PERCY HILLHOUSE
(examination resumed).
By Mr. Newcombe:
6733. It has been stated that the draught of the vessel on leaving Quebec was 26 feet 10 inches forward and 28 feet 10 inches aft -
- Yes, sir, that is correct.
6734. That would be in fresh water?
- In fresh water.
6735. How much would she rise in salt water?
- About 7 inches due to the difference between fresh and salt water and another difference due to the consumption of coal and fresh wrater and stores of about 2 inches, a total of 9 inches.
6736. So that at the point of sinking that gives you a variation of 9 inches?
- Yes, 21 feet 1 inch forward and 27 feet 11 inches aft, a mean of 27 feet.
6737. We were speaking about the listing of the ship and I think you had explained that if water began to come in in quantity on one side of the ship the tendency would be for her to list towards that side?
- Yes.
6738. I suppose that once a ship begins to list to starboard there is an inclination to increase that list by any additional weight of material on that side?
- It would necessarily increase the list. She could come back to the upright provided the free water was not more than a certain amount.
6739. This ship, of course, did not come back?
- That is so.
6740. The list appears to have increased after she tipped over. Can you say whether a top weight on the boat deck would accelerate the list of the ship having regard to the fact that she had taken water on the starboard side?
- Yes, the top weight certainly does accelerate the list.
6741. I should like to know if a ship of this sort which comparatively might be described as more like a river boat than a sea-going ship - I mean there is a considerable amount of deck structure on her, is there not, comparing her with a ship like the Etruria or the Campania?
- Compared with the Etruria or the Campania, there is more deck structure but not in comparison with many other modern vessels.
6742. If you had a ship like the Etruria receiving an injury like this one, would you expect it would lose its balance and tip over as the Empress did?
- Yes, because the Etruria did not have so much stability as the Empress had.
6743. To look at her you would suppose that the Empress would upset very easily, would you not?
- Yes, but in looking at the top one only sees the height of her; one does not get any idea of how much weight is below water or what the breadth of the ship is.
6744. Have you any opinion to offer as to the cause of the vessel sinking so quickly?
- Yes, I can give an opinion or a surmise, but in the absence of more definite information as to the damage done to the starboard side of the vessel or as to the exact condition of the water-tight doors and side lights it is impossible to give any accurate statement of what the sequence of events was.
6745. You have an opinion as to what probably happened, I understand?
- Perhaps first I might explain as concisely as I can on what the element of the stability of a ship depends. In the condition when the side of the ship is slightly inclined one side is pushed down in the water and the other side is raised above the water. The side which is pushed down calls into play the force of the buoyancy which tends to push that side up again. The side that is drawn out of the water loses buoyancy and that which was formerly supported by the buoyancy is now unsupported. The transference of the buoyance from the high side to the low side of the ship is what the ship relies upon to come back to upright. If, on the other hand, there is anywhere inside the ship a weight of any kind which will move across to the low side of the ship, such weights perhaps being coal or grain or loose water, then there is a transference of weight from the high side to the low side and that transference of weight is in opposition to the transference of buoyancy. During the life of the ship there is a conflict between the buoyancy of the ship and the shifting weight. Ordinarily there is always some loose water, in the fresh water tanks and in the feed water tanks. But the stability of the ship is such that the transference of weight is not of serious consequence. But if any large quantity of loose water comes into the ship then the transference of weight becomes much more serious and stability may be seriously reduced. In the case of the Empress calculations show that she could withstand the amount of water contained in the two boiler-rooms. But if in addition to that there should have been anywhere more free water then her stability would be reduced and become negative and the ship would heel over and ultimately capsize. In my opinion in this case water has found its way into other compartments than the two boiler-rooms partly through water-tight doors and partly through side lights and I think that was the cause of her heeling over and finally foundering.
By Chief Justice McLeod:
6746. In your opinion the watertight doors would not be closed, neither would the ports?
- No, I think there has been no evidence that states that all of these were closed.
By Lord Mersey:
6747. Would one or two port holes being open allow the water to run in rapidly enough to sink the ship?
- As to the time I cannot give any opinion, but any water entering the ports would inevitably gather on the starboard side, heel the ship down on that side and cause more water to come in.
By Mr. Newcombe:
6748. In your statement of the metacentric height of the vessel at the time of construction did you have regard to the ballast tanks as full or empty?
- The water ballast tanks were all full.
6749. There is a question submitted which I wish you would listen to: In the actual design and construction of the Empress, what special provisions, if any, were made for the safety of the vessel and the lives of those on board in the event of collision and other casualties?
- That is question three which I was to answer. The special provisions made were, first of all, the following out of the recommendations of the Bulkhead Committee. The adoption of these recommendations was purely optional on the part of the owners; it was not required by law at that time. That, therefore, may be called a special provision for safety. In addition to that there was the usual provision of wireless telegraphy, submarine signalling and lifeboat accommodation for everybody on board.
Lord Mersey:
Have you any questions to ask, Mr. Aspinall?
Mr. Aspinall:
I think it would be fairer, in the event of Mr. Haight having any questions to put to this witness - I do not know that he has - that he should put them before I ask the witness any questions. He is really our witness. We have placed him at the disposal of the Board of Trade and I submit it would be only right that I should come last.
By Mr. Haight:
6750. According to my computation, Mr. Hillhouse, there are in all twenty watertight doors in your ship?
- Twenty-four.
6751. All of these have doors through them except the first two?
- You are talking of bulkheads or doors.
6752. All of the watertight bulkheads have doors through them except numbers 1 and 2?
- Yes.
6753. Was Dr. Francis Elgar, before or after he designed this vessel, the chairman of the Fairfield Company - the company that built this boat?
- Yes. he was.
6754. When was he chairman?
- He was chairman, I think, some years before he designed this vessel.
6755. How long before he made the designs of this vessel was it that he ceased to be the chairman?
- Very shortly before.
6756. Were you familiar with the design of the vessel before she was built?
- Yes.
6757. You worked with him on the plan, did you not, Mr. Hillhouse, yourself?
- Which plan do you mean?
6758. The plans of the Empress of Ireland?
- Yes.
6759. You are then familiar with any innovations that were made in the construction of this vessel?
- Yes.
6760. Were there not some departures from ordinary ship designing made when these plans were drawn?
- Yes.
6761. Is it not unusual for a merchant vessel to have a rudder which is entirely submerged?
- Yes, there are not many merchant vessels with such rudders.
6762. Were not the two Empress boats practically the first large merchant vessels that were built from this design?
- No, before that the City of Paris and the City of New York had practically similar rudders.
6763. Is it not true that the lines at the stern of the two Empressses were very much fuller than the lines usually are at the stern of such vessels?
- They were a little fuller, but not very much.
6764. How much fuller would it he on the Empress than is usual, or was usual, with merchant vessels at the time these designs vrere made?
- It is difficult to give any measure of fullness; say roughly, perhaps, at 30 feet from the stern the water line may have been one foot broader on each side.
6765. Is it not true that for thirty or forty feet from the stern, the lines of the two Empress boats are distinctly fuller than is usual on merchant vessels?
- It is exceedingly difficult to answer that question, because merchant vessels are built all degrees of fullness.
6766. How many designs had you worked on before you actually worked on the designs of this vessel?
- Perhaps five or six large vessels.
6767. Since that time you have worked on the designs of many large vessels?
- Yes.
6768. Is it not true that the lines of the Empress for about 40 feet from the stern were fuller than any boat you had ever worked on before?
- No, it is not the case.
6769. I mean any boat that is a merchant vessel, that is designed as a passenger boat and similar in class?
- No, I think if you will compare the lines of the Empress with the lines of any of these boats you will find that they are very similar.
6770. Are you to-day building vessels with as broad a line at the stern as the Empress of Ireland had?
- Yes.
6771. Is it not true that a broad stern tends to cause eddies under the stern and has an effect upon the rudder?
- It possibly has some effect, but at the same time we have built many ships with much fuller sterns than that of the Empress and no trouble has been experienced in their steering.
6772. The tendency of the broad stern is to decrease the efficiency of your rudder?
- Yes.
6773. Is it not true that after the Empress was first built you found some difficulty with the rudder as originally designed?
- On the trials of the vessel everybody was absolutely satisfied with her steering qualities. Some time later the fore part of the rudder got carried away accidently and when that was being renewed advantage was taken of the change to slightly increase the area of the rudder.
6774. What was the original area of the first rudder as designed?
- I cannot tell you the exact area.
6775. What was the original percentage of the area of your rudder as compared with the area of the immersed plane of your vessel?
- That is largely a matter of opinion.
6776. What is your opinion?
- For such a ship as the Empress?
6777. According to my understanding, among naval architects you figure the immersed plane of your vessel running the plane through the keel vertically?
- Yes.
6778. And there is some understood proportion which the rudder must bear to the submerged plane in order to give your vessel proper steerage?
- That proportion varies according to the type of vessel from, perhaps, in the case of cruisers, 1-40th of the immersed area down to about 1-100th part in the case of cargo vessels.
6779. What was the proportion of the area of the original rudder of the Empress?
- I am sorry I do not know that figure, Mr. Haight.
6780. Do you know if it was less than one per cent?
- No.
6781. Will my plan enable you to tell that?
- Yes, I could check that.
6782. I wish you would. When you put in your new rudder how much did you increase the area?
- As far as I remember there was about one foot in breadth added to the back edge.
