We have not had the assistance of any skilled adviser on the subject. If they have had any, we have never been permitted to see or consider any reports or recommendations by such adviser, have never been asked for any explanations or elucidations on practical points about which difficulties may have arisen, have never had any opportunity of fairly discussing the position with any Government Officer.
We do not think this reasonable or fair. We are establishing a new branch of trade, we are expending a large sum of money in the Colony and are adding to its wealth and enterprise by our enterprise. We are entitled to a certain amount of consideration if only for that reason and yet all sorts of difficulties and obstacles are thrown needlessly in our way. If grave danger is anticipated from our proceedings, of course there must be restrictions and conditions: The public safety comes first. But to conclude that our proceedings involve grave danger and require stringent conditions ought first to be proved and we object strongly to have vital points decided against us without knowing what is said on the other side or by whom and without an opportunity of answering and explaining.
In the first place, we ask your Lordship's serious attention to the wording of these Rules and Regulations. They are so confusedly framed and so badly put together that it is difficult in many cases to ascertain the meaning. Look for example at Rule 4: it is impossible to tell what is forbidden and what is allowed. These rules as they stand will only lead to fruitless prosecutions and appeals. But our main objections are to the substance and not to the form.
We object strongly to Rule 6 as worded. In the original draft rules all Petroleum had to be tested on arrival in the Colony and 24, 36, 48 hours might be taken in the testing and before the Tanker could be permitted to go alongside and commence her discharge. With such a waste of time the carriage of Oil in Bulk becomes futile and useless. A load of Oil in tins and cases might have been discharged...