Masthead navigation light: Are lights conforming to COLREGS Rule 25(c) disallowed?

[pbryant]

The Race Rules state: "4.30 Navigation lights... All yachts shall have a masthead tricolor light," -- which is described in COLREGS as Rule 25(b).

When I got my Master's license, one of the mnemonic phrases I had to remember was: "Red Over Green - Sailing Machine." I am a strong proponent of the optional navigation light configuration allowed under COLREGS Rule 25(c). It clearly defines my vessel as a sailboat to other professional mariners (i.e., "big boats") who know the navigation rules forward and backward. A single light at a sailboat masthead hovering in space against a dark sky cannot be discerned at a distance from an ordinary small motor vessel - especially when viewed from astern where both types of vessels will only display a single white light. The combination of red-over-green lights at the mast top plus the three navigation lights on deck is far more noticeable. It's says unmistakably: "This is a sailboat." The vertical spacing of the lights allows estimating distance, and the orientation of the red-over-green lights to the navigation lights on deck provides aspect information - which a single visible color from tricolor light cannot do.

I know it's not common in these parts, but the Rule 25(c) configuration is common in other parts of the world that have much more congested waters.

I've lighted my own boat from the perspective of someone who has stood watch far above the surface on commercial vessels, where a common question asked between watchstanders was: "What kind of boat is that? If it's a motor vessel - they give way. If it's a sailing vessel - we give way." The red-over-green lights answer the question. Must my vessel conform to what is arguably a less safe configuration? The only advantage of rule 25(b) is that it requires less power - but with LEDs, who cares? I'd rather burn another 8 amp/hours per night and be safer.

You can see my configuration here, along with an excerpt of COLREGS Rule 25(c): http://www.pearsonariel.org/discussion/showthread.php?913-Navigation-Lights&p=26779#post26779

I understand the reason for requiring lights aloft at the masthead. They greatly improve visibility in ocean swells. But there is another - and in my opinion based on standing watch on commercial vessels - a better, alternative to tricolor lights.

 

[BobJ]

I looked at your photo. When the main is set (at full hoist) are your green lights visible for 360 degrees? The illustrations used with 33 CFR 83, such as in the USCG's "Boat Responsibly" publication, show the all-around red and green lights mounted above the masthead where they are unobstructed. Also, don't the green lights screw up your night vision, especially glowing off the main? (I'm doubtful about your comment that you always sail reefed, having experienced the long periods of light air we can get in a Hawaii race.)

Sec. 83.25(c) states that "in addition to" the red and green all-round lights, deck level lights must also be used. Linky to Sec. 83.25. You're right about that being a lot of power draw for a Hawaii race - are yours in fact all LED's? I think it would be easier to change out your red all-around light for a LED tricolor for the race, disconnect the others and call it good. A tricolor doesn't cost that much and draws very little power compared to what you probably have now.

Given the construction of 83.25 I think this is pretty simple: (b) is what is required for the SHTP. (a) is not sufficient and probably because of the deck level stern light, neither is (c). Regarding (d) for sailboats less than 23 feet, in the 2010 rules we specified that this was not sufficient - those Cal 20s, Minis, etc. needed to have regular nav lights. The requirement for a masthead tricolor covers that issue as well.

If you're adamant about it you can submit a request for waiver to the SHTP R/C.
.

 

[pbryant]

I looked at your photo. When the main is set (at full hoist) are your green lights visible for 360 degrees? The illustrations used with 33 CFR 83, such as in the USCG's "Boat Responsibly" publication, show the all-around red and green lights mounted above the masthead where they are unobstructed. Also, don't the green lights screw up your night vision, especially glowing off the main? (I'm doubtful about your comment that you always sail reefed, having experienced the long periods of light air we can get in a Hawaii race.)

Sec. 83.25(c) states that "in addition to" the red and green all-round lights, deck level lights must also be used. Linky to Sec. 83.25. You're right about that being a lot of power draw for a Hawaii race - are yours in fact all LED's? I think it would be easier to change out your red all-around light for a LED tricolor for the race, disconnect the others and call it good. A tricolor doesn't cost that much and draws very little power compared to what you probably have now.

Given the construction of 83.25 I think this is pretty simple: (b) is what is required for the SHTP. (a) is not sufficient and probably because of the deck level stern light, neither is (c). Regarding (d) for sailboats less than 23 feet, in the 2010 rules we specified that this was not sufficient - those Cal 20s, Minis, etc. needed to have regular nav lights. The requirement for a masthead tricolor covers that issue as well.

