Wreck Commissioner's Inquiry

NINTH DAY

 

JOHN REID,

naval architect,

 

Sworn.

 

Examined by Mr. Haight:

 

7254. What is your profession, Mr. Reid?
- Naval architect.

7255. Where did you obtain your education?
- On the Clyde, and elsewhere.

7256. What practical experience have you had in ship-building, ship designing and construction?
- Twenty-five years; 13 years a ship-builder and the rest as naval architect.

7257. Where was your ship-building experience obtained?
- On the Clyde, on the Mersey and on the Tyne.

7258. With what different yards?
- Stephen on the Clyde, just below Fairfield, where this boat was built; Cammell, Laird & Co., on the Mersey, and Armstrong, Whitworth, on the Tyne.

7259. Where have you been practising as a naval architect, on this side or the other?
- Both; I have offices on both sides.

7260. You have now?
- Yes.

7261. Just give me roughly, Mr. Reid, an idea of what boats you have designed and built; that is, how many and of what character, in general terms.
- In the employ of Alexander Stephen & Son I had to do with the designing and building of the Tunisian and a large number of Atlantic liners, both first class and intermediate ships.

7262. Name some of them.
- Alexandra, Boadicea, Bohemian, and quite a few others.

7263. What experience have you had subsequently?
- I have designed a large number of vessels of all kinds of types.

7264. Will you name a few of these?
- Well, a large number of Canadian canal vessels, small passenger vessels, tugs and so on.

Lord Mersey:
I think we may fairly credit this gentleman with a sufficient and proper knowledge of his profession.

 

By Mr. Haight:

 

7265. Did you, Mr. Reid, at my request examine the physical damage sustained by the Storstad in her collision with the Empress of Ireland?
- I did.

7266. Where was the examination made?
- At Montreal.

7267. Will you please state for what purpose the examination was made?
- To see if it could be determined how the damage to the Storstad's bows had been brought about by contact with the Empress.

7268. Did you make your examination with particular reference to the angle of contact and the depth of the wound?
- I did.

7269. Did you also note such evidence as there was of the movement of the vessels after they came in contact?
- I did.

7270. Did you have submitted to you a cross-section, midship section, of the Empress of Ireland, which is an exhibit in this case?
- I had.

7271. What other data did you have to work on in the first instance?
- I had the draught of the Storstad, the draught of the Empress and an approximate position for the contact.

7272. What did you assume the draught of the vessels to be?
- I took the Storstad at 25 feet low draught and I took the Empress draught giving me a mean midships of 27 feet 9.

7273. According to the testimony of yesterday, 27 feet 9 mean would be Quebec draught?
- Yes, that is right.

7274. There would be a difference, therefore, in the vessel’s draught when she reached Father Point?
- Yes.

7275. Have you taken that fact into account?
- I have.

7276. What is the general construction of the ship?
- She is constructed in the longitudinal or Isherwood system.

7277. How does the fore and aft strength of a vessel built on that system compare with the ordinary construction of frames that run like ribs round the vessel?
- It is considerably in excess against deformation by collision, collapse, or crushing of the material of the bow.

7278. A vessel built on that design and running head on to anything has practically all of her frames meeting the blow endwise?
- That is correct.

7279. Will you be good enough to state, in detail, the various facts of deformation which you found on the bow of the Storstad?

Mr. Haight:
I have prepared, if the Court please, copies of the Exhibits previously submitted, which I think your Lordships will find convenient in following Mr. Reid’s testimony.

 

By Lord Mersey:

 

7280. Are you going to use the model, Mr. Reid?
- I was going to use the model to show the general deformation of the bow of the Storstad, and I was going to use the photographs to show the detail, because the actual marks are not shown on the model. They are too minute.

7281. Well, take the model first?
- After examining this deformation of the bow, my Lord, I wished to try to reconstitute the contact as nearly as possible, and I made careful measurements and plans in order to determine just what angle was the most likely to have brought about this extraordinary movement of the stem, this heavy crushing, and the displacement of the anchor.

7282. That is on the starboard side?
- Yes, my Lord. When a collision takes place between a vessel such as the Storstad - I might say when a vessel such as this strikes another, the stem always gives indication very quickly of what has happened at the first moment. The stem is a heavy bar, which is full of holes. It is almost inevitably broken by the contact, as actually happened in this case. The head was knocked off by the contact with the shelter deck of the Empress. It snapped off short at the deck, and I was much surprised to find there was no appearance on this stern of having been in contact with the Empress at all. I should have expected to find scores across it.

I therefore came to the conclusion that this was not the place of first contact, but
that the stern had been turned by some agency so that the bar did not actually come
in contact with the Empress at the first moment. That put out of the question a right
angle blow, or any blow in that neighborhood. I then turned to an angle of forty-five
degrees - simply an arbitrary attempt to find the angle - and I tried the Storstad up
against my drawings of the Empress at that angle.

Now the Empress has a 'tumble-home' which is rather a difficult thing, that is it
complicates things, so I eliminated that for the time being.

