pass on the left side of each other. By the International Rules, three blasts of the whistle means the ship is going astern, whereas three blasts of the whistle by our rules is the regular fog whistle blown every minute. Many of the fog rules are entirely different and nonworkable in our waters. For instance, the International Rules require a ship to stop her way entirely whenever she hears a whistle forward of abeam on either side. We couldn't comply with this requirement without exceedingly great danger to our shipping, because we have numerous narrow channels with a current where descending ships practically have to keep going slowly so as to keep control and, if such ships, on hearing a whistle anywhere forward of abeam, had to stop, they would have to back to do so and as soon as a ship starts to back in a current she is pretty apt to lose control and might go crosswise with the current. Sometimes with some of our ships over 600 feet in length, they are longer than the channel is wide, and a ship going crosswise is liable to block the whole channel and bring about disaster to herself and other shipping. Our rules do not require this stopping, but on hearing a whistle within four points of ahead, we check to bare steerageway, keep control of our boat, sound passing signals, and, upon getting agreement with the approaching ship, each ship proceeds slowly on its respective side so that they can pass without losing control and bringing about disaster. Ships navigating the ocean very seldom blow passing signals to each other because they have lots of sea room and therefore a oneblast whistle in fog is probably sufficient for their purposes. We, however, on the Great Lakes are constantly blowing passing signals because we are always meeting in these channels at fairly close quarters, and we must have an understanding with each other as to how we are to meet and pass. One blast indicates a passage one way, and two blasts indicates a passage the other way, and every ship must have an understanding in this respect before getting within a half mile of each other. We are constantly speaking to each other with our whistles, therefore, and establishing understandings and in that method are enabled to navigate our channels. Even if we had the International Rules therefore we would have to have these narrow-channel rules in order to conduct our navigation. Our rules provide that in narrow channels of 500 feet or less, where there are currents, the descending ship shall have the rightof-way and there must be some established and recognized right-ofway so as to avoid possible confusion. Also our rules provide that in such channels an overtaking ship shall not attempt to pass an overtaken ship and never at any time without getting the consent of the overtaken ship. Also our rules have provision in reference to rafts and vessels towing rafts. They apparently have no such thing on the ocean, and we have large log rafts and pulpwood rafts towed on our lakes, and there must be special regulations in reference to them, and boats doing this towing must have special types of whistles so that in foggy weather it will always be recognized that such ships are towing rafts. These kinds of rules we would have to have anyway even if we had the International Rules, and would have to have them engrafted thereon to take care of our special conditions. It has always been so that different waters have different rules adapted to their conditions. Ours have been tried out for many years and have been gotten up out of our special conditions and are found from long experience to be best adapted to our conditions and as we are the ones who want them and anyone else who comes up here has to employ pilots familiar with them anyway, why let the tail wag the dog, and just because some little Norwegian tramp comes up here and tries to take our business away from us with his cheap crew and un-American living conditions, why make our great commerce change and adapt itself to his conditions? When we are in Rome we expect to do as the Romans do, and if the salt-water tramps want to come up to our waters, it is only fit and proper that they conform to our conditions, especially as they have to have local pilots anyway to take them about, and such local pilots are perfectly familiar with our conditions and our rules of the road and have been licensed thereon, so that it costs these foreigners nothing additional whatever to comply with our regulations, as they have the men aboard and must have the men aboard who are thoroughly familiar therewith. Respectfully submitted. INLAND WATER LINES ASSOCIATION, BRIEF OF HERBERT H. PARSONS, NICHOLSON TRANSIT CO. [Representing: Nicholson Transit Co., Tri-State Co., Nicholson Universal Steamship Co., and Detroit Sulphite Co., with a total of 23 steamers of approximately 64,000 gross tons, all of Detroit, Mich.] The collision rules, or rules of the road, of the London convention are similar to the international or ocean rules now applicable to ships navigating the high seas; but these rules are vastly different from the Great Lakes Pilot Rules, established under authority of the act of Congress, approved February 8, 1895, and commonly known as the White law. Canada, in 1896, enacted rules of the road identical with ours, and ever since has maintained complete uniformity in respect, to Great Lakes navigation rules, so that if this Senate bill, S. 1273, becomes a law, our