If you're adamant about it you can submit a request for waiver to the SHTP R/C.
.

Imagine viewing a sailboat with a fully hoisted main with the mainsail luff attached to a reasonably wide mast on a track. Is there any orientation of the boat or the mainsail in which you could not see a part of the mast near the head, where depth of the sail's camber (draft) is minimal? Now imagine lights attached to the mast that are offset a small distance away from the mast. Could you not see, in any orientation, those lights provided they project light in your direction?

I have four sets of green lights, each projecting in 112.5 degrees of horizontal arc (the specified minimum for nav side lights). That's a total of 450 degrees of arc -- providing 90 degrees of overlap. The lamp housings are oriented so 45 degrees of overlap is forward, and 45 degrees is aft. Even with the main at full hoist and set as close abeam as it will set (such as on a beam reach), the overlap is sufficient to prevent blockage of at least one light.

The green lamps are supplied with black plastic cover "screens" that limit the vertical sectors to just over 25 degrees, so the only green light I see from the cockpit is the light reflected off the upper shroud wire rope and a sliver (about 25 degress wide) of the mainsail near the head, and then, only the top of the sail is illuminated. You are right, green light degrades my night vision, but I spend very little time looking at the sail head. I use the wind instrument at night because a black windex would be invisible even if I looked at it. My boat is really over-canvassed, so I only shake out the first reef in winds less than 8 knots. But yes, that does occur. For several years, I had a pole with red-over-green lights at the masthead, but I found there was little gained by it over what I have now, and it added weight aloft on a long lever-arm above the masthead.

All navigation lights on my boat are LEDs. They are a combination of Hella Marine and Aquasignal lights. The total current consumption for all of the navigation lights is 2.7 amps -- 34 watts. A little more than the single incandescent lamp commonly used in a "two mile" incandescent tricolor light (the common BAY15d bulb consumes 25 watts). I don't have a single incandescent lamp anywhere on my boat. I've even replaced my compass light with an LED.

All of the lights on the mast (as well as on deck) are USCG approved with the wider 25 degree vertical sectors required for sailing vessels (COLREGs § 84.19 (b)(2) "Vertical sectors"). The vertical sector specification, by the way, is very important. There are some off-brand LED vendors that don't label their product approvals as being limited to motor vessels - which only require 7.5 degree vertical sectors (with those lights, heel much past 7.5 degrees - and your navigation lights vanish!). It's cheaper to manufacture LED lamps with smaller emitters that concentrate light in a narrower vertical beam -- and then foist them on sailors. That's something everyone should look out for.

Except for confusion from lack of recognition my lights could cause to mariners unaware of Rule 25(c) (that would be those who never had to pass the Coast Guard rules-of-the-road exam), I don't see a downside. I have 400 amp/hours of batteries, 330 watts of solar panels, a towed-propeller hydrogenerator (that produces 8 amps at 5.5 knots 24 hours a day), and a Honda generator aboard. 34 watts of power consumption only at night is well within my power budget.

Of course, my AIS Class B transponder with a Vesper Marine display and a wake-the-dead-loud alarm is primary for collision avoidance with commercial vessels. I've worked commercial vessels enough to know that there is disturbingly little time spent actually looking out the window at night, and the tiny passive radar reflectors we carry aren't very effective. In terms of collision avoidance, commercial oceangoing vessels these days should be regarded as automated floating robots (one reason I enjoy the contrast of sailing). We need to avoid them, not the other way around. Expending effort to be seen is worth while, but knowing when to get out of the way is much more important.

I understand, support and appreciate why everyone wants to minimize their power use. But power conservation is no more a reason to exclude a standardized and internationally-accepted lighting configuration than would be a prohibition on using our stereos while under way. In this instance, it seems to be either an oversight or irrational. I'll check out the waiver process.

 

[BobJ]

Neither an oversight or irrational - several of us have Master's licenses so we've taken the same tests you have. I've found that very little of that material was useful for racing a sailboat to Hawaii. You will have far larger issues than the configuration of your running lights. It won't be my decision but as long as the sails do not mask the light(s) it would appear they are effectively equivalent to a tricolor.

