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Go Back   SailNet Community > General Interest > General Discussion (sailing related) > Registration Numbers
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Topic Review (Newest First)
03-08-2013 01:53 PM
billyruffn
Dinghy Registration Numbers

Quote:
Originally Posted by Minnewaska View Post
Some say that putting the symbol T/T (which denotes Tender To) and then your Documented boat's name will somehow attach it to the boat and avoid the need for titling or registering it. I've never found where that is actually permitted in RI, but may be in other state. My best guess is this is rumor that confuses the difference and the T/T only tags along with the boats title (documentation), not its registration.
This post is focused on the rules regarding yacht tenders / dinghies and not on the broader issue of the yachts themselves.

I'm no lawyer, but........

......I think the source of the confusion Minnewaska mentioned above lies in trying to figure out the meaning of quotes from the US Code and the CFR shown below. Like so much of federal law and regulation it isn't immediately obvious and requires you to pay attention to which shell hides the pea.

The first quote is from the US Code Title 46. It establishes the States with an "approved numbering system" (no doubt approved by the Feds) as the "issuing authority" (as in issuing registration numbers). When a state does not have an approved numbering system, "the Secretary (of the federal department having control over the Coast Guard) is the issuing authority." I would imagine most states have an approved numbering system, and therefore in most states the registration of vessels is a state matter.

Note that in all the quotes below I've cut out sections of the documents that don't apply, but retained enough of the citations so you can go look it up and read it in it's full literary glory should you be so inclined.

Quote:
TITLE 46 - SHIPPING
Subtitle II - Vessels and Seamen
Part H - Identification of Vessels
CHAPTER 123 - NUMBERING UNDOCUMENTED VESSELS

-HEAD-
Sec. 12302. Standard numbering system

-STATUTE-
(b) A State with an approved numbering system is the issuing
authority within the meaning of this chapter. The Secretary is the
issuing authority in a State in which a State numbering system has
not been approved.
So, if you're a state with an approved number system...."You're the man!"

In the quote below, the US Code allows both the "Secretary" and the states to exempt certain vessels from numbering requirements. The phrase is "When the Secretary (or state) is the issuing authority..." seems to lead us to who's exemptions may apply.


Quote:
TITLE 46 - SHIPPING
Subtitle II - Vessels and Seamen
Part H - Identification of Vessels
CHAPTER 123 - NUMBERING UNDOCUMENTED VESSELS

-HEAD-
Sec. 12303. Exemption from numbering requirements

-STATUTE-
(a) When the Secretary is the authority issuing a number under
this chapter, the Secretary may exempt a vessel or class of vessels
from the numbering requirements of this chapter under conditions
the Secretary may prescribe.
(b) When a State is the issuing authority, it may exempt from the
numbering requirements of this chapter a vessel or class of vessels
exempted under subsection (a) of this section or otherwise as
permitted by the Secretary.
Now we go the Code of Federal Regulations where the "exemptions" allowed by the "Secretary" are spelled out. You'll have to go look at your state laws to see what exemptions to numbering the state may allow.

Quote:
(From Code of Federal Regulations)

§ 173.13 Exemptions.

Where the Coast Guard issues numbers, the following classes of vessels are exempt, under Section 12303 of Title 46, United States Code, from the numbering provisions of Sections 12301 and 12302 of Title 46, United States Code, and this part:

(a) A vessel that is used exclusively for racing.

(b) A vessel equipped with propulsion machinery of less than 10 horsepower that:

(1) Is owned by the owner of a vessel for which a valid certificate of number has been issued;

(2) Displays the number of that numbered vessel followed by the suffix “1” in the manner prescribed in §173.27; and

(3) Is used as a tender for direct transportation between that vessel and the shore and for no other purpose.
Here is where the confusion arises about numbering dinghys. If you have a dinghy that meets the criteria spelled out in sub paragraph b the text suggests that it doesn't need to be "numbered"......but, note that there is a condition. The expemption applies when the Coast Guard (acting for the Secretary) issues numbers.

