D.
E
TR
sailed from Far Eastern ports to Vietnam, This general point is referred to by the Rochdale Report in paragraph 14,80 whero they arguo that it would be better if ships operating from a particular country were registered in that country and that the whole concept of Commonwealth registration should gradually be abandoned. The present position is of course, positively misleading in that ships registered at the port of Hong Kong are on the British registry but thoir real links with Britain or the British economy are minimal or non-existent. We can see the case for Hong Kong having a soparate registry so that there is a minimum of confusion but we can sce no advantage in allowing Hong Kong to remain a port of registration under overall British registry but at the same time operating to different and possibly lowor standards. We see no point in the concession which Ir Pao is asking for unless there is some visible advaz- tage to Hong Kong or to Britain, The question of prestige would hardly seem sufficient nor would it seem appropriate for Nr Pao to have the advantage of world wide British Consular representation, if these are an advantage to him if the standards of safety or manning on his ships are not British standards.
(c) No. Hong Kong registered ships would still remain British and the problems in
Commonwealth ports would remain,
QUESTION 7. The implications would appear to contain a strong possibility of creating yet another flag of convenience at the very time when we hope to exert some influenco through the medium of ICO to persuado other countries that action is necessary in the interests of safety to raise the general standards of training and competency of officers in charge of watches on ships. We can see no material benefit to the UK or to Hong Kong by Kr Pao's proposals.
There is one further matter I should mention. In the longer term as Mr Madigan has already explained to you, changes will be forthcoming in the manning requirements both in respect of certification and possibly nationality requirements in the manning of British ships. These will be the subject of regulations under the Merchant Shipping Act 1970 and in due course the Aliens Restriction (Amendment) Act 1919 will be repealed. It would seem to us that when regulations for the manning of British ships are made under Section 43 of the 1970 Act and those are brought into force, the regulations might not apply to Hong Kong ships unless an Order in Council is made under Section 94 of the 1970 Act. This is a matter on which legal advice is required. However the Marine Division are proposing to consult Commonwealth Governments and certain Colonial Administrations including that of Hong Kong giving details of our proposals under the 1970 Act. We understand it is the intention of the Hong Kong administration to consider amendments to their Merchant Shipping ordinance to take account of the developments which will arise from the 1970 Act and no doubt this Department will be involved in the course of their considerations.
The pace and content of the changes in United Kingdom Law affecting British ships will, of course,
be determined by British interests, that is to say by our negotiations with the British Shipping Federation, the Chamber of Shipping of the United Kingdom and the representative organisations of British seafarers in the United Kingdom.
I will write to you again on the one or two points still outstanding. I hope that will enable you to settle this matter finally because although we are always anxious to do what we can to help, we seen to be devoting an inordinate amount of time to considering proposals which can have no benefit for the United Kingdom and very little for Hong Kong either.
Yours sincerely
J. B./Shouler
governmental
* Internal Maritan Consultations Deprecation (a UN organmanson)
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