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(2) No complaints of general inefficiency, inadequacy or of unreliability lie, it is confidently claimed, against the Tramway Company; whereas, there and immediately prevalent, serious public complaints against the motor-buses on precisely these grounds.
are,
(3) A further obligation upon the Tramways, supplemental to its overriding general liability for the maintenance and upkeep of large areas of public roadway (in all over 10 route miles-largely of double Track width- to which the wear and tear of the road surface is almost entirely caused by other users of the way), is that a complete restoration of such road- way is a precedential requirement before it may remove from, alter or abandon any or part of any of its routes. The Bus Company is now seeking to participate still further, over large stretches of our own track, in the advantages of a carefully pre-fostered and slowly built-up traffic and also to benefit from the heavy roadway maintenance outlay expend- ed, and to continue to be expended, by ourselves without similar obliga- tion (on either such routes or elsewhere) whilst remaining free to depart therefrom, without cost to themselves, at any future time, by an appli- cation so to do, in case of need or economic pressure (and after direct injury to our interests).
(4) Although, for unforeseen reasons, the Government has, up to date, been unable to complete the new 100 ft. Shaukiwan Road, yet in order to cater for the needs of the public, this Company, in the recent past, has, at considerable expense, provided additional loops and doubled all single track, wherever possible-the whole of which work and construction will need to be scrapped as the new roadwork progresses-in order to provide a quicker and more frequent service.
When agreeing with Government some years ago to put down throughout the entire length of the new 100 ft. Shaukiwan Road, when completed, a first class double-track, the Company certainly did not anticipate com- The final cost of petitors being allowed to run over the same route. this new double track, on completion, will not be less than $800,000.00. (5) One further point in this aspect of perhaps minor force but concerned, no less, in the particular application to operate along our track on the Hennessy Road stretch-is that in 1925 this Company voluntarily, at its in the general interest of all road users at that point, carried out the widening of the Bowrington Canal Bridge including the provision of side-walks (previously non-existant) to the additional general safety also of all pedestrian traffic.
own expense,
(6) Some protection, therefore, from undue, uneconomic intensive encroach- ment from competitive undertakings (not in any case contributors, in any degree, to such heavy road-maintenance expenses that falls to the liability of this Company) is to be justly expected and ought surely to be under- stood by fair and reasonable implication.
(7) Such directly competitive revision of routes to run not only contiguous to but actually upon our own track cannot reasonably be read as con- templated in drafting the schedules of services attaching to the conditions of tender under which the present operators acquired their existing rights.
(8) In connection with which, it may also be said that in 1928 when supple- mentary city motor-bus transportation was first introduced upon the Island the principle was adopted, as far as possible, of avoiding their running over actual tramway routes.
(9) The present applications are definitely in the nature of encroachment with the clear probability of subsequent intensification of competitive tactics, in the long run reacting as seriously detrimental to the efficiency of both units, and, will further concentrate the density of movement to the main arterial roadways as against a more desirable and economic traffic spread- over. This being noted with special force in regard to application item (C).
(10) There already exist competitive bus services along Queen's Road from Kennedy Town to Causeway Bay and if the extensions and diversion now applied for are granted, then an additional and directly competitive ser- vice will be instituted against this Company operating the whole way from Eastern Street (west) through the Central districts to Shaukiwan terminus (east)-part of the way in very close proximity to and for the remainder, of no less than 5 miles, actually over our own tram tracks. (11) Reference to the Road Traffic Act of Great Britain, the causes leading to the introduction of which involve a distinct bearing in a consideration of the position now given rise to by these present applications, is well worthy of mention here and I beg your serious regard thereto. This Road Act of 1930 was enacted to regulate the whole of the Road Transportation of Great Britain, its chief object being to cut down to a minimum all unnecessary and unfair competition which had gradually reduced the public transportation of the country to com- plete chaos, resulting in unsafe, badly maintained vehicles and irregularly maintained and unreliable services.
The whole of Great Britain is split up into 13 areas, each under the control of a Traffic Commissioner, who has the authority to refuse, and does refuse, to grant any additional licence, extension or diver- sion in areas already provided with adequate and properly maintained
services.
As tramway undertakings have, by law, to maintain a large portion of the roadway over which they operate, special protection against un- necessary competition is afforded them under the machinery of this administration.
It is generally acknowledged that the Transportation of Great Britain has
improved vastly since the Act was brought into force.
(12) I beg to submit that this Company is at present providing and maintain- ing adequate and efficiently run electric tramway services (at very cheap fares-fares, in fact, which are unequalled in any other city in the world) which, supplemented by the existing Queen's Road and Happy Valley Motor-Bus services are surely sufficient to meet all reasonable public re- quirements within these districts.
If the proposed Motor-Bus extensions and diversions are allowed it will undoubtedly bring about unnecessary competition in areas where excellent services are already provided.
The outcome of such gradually increasing competition must result in added congestion and a general decrease in the efficiency of the Road Passenger Transport of Hong Kong.
This, beyond question, is exactly opposed to what must have been the direct intention of Government in bringing forward their Road Passenger Transport co- ordination scheme of recent inception on both the Island and in Kowloon.
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