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who are not travelling outside as well as within the danger zone, and in any case in the southern direction strangers would at once be detected. We think it reasonable, therefore, that such vessels should be exempt from the new regulations.
(b.) The number of passengers carried by Coasters trading between Hongkong, Hoihow, Pakhoi and Haiphong is so small that it would take a very long period to recover the cost of the alterations called for.
Additional reasons for their exemption arise out of the following remarks on certain of the regulations:-
(c.) Regulation No. 5 requiring access to the bridge from below to be abaft the grille appears to assume that all boats are built much alike, whether special river or ocean going boats, and that it is of equal feasibility to make the required changes with the one as in the other, besides the assumption that need also is equal, whereas the fact is that the construction of river boats differs from one another and greatly from coasters, while there is further great variation between the designs of coasters. To comply with this regulation on many of the Coasters means either the removal of certain fixed ladders and severing the connection between the fore deck and the rest of the ship or sending the boats to a dockyard and changing the design at great cost and delay.
(d.) Regulation 7 requiring the protection of the emergency steering gear would, to be effective, mean a steel house of considerable dimensions and this alone would cost not less than $2,000 on each vessel.
(e.) Regulation 11 requiring the isolation of other than 1st class passengers would mean a grille across two alleyways which are the ships' only thoroughfares and would therefore be extremely inconvenient if not impracticable.
(f) Regulation 13 requires that deck cargo shall be made inaccessible. This is imprac ticable and would mean no deck cargo at all.
(g.) Regulations 23 to 31 require Guards to travel by the regular and irregular vessels, and we think we have given sufficient reason in the fact that the boats engage no passengers between Hongkong and Canton or vice versâ for their not being burdened with the incon- venience and cost of carrying guards.
(h.) Regulation 40 on coasters, passengers, an average in number of whom we may men- tion is only about 60 to 100 are carried in an after deck house, and when that overflows, in the tween decks below and the balance of the space on those tween decks is usually occupied with cargo.
The passengers have the run of the after tween decks through the voyage. To coop them up, therefore, behind locked grille doors while the ship is in the danger zone would be greatly resented, and the fitting of such doors or barrries across the tween decks cannot, we think, have been contemplated.
The foregoing applies with equal force in all respects to the frequent but irregular coasters such as those chartered with Yangtsze produce partly to Hongkong and partly to Canton. They carry generally one kind of cargo and few, if any, passengers, and none between Hongkong and Canton.
Points of agreement are the requirements of (steamers) Regulations 12 and 15 to 21, 32 to 39, 41 to 43.
COLONIAL SECRETARY'S OFFICE,
26th August, 1914.
SIR, I am directed to acknowledge the receipt of your letter of the 18th instant and to inform you that His Excellency the Governor has after careful consideration of the recom- mendations suggested by your Committee come to the conclusions set out in the enclosed Memorandum.