I agree with everything you said, except this...
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I disagree most with the limit of two people being towed behind a boat. As long as each person has their own observer, I believe towing a couple more people would be safe.
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if I understand you, towing, say 4 people is ok? man that is getting pretty busy back there, which means you have a driver and 4 people in the boat, with 4 ropes and likely 4 tubes...
you would need a big boat to haul 9 people and 4 tubes...I must have misunderstood you.