Preamble to Part 5 says

The protest form that was included in previous editions of this book has
been replaced by two forms, a hearing request form and a hearing
decision form. The new forms, in various formats, are available at the
World Sailing website at sailing.org/racingrules/documents. They may
be downloaded and printed.
Note that The Racing Rules of Sailing does not require a particular form
to be used.
Suggestions for improving these forms are welcome and should be sent
to rules@sailing.org.

While, the Preamble falls within the definition of rule, the only part of it recognisable as a rule (imposing an obligation or conferring a right) is the second paragraph which entitles a boat to deliver a protest in writing not in the form of a Hearing Request (or any other) Form.

I don't see how the Preamble affects where or how protests may or may not be delivered.

RRS J2.1(7) requires that the SI or NOR include the

location(s) of official notice board(s) or address of online notice board; location of the race office.

Appendix LG 3.2 provides sample text

The race office is located at <location> [, telephone <phone number> ][, email <email address> ].

RRS J2.1(7) permits information about the official notice board to be provided by either physical location or an address of an online notice board.

RRS J2.1(7) requires that information about the race office be provided by giving its 'location'.

It is arguable, by extension from the provision about the official notice board, that the rule does not permit the location of the race office to be specified solely by an electronic address.

It is also arguable that the right of a boat to deliver a protest in writing but in any form established in Preamble to Part 5 means that submitting a protest using a particular on-line system is contrary to the Preamble.

That said, RRS 86.1 permits the SI to change any part of Part 5.

A SI stating 'Protests shall be submitted using the XYZ system and protests delivered in any other way shall be invalid.  This changes RRS Part 5 Preamble.' would be valid.

But there had better be clear express words in the SI.

Wasn't there a Q&A some time ago answering the question of whether 'online' (typed) was considered 'in writing'?  It is. 

To me, unless it specifically mentions that hearing requests shall be made using the specified online system, the PC must accept any hearing request in writing. 

'Location' doesn't have to be a physical location.

Interesting. 

Ben, ''Location' doesn't have so be a physical location."

I think, that given the different way the requirements for official notice board and race office in RRS J2.1(7), I think that it is at least arguable that it does.

RRS J2.1(7) requires that the SI or NOR include the

location(s) of official notice board(s) or address of online notice board;

and the

location of the race office.

John.  Perhaps.  I can see where you're coming from, but I think its rather absurd in today's day and age to make a distinction between physical and online - whether it be intended by RRS or our lay-interpterion of the RRS.

By that reasoning, the official notice board cannot be wholly (exclusively) presented on the world wide web!  Alternatively put, that the Official Notice Board must be physical.  That will soon grow old, for sure (if it's not already).

Not sure why we are talking about noticeboards.
My query is as to the need to change the preamble when using online protest systems.
The preamble states (using new rules) 'The RRS does not require a particular hearing request form.' 
This is not really written in the form of a rule as it is simply a statement so does requiring a particular form change the rules and, if so, then should the change be made in accordance with 85.1.
 I think it is a change and if not done in accordance with 85.1 then protests can be submitted in any format and should be considered by the PC and not thrown out because they have not been submitted online.

Two points
1. There is English case law that "written" now includes electronic (email/fax/scanning), so scanning a request form or just a piece of paper on which the required items are written or typed , then emailing it etc to the required delivery address is legal. Do not know if other countries have changed their laws.
2. I think that the ref to the Part 5 preamble is missing the point. Delivery of the protest is governed by 61.3 (60.3 new rule book). Both say "shall be delivered to the race office". Unless the NOR or SI (present rule book) specify the means of delivery, then any means can be used (pigeon ?). In the new book it now specifically says "or by other such means as stated in the sailing instructions". So it is 61.3 (60.3) that has to be amended to limit the means of delivery, not the preamble. Posting it on the event notice board is the job of the race/protest office and is not relevant to delivery to the race office by or on behalf of the protestor.

John re: "This is not really written in the form of a rule as it is simply a statement so does requiring a particular form change the rules and, if so, then should the change be made in accordance with 85.1. .... I think it is a change and if not done in accordance with 85.1 then protests can be submitted in any format and should be considered by the PC and not thrown out because they have not been submitted online."

