It is unfortunate that the conclusions reached

aze so emphatically against the proposals. Being far removed from the V.K., doubtless the practical difficulties experienced in administering our Merchant Shipping legislation are not fully appreciated, and whilst the establishment of a long Kong register, and a relaxation in manning requirements might suggest benefits accruing solely to the shipowners, this is hardly the caso. Taking the issos of dispensations as an example, this is a device, no less, which we have been forced to fall back on, time and time again, in order to meet various legal obligations, but only to the extent of making a mockery of our shipping legislation. Again rigid application of the rules relating to British type approval of materials etc. operates completely to the disadvantage of owners building vessels in the area for Hong Kong registry. So far as the potential tonnage associated with a separate register is in the order of 15/20 million tons, it follms I feel, that dus cognisance must be paid to the needs of our local shipowners, and accepting U.K. shipowners not reacting unfavourably, then your recommendations could only be related to a possibility that officers associations might raise objections. If so than by no stretch of the imagination can sach objections be held valid, and it is felt that a position should be attained, where a separate Hong Kong registry is available for these shipowners who wish to register their vessels in the Colony, on terms not quite so demanding as at present, such terms being largely dictated by U.K. Whether or not advantages would accrus by so doing, would be for decision- making on the part of the shipowners involved.

The questionnaire has been answered in a separata document, a copy of which is attached.

e.c. Hon. c.s.

Yours faithfully,

(A. Fletcher) Directer of Marine.

Foreign & simonwealth Office ✓

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