6783. Is it not true that your reason for increasing the area of your rudder was because complaint had been made that the Empress did not steer well?
- The reason, as I understand it, was that they wanted to improve her steering qualities, but she had previously to that, on trials in our hands, steered very well indeed.
6784. But on practical trial, as operated on the line, complaint had been made; is that not true?
- Well, if so, I did not hear of it.
6785. You heard enough to know that they wanted her to steer better?
- Yes.
6786. Will you please tell me when that change in the rudder was made?
- I think about 1908, but I do not know the exact date.
6787. Was a similar change made in the rudder of the Empress of Britain?
- Yes, I think so.
6788. She had not had an accident?
- No.
6789. Did you yourself draw the designs, or work upon the plans of the larger rudder?
- It was done in the drawing office under my supervision.
6790. Was your attention ever called to the fact that any of the masters of the Canadian Pacific Railway Company, after you had made the changes in the rudders of both boats, still complained about their steering qualities?
- No, I heard no complaints.
6791. Directly or indirectly?
- Directly or indirectly.
Lord Mersey:
Will you ask him whether before the alterations in the area of the rudder, he had had, or heard of, complaints from the masters of either one of the two ships?
By Mr. Haight:
6792. Had you, before the changes were made, heard of complaints of that character from the captain of either of these boats?
- No, sir, but from the fact that the owners desired to take advantage of the accident to increase the area of the rudder, I assumed that they thought her qualities might be improved.
6793. Your position would not be such that complaints of the officers wrould come to you?
- No.
6794. Will you tell me what the displacement of the Empress of Ireland was at a draught of 27 feet 6 inches mean?
- I could give the displacement exactly at the time of the accident if that is perhaps more to the point?
6795. Yes, that is what I really want.
- 18,750 tons.
6796. What do you figure to have been the actual draught forward and aft of the Empress at the moment of the collision?
- 26' 1" forward, 27' 11" aft.
6797. And that allows for how much rise after leaving Quebec?
- Nine inches.
6798. Have you figured on the density of the water at Father Point?
- Yes.
6799. Do you know whether any accurate test has been made?
- No; I assume that the water at Father Point is salt water and at Quebec fresh water.
6800. Would you call Quebec absolutely fresh?
- Yes.
6801. And Father Point absolutely salt?
- Yes.
6802. Is it not true that the current running down affects considerably the density of the water as far down as Father Point?
- That I do not know.
6803. As I understand, according to your computation at the time of the accident, the metacentric height was 40½ inches and it was only 42½ inches as originally designed?
- Yes.
6804. Is the metacentric height affected by the conditions of stowage and such conditions?
- Yes, certainly.
6805. What have you assumed to be the disposition of your cargo, supplies, and so on?
- I got a note of the actual disposition of the cargo from Capt. Walsh and I have taken that in my calculations.
6806. You know whether it was on the lowest deck or on certain decks or where it was?
- Yes, I got a complete diagram.
6807. Lord Mersey: Do you want that statement?
Mr. Haight:
I have no doubt it is accurately taken.
Mr. Hillhouse:
Capt. Walsh has the original document and he could give you a copy.
Lord Mersey:
Have you a copy, Capt. Walsh?
Captain Walsh:
The original documents are handed in, my Lord; our solicitors have the original documents. I have a copy at the office.
Lord Mersey:
Have you a copy of it, Mr. Haight? Show it to Mr. Haight and let him tell me if it is a document of importance. (A copy of this document was handed to Mr. Haight.)
Mr. Haight:
I may be posing as a naval architect but it is really a pose; I can no more tell you whether it is important by looking at it - this will be of no use to us unless we know the weights of each class of cargo stowed.
Lord Mersey:
Where do you propose to get that from?
Mr. Haight:
I do not propose to get it anywhere.
By Lord Mersey:
6808. Where are the weights?
- (Witness.) They are all in Mr. Walsh’s hands.
Lord Mersey:
Have you the weights, Mr. Walsh? If so, give them to Mr. Haight.
Mr. Haight:
I doubt if there is any reason for criticising the way in which the cargo was stowed.
Lord Mersey:
What I want to know is this: Do you understand it?
Mr. Haight:
I do to a certain extent. These figures indicate where the various classes of cargo and baggage were stowed and they indicate that the stowage was towards the bottom of the ship and this has a very important bearing on the stability of the ship.
Lord Mersey:
They give the weight of the cargo that was in a particular place?
Mr. Haight:
They indicate in a separate list the weights of each class of cargo.
Lord Mersey:
Have you got it all?
Mr. Haight:
Yes.
Lord Mersey:
Have you realized the effect of it?
Mr. Haight:
As well perhaps as I can. I should say that it appears to me to have been so stowed as to have increased the stability of the ship. They are ballast because they are towards the bottom. Just what effect that would have had in inches upon the metacentric height I am sure I could not guess.
Lord Mersey:
I am very glad to hear you say that; it is a wise answer. I suppose these cargoes were stowed in Montreal or Quebec. They are stowed by stevedores and stevedores, I dare say, exercise their judgment by a rule of thumb more than anything else?
Mr. Haight:
More or less, sir, yes.
Lord Mersey:
I suppose they are people who know how to stow a vessel so as to make her fairly safe?
Mr. Haight:
That is my experience unless in bad weather.
Lord Mersey:
That is my experience, but I do not profess to be able to criticise what stevedores do.
Mr. Haight:
Ordinarily, in my experience the cargo does not shift except upon rare occasions.
Lord Mersey:
Very rare. It must be very bad stowage or it must be very bad weather. Well, we will have these statements put in. (Stowage put in and marked Exhibit A-1; statement re stowage of cargo put in and marked Exhibit B-1.)
By Mr. Haight:
6809. Will you refer to the passenger diagram, look at room 328 and tell me how many feet that room is distant from the closet bulkhead and whether it is forward or aft of the bulkhead?
- The wooden partition upon which No. 328 is fastened is 15 feet 9 inches from the bulkhead between the two boiler rooms.
6810. If we assume then that the stem of the Storstad touched the side of the Empress exactly in line with the wooden bulkhead the entire wound would have been aft of the bulkhead?
- Not exactly, because the Storstad penetrated some distance - the wound spread out sideways and might very well cover the 15 feet 9 inches.
6811. Have you examined the Storstad?
- Yes, I looked at her.
6812. From the examination which you have made how far do you think she penetrated inboard from the side of the Empress?
- About eighteen feet. That is partly from an examination of the Storstad herself and partly from measurement of the model which was produced.
6813. Did you take the beam of the Storstad 18 feet back from the stem?
- Yes, I measured the breadth of the deck between the point of damage on the starboard side and the last point of damage on the port side and the breadth measures 28 feet.
6814. Do you know, Mr. Hillhouse, that on the forecastle of the Storstad for a certain distance back everything had been swept clean as though that deck had gone under one of the decks of the Empress?
- I was not able to see the forecastle deck of the Storstad.
6815. Why not?
- Because we were not allowed to go aboard and I did not care to climb on the top of buildings alongside. There was a watchman on the gangway who would not allow me to go on.
6816. Did you explain who you were and what you wanted there?
- No.
6817. I am sorry you did not make application.
- No answer.
Lord Mersey:
You should have explained who you were. I should think they would be quite right to refuse to allow a stranger to go aboard.
By Mr. Haight:
6818. Do you know Mr. Hill?
- Yes.
6819. Has he not been aboard?
- I do not know.
6820. Your computation as to the extent of the Storstad’s penetration inboard of the Empress is not based upon any accurate observation made on board the Storstad herself?
- No.
6821. Questions have arisen, Mr. Hillhouse, in connection with Capt. Kendall’s story as to the movement of the two vessels after the collision occurred. Capt. Kendall, for instance, indicates that actually the Storstad made an angle with the forward side of the Empress of about 7 points. Other witnesses gives the angle as being somewhat more acute by diagram. Assume if you will that the Empress, when the vessels came together, had some headway through the water and that the Storstad for some appreciable interval of time remained with her stem sticking into the wound and that her bow was swung to starboard, what effect would the position of the Storstad in the side of the Empress have upon the heading of the Empress as she moved forward?
- Yes, if the Storstad stuck in and was gripped very tightly it would act as a retardation upon the starboard side and swing the Empress head to starboard.
By Lord Mersey:
6822. Bring the Empress head to starboard?
- Yes, to starboard; the Storstad would act as a drag upon her starboard side.
By Mr. Haight:
6823. So long as she remained at all fast in the wound the natural tendency would be to swing the Empress to starboard?
- Yes, on the assumption you have made and if there was no head motion on the Storstad.
6824. The head motion of the Storstad would be taken up by the time it ceased to penetrate, would it not?
- Yes.
6825. So that from the time she had reached her maximum penetration and until she was swung clear she would operate as a starboard rudder?
- Yes.
6826. As I look at the diagrams, room 328 is almost mathematically the exact centre of the Empress calculating from stem to stern? Am I correct?
- It must be very near to it; I have not measured it in that light.
6827. Could you now satisfy yourself if that is true?
- Yes. (Witness made measurement on accommodation plan). Yes, it is almost exactly in the centre.
6828. If, therefore, the Storstad strikes the Empress at the angle indicated by Captain Kendall, or at a slightly more acute angle, opposite room 328 would there be any tendency resulting from the blow to swing the stern of the Empress one way or the other?
- No, I think not.
Lord Mersey:
Just put that again.