You are preaching to the choir here. I agree 100% and have made the exact same argument repeatedly when I'm presented with SI's that use "shall" and then describe an electronic portal.   I have made the case as you have that, if they want to do that, they must state it properly as a change of rule 61.3 ... and in the absence of that language ... that the delivery method should not be basis of invalidity as long as it is in writing.  

This is especially true when a standing PC has a physical presence on-site at the regatta.  I remember one regatta where this electronic-only "shall" applied and we watched as a sailor frantically tried to figure out how to take a pic of the protest with their phone and e-mail it to the office ... while we, the PC, were standing right in front of them.   On the other hand, when no physical presence is anticipated post-race and/or virtual hearings are utilized, electronic-only makes a lot of sense ... but should be stated properly as a rule change. 

PS: I agree with John A that there is a 'backdoor' (my characterization) of sorts where the SI can define the "race office" as an email address and for good measure state that "there is no physical location for the race office".  

In doing so, delivery to the race office could only be done by email ... and would not require a statement that it changes RRS 61.3. 

But the competitor could still write out a protest and email it as an attachment. It would not necessarily need to be done through any nominated protest system.

John S re: "It would not necessarily need to be done through any nominated protest system."

Yea I think so too, if the "Race Office" is defined as only an email address or if the SI states that the race office can be reached at an email address, and if the limit to only using the "protest system" is made without citing the change to 61.3 [as required by 85.1] (IMO)

OK - I am old and stuck in old ways.  Officials are there it serve the sport and its athletes. 
At a recent OA, RO, PC  Zoom call where the OA//RO had the same clause, shall be filed on line, I requested a "may" instead of "shall".  I also said, if a protest form or request came to me in paper form, I would accept it, SIs notwithstanding.
RRS 2021-2024 61.2 Protest Contents - "A protest shall be in writing ...."  RRS 2025-2028 60.3(a) ".... a protest shall be in writing ..."  Paper fulfills that requirement.  
If officials are there to serve the sport, I have a tough time accepting that an on-line only requirement satisfies that end. 
To assume at an international event that all person attending have the capabilities of filing on line, is a bold assumption.  

Leo re: "I requested a "may" instead of "shall". "

I've been on the same mission!  Unfortunately, items like that have a longevity as one regatta doc is used as the template for the next and that "shall" lives on and multiplies sometimes without consideration.  

One of my habits when reviewing docs is to look for that ... and to click-on each and every hyperlink in the doc to make sure it goes where it is supposed to and send test emails to the addresses listed. 

For instance, I have clicked on the hyperlinked email address for the race office and though the text in the PDF was correct, the hyperlink actually filled an incorrect address, sending the protest into a void. Also links that connect to last year's event of the same name.  All this needs to be tested and verified. 

For those regattas using YachtScoring and their protest portal, there is another issue. The protest-link does not show up until the first results are posted. Therefore, a competitor can't familiarize themselves (or the PC test) the protesting filing systems before racing.  

I disagree.

RRS J2.1(7) specifically permission SI to specify either a location or a web address for the ONB.  it doesn't provide that option for the race office.

I think there is a considerable practical difference between the ONB, where competitors need to read documents, which can readily be done on a mobile phone, and competitors needing to compose written protests, which may require quite lengthy text and diagrams, which may be difficult on a mobile phone.

I think that's justification for treating the two differently.

Ang, I certainly didn't say there is a "backdoor" of sorts where the SI can define the "race office" as an email address.

I said that SI could say 'Protests shall be submitted using the XYZ system and protests delivered in any other way shall be invalid.  This changes RRS Part 5 Preamble' but this requires clear express words in the SI.

BUT 

Thanks to Robin for pointing out the change in 2025 RRS 60.3, referring to "or by other such means as stated in the sailing instructions'

In my opinion this changes the context of the Preamble to Part 5, and specifically permits the SI to require protests to be delivered electronically either by email, or messaging or using an event management system.

This is a 'SI otherwise provide' rule so the magic words 'This changes rule ...' are not required because the chang is being made in accordance with the alternative provided in the rule.

Bottom line, 2025 RRS have been changed to allow SI to require protests to be delivered by a specific means, including an event management system.

I would suggest that before doing that, the race committee should consider how good the protest module of their system is.

John A .. "backdoor" is 100% my characterization .. I didn't mean to put that out as something you said. - Ang

PS .. I changed my post to make that clearer.

Leo, 'To assume that all [competitors] have the capabilities of filing on line, is a bold assumption,'

This seems to me to be a bit of an 'old ways' approach.