Because the Coast Guard issues vessel documents all over the USA, it would appear from this section of the CFR that the exemptions of this section would apply all over the US.

But not so fast..... back to the US Code Title 46:

Quote:
46 USC § 12302 - Standard numbering system.

(a)The Secretary shall prescribe by regulation a standard numbering system for vessels to which this chapter applies. On application by a State, the Secretary shall approve a State numbering system that is consistent with the standard numbering system. In carrying out its numbering system, a State shall adopt any definitions of relevant terms prescribed by regulations of the Secretary.

(b)A State with an approved numbering system is the issuing authority within the meaning of this chapter. The Secretary is the issuing authority in a State in which a State numbering system has not been approved.
My reading of the above paragraphs is that when the state has an approved numbering system (which most do), sub para b says the state is "the issuing authority within the meaning of this chapter." In states without an approved numbering system or in places where US vessels go where states have no jurisdication (like international waters and foreign countries) the Secretary is the issuing authority and so the Secretary's exemptions (outlined in the CFR Sec 173 above) apply.

I think this means that you have to register your dinghy in states having approved numbering systems and where the boat operates under the regulations of the state. So, if you live and operate your boat in a state, that states numbering system applies for the dinghy. Most states don't require registration if the vessel is registered else where and it does not spend more than X days in the state's waters. In my state, it's 60 consequtive days that triggers the requirement to register.

But what if your boat is operated outside the US, or inside the US but is moving about so that it does not trip the 30, 60 or 90 day trigger requiring registration by that state? I believe it means that in those circumstances the Secretary is the issuing authority and the exemptions outlined in the CFR apply.

Note in these limited circumstances, you still have to number have numbers on the dinghy. You need to see another section of the CFR for the details on that scheme (§173.27), but it's basically this: the Document number followed by a hyphen and the number 1 (or 2, if you have two dinghies).

As I said, I'm not a lawyer, but because BR spends a lot of time outside the US and moves around a lot while she's here, I've tried to figure it out as I wanted to be in compliance with US law and have an answer for any foreign coast guard or harbor police that might want to see my dinghy registration.

I'd be interested in what the lawyers in the SailNet community might have to say my intrepretations of the Code and CFR.....particularily if any are judges!
03-08-2013 12:17 PM
TakeFive
Re: Registration Numbers

Quote:
Originally Posted by chucklesR View Post
I take exception to the 'you never get both' statement.

USCG documentation does not preclude state issued titles. In fact to sell a vessel, USCG documented or both you will need that title.
Call the National Vessel Documentation Center at 800-799-8362. I am virtually certain that they will tell you that it is illegal to have both documentation and a state title on the same boat.

Having both opens up a whole host of problems. For one, you will not be able to get a loan for the boat, because the lender cannot place a reliable lien. If they place a lien on the state title, you could sell the boat with the unliened doc papers and run off with the money without paying off the loan. Same if they place the lien on the documentation. They will not place a lien on both, because they know it's illegal to have both, and will do a title/documentation search prior to issuing the loan to make sure it has only one. Obviously you can bypass this issue by paying cash when you buy a boat, but then you might not be able to sell it.

There are a bunch of other problems that they told me about, but it was 3 years ago and I can't remember. Some of the other problems can end up with someone else being able to claim ownership of your vessel.
03-08-2013 12:02 PM
chucklesR
Re: Registration Numbers

I take exception to the 'you never get both' statement.

USCG documentation does not preclude state issued titles. In fact to sell a vessel, USCG documented or both you will need that title.
03-08-2013 08:52 AM
Minnewaska
Re: Registration Numbers

First, let's clarify the difference between Documented and Registered.