There's nothing in writing about the waiver process. First you enter the race and meet the qualifications (complete the qualifying sail, etc.) In the process you equip the boat in accordance with the rules (it's a race and like all races, it has rules). If you have something you believe meets the requirements but is done a different way, such as your lights, the inspector will look at it and decide whether it is subject to a request for waiver. Most requirements are not. If a waiver is requested, the Race Committee will discuss it and decide whether to grant it.

Good luck with your prep.

 

[pbryant]

> Neither an oversight or irrational - several of us have Master's licenses so we've taken the same tests you have. I've found that very little of that material was useful for racing a sailboat to Hawaii.

I agree. Maybe I misstated my point: Those of us who had to take the tests were required to memorize all those light configurations, while more practical sailors just keep a copy of the COLREGs on board for reference. I hope I never encounter a working minesweeper, but I know its "lights and shapes." Presumably, whoever is at the helm of any cargo ships along the way to Hawaii has also memorized the same information and recognizes what red-over-green signifies. There is, as you say, very little in the Master's common body of knowledge that would be useful to me for sailing to Hawaii.

Thanks for your time and replies. I'll have to decide whether to equip my boat, pay all the fees, and then risk disqualification at the very end. It's too bad there isn't as waiver process, because I'm not a person who relents easily on matters of safety, and I'll probably decide last-minute disqualification is an unacceptable risk.

 

[BobJ]

Not to make light (pun?) of your concerns but most of us have found you have to really want to do this race. Once you've met some of the folks, attended a few seminars, done a solo Farallones race and/or LongPac, etc. you get hooked. Then if the rules required purple underwater lights you'd happily install them just so you can be part of the SHTP.

Otherwise any of us can sail to Hawaii any time we like.

 

[pbryant]

I have already met some folks when I attended some of the seminars for the 2014 race. And they're great! I couldn't agree more!

 

[Harrier]

The tricolor masthead light is a new "hoop" for SH Transpackers to jump thru. Never has been in the ROC for previous races. Por que este tiempo?

 

[BobJ]

Stick around pb - we haven't had the biennial argument about strobes yet!

Harrier, it evolved in 2010 or 2012 (my R/C years) to needing to have something at the masthead besides Greg's inflatable doll. It could be a strobe or a tricolor. Apparently they've settled on a tricolor.

 

[pogen]

A tricolor masthead has been part of local offshore regs for many many years. SHTP2014 required masthead tri-color or strobe (RRC 4.30). The strobe requirement frankly contravened COLREGs. The red-over-green approach is probably not legal if the lower light is obscured by the top of you mainsail from some directions.

If you have any sort of masthead light, it is probably worth it to replace it with a LED unit, the power consumption is far less.

 

[BobJ]

I guess we're doing it. On Inland Waters a white strobe is a distress signal and is not permitted otherwise. Outside it has no specific meaning except when they can't see you. Then it's: "We can't see you." "Okay, (turning on strobe) can you see THIS?" "Yes, we see you now."

A yellow strobe is a submarine surfacing. Sometimes it feels like that in the GOF but we can't use a yellow strobe to signal it.

 

[pbryant]

Stick around pb - we haven't had the biennial argument about strobes yet!

Harrier, it evolved in 2010 or 2012 (my R/C years) to needing to have something at the masthead besides Greg's inflatable doll. It could be a strobe or a tricolor. Apparently they've settled on a tricolor.

That's bad luck for me. I already have a strobe at the masthead. I'm considering mounting a red all-round atop an LED tricolor so I can flip a "Rule 25(b)/25(c)" switch and have either red-over-green with deck nav lights, or just the tricolor.

In either configuration, I have antennas and a wind instrument sensor that will block either the tricolor or the red all-around over more degrees of arc than a sail could ever block the green lights below on the mast. And I bet that situation exists on everyone's boat -- unless someone has elevated their tricolor on a pedestal that's higher than their windex/wind sensor and large-diameter tuning coil at the base of their VHF antenna. That's one other reason why I prefer the 25(c) configuration which permits running the nav lights on deck along with the red-over-green all-arounds. Built-in recognition redundancy. But... if I've got a switch then maybe I'll label it: "pass SHTP inspection / run safely." How dull would life be without a little absurdity?

 

[Harrier]

Changing what is already at my masthead (strobe per previous SHTP requirements) is a giant pain in the ass which I don't need! And I figure on making it to Hanalei without a tricolor.....I have converted my nav lites to LEDs some time ago and truly understand the savings in power consumptions. Thanks for the advice tho....