 

7283. What is that, Mr. Reid ?
- The side of the Empress has a fall-in from the water line of about 13 inches at the shelter deck, but I intend for the moment to eliminate that, so as to avoid complicating the calculation. I wished, in other words, a vertical detailed plane to bring the Storstad up to, and to make allowances afterwards for the tumble-home. I took a plane through the whole side of the Empress, about amidships. She has very little fore and aft shaping, so I was clearly correct in taking it that the Storstad had entered at a perfectly vertical line, and one going practically straight fore and aft. That is to say, I was bringing this vessel up to a plane parallel to the vertical centre line of the plan of the Empress.

I found, my Lord, that down here on the stem, there was a very big part of the
stem turned this way, to starboard, whereas the rest of the stem had gone over to port.
In other words, there was an initial tendency to go to starboard. And I came to
the conclusion that that was caused by the Storstad striking the orlop deck, or the
orlop deck stringer, of the Empress, and then being pulled over this way, and then
before any large result of that could accrue, the anchor of the Storstad, which was
hanging in its hawse-pipe, came in contact with the side of the Empress. It was projecting
about 18 inches from the normal side of the Storstad.

The result, my Lord, was this; that the anchor was driven right through its hawse
pipe, a very heavy casting, and was caught here, as shown in the photographs, and that
set this stern starting to go over.

Now I ought to add a little explanation about the Isherwood system, to what was
said yesterday. Our longitudinal frames - each longitudinal frame, as it goes up to
the stem, is held to its corresponding frame by a small triangular bracket, and these
are only 18 inches apart up here in the bow. And with the bar, and the two places of
plating here, and these brackets, you have as it were a triangular section of girder,
all the way down the stem, and the whole thing went over, getting the initial impulse
here (indicating).

Mr. Haight:
When you say 'here' will you, for the benefit of the stenographer, say over to port or over to starboard, as the case may be, at the same time designating the spot on the model?

Lord Mersey:
I am very much afraid, Mr. Haight, that the shorthand notes of all this won't amount to very much. The shorthand writer of course cannot possibly help that, but you see the witness is continually saying ‘here’ and ‘there’ and point ing to the model, and that means nothing on the record.

Mr. Haight:
No, and if the witness will just bear that in mind and say to port or to starboard, or inboard or outboard, as the case may be, and use expressions of that kind, it would be much more intelligible when we come to read it.

7284. Will you please proceed, Mr. Reid?
- The anchor, my Lord, was caught momentarily between the bow of the Storstad and the side of the Empress, and the reason that the force was so great was that just at this place the deck of the Empress is only a foot below the corresponding deck in the Storstad, that is, these two decks were almost face to face and the anchor was caught between them.

7285. Have you designated on the cross-section drawing, Exhibit N, I think it is, the relative position of the Storstad and the Empress?
- Yes.

7286. Will you please show that to the court?
- Yes, I simply turned over this edge your Lordship, and that gives the position of the Storstad's stem, relative to the decks of the Empress. Here is the anchor (indicating), and the position of the hawse-pipe, and the deck which comes almost opposite the upper deck of the Empress, and you have the other decks further down on the Empress, which left their marks on each side of the Storstad, which I shall come to.

Mr. Aspinall:
My Lord, I was unable to follow that. Could the witness repeat what he has just said.

Lord Mersey:
Now, do you mean -

Mr. Aspinall:
Well, of course, I can ask him later.

Lord Mersey:
No, I think it is convenient to ask him now. I think you should look at that plan, Mr. Aspinall, and have him explain it to you as he explained it to us.

 

By Mr. Aspinall:

 

7287. Will you just tell me, Mr. Reid, what you have just told his Lordship?
- Yes. (Here the witness stepped down to counsel’s desk and exhibited the plan in question to counsel and repeated the remarks he had made in answer to Lord Mersey.)

Mr. Haight:
May the witness proceed, my Lord?

Lord Mersey:
Yes, go on with your explanation, Mr. Reid.
- Well, my Lord, this was the initial impulse, to turn this stem, your Lordship, which I wish again to emphasize was almost like a triangular section of girder all the way down the stem, on account of these brackets being tight together. As the contact continued and the Empress side turned out on account of the tumble-home, the stem came in contact with deck after deck, continuing this impulse. Now, this initial impulse here (indicating) which was going the opposite way, came in contact with that (indicating), and just here, where it turns to starboard, there is a scarf in the stem, in other words, the stem is put in in two pieces with a scarf connection, and that scarf opened and made this tendency die away. I only wish to call attention to this point - it is not really of great importance - that the first contact was here just at the fore-foot. Now, to come to the port side, here you have, my Lord, a deep hollow or bay in the plating, that is on the port side of the Storstad’s stem.

7288. Would you repeat what you said just now - I think I understood you to say that the first contact, the first point of contact, was at the bottom of the stem?
- Just at the fore-foot, my Lord, about thirteen or fourteen feet up from the keel line of the Storstad, that is where the orlop deck stringer of the Empress of Ireland comes.

7289. Yes, now let that be so - you say that is about fourteen feet up from the bottom of the Storstad?
- Yes.