Mr. Haight:
The question was whether, striking the Empress at the dead centre that Captain Kendall indicates or at a slightly more acute angle, the blow delivered by the Storstad would tend to swing the stern of the Empress one way or the other. It would not, the witness says.
Lord Mersey:
I do not understand that.
Mr. Haight:
Your Lordship remembers that Captain Kendall’s story was that we struck him aft of amidships, turned his stern around and swung his bow to starboard.
Lord Mersey:
I understood this witness to say just now that the Storstad, in the position in which he placed her, having regard to all the stories of the other witnesses, was acting as a rudder and would turn the stem of the vessel around to starboard.
Mr. Haight:
If the Empress were moving forward through the water.
Lord Mersey:
Yes.
Mr. Haight:
Now, I am asking if the Empress were dead in the water. (To witness). Did you understand my question to be whether the blow would have taken her one way or another if the Empress were dead in the water?
- Yes.
By Lord Mersey:
6829. And you say it would not?
- It would not.
Chief Justice McLeod:
One question was based on the assumption that the Empress was moving in the water, and the other on the assumption that the Empress was dead in the water?
Mr. Haight:
Yes, my Lord. I was at fault in not making the question clearer. (To witness):
6831. You are familiar, Mr. Hillhouse, with the effects upon a moving vessel of a reversed propeller? Assuming that the Storstad had a right handed propeller the tendency, if the propeller were reversed, would be to swing her bow to starboard, would it not?
- A very slight tendency.
6832. The tendency is not only slight but it does not really develop until the engines have been some little time running astern.
- I understand that the tendency is slightly due to the rotation of the propeller and would expect it to manifest itself immediately the propeller began to revolve.
6833. Is it your experience that when a vessel is moving through the water and her engines are reversed her head immediately begins to swing to starboard or she hangs on her course for a short time then starts gradually and the swing increases?
- I could not tell anything about that because I have had no experience in those matters or in the handling of ships.
Lord Mersey:
Would not that depend very much upon the depth of the ship in the water, the weight of the cargo and considerations of that character?
Mr. Haight:
A vessel that is dead light will swing more quickly.
Lord Mersey:
That is what I mean.
Mr. Haight:
I think the real explanation is that because she is dead light (she is trimmed more at the stern; she would draw 7 feet forward and 15 feet aft. If the forward and aft draughts are approximately level it is difficult to make a fair running trim. Still, it is pot very important. (To witness):
6834. Captain Kendall was of the opinion, Mr. Hillhouse, that his vessel was absolutely dead in the water and that the effect of our reversing engines was so pronounced that we moved his entire ship ahead. Would any such effect as that be remotely possible as a result of a reversed propeller with a ship like the Storstad or any other ship?
- The tendency, if any, would be exceedingly slight.
6835. Do you know that the construction of the Storstad is not the usual construction but that she is one of the Isherwood class of vessels?
- Yes.
6836. Would you please state, for the benefit of the court what the Isherwood construction is?
- Under the ordinary system of construction the frames which support the outside plating stand vertically at right angles to the keel. Under the Isherwood system they run longitudinally more or less parallel to the water line.
By Chief Justice McLeod:
6837. That applies to the Storstad?
- Yes.
By Mr. Haight:
6838. A vessel built on that system has far more strength fore and aft than an ordinary vessel to withstand the impact of a collision?
- Yes.
6839. Every angle which ordinarily forms the ribs of the ship in cross-sections is on the Isherwood vessel run lengthwise?
- Yes.
6840. You are striking the ends of your strengtheners rather than the cross-section?
- Yes.
6841. Bearing in mind the construction of the Storstad, I will ask you to assume that when 100 feet away from the Empress she is coming so fast as to throw bow waves which can be seen at night in a fog by a man fifty feet above the water at a distance of 100 feet. Assuming that at that instant the Storstad's engines are reversed, the stem of the Storstad being only 100 feet away from the side of the Empress and that the Storstad has a dead weight cargo of coal of 10,400 tons, what would you think would be the penetration of a vessel travelling at that speed and so constructed if she hit amidships of the Empress practically in the unsupported boiler-room space?
- I can give no idea as to what I would expect the penetration to be. It is not shown on the bow of the Storstad at all. It is one that it is impossible to make any calculations about.
6841½. Have you any idea that a vessel so constructed and driven at that speed would have gone at least half through the Empress?
- I cannot tell.
6842. Would you mind stating what your real opinion is? Assuming that it will not be scientific, it is not expected to be accurate.
- I am not in a position to give any opinion at all. I have never studied collisions between ships, or seen the results of collisions.
6843. Your boiler room space is the most sensitive part of your ship, is it not? The boiler room and engine room space?
- Sensitive, in what way, Mr. Haight?
6844. You get nearer to hitting into an empty box there than anywhere else; your decks do not run clear across the ship?
- No, but that space is filled with the coal, a considerable weight of coal, just where the Storstad struck in this particular case.
6845. But you do not have the strength which comes with decks that run clear across the ship?
- The only deck missing in that part is the orlop deck, and that is replaced by one or two stringers.
6846. If there is any difference, the place where the Empress was struck is weaker than places forward of the boiler-room or aft of the engine-room?
- No, I think it would be stronger, because in the middle part of the ship the scantling is run across and the shell plating is thicker and the decks are thicker.
6847. Will you please refer to your plans and tell me precisely how far inboard your boilers are on the starboard side? I want to know how far inboard the measurement would go when it just goes to the side of the boiler nearest the shell plating?
- Nearest the shell plating, about 7 feet.
6848. At the point where we are assuming the Storstad struck, abreast of room 328, what is the distance from the shell plating of the ship into the boiler, the starboard side of the boiler? Please look at your plans, and make an exact measurement.
- Just at that particular point, Mr. Haight, there is no boiler, and 4 feet 6 inches after that we have a boiler whose side is about 15 feet from the vessel’s side.
By Lord Mersey:
6849. Tell me, Mr. Hillhouse, have you any plan to show the position of the boilers?
- No, my lord.
6850. Can we not have once for all a complete set of plans referring to this? I was just told that you are looking at a plan which is not yet in evidence.
- This is a copy of the hull plan; the plan which is one of the exhibits was a plan produced by the Canadian Pacific Railway Company, and that plan did not show the boilers.
6851. Is it not possible for us once for all to have a plan which relates to these things?
- It would take some time to get copies made, My Lord; it can be done.
6852. Do they not exist? Because if you could make copies there must be some originals?
- These are the originals I have here.
6853. Why not give us the originals; they would be better than copies.
- Oh, I cannot leave the originals, my Lord.
6854. Oh, yes, you can; the ship has gone down to the bottom you know; the plans are not of very much use except as curiosities. Can you leave the plans?
Chief Justice McLeod:
We won’t destroy them.
The Witness:
I should like to have copies made; I can leave them just now and get copies made later.
Mr. Haight:
Do I understand that this drawing now becomes an exhibit?
Lord Mersey:
Yes.
The Witness:
There will be quite a number of plans if I put them all in; this is only one of twenty or thirty plans.
By Mr. Haight:
6855. You have suggested, Mr. Hillhouse, that the bow of the Storstad might have touched the bulkhead something over 15 feet forward of room 328?
- Yes.
6856. Is it not true that the Storstad would necessarily have hit the boiler, which was only 4 feet 6 aft of that bulkhead, if she had penetrated 15 feet, especially assuming that the angle of contact was somewhat towards the stern?
- If she penetrated 15 feet at a point 4 feet 6-forward of the boiler, then I think she would not touch the boiler.
6857. Now, Mr. Hillhouse, 4 feet 6 aft of the door on which 328 was fastened, is the forward end of the boiler?
- Yes.
6858. You have already expressed the opinion that the Storstad, with her stem entering opposite that partition at an angle somewhat towards the stern -
- Towards the bow.
6859. An angle towards the bow, or with her keel pointing towards the stern, might have struck and damaged a collision bulkhead 15 feet 9 inches forward of No. 328?
- Yes.
6860. If the deck and the bow of the Storstad is wide enough to injure something 15 feet 9 inches forward of 328, and we assume the stem starts to penetrate on the partition where 328 is, must not the port half of the stem of the Storstad hit your boiler, which Is only 4 feet 6 inches aft of 328?
- Not necessarily, because the point of the stem of the Storstad is a small point, whereas the breadth of the deck at the Empress’ side is much wider.
6861. But I understood you to slate that the depth of penetration, according to your idea, was 18 feet?
- Eighteen feet.
6862. Now, do you think that the stem plate of the Storstad can rupture the side of the Empress directly in line with No. 328, penetrate 18 feet, and not touch a boiler which is 15 feet in from the side and only 4 feet 6 inches aft of No. 328?
- Would you let me try it on the plan a minute; it is rather a difficult thing to answer. (Plan referred to by witness.) This little diagram shows that assuming that the stem of the Storstad entered the side of the Empress abreast of the partition upon which No. 328 was, at an angle slightly towards the bow, and penetrated the distance which I have said, 18 feet, it would simultaneously touch the bulkhead between the two boiler rooms and that single ended boiler.
6863. And it would not only touch the boiler, but it would knock about 8 or 10 feet off the end of it, wouldn’t it?
- No, I do not think it would knock anything off the boiler; it would probably damage the Storstad.
6864. Assuming that the Storstad's bow is strong enough to. withstand it, how far would it go into the boiler, according to the measurements which you make?