 

[BobJ]

I think this scenario fits a waiver request but I'm not even the hired help. Brian and George work in the "thick carpet" end of the building.

They're going to need a raise - I suggest 10%.

 

[svShearwater]

In Pac Cup 2014, while drifting around the first night, west of the Farralones, I could see almost all of the boats that started the same day as us. 15 or so. Every boat had a tri-color and were easily visible. Luna Sea brand seem to be the brightest.

Personally, I don't like the light pollution of deck level running lights.

 

[pbryant]

By the way, since vessels up to 70 feet can enter the race, there will be some very unhappy skippers of any vessels 20 meters (65.6 feet) and longer because tricolor lights are disallowed on vessels 20 meters in length and up (Rule 25(b)). For those larger vessels, the only option for lights aloft on the mast is exactly what I have now: red-over-green. Those skippers will have a conflict between safety and legality versus the racing rules by being forced to violate the 20 meter limitation in COLREGs 25(b). If those who wrote the rules wish to require lights aloft on all vessels (a worthy goal) while remaining within compliance with COLREGs, then either the racing rules need to be revised to disallow vessels 20 meters and up, or the tricolor requirement needs to be revised to permit red-over-green lights conforming to rule 25(c).

 

[pbryant]

I've thought this over. I considered sailing in the 2014 race, until economic necessity prevented it. Back then, I added a strobe to my masthead since - besides being required by the race rules - it seemed like a good safety enhancement. I installed an FAA TSO'd light that works well yet weighs very little. Now, I'm supposed to add a tri-color light there too for 2016? Where does this end?

Since I steadfastly believe my red-over-green configuration is safer than a tri-color, that means I won't remove the lights I have - and I will just have to add yet another light to my masthead to conform. It's getting to the point where, I'd have so much stuff up top that I might as well tie an anvil to the masthead. This seems like a case of mindless conformity - especially since there are boats of such size that could enter the race where a tri-color light violates COLREGs (see my previous post), and yet, the legal option of a red-over-green configuration isn't accommodated in the rules. It's this simple: if 70 foot boats can enter, then this rule is wrong. I also feel for the people who installed a strobe, and now have to reconfigure.

I have a rule: when people start to conform to things that aren't well thought out in terms of legality or safety - I speak up - and then leave the party. I'll keep an eye on the race rules, but if they remain unmodified on this point - I'm out. I can't afford to put time and resources into the race on the mere speculation that I might get a waiver for a configuration that's safe and legal.

 

[BobJ]

As an inspector and former SHTP Race Chair, I think I was pretty clear that you would likely qualify for a waiver. If you don't really want to do the race, cool, but don't blame it on the rules.

 

[pbryant]

As an inspector and former SHTP Race Chair, I think I was pretty clear that you would likely qualify for a waiver. If you don't really want to do the race, cool, but don't blame it on the rules.

I wasn't aware of your status. Sorry if I didn't recognize your name. I'm kinda new here. OK. A waiver would solve my problem. But how do I find out if I qualify? Pay all the fees, rent/buy a liferaft, attend the courses (involving unpaid time off for me), arrange for several weeks of unpaid leave... and then possibly find out on race day that my vessel is disqualified because my lights conform to the more difficult requirements of a vessel 20 meters or larger? Seems like quite a gamble. I asked before what the process was to get a waiver, and I believe the answer was there is no process. I'm not blaming the rules, but in that case, they do seem a little odd to me. What do I have to do? I haven't gotten an answer to that question - or at least one that I comprehend. Pour out libations to Poseidon asking for dispensation? I just don't know! I'm just asking for a straight answer. Maybe it's a tribal/cultural thing I'm not getting, some answer between the lines that I'm not reading. I'm really in the dark here. Maybe you assume I'm smarter than I really am.

If I didn't want to do the race, I wouldn't be here, and I wouldn't have spent the last two years preparing my boat for it. It's the conditions that I have a problem with.

I do feel my enthusiasm deflating by the minute over what looks a lot like bureaucracy. The worst kind - one where there isn't even a form to fill out. Maybe I really don't want to do the race. You're doing a good job of convincing me. Gotta think about that...

 

[brianb]

Hello PByrant,

We will grant a waiver for the vertical lighting as it is in full compliance with COLREGS. I apologize our bureaucracy has none of the paper trappings usually found within a bureaucratic establishment. The only excuse is we are a group of volunteers with many other projects in flight.

Regards,
Brian Boschma