I think its quite OK for a race committee to assess that their event management system is sufficiently user friendly for it to be reasonable to require on line submission.

But I agree it should be the subject of careful assessment.  Maybe at a Dragon regatta, No, but at a Kiteboarding event Yes.

Rule 63.1 requires the protest committee to hear all protests and requests for redress that have been delivered to the race office. Will the protest committee have to hear a protest that is delivered to the race office on the wrong form and find it invalid?

Doesn't make the protest committee look very user friendly!

BTW - my opening statement was not to prevent on-line protest completion, just not to make it the only method
My questions - 
Who benefits more from having an on-line only protest submission - competitor or officials?
What is the benefit from on-line only protest submission for the competitor?
Which is easier for the competitor - finding an 8-1/2 x11 (or a protest form) to write the protest and hand it to the Jury Desk or RC office, or,  to pull out a phone, find the website, find the form, fill in the details on a tiny screen (wont mention how to draw a diagram) and press enter to submit it. 
One other question which no one has brought up - would a competitor be able to submit a protest in a language other than English?
I repeat - we are there to serve the competitor - not to put another loop top jump through!

Leo, Below is a protest I received and heard at a recent regatta.

Rules Broken: 第1・第2レースでセールナンバーが4405ではなく4401のメインセールを間違えて使用してしまいました。3レース目には4405のセールナンバーのメインセールに変更しました。1.2レース目に関する救済をお願い致します。

Leo - I know you're old and stuck in old ways ;)

But I agree with you.  As hard as we try, it's difficult to provide an interface that makes submitting a request via an electronic device fool proof and easy enough that it can be mastered in just a few minutes by everyone.  I've seen events use absolutely no paper because it wasn't needed and events that couldn't get any electronic devices to work.  It would seem to me that if a competitor wants to file a hearing request within the time limit, we should pretty much accept anything they are able to give us as long as it identifies the responding party and identifies the incident.  I can't for the life of me understand why we would set up barriers to limit it.

But let's be honest, how often is a diagram submitted by a competitor at an event even remotely helpful during the hearing? I've had many requests to build such a thing so it can be done electronically and I think it's a complete waste of time.  And worse, it makes the competitor believe they need to provide something. 

I think it is worth pointing out that the 2025 rules only require a protest to be in writing and identify the protestor, protestee and the incident. (New rule 60.3(a))
There is no requirement for a diagram. This makes online submission significantly less complicated as there will be no need to create and upload diagrams or documents.
 There will be no opportunity to identify the protestor or protestee, at a later time, (but before the hearing) as under the current rules.
New rule 60.3(b) also advises 'A protest shall be delivered to the race office (or by such other method as stated in the sailing instructions) within the protest time limit ....etc.
This certainly allows Si's to require protests to be submitted online. 
Back to my original point. Do the Si's need to say 'This changes the preamble to Part 5?'
Online systems are excellent as they keep control of documents and ensure they do not get lost. They also usually have the ability for a protest to be photographed and uploaded into the system and I think events should be prepared to do this for sailors who are unable to master the technology. we should not be throwing out protests because they have been handed in in an incorrect manner imo.

John S re: "I think it is worth pointing out that the 2025 rules only require a protest to be in writing and identify the protestor, protestee and the incident. (New rule 60.3(a)) ...There is no requirement for a diagram. This makes online submission significantly less complicated as there will be no need to create and upload diagrams or documents"

Actually, the 2025 quad change INCREASES the information required on the written protest when filed ... as compared to the current 2021 quad.

I started a 2017 thread here: Exploring the absolute, bare-minimum protest filing

The new quad is infinitely clearer and improved in stating what is actually required. But for those who take the time to parse the current rule, it is only a description of the incident that is required at filing in the current 2021 quad. 

That said, I want to support one of the points  of your comment.  When we supply a place for sailors to add information... on a form or online .. we leave the impression that the information (or the form) is required.  [.. and the cumulative subliminal effect of that on sailors is that filing a protest is difficult and time consuming]. 

How many times have we seen sailors running around trying to find a "protest form" ... when such a form was absolutely NOT necessary? 

Or someone trying to download, print, photo and email a protest form when all they needed to do was send a formless email to the race-office email-address with a description of the  incident?