vessels would be governed by one set of rules and Canadian vessels by another. The obvious confusion that would result would create a menace to the safety of lives and ships. Every time two vessels came into passing relationship there would be a threatened collision, because of uncertainty of establishing passing agreements. During the navigation season of 1937 on the Great Lakes, there passed through the Detroit River 20,554 freight vessels, not including passenger ships, car ferries, or ferryboats, which are continuously operating back and forth across the river at right angle to these 20,554 freight vessels. I do not believe there was a collision in the Detroit or St. Clair Rivers during last season, which to my mind is largely due to the fact that our fog signals of three blasts, and our passing signals of one and two blasts are easily distinguishable and without confusion, as compared to the one long blast fog signal of the London convention, which immediately destroys the use of passing signals and, on behalf of the companies which I represent, and also the deck officers of all of our ships, we entreat your honorable committee to modify this bill so as to exempt the Great Lakes district from its provisions. Respectfully submitted. HERBERT H. PARSONS, Superintendent, Nicholson Transit Co. APPENDIX MISCELLANEOUS CORRESPONDENCE THE KELLEY ISLAND LIME & TRANSPORT Co., Hon. SCHUYLER OTIS BLAND, Chairman, Merchant Marine and Fisheries Committee, House of Representatives, Washington, D. C. DEAR SIR: We are just advised that the Senate passed Senate bill, known as S. 1273, without according interested parties an opportunity for a hearing. This bill we understand now goes to the House of Representatives where it will be referred to the Committee on Merchant Marine and Fisheries of which your are chairman. We desire to protest very vigorously against the enactment of this bill into a law. This bill if it becomes a law in its present form will work a serious hardship on all owners and operators of vessels plying the Great Lakes. We hope before this bill leaves your committee that you will accord the interested parties a hearing on same. Thanking you in advance for your favorable consideration we beg to remain, THE KELLEY ISLAND LIME & TRANSPORT CO., ERIE STEAMSHIP CO., Cleveland, Ohio, August 10, 1937. Hon. SCHUYLER OTIS BLAND, Chairman, Merchant Marine and Fisheries Committee, House of Representatives, Washington, D. C. DEAR SIR: If the bill referred to as S. 1273 is enacted to include the Great Lakes in the rules for the prevention of collisions contained in annex II of the International Convention for Safety of Life at Sea, signed in London, May 31, 1929, it will result in interminable confusion and accidents, in our opinion, and we, therefore, urge that the bill be changed so that the Great Lakes are excluded from regulation. It is our opinion that it would require many years for the Great Lakes captains, mates, and seamen to learn the new rules of the road specified in this bill, resulting in many accidents meanwhile, and that a further cause of confusion would be the fact that Canadian vessels would still be using the same rules and signals now in effect, so that Canadian and American vessels would be attempting to signal each other with entirely different systems. Yours very truly, Congressman SCHUYLER OTIS BLAND, ERIE STEAMSHIP Co., BUFFALO GRAVEL CORPORATION, Chairman, Merchant Marine and Fisheries Committee. House of Representatives, Washington, D. C. DEAR SIR: It has been called to our attention that on August 7, 1937, the United States Senate passed a bill known as S. 1273, which, if enacted into a law, will repeal the present Great Lakes Pilot Rules. We, as operators of vessels on the Great Lakes, object to the enactment of this bill to a law because of the difficulty and impracticability of makng the change 41 from our present pilot rules to these new international rules as outlined in the above bill. It would mean that every master, mate, and seaman having to do with the navigation of our lake ships would have to learn anew all of the rules of the road. Such a process would involve an educational program which would take a long time to complete. Furthermore, Canada in 1896 enacted rules of the road identical with our pilot rules and ever since that time we have had complete uniformity with Canada in respect to Great Lakes navigation rules. Canada has not adopted for her Great Lakes vessels these International Rules. So it would mean that, if this Senate bill becomes law, our ships would be governed by one set of rules and Canadian vessels by another. Out of the confusion that would result among vessels in the teaching of our mariners these new pilot rules and from the discrepancy between American and Canadian rules, a menace to the safety of lives and ships would arise, the like of which never before existed on these waters. Every time two vessels came into a passing relationship they would be threatened with collision because of uncertainty in establishing passing agreements. We earnestly urge that this bill shall not be passed in its present form and we believe that the operators of vessels on the Great Lakes should be given an opportunity for a hearing. If no hearing can be had on this bill, we would suggest a modification of it to exclude the operation of Great Lakes vessels under the international or ocean rules. Your earnest consideration of our request in this matter will be greatly appreciated. Yours very truly, BUFFALO GRAVEL CORPORATION, President. SAULT STE. MARIE, MICH., Hon. SCHUYLER OTIS BLAND, We want to express our strongest objections to Senate bill S. 1273 as passed by Senate August 6. Since 1896 Canada and United States have had identical pilot rules on the Great Lakes. If this bill is enacted into law the result will be adoption of ocean rules on the Great Lakes for United States vessels, and they would be governed by one set of rules and Canadian ships by another. We demand an opportunity for a hearing by your honorable committee as this bill as it now stands will result in greatest menace to safety of navigation on the Great Lakes. THOMPSON TOWING & WRECKING CO., Hon. SCHUYLER OTIS BLAND, HOUSE OF REPRESENTATIVES, Washington, D. C., August 19, 1937. Chairman, Merchant Marine and Fisheries Committee, Washington, D. C. MY DEAR MR. BLAND: I am enclosing herewith a letter from Mr. L. H. Kent, superintendent of steamships, Pere Marquette Railway Co., Ludington, Mich. Mr. Kent states a rather strong case against Senate bill 1273; in fact he states the case much better than I could. I would appreciate it very much if you would take these arguments in the letter into consideration when you consider this bill. Sincerely yours, ALBERT J. ENGEL. Hon. ALBERT ENGEL, PERE MARQUETTE RAILWAY CO., House of Representatives Office Building, Washington, D. C. DEAR SIR: With further reference to my letter of August 11. After further study, I cannot help but beg that you give serious consideration to S. 1273. This bill, referred to as S. 1273, proposes to make applicable to all American vessels navigating the high seas and all waters connected therewith navigable by sea-going vessels, the rules for the prevention of collisions contained in Annex II of the International Convention for Safety of Life at Sea, signed in London, May 31, 1929. The collision rules of the London convention are similar to the international or ocean rules now applicable to ships navigating the high seas, but these rules are vastly different from the Great Lakes pilot rules, established under authority of the act of Congress, approved February 8, 1895, commonly known as the White law. As the Great Lakes are connected by the St. Lawrence River with the high seas and are navigable in fact by sea-going vessels, these London convention or international rules would be made applicable to Great Lakes American ships and would take the place of existing pilot rules, if the Senate bill referred to becomes law. The difficulty and impracticability of making the change from our present pilot rules to these new international rules should be apparent to everyone. It would mean that every master, mate, and seaman having to do with the navigation of our Lake ships, big and small, would have to learn anew all of the rules of the road. Such a process would involve an educational program which would take at least a generation to complete. Furthermore, Canada in 1896 enacted rules of the road identical with our pilot rules and ever since that time we have had complete uniformity with Canada in respect to Great Lakes navigation rules. Canada has not adopted for her Great Lakes vessels these international rules. So it would mean that, if this Senate bill becomes law, our ships would be governed by one set of rules and Canadian vessels by another. Out of the confusion that would result among vessels in the teaching of our mariners these new pilot rules and from the discrepancy between American and Canadian rules, a menace to the safety of lives and ships would arise, the like of which never before existed on those waters. Every time two vessels came into a passing relationship, they would be threatened with collision because of uncertainty in establishing passing agreements. In the press toward adjournment there may be a disposition to treat this bill hurriedly, and we would urge that in the interests of safety that Congressman Schuyler Otis Bland, Chairman, Merchant Marine and Fisheries Committee, House of Representatives, be urged to table this bill until proper and safe study can be made of the Great Lakes. Thanking you for your attention in this matter, we are, L. H. KENT, Superintendent of Steamships. THE ANN ARBOR RAILROAD Co., Congressman SCHUYLER OTIS BLAND, Chairman, Merchant Marine and Fisheries Committee, House of Representatives, Washington, D. C. DEAR SIR: It has been brought to my attention that a bill, known as S. 1273, passed the Senate on August 6, 1937, without affording interested persons an opportunity for hearing. As we understand this act, it brings the Great Lakes under the same navigation laws as used on the high seas. The writer has had 35 years experience on the Great Lakes in nearly every type of vessels plying these waters, and at the present time is marine superintendent of the Ann Arbor Railroad Co., owners of a fleet of five car ferries, representing a gross tonnage of 13,947, carrying railroad freight cars, automobiles, and passengers across Lake Michigan from Frankfort, Mich., to Manitowoc, Wis., Kewaunee, Wisc., Menominee, Mich., Manistique, Mich., and covering 940 vessel miles daily. Including the Ann Arbor fleet, there are some 20 large and powerful car ferries crossing Lake Michigan the year round east and west through heavy steamboat traffic from the north and south, and the present navigation rules for the Great |