The Acting Secretary of State to the British Ambassador (Lindsay)

Excellency: I have the honor to refer to your note No. 455 of December 31, 1931, regarding the Revised Collision Regulations, Annex II of the Convention for Promoting Safety of Life at Sea, and enclosing a copy of a memorandum containing certain suggested amendments to the Revised Text of the regulations.

With reference to the suggested amendments the views of this Government are as follows:

Article 2

The United States Government has conducted a number of tests with regard to the location on submarines of the two steaming lights required by Article 2 (a), (b), and (c). While it has not been found practicable to comply with the requirements of Article 2 (c) as to the vertical height of the forward of these two lights, it has been found practicable to install a forward range light on all submarines of the United States Navy, now in active service, and it is the opinion of the Navy Department that the fitting of such forward range lights is especially desirable for the safe navigation of vessels of this type.

In the case of some of the cruisers, it has not been possible to install the after range light so as to prevent its being obscured for a small angle on each bow by the structure of the foremast. In no type of naval vessel, however, has it been found impracticable to fit the two steaming lights in question.

This Government is of the opinion that it is in the interests of safe navigation that the two steaming lights required by Article 2 (a), (b), and (c) should be fitted on naval vessels as well as on merchant vessels and that every effort should be made to meet the provisions of this article “as closely as circumstances will permit.”

Article 10

The proposal of the Netherland Government is satisfactory and thoroughly desirable. In our Navy we are providing a standby stern light on the conning tower fairwater (“turret”) which is used in the event of failure at sea of the low stern light, which is placed “at the stern”.

[Page 910]

Article 9 (b) and (c)

The change proposed by the Japanese Government is acceptable.

Article 15

The change in this article proposed by the Belgian Government is acceptable.

Article 11

The change in this article proposed by the Netherlands Government is satisfactory. There are some advantages in not having the anchor light too high since the areas in which the vessel may be anchored are frequented by small craft. It is, however, preferable that the lights should be visible around the horizon than that they should be especially conspicuous to small boats.

Accept [etc.]

W. R. Castle, Jr.