Let's stop leaving a place for the drawings on these forms ... both on/off line.  Let's use those forms (both paper and online) as an opportunity to teach sailors how simple a filing is, by only asking for the information required for validity ....

... and if a place for any other info is made, put it under a bold line stating "OPTIONAL INFO BELOW - NOT REQUIRED FOR FILING". 

I wonder if my crusty old English grammar and punctuation teacher would think that the Part 5 preamble was a 'rule'. 

Ben
Re "I wonder if my crusty old English grammar and punctuation teacher would think that the Part 5 preamble was a 'rule'.'
Probably not but the RRS define it as a rule. Definition Rule (a).
Angelo
Re 'Actually, the 2025 quad change INCREASES the information required on the written protest when filed ... as compared to the current 2021 quad.'
Agreed . However, I have always wondered how a PC could organise a hearing if the protestor and/or protestee were not identified!

Ben,  Depending on how generous you are feeling, the second paragraph of Preamblel to Part 5 can be interpreted as conferrign a right or entitlement:  that would make it a rule.  Additionally, as John S has pointed out, the definition of Rule says it is.

Under the 2021 rules, I'd be happy, as I think most judges are, to take that view and regard any SI that purports to require a specific protest form, without express words changing the Preamble, as invalid.

I think that the insertion of 'by such other method as stated in the sailing instructions' in 2025 RRS 60.3(b) changes the context of that interpretation an indicates the specific intent of the RRS to permit SI to prescribe a particular 'means', which may include a format, and that because it's a 'sailing instructions otherwise prescribe' provision, no magic words are required once the 2025 RRS come into force.

John​ ​​and John,

Thanks for replies.

Actually I'm just messing with your minds / throwing a spanner in the works.

'Grammar/punctuation teacher asks whether Part 5 is a relevant Appendix.'

In other words, as it's written in the Definition of Rule, could it be validly interpreted as preambles of appendices, the rules of appendices but not titles of appendices. 

If so, then OPs question is answered!

Ben 
Happy to have the mind played with. 
I suppose it depends on where you were educated but my education says that a comma is not needed before an 'and' in this case. If there are other interpretations, then we do not have a good rule.
We continue to make difficulties for the sport when judges are having this sort of discussions. It is no wonder the average sailor despairs at times!
There are other preambles that are, and need to be, rules.

As much as I love online submissions as if done right they can avoid invalid protests I agree with Leo. We are here to serve our customers who are the sailors.  There are very few protests as it is and we need to remove what barriers we can. For us as officials protests are routine for the sailor they are often a mystery.  Again serve our customers and if you elect to be rigid you would have to change the rule in the si’s

IMO, no mention of a change to the preamble is required.  The preamble statement, "Note that The Racing Rules of Sailing does not require a particular form to be used." remains true, even if an SI later does require a particular form. 

Angelo
Do we then not have conflicting statements?
The Si's are a rule. So we have an Si that requires a particular form to be used and a preamble that says the rules do not require a particular form                                     

About Diagrams and information not specifically required

I don't agree that diagrams are not useful.  They may not mean very much once a formal hearing is commenced, but a picture is worth a thousand words, particularly given that some competitors can be somewhat incoherent in their written description of the incident.  For a busy duty judge, the combination of a diagram, however sketchy, and the written description helps greatly to get an idea of the 'story' the protestor is trying to tell.  I also think drawing a diagram probably does quite a lot to help competitors get their thinking clear.

I think encouraging protestors to provide information in excess of the minimum required by the RRS is a very good idea.  The RRS have always included a protest form encouraging protestors to provide more information.

It's a balance.

Encourage protestors to provide enough information to help the protestee identify the incident and perhaps give a very broad picture to support what the allegation is. 

But discourage competitors from writing essays about it, or worse still, being put off from protesting because of the perceived (but unnecessary) burden to fill the form with extra stuff.

This is the form used in the Olympics. Very minimal and easy to use. Provides all the necessary information.

John S re: "Do we then not have conflicting statements?"

Yep!  Woke up this morn realizing I painted myself inside a circle and gave myself a dunce slap. 

Regarding the "extra info", I am not saying that we should not provide space for that info, but rather to have it clearly marked or separated between what is required and what is not. 

The case I'm making is that, in doing so, we take the opportunity to teach the rule each time a sailor looks at the form. 

Let's do it with a " * " on the field-label and a red-bold-outline for the box ... which in the USA at least is a universal indication of required info.