When you buy a boat, naturally you will want some proof that you own it. That is either in the form of a State issued Title or a Federally issued USCG Vessel Documentation (a documented boat). You never get both. The USCG has minimum requirements to document with them. See here: USCG National Vessel Documentation Center, FAQ Page

Registration is strictly a State requirement to identify vessels that remain in their waters for a period longer than they identify. This varies highly, but 30 to 90 days is common. They do this so that they can effect regulation, track usage and collect taxes.

You will always have a form of title, and almost always have a registration as well, unless you are eternally transient or overseas.

Our boat is Documented with the USCG and registered in RI. However, I am not required to display any RI registration numbers, because I am Federally documented. The Federal Documentation number must be permanently inscribed aboard, but it not required to be visible. Your documented boat name and hailport are required to be visible and there are specific requirements for them (size and location).

Our dinghy does not meet the minimum size requirements to be USCG Documented and, therefore, is both State Titled and Registered. Therefore, registrations numbers are required to be displayed on it.

Some say that putting the symbol T/T (which denotes Tender To) and then your Documented boat's name will somehow attach it to the boat and avoid the need for titling or registering it. I've never found where that is actually permitted in RI, but may be in other state. My best guess is this is rumor that confuses the difference and the T/T only tags along with the boats title (documentation), not its registration.
03-08-2013 12:09 AM
chef2sail
Re: Registration Numbers

If your dighy is motorized it also must have registration numers and they must be displayed in MD.
03-07-2013 10:20 PM
TakeFive
Re: Registration Numbers

Quote:
Originally Posted by Nicklaus View Post
Thanks.

Did some more digging and it appears as long as the federal registration number is attached (I believe it is carved on a plaque by my nav station) the vessel does not need external numbers. I will need to display my Maryland decals, which I have, on the port and starboard side.

The previous owner didn't have his displayed anywhere.

I wasn't worried about the cost of the decals - just wanted to avoid putting any more stickers than necessary on my hull.
It's a documentation number, not registration. I believe that you must transfer the documentation to your name. It takes the place of a title. It's illegal to have a title on a documented vessel - you have one or the other, but not both. Hopefully you had a doc search done prior to purchase, to verify that there are no liens on your vessel. If you took out a loan, the lender would have made sure this was done. If you paid cash, you or your broker were responsible for this. If this was not done, you may be in for an unpleasant surprise.
03-07-2013 09:34 PM
Nicklaus
Re: Registration Numbers

Thanks.

Did some more digging and it appears as long as the federal registration number is attached (I believe it is carved on a plaque by my nav station) the vessel does not need external numbers. I will need to display my Maryland decals, which I have, on the port and starboard side.

The previous owner didn't have his displayed anywhere.

I wasn't worried about the cost of the decals - just wanted to avoid putting any more stickers than necessary on my hull.
03-07-2013 08:54 PM
Tempest
Re: Registration Numbers

The documentation number does have to be permanent but doesn't have to be visible from afar. My number is inside the vessel on the hull. The vessel name and home port need to be painted on the transom and match the documentation papers.
03-07-2013 08:48 PM
TakeFive
Re: Registration Numbers

Quote:
Originally Posted by Nicklaus View Post
My new-tp-me boat doesn't have any registration numbers on the hull - and I'm not sure about the dinghy.

Anyone have ideas on alternative set-ups to avoid the decals, but still be in compliance should I get inspected?
If you document, then you don't have to display any numbers.

I believe that numbers have to be permanent, so painting them on may be the only way to do it without decals. I believe that putting numbers on a piece of wood and hanging them on a lifeline is not permanent enough, and would like lead to you getting boarded.

What's wrong with decals anyway? 50 cents each at Lowes.
03-07-2013 08:46 PM
Tempest
Re: Registration Numbers

Federally documented vessels, generally are not required to display state registration numbers. However, depending on your state regs, you may still have to register your vessel and display an " annual" registration sticker. For Maryland it looks like a two year "documented vessel sticker. I don't live there..so don't trust me. ;-)

Check the dinghy requirements too.

Maryland Department of Natural Resources - Boating
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