- About 2 feet; that is, supposing that the boiler was strong enough to penetrate the Storstad it would go in about 2 feet.
6865. As I have listened to the testimony I have understood that men in the boiler-room saw water coming out of the bunkers and that the inside wall of the bunker was not at all ruptured. Is that your understanding of the facts?
- My understanding is that water only came through the bunker doors.
6866. And that the inner side of the bunker was absolutely untouched by the stem?
- Yes.
6867. How far in from the side of the ship is the inner partition of the bunker?
- Fourteen feet.
6868. We are absolutely safe, therefore, in assuming that the Storstad did not penetrate 18 feet; on the contrary, that she did not penetrate 14 feet?
- I do not think so.
By Lord Mersey:
6869. Does that follow?
- It all hangs on the assumption that the stem entered immediately under 328.
Lord Mersey:
It does not seem to me to follow.
Mr. Haight:
According to my understanding, my Lord, we have a bunker space at 328 -
Lord Mersey:
All that we know is this: that this number got somehow or other, nobody knows how, on to the deck of the Storstad. That is all we know; we assume that it is a plate off the cabin No. 328.
Mr. Haight:
I understood that to be conceded at the time.
By Mr. Haight:
6870. How far forward and how far aft of room 328 does your bunker space run?
- The bunkers extend about 58 feet aft and about 120 feet forward.
6871. Then if the inner side of the bunker which is 15 feet wide was never broken, the Storstad’s stem could not have penetrated, inboard.
- The inner side of the bunker bulkhead is not 14 feet from the ship’s side throughout the whole of that space.
6872. Please tell me how far aft and how far forward of 328 the inner side of the bulkhead is 15 feet distant from the skin of the ship?
- Aft of 328 it goes back - there is first of all 2 feet 3 with no bunker bulkhead at all, and then 16 feet where the bunker is 14 feet from the ship’s side.
6873. I was wrong in stating 15; it is 14?
- Fourteen.
6874. Captain Kendall has stated that in his opinion on the night of the collision - given his draught and all conditions as they were - his vessel could be stopped running full speed ahead in two lengths by putting his engines from full speed ahead to full speed astern. Could you as the designer of the boat, and with your technical knowledge of her engines, give us any opinion as to how fast in your judgment such a vessel can be brought to an absolute dead standstill from full speed ahead?
- No stopping experiments were ever made with the Empress of Ireland; I cannot say in what distance she would stop.
Lord Mersey:
Will you tell me what full speed ahead means? Does it mean that the engines are making as many revolutions a minute as they can?
Mr. Haight:
Full speed ahead is exceedingly misleading, I admit. It means that the telegraph on the bridge and in the engine-room is standing at full speed ahead; an order to that effect has been given.
Lord Mersey:
But it does not mean that the engines are working at as high a speed as it rs possible?
Mr. Haight:
It does not necessarily mean that at all, my Lord.
Lord Mersey:
Because my recollection is that the evidence shows that these engines were never worked at that speed.
Mr. Haight:
They had never got the throttle wide open so as to give the vessel full steam.
Lord Mersey:
Therefore full speed ahead is a little misleading.
Mr. Haight:
It is, sir.
By Mr. Haight:
6875. Assuming, Mr. Hillhouse, that the Empress of Ireland, with her telegraph standing full speed ahead, is actually making revolutions enough to give her 15 knots through the water, could you give us any idea how far she would run if her engines ere put full speed astern with the same number of revolutions that she had been making full speed ahead?
- No, I cannot give any idea.
Lord Mersey:
Is it a thing that is ever done immediately to reverse the engines?
Mr. Haight:
I was going to ask that subsequently. I think my Lord, that in my experience it has never been done; Captain Kendall, I understand, has done it by experiment.
Lord Mersey:
Yes, it seems to me an extraordinary thing, because I have always understood that to use your engines in that way was dangerous.
Mr. Haight:
Every flying part is subjected to a tortion which not infrequently will break your shafting, blow out all your packing, and strain pretty much all your running parts. Of course, I do not mean to testify; I am merely -
Lord Mersey:
Put it so that we can understand it. (To witness): If you are going to reverse your engines, do you go full speed ahead, or how do do it, under ordinary circumstanced?
- You have to catch hold of the wheel in the engine room and rotate it several times; I am not an engineer, and I cannot tell exactly.
6876. You do not suddenly put the engines full speed astern?
- No, my Lord.
6877. You do it by degrees; what are the degrees?
- I am really not enough of an engineer to tell you, my Lord.
By Mr. Haight:
6878. It is technically possible, is it not, Mr. Hillhouse, to throw your links absolutely over so that your engine is put from her forward movement to her backward movement by the single motion almost instantaneously?
- I think not; I think these links have got to be put over by a small steam engine, which takes some time to put them over; but Mr. Sampson would tell you all about that better than I can.
6879. You are unable, even with your knowledge of the power of the engines and the size and pitch of the propellers, to form any estimate as to how many lengths the Empress would run if she were going 15 knots through the water and her engines were instantly put full speed astern?
- I cannot give you any idea.
6880. Have you personally known of cases where in emergency the engines have been put full speed astern instantly to avoid collision or stranding?
- No.
6881. Were you familiar with the damage sustained by the Lusitania some time ago, a year or more ago?
- No.
6882. Did you never hear of it?
- No.
6883. Did you never hear that she had stripped her turbines when putting her engines suddenly full speed astern?
- I heard about her stripping her turbines, but I did not hear any reason given for it or what the cause of the accident was.
6884. You did know that the Lusitania was laid up for months for repairs?
- Yes.
6885. You never heard anything directly or indirectly as to how she happened to put her engines full speed astern?
- I did not even know that the damage was caused by such a manoeuvre; I knew only that her turbines had been stripped.
6886. Will you please refer to your plan and tell me how many feet it is from the centre of the bridge to room 328, I mean along the side of the ship, fore and aft?
- About 105 feet or thereabouts.
6887. Will you measure it on your largest plan, if you can?
- I am referring to two or three plans, sir.
6888. My understanding is about 120 feet. (Witness refers to plan.)
By Lord Mersey:
6889. This is another plan?
- This is one of the plans which I propose to submit, my Lord, with 20 or 30 others. (To Mr. Haight): 130 feet.
By Mr. Haight:
G890. Captain Kendall has testified, Mr. Hillhouse, that in his judgment when the Storstad struck the side of the Empress she actually rebounded like a ball striking the water. Would you say from your knowledge of ship construction and of moving forces that such a rebound would be possible?
- No, I do not think so.
6891. In other words, the forward movement of the Storstad is absolutely taken up in the crushing in of her own bow and the crushing in of the side of the Empress?
- Yes.
6892. If the Empress is absolutely dead in the water, after the Storstad has exhausted her forward movement, the two vessels would lie still in the position?
Lord Mersey:
Is that absolutely certain?
Mr. Haight:
Assuming that the Empress -
Lord Mersey:
Is there no resiliency, no possibility of a rebound, when these two boats come together?
By Mr. Haight:
6893. As I understand it, with the empty spaces in the side of the Empress, you exhaust your forward movement by penetration, and as long as you have got any momentum at all, it tends to crowd you into the hull; when you have exhausted that the moving mass becomes inert. Am I correct, Mr. Hillhouse?
- Yes, there might be some slight motion left, but theoretically I think you are right.
By Lord Mersey:
6894. That is substantially correct?
- Substantially correct, yes.
By Mr. Haight:
6895. Assuming that to be the case, Mr. Hillhouse, the fact being admitted that after the Storstad entered the side of the Empress the Storstad was seen disappearing in the fog astern, or was apparently swung to starboard herself, to what do you attribute such movement of the two vessels?
- Well, that might have been caused by the Storstad going astern with her rudder over; it might have been caused by a head motion on the Empress.
6896. I will ask you to assume that when the Storstad struck the Empress, the instant that she struck the Storstad’s engines were put ahead and that under those circumstances the vessels separated almost in a parallel position; could anything but the movement of the Empress explain such a position?
- I think not, if the Storstad’s engines were kept going ahead.
6897. The same thing would be true if the Storstad’s engines were stopped?
- Yes.
6898. Only one more point. Will you be good enough to describe a little-more accurately than was done by a preceding witness, the telemotor system of steering.
Lord Mersey:
Has this something to do with Galway’s point?
Mr. Haight:
He is going to approach that testimony, yes, my Lord, but more particularly the testimony of the engineer who had the sole charge of the steering apparatus for eight months prior to the accident.
The Witness:
The word ‘telemotor’, first of all, means a mover at a distance, the same as telegraph means writing at a distance and telephone sound at a distance. The instrument is a means of communicating the motion of the hand wheel upon the bridge to the steam steering engine at the after end of the ship; it replaces the ordinary system of shafts and bevel wheels, chains and wheels. The motion of the hand wheel works a plunger inside of a cylinder and forces a mixture of glycerine and water into one or other of two pipes, which pipes travel the whole length of the ship, and at the other end are connected to another cylinder. According as the pressure comes on one end or the other of that after cyinder, so the steam valve of the steering engine is moved one way or the other, and the steering engine moves to port or starboard. After it is moved a certain distance, it automatically cuts off its own steam, so that if the steersman puts the wheel over to a certain point and holds it there, the engine will follow and stop after, having travelled a distance proportionate to the amount the wheel has been turned. When he releases the wheel, springs at the after end pushes back the telemotor cylinder, and rotates the hand wheel back to the original position. On the bridge and connected with these two pipes there is a small reservoir or tank, the only duty of which is to make up any leakage which may accidentally take place in the telemotor pipes, and on that tank is a little brass gauge, so that people on the bridge can at any time see whether the telemotor system is properly full of glycerine or not.
