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making way "Making way through the water" or "not making way" is referred to several times, mainly with regard to proper lights and sounds. See Rules 26, 27, and 35. Each time the phrase is "making way through the water" so the presumption is that this term implies motion relative to the water. Even if you are drifting at 3 kts in a current, if not moving relative to the water you are not "making way." This would often not lead to confusion since other vessels seeing you drifting could just as well be drifting in the same current... but then again they might not be; they could be not underway or drifting in a different current. It is a subtlety to look out for when interacting with the vessels involved in the presense of strong currents. See also discussion of "meeting head to head" under head-on.

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