Yes, I've actually seen that. I was told if I had a head
lamp I'd be fine. So by the "letter of the law", yes.
Opinion:
In terms of the smart thing to do, no. At least not IMHO.
Kind of like how you only need a PFD in the kayak at all
times on the water, not on your person. That's freedom
that we are allowed, but the Darwin Awards are handed
out every year for a reason...
After being out on the water, even the coves and places
where boats come in (in daylight), I can't imagine going
out at night w/o having a 360º light. Yeah, that light
wouldn't save me from a drunk, passed out boater...
I know I am overly cautious...but hey, I wanna live! LOL