By Mr. Haight:
6899. The system, as I understand, is practically a closed system, a closed circuit?
- Yes.
6900. There is no room for evaporation?
- No.
6901. The pipe is theoretically absolutely tight, and so are the valves?
- Yes.
6902. If, then, it is found by looking at the gauge that a considerable amount of the glycerine and water has disappeared from the system, that fact inevitably means a lack somewhere, does it not?
- Yes.
6903. What is the ordinary size of the pipe through which this glycerine runs?
- Five-eighths of an inch in diameter.
6904. It is copper, is it not?
- Yes.
6905. What is the thickneste of the copper, do you know?
- No.
6906. If you found that periodically after some days in port any quantity of your glycerine had disappeared, it would be vital, would it not, to trace out your system and find where the leak was?
- Yes, it would be.
6907. What is the effect of any break in the fluid in your pipes upon the facility with which your wheel and your steering engine can be operated?
- What do you mean by a break in the fluid?
6908. Assuming that there has been a leak sufficient to leave an appreciable section of pipe empty, how will that affect your steering apparatus?
Lord Mersey:
You are assuming something in that question which does not appear very clear to me. If there is a leak, does it leave what you call a space of the pipe quite empty?
Mr. Haight:
No, it would not necessarily leave a bubble, although I am inclined to think that it works somewhat that way, but it must leave some empty space in the system.
Lord Mersey:
Of course it must, but what I thought you were assuming in your question was that a certain length of pipe would be empty; and I do not think that would be the effect.
Mr. Haight:
I am not sure; I rather think it would leave an air bubble. (To witness): Mr. Hillhouse, when a leak does occur, and at a certain point in the pipe glycerine drops out, does it leave an air bubble such as you sometimes see in a thermometer, or does it simply make the whole system slack to that extent?
- I do not absolutely know, but my impression is that if glycerine leaked out of such a pipe, it would leak out because there was pressure inside that would show that other glycerine was crowded towards the place, and the pipe would remain full and be supplied from the supply tank in the chart house.
6909. But let us suppose that there is a sufficient leak actually to leave some space empty in the system; what I want to know primarily is: what effect does it have upon the efficiency of your steering system?
- If there was a considerable leak and it left some part of the pipe empty, I do not think it would work at all.
By Lord Mersey:
6910. Would it leave part of the pipe empty or would it simply diminish the whole stream that runs through the pipe? I understood that this pipe is one continuous pipe?
- Yes, my Lord.
6911. Well, now, if it were a pipe of water - I do not know whether glycerine makes any difference - and there were a leak somewhere, that leak, according to my notion, would not cause a part of the pipe to be empty, but it would cause the whole stream from one end of the pipe to the other to be less in quantity?
- No, my Lord. I do not think that would be the effect. You must remember that this pipe comes from the bridge and descends and goes along to the steering gear. My impression is that if any leak occurred, the pressure of glycerine would fill up the empty space.
6912. This pipe is not a horizontal pipe all the way?
- No.
6913. It bends?
- Yes, and it is very small in diameter also.
6914. If any water would get out, it would cause an empty space at the top of the pipe?
- At the top, yes.
By Mr. Haight:
6915. If we assume, Mr. Hillhouse, that some has leaked out and has not been replaced, and you therefore have had your pipe to some slight extent empty, please tell me what effect that would have upon the efficiency of the system?
- The steering gear would probably not work at all.
6916. The efficiency of the system depends upon a continuous circuit of fluid?
- Yes.
By Lord Mersey:
6917. Then you mean to say that if there is a leak the telemotor ceases to act at once if the leak is not supplied by a fresh supply of glycerine?
- Yes, my Lord.
By Chief Justice McLeod:
6918. Does it cease to act altogether, or does it act, but not as well?
- It would cease to act if there was any considerable empty space in the communicating pipe.
6919. Supposing there was leakage of a small amount, not a very considerable amount?
- I do not think one or two air bubbles in the pipe would throw it out of action.
6920. What I want to get at is this: would it affect it so that it would not act as well, or would it cause it to cease to work altogether?
- No, a small leak, I think, would allow it to work.
By Lord Mersey:
6921. I do not think that is an answer to the question that is put to you. The question is this: Supposing there has been a leak and that leak has not been obviated by a fresh supply, will the telemotor still act, or will it stop altogether? If you do not know, say that you do not.
- I do not know; it depends so much on the size of the leak and where it is.
6922. May it have the effect not of throwing the apparatus out of work altogether, but of causing it to work in an unsatisfactory manner? If you cannot answer that, say so.
- I cannot answer that, sir.
By Mr. Haight:
6923. Suppose, Mr. Hillhouse, that it is found in actual work in the turning of the wheel by one of the quartermasters of the ship, as testified to by Mr. Murphy in this case, that when he receives the order to port and he puts his wheel over, she does not go. and in order to get her to go he puts his wheel back again to the centre and then puts her round the second time and she does go; suppose that to be the fact, what does that indicate to you as to whether the system is or is not full of fluid?
- I cannot answer that.
6924. I understood Murphy the quartermaster to say that sometimes when you put your wheel over to starboard, she would not answer, and then all you have to do is put your wheel back to the centre and then put it over a second time and she will go. Can you tell me what that means?
- No, I never saw a wheel act in that way and I do not know what it would mean.
6925. It would mean something cut of kilter, wouldn’t it?
- It would seem to me that in a case like that the gear wouldn’t be working at all; it would be entirely out of order.
6926. If, for instance, you turn your wheel to starboard you pump a certain amount of fluid up out of the top of your cylinder, and down towards the stern of the ship?
- Yes.
6927. Now, if that quantity so pumped out is not sufficient to start your steering engine, when you bring your wheel back to amidships and turn it over once more, you pump a further quantity out through the top, do you not?
- No, because there is The same quantity of glycerine between the telemotor in one pipe and the aft telemotor.
6928. There should be the same?
- If you move this you only push it backwards or forwards; it is always the same quantity.
6929. There should be the same, but suppose a leak has occurred in the pipe that leads down to port side, and there is therefore some empty space in that part, whereas the starboard pipe is absolutely full, would you not, under those circumstances, by turning your wheel back to the centre and making a second turn towards the star-board, supply a certain extra quantity of fluid which might take up the space that had heen lost?
- No, because in turning the wheel back you reverse and again turn the wheel forward.
6930. But if you got air at the top of the pipe, when you turned the wheel back you might not draw the fluid, but might simply take up the dead air, might you not?
- Do you mean to say you take dead air when you turn it one way and not pump in dead air when you turn it the other?
6931. Having the fluid at the top, turning starboard would pump the fluid out. Now, if when it reaches the top of the pipe, which, according to my understanding, is right at the top of the cylinder, it runs down hill, you might turn the wheel back a second time and get a supply to force over, might you not?
- I do not think so, Mr. Haight; I cannot follow that.
6932. But in any event, if you put your wheel to starboard, and the vessel’s head refuses to swing to starboard, you have got something radically wrong?
- Yes.
6933. Something that requires instant attention, if your vessel is going to be safe so far as her steering gear goes?
- Yes.
6934. The valves in the telemotor cylinders are packed with leather, are they not?
- Yes.
6935. Have you ever known cases where valves have not been opened and packing put in for a considerable time, the leather deteriorates and the valve at one telemotor or the other would cease working effectively, sometimes cease working entirely?
- I have no experience of that, because we deal only with new ships.
Lord Mersey:
That, Mr. Haight, is an entirely new point, isn’t it?
Mr. Haight:
I am acquiring information as I go along, my Lord.
Lord Mersey:
But I want you to acquire information that is going to be of use to us. All these subjects are very interesting, no doubt, but are you going to suggest that the valves were packed with old packing that had withered?
Mr. Haight:
The only information we have, my Lord, is that one man had exclusive charge of overhauling the telemotor system of the Empress, and we have not a syllable to suggest that he ever examined the pipes; on the contrary, we have had admission that he did not know where they were. We had not a syllable to suggest that the valves were ever taken out of the cylinders and examined. Now, two things will put the entire system out of effective operation; one is a lack of liquid and the second is the lack of a perfectly tight valve.
Lord Mersey:
I can understand that, but what I am saying is that I never heard it suggested until this moment that there was a possibility of the packing of the valves having been defective.
Mr. Haight:
This is the first expert, my Lord, who has been put on the stand to whom that question could have been addressed.
Lord Mersey:
You might have asked somebody else about it.
Mr. Haight:
The only other man who had anything to say on the subject was the engineer, who admitted that he had never examined anything, so he would not know.
Lord Mersey:
Well, you should have put it to him; you had this point in your mind?
Mr. Haight:
I am forced to confess that I have learned a good deal about the telemotor since he was on the stand. I did not myself have the slightest idea how many cylinders there were nor how they were packed; I have subsequently used some of my spare time along that line. However, I will withdraw the question if your Lordship wishes.
Lord Mersey:
Oh, no, I did not mean that. I understand the question to be whether it is possible that the packing, if not regularly attended to, will become slack and ultimately useless?
Mr. Haight:
It is to that effect.
The Witness:
I should think that is probable - possible.
