CG D8(dp) Policy Letter 02-2022 establishes that towing vessel sidelights located on outer edge of pilothouse or superstructure are considered compliant. Lighting requirements under the International Navigation Rules state that power-driven vessels of 20m or more shall have side lights place “at or near the side of the vessel”. The Coast Guard’s Marine Safety Manual interprets “at or near the side of the vessel” to mean not more than 10% of the breadth of the vessel inboard from the side, up to a maximum of 2 meters.
This policy along with D8 communication clarifies that a Certificate of Alternative Compliance (COAC) is not required when a towing vessels’ sidelights are located on the outer edge of the pilothouse or superstructure.
For full details, see the policy letter here.