts, to decide what the rules mean.

[Hornblower]

Or, just slow down a bit and have a nice cup of tea.