By Mr. Haight:
6936. From your knowledge of the system, Mr. Hillhouse, what derangement would allow the telemotor system to work so as to start your engine going, and start the rudder moving one way or the other, and then interfere with your stopping the turning of the rudder and bringing the position back to amidships?
- I don’t think I can tell you that, Mr. Haight.
6936½. I have understood that at times, when the wheel is put over and the steering engine is started pulling, if you like, the helm towards the port, it has been found for one reason or another impossible to stop that engine, and that vessels have in times past taken sudden sheers, the Lusitania, for instance.
Mr. Aspinall:
I do not think my friend should mention other occasions.
By Mr. Haight:
6937. What derangement would prevent the steadying of the wheel so as to stop the rudder from continuing in its motion one way or the other after the engine had once been started running, do you know?
- I do not know.
Lord Mersey:
That is, at all events, an answer.
Mr. Haight:
That is all, my Lord.
By Mr. Aspinall:
6938. You have not told us what your qualifications are; are you a naval architect?
- I am a naval architect.
Lord Mersey:
I think the best qualifications that this gentleman has, so far as we are concerned, is the way in which he has given his evidence.
By Mr. Aspinall:
6939. With regard to this telemotor system, is it a well known system?
- Very well known, and fitted in all first-class merchant vessels. It is acknowledged to be the best system of steering large passenger vessels and is adopted by all the best lines.
By Lord Mersey:
6940. Is this system in common use on ocean-going steamers?
- Yes, my Lord.
6941. Is it, for instance, in use on the Cunard boats?
- Yes.
6942. Is it in use on the Allan line boats?
- Yes.
6943. Is it in use on the White Star boats?
- Yes, I think so; I do not know for sure.
6944. At all events, it is not a new fangled thing that you have in your boats?
- By no means.
69415. I am asked if it is on the Essex?
- I understand that it is, my Lord.
By Mr. Aspinall:
6946. With regard to this suggested leakage, assuming there is any leakage, is it taken up from the tank which supplies the material?
- Yes, that is the object of the tank.
6947. You have a tank, as I understand it, in the wheel house, haven’t you?
- Yes.
6948. And that automatically feeds the machine?
- Yes.
6949. So that in the event of there being any leakage, if the tank does its work properly; the leakage is at once taken up and gone?
- Yes.
6950. Is that a simple mechanism?
- Yes.
6951. Which in your experience is effective?
- Yes.
6952. Now, with regard to the alteration in the area of the rudder. In what year was that done?
- The ship was built in 1906, and I think it was about two years later.
6953. That takes us to 1908?
- Yes.
6954. As you have said, it was done presumably because the owners wanted it?
- Yes.
6955. And you did it?
- Yes.
6956. Now, having done what they wanted you to do in 1908, have they asked you to do anything since?
- No.
6956½. Now, taking your evidence in the way in which Mr. Haight has dealt with it, as I understand you, you tell us this: that your view is that owing to this rapid inflow of water, there was a big initial list on the starboard side?
- Yes.
6957. Can you tell me, in view of what you assume to be the area of the wound in the side of the ship, in what space of time the whole boiler compartment which has now become one, would be filled?
- It is very difficult indeed to estimate times, on account of the fact that the orifice is not a small one, and that the head of water is continually changing, but I should say that one and a half to two minutes should fill the whole space.
Lord Mersey:
Put that question again.
Mr. Aspinall:
In view of what he conceives to be the extent of the wound in the side of the ship, in what time would the water coming in fill up the area of the two boiler rooms which are now converted into one, and the answer is in one to two minutes.
By Lord Mersey:
6958. Now, I am asked to ask you this question: Can you give any estimate as to the area in square feet of the breach in the side below the load line?
- I estimate that to be about 350 square feet, assuming that the area of the hole is exactly the same as the cross-section of the Storstad’s bows.
6959. That is the way you arrive at the area?
- Yes, purely by measuring the Storstad.
6960. Then, can you tell us what would be the initial inflow of water in tonnage per minute, assuming the inflow to be unobstructed?
- I make it that the quantity coming in through such an area at the beginning would be 265 tons per second.
6961. I do not see how this ship could remain afloat. Two hundred and sixty tons per second?
- Two hundred and sixty-five.
By Mr. Aspinall:
6962. Wouldn’t that give the ship a very great initial list?
- Yes, it would give her an initial list of some kind, depending upon how fast that water got across to the other side of the compartment.
6963. If it remained at all heaped up on the starboard side, the list would be great, would it not?
- Yes.
6964. And would every second increase?
- Not necessarily, because in every second more would be getting across to the other side.
6965. Which would be greater, the incoming of the water or the facility with which it found its way over to the port side?
By Lord Mersey:
6966. The water coming in through the aperture in the side of the ship is coming in without any obstruction of any kind, isn’t that so?
- Except perhaps the coal in the lower part.
6967. When you talk about the area of the opening, I am assuming that you mean the area of the opening into the water?
- Yes, I was asked for the area of the opening unobstructed, if there was no obstruction.
6968. That is what I mean, the area is an unobstructed area in the skin of the ship?
- Yes.
6969. That is your assertion?
- Yes.
6970. Then when you get the water in the side of the ship and finding its way to the port side, is it unobstructed?
- No.
6971. It is obstructed by the boilers?
- By coal and by the bunker bulkheads.
6972. And therefore the tendency - I ask you - the tendency will always be rather to increase the list? I do not know; perhaps I am wrong.
By Mr. Aspinall:
6973. Mr. Hillhouse, what you claim, and I daresay, rightly claim, is this: That assuming that the boiler room space which has been two spaces is now one, if you were to pour water in through a pipe say into the middle of that compartment and it readily found its way all over the floor of that compartment, that ship would remain a safe ship?
- Yes.
6974. That is what you had in your mind when you told us that this ship would safely float with two adjacent compartments flooded?
- Yes.
Lord Mersey:
I did not hear that.
Mr. Aspinall:
What he told me was this, that when he claims that this ship will float upon two adjacent compartments flooded, what he means is that he is assuming that the water, as I suggested to him, goes in through a pipe in the middle and readily finds it way over the floor.
Lord Mersey:
He told us that long ago, Mr. Aspinall.
By Mr. Aspinall:
6975. Well, the conditions in this case were different, were they not?
- Yes.
6976. As you have told us, you have this original inflow of water on the starboard side?
- Yes.
6977. And in addition you have this factor that the Storstad herself has run in, and to the extent which she has run in, is no longer a water-borne ship?
- Yes.
6978. And to the extent to which that is a factor, it is a factor increasing the list?
- Yes, a certain part of the Storstad which was formerly supported by the water is now away from the water and rests upon something else, which is the Empress.
6979. It had been water-borne before?
- Yes.
6980. Now, Mr. Haight has suggested that the entry of the Storstad disturbed the boilers and their cradles?
- Yes, but I don’t think there is any evidence to show that that actually did occur.
6981. If in fact it did occur, if a boiler or its cradle were disturbed, that would probably throw the boiler to the starboard side, wouldn’t it?
- If the cradle were disturbed, yes, sir. As soon as the Storstad withdrew the boiler would go over to the starboard side.
6982. Well, that might be a factor which we might have to consider?
- Yes, it might be, but I think the evidence shows that the boilers were not, actually disturbed.
6983. If you got sufficient initial list, I suppose it might be that it will bring the side of the ship so much over that it might bring these upper port-holes below the water level?
- Yes.
6984. And if they are open that will admit water into other compartments than the damaged compartments?
- Yes.
6985. And then again that may be a factor in this case?
- Yes.
By Lord Mersey:
6986. I wonder if you can tell me what the area of an open port-hole is?
- Yes, my Lord. The port-holes upon the main and lower decks are ten inches in diameter, that is an area of about eighty square inches.
6987. And how many square inches are there in a square foot?
- 144.
6988. Very well, then, it is a little more than half a square foot?
- Yes, my Lord, fifty-five per cent of a square foot.
6989. And what volume of water would come through that in a second?
- That depends on how far that is under the water surface.
6990. How far the port is under?
- Yes.
6991. And you cannot tell me how much water will pass through that space in a second?
- No, my Lord, not unless you can tell me how far you will assume the port to be under the surface of the water.
Lord Mersey:
And I am sure I cannot tell you that.
By Mr. Aspinall:
6992. Now, leaving that matter, and turning to another, you have told us that in view of what you conceive to have been the breach, that this flooded compartment would be filled in from one to two minutes?
- Yes.
6993. So that unless the water-tight doors which are in this compartment have been closed before the impact, those who have to operate them have to do their work in from one to two minutes?
- Yes.
6994. That is the time they would have?
- Yes.
6995. I dare say you heard some of the evidence that the water was within a very short space of time discovered upon the upper deck, didn’t you?
- Yes.
6996. That would point again to the fact that the inrush of water must have been extremely rapid?
- Yes.
6997. Well, now, I want you to tell me, with regard to the water-tight doors that are to be considered in connection with these compartments - you understand, of course, the boiler space is now to be considered as all one space?
- Yes.
6998. And I want you to tell me how many water-tight doors there are in the three bulkheads which had composed the boiler room spaces?
- Yes.
6999. First of all, how many are there? Are they twelve in number?
- Yes, twelve in number.
Lord Mersey:
I have not been quite following that, Mr. Aspinall.
Mr. Aspinall:
My Lord, he has stated that in the space which is flooded there are 12 water-tight doors.
7000. Are there two of them in the hold, both of them vertical?
- Yes.
7001. You know you have told me about this before, and I think I can sum it up pretty quickly. Was one of those in the bulkhead which was destroyed?
- Yes.
7002. So we can leave that out of the question?
- Yes.
7003. That is ineffective, that is gone for the purposes of the inquiry?
- Yes.
7004. Is the other vertical one in the lower hold in the middle of the bulkhead which is immediately forward of that?
- It is in the middle of the bulkhead, immediately after that.
7005. Aft?
- Yes.
7006. And that vertical door was the door which we were told was shut?
- Yes.
7007. Very well; that is two of the twelve?
- Yes.
7008. That is in the hold?
- Yes.
7009. How what water-tight doors are there on the lower deck?
- There is one at the fore end, forward of the boiler room on the lower deck.
7010. Yes?
- But in the bulkhead which was damaged and dead, in the bulkhead on the boiler room.
7011. Well now, that is five we have disposed of?
- Yes.
7012. On that level?
- Yes.
7013. How many of those are on the port side?
- Two.
7014. How many on the starboard side?
- Three.
7015. No, surely not three on the starboard side?
- Yes, the one at the fore end is two feet on the starboard side, almost in the centre.
7016. And one of those three is in the damaged bulkhead?
- Yes.
7017. So we can leave that out of consideration?
- Yes.
7018. We need not trouble about the water-tight doors on the port side?
- No.
7019. So that leaves us two to consider on the starboard side?
- Yes.
7020. Now then, with regard to the main deck, how many water-tight doors are there?
- Five doors.
7021. How many of those doors are in the bulkhead which was destroyed?
- Two.
7022. And that leaves three?
- Yes.
7023. How many of the remaining three are on the port side?
- One on the port side, and two to starboard.
7024. So that, as a result of that, there are four doors that we have to consider, four only, and those on the starboard side?
- Yes.
7025. That is right?
- Yes.
7026. Now with regard to one that the man Hayes told us about, he went and tried to operate it. you remember his evidence?
- No, I didn’t hear his evidence.
7027. Well, he said he was stopped through water getting in there - that he couldn’t get there on account of the water?
- Yes.
7028. That would be three that we have to consider?
- Yes.
7029. Did you hear the evidence of Harrison this morning?
- Yes.
7030. He told us he couldn’t get to one?
- Yes.
7031. Well that leaves two that we have to consider?
- Yes.
Chief Justice McLeod:
These could not be closed, I understand, Mr. Aspinall. 1 mean the ones you have been speaking of?
Mr. Aspinall:
No, my Lord, they could not be closed. What I am trying to get at is what we have to consider, and what is the evidence with regard to these four. Hayes tried to get to one, and Harrison tried to get to another, that would leave two that may or may not have been operated. That is correct, Mr. Hillhouse?
- Yes.
7032. I don’t know whether you heard the evidence of Mr. Rankin?
- Yes.
7033. He was an engineer and he says he heard something in his vicinity being operated?
- Yes.
7034. Might that be one of these remaining two?
- It is difficult to say; it may have been. I think the remaining two doors were in all probability closed, because they were one of them between the coal bunkers and the passenger space, and while the coal was being put in that must have been shut to keep the coal dust from passing through, and the other is between two bunkers, and in all probability was shut.
7035. So the result of your evidence is this, that whilst it is material to consider these four watertight doors on the starboard side, you think it is highly probable that two were closed, and you have either heard the evidence or have heard me tell you that Hayes and Harrison said they tried to close the other two, but couldn’t?
- Yes.
7036. And I gather from what you have told Mr. Newcombe that in view of the fact that this box, as I call it, failed to contain the water, that that may be the cause of the disaster?
- It may be.
7037. It may be the cause?
- Yes, that the water flooded through the doors or side-lights, into more than two compartments.
7038. And the only two watertight doors we can trace it to are those two which were said to be operated upon by Hayes and Harrison?
- Yes, and in addition a certain quantity of water probably got through to the engine room before that door was shut.
7039. Before the man succeeded in shutting it?
- Yes.
7040. Now that exhausts the water-tight doors which had anything to do with the effect of this accident?
- Yes.
7041. That is right?
- Yes.
7042. Well, now, with regard to these watertight doors in the stoke-hold in the bottom of the ship, is there any recommendation with regard to the necessity of their being closed, if there are less than five, excluding the tunnel?
- No, the new convention for the safety of life at sea, speaking about watertight doors, states that unless there are more than five doors altogether, counting the two into the tunnels, then the doors need not be operated by power.
7043. And in this case there were two tunnel doors?
- Yes.
7044. Excluding these, how many are left?
- Three in place of five.
7045. So that if that recommendation is to be given effect to, there would be no need for having these doors closed according to the recommendation of that body?
- There would be no need for having them fitted with means of closing them from the bridge.
7046. Oh, that is the recommendation, is it?
- Yes.
By Chief Justice McLeod:
7047. There is now a means of closing such doors from the bridge, I understand?
- Yes.
7048. It is possible to have an arrangement by which they can all be closed at once?
- Yes.
7049. But according to the regulations you say that does not apply to vessels unless there are more than five doors?
- No.
By Mr. Aspinall:
7050. When you built this ship and handed her over in 1906 to the Canadian Pacific Railway Company, did you then think, of your best knowledge, that she was a good, efficient, and seaworthy vessel?
- Yes, at the time she was built she was, if anything, of a higher requirement than the majority of ships. Very few ships at that time had been built in accordance with the recommendation of the 1891 Bulkhead Committee.
7051. Has this present disaster somewhat puzzled you?
- Yes, I was at first puzzled to account for the heeling of the ship.
7052. The what?
- The listing or heeling of the ship.
7053. You have told us all you know about that?
- Yes.
7054. Now, with regard to another matter which Mr. Haight asked you about - he asked you if it would be easy for the Storstad to penetrate in a good distance into this boiler-room space - I want you to tell me in detail through what would the stem of the Storstad have to travel to get where it did get?
- Well, it would have to travel through -
7055. The coal?
- Yes, the coal.
7056. And next?
- The bilge-keel.
7057. The stringer, is that?
- No, the bilge-keel is a projection on the outside of the ship. Then it would have to travel through the stringers in the hold space, through the lower deck, the main deck, the upper deck, and possibly the shelter deck.
7058. It would have to go through all these obstructions before it was brought up?
- Yes.
7059. I think you saw the Storstad, did you not, Mr. Hillhouse?
- Yes.
7060. And I think you have told us that the model fairly represents the present damaged condition of her bow?
- Yes, it does not pretend to be an accurate representation, with all the details shown, but roughly speaking it agrees with my memory.
7061. Have you formed an opinion as to whether the present state of her bows was formed before she penetrated through the plating of the Empress or not?
- My impression is, the deflection of the stem to port was caused by the first impact.
7062. Before it penetrated the plating?
- Yes, before penetration.
7063. What would you think would determine the fact that it went to port?
- The fact that the stern of the Storstad was somewhat nearer the Empress’s bow than it was to the stern, or in other words that the angle of attack was of this kind: (indicating.)
7064. Leading aft?
- Yes, and that the collision took place in that way, and drove the stem to the port side.
By Chief Justice McLeod:
7065. And your idea is that that was caused by the impact?
- Yes.
By Mr. Aspinall:
7066. In other words, that before it got in damage had been done to the attachment of the bow, and that a little difference in the angle would determine which way the bow would go?
- Yes, at the moment of impact something had to crush, and it was the slight angle which determined whether the bow should turn to port or to starboard.
7067. Now, I want to ask you about the angle between the two ships. Captain Kendall gives it as his opinion that it was a seven-point blow. You have had the advantage of seeing the damaged ship since - on which side does the damage extend farther aft?
- It extends farther aft on the starboard side.
7068. How much farther aft to the best of your judgment?
- About eight feet.
7069. You say the damage on the Storstad’s bow extends farther aft on the starboard side by about eight feet than it does on the port side?
- Yes.
7070. In view of that, at what angle do you think the two ships came together?
- At an angle of about eighty degrees, that is not quite a right angle, but a little less. About ten degrees less than a right angle.
By Chief Justice McLeod:
7071. That ite an angle of about eighty degrees towards the bow of the Empress?
- Yes.
Mr. Aspinall:
That is all.
Mr. Haight:
One question, my Lord.
7072. Is it not true, Mr. Hillhouse, that after the water entered through the wound in the side of the Empress it got into the bunker space, and would be contained there, and that the bunker doors would really be the only entrance for the water into the ship?
- Yes, the access of the water from the starboard bunkers would be through those doors to the stokehold, and then in addition it could travel freely across the lower deck, and from the lower deck could fall down to the stokeholds, and the opposite bunkers through a number of coal hatches.
7073. Now you have said that you estimate the area of the hole in the side of the ship at about 350 square feet?
- Yes.
7074. Is it not true that the area through which the water really entered into the body of the ship would be the area of the doors leading from the bunker space?
- Those in addition to the hatches on the lower deck. You understand the lower deck is open from side to side; there is no obstruction there except what coal was lying in the upper bunker.
7075. You mean there are hatches from the upper bunker to the lower one?
- Yes.
7076. Is the upper bunker below the water line?
- Yes, the floor is.
7077. Then if you had a hole in the side of the ship which let in the volume of water, whatever volume you like, into the bunker, the actual area through which the water would go into the body of the ship, would be the area of the bunker doors opening, and the bunker hatches going down through the floor of the upper bunker?
- Yes.
7078. Now what would be the area of those doors?
- Seven doors, each 12 square feet, that makes 84 square feet, and the total area of the hatches is 120 square feet, making a total of 204 square feet.
Mr. Haight:
Now, my Lord, by the aid of my own expert, I have reached quite a different conclusion as to the angle of contact. Does your Lordship desire that I should cross-examine this witness at length on his result?
Lord Mersey:
Certainly I do not desire that; but I do desire that you should put that to him. Put your points to him, because if you are going to set up some new theory when your experts go in the witness box, you ought to give this gentleman an opportunity of understanding them and answering them; but you need not do it at length.
Mr. Haight:
Well, my Lord, it is a rather complicated computation to figure out the angle, but I will do my best to make it as clear and as short as possible.
7079. Mr. Hillhouse, Mr. Reid, who has been advising me on the question of the physical condition shown on the Storstad, by taking the traces of your decks as they are shown on our starboard side, first crushing in the upper deck, where she took the bilges out, subsequently crushing such and such a deck, until we get down towards the water line - one mark from one of your decks runs lengthwise from the line of the side of the ship?
- Yes.
7080. From that, assuming the draught of the two vessels as now known, Mr. Reid has figured that the angle is in the neighbourhood of forty degrees. Now do you feel that your study of the Storstad has been sufficiently accurate to justify you in differing so radically with him, or is your estimate largely approximate?
- My estimate was largely taken - partly approximated by looking at the Storstad, and partly from this model. I measured the point on each side to which the damage extended, and joining these up, I got an angle of approximately eighty degrees.
7081. Do you then agree, with reference to the angle of the damage upon the bow of the Storstad, that it is by taking this and nothing else that you have reached your conclusion as to the angle of contact?
- Yes.
7082. And if, as a matter of fact, the damage on the upper deck, which I understand is where you measured the amount of damage done - is that right?
- Yes.
7083. Well if, as a matter of fact, the damage on the upper deck was due first to penetration, and subsequently to leverage and a swinging motion, that would not be a very accurate factor to work from, would it?
- No, it is only accurate if that damage indicates the extent on the two sides to which penetration has taken place.
7084. Well, do you mean at first or at some other time?
- No, it must be at first.
7085. If the vessel comes in on an angle of forty degrees, and then is swung by virtue of a forward movement of the Empress, after the upper deck of the Storstad is under one of your decks, she is wiped right off - everything on the upper deck is wiped off as the vessels swing?
- Probably.
7086. Now did you note in your examination of the port bow of the Storstad distinct imprints from parts of your vessel?
- As far as I remember there were cuts and scratches as if the decks had made marks.
7087. Did you note any definite imprints which indicated precisely what it was on your vessel that had hit the port side of the Storstad?
- No, the only thing I noticed was the deck levels.
Mr. Haight:
Mr. Reid, my Lord, will point out to the court to-morrow, not only the traces of the various deck levels, but various other data, which show from a careful study of these diagrams just what it was that touched us. For instance, there is a round print to-day in our plating of a bull’s-eye, a port hole. There is below it, and a little aft, a straight punch, a straight indentation which is unquestionably traceable to a valve, which is-shown on the diagram; and from data of that character, which I shall not undertake to give at the moment, Mr. Reid reaches quite a different conclusion. But if your Lordship feels that I need not go farther at the moment, I would rather call Mr. Reid than re-examine Mr. Hillhouse farther on the subject.
Lord Mersey:
All I want to say is this, that if you are going to ask Mr. Reid any questions which it would be fair and right to put to this gentleman before he leaves the box, you ought to put them now.
Mr. Haight:
Well, my Lord, personally I certainly do not wish to show any unfairness to Mr. Hillhouse, but I can hardly see that there is any particular object in asking him about data which have not come under his observation.
Lord Mersey:
In any event we shall have Mr. Hillhouse here, and if Mr. Reid gives us any evidence which seems to us to call for an explanation from Mr. Hillhouse, and if he wishes to give that explanation, he will be available to put into the box again. Now, have you finished with Mr. Hillhouse?
Mr. Haight:
Quite finished, my Lord.
By Lord Mersey:
7088. Have you given the metacentric height before the damage?
- Yes.
7089. Have you calculated it after the damage?
- Yes, my Lord, I have.
7090. Well I am not sure, but I thought you had in your hand a plan intended to indicate it?
- No, my Lord, not a plan to indicate the metacentric height after the damage.
7091. Now can ycu tell us what that metacentric height after the damage would be?
- When the water has reached a height of half way between the main and the upper decks, and has filled the compartments the metacentric height I estimate to be 26 inches.
7092. Well, assuming the metacentric height to be 26 inches, would you expect the list to be as great as we were told it was?
- Because the inrush of water was so great on that side, and the Storstad herself pressed the ship down, and some of the water got over to the starboard side.
7093. Got to the starboard side?
- Yes, to the starboard side of the ship through the doors of the engine-room, and also possibly passed quickly along through the main deck here.
7094. Now, I am asked to ask you whether you think you can trace the course that the water could follow?
- Yes, my Lord, I think I can.
7095. Well, then do it?
- First in order, the water would reach all the bunkers upon the starboard side of the ship, both below and above the upper deck; from these bunkers the water would pass through the coal bunker door into the stokeholds from the stokeholds it would pass to the bunkers upon the port side of the ship, and at the same time the water would be passing from the lower deck bunkers through the coal hatches to the coal bunkers upon the port side of the ship.
By Chief Justice McLeod:
7096. That would not increase the list?
- No, the passing of the water across the ship would tend to diminish the list.
By Lord Mersey:
7097. Are you able to give us any estimate of what the list would be, having regard to the fact that the water is entering on the starboard side?
- I could estimate the list on various assumptions as to the difference in quantities of water on one side or the other, but I am unable to estimate what these differences of water would be, because it is so difficult to estimate the speed at which the water would cross to the other side of the ship.
7098. It has been suggested to me that with a metacentric height of 26 inches there should have been no list, or very little list?
- Even with a metacentric height of 26 inches, if there was a considerable excess of water on one side of the ship, a large list might be reached.
Chief Justice McLeod:
There certainly was a list, there is no doubt about that?
- Even with a metacentric height of 26 inches, a considerable angle of the hull may be caused by a want of balance in the weight. If there is more weight on one side than on the other.
By Judge Routhier:
7099. If the water went to the port side it should diminish the list?
- Yes, my Lord.
Lord Mersey:
Mr. Aspinall, I am going to do something which is rather unusual, but I think it will be the best way of dealing with certain of these technical questions which puzzle me, and I am going to ask the assessors to put some of the questions direct to the witness instead of merely suggesting them to me.
By Mr. Welch:
7100. The arrangement of the bulkheads in this vessel are somewhat unsymmetrical with regard to the middle line, are they not?
- No, sir, very little.
7101. Well, take the boiler room for example?
- Well, in the case of the single-ended boiler, there is a slight difference.
7102. So that, if water came in in the neighbourhood of one boiler room, the initial effect would be an accumulation of water on one side of the ship - it would naturally go to the port side as well as the starboard side, but the starboard side, the volume of the bunker on the starboard side being greater than that on the port side, the first effect would be to list the ship to starboard, would it not?
- Are you assuming that the water is in the bunkers only and not in the stokehold?
7103. I am assuming that the initial effect would be there, before it got into the stokehold - of course it would get into the stokehold afterwards?
- The initial effect certainly is to heel her to the starboard side if the water is only in the starboard bunker, but not due to any want of symmetry in the bunkers.
7104. Would you refer to the plan and just be sure of that?
- The only want of symmetry is in the way of the single-ended boilers, where there is a passage around the boiler and at the back of it.
7105. Take the blue print if you will, I can’t see that plan?
- Yes, here is the blue print. This, is the want of symmetry to which you refer?
7106. Yes?
Lord Mersey:
I hear another gentleman behind me here saying: no, it is not.
The Witness:
Oh, perhaps it is this recess here.
Mr. Welch:
Yes, that is a little out of line? Is it not?
7107. What I wanted to know was whether the effect of a blow in this vicinity would be such as to let more water on the starboard side, initially than the other?
- Yes, certainly.
7108. Because you have that there on the other side (indicating)?
- No, not on account of that, Mr. Welch, simply because the water comes on this side, and afterwards I suppose it would finally fill.
7109. But I am asking for the initial effect - finally I know it makes no difference, but the first effect, wouldn’t it be to fill up that bunker, and then of course you have coal in this portion here, which is not quite the same there. I mean you have a bigger space for coal on one side than on the other?
- Yes.
7110. So that to that extent the water would get around quickly?
- Through the coal.
7111. And fill it in here in both boiler rooms?
- Well assuming that at the beginning the water would be right around here, then in that case it would get partly in the coal and there would be a little more water on this side and there might be a little effect.
By Commander Howe:
7112. Do you think the damaged bulkhead between the boiler rooms, being stepped, had any effect?
- No, the step in that case had no effect, because the bulkhead was destroyed.
7113. You don’t think it could have the effect of holding the water on top of the deck?
- No, because the water was coming from below as well as from above.
Lord Mersey:
Well, that will do. Now, do you want to ask this gentleman anything further, Mr. Newcombe?
Mr. Newcombe:
No, my Lord.
Lord Mersey:
Then, if no one has any questions to ask Mr. Hillhouse, we want Captain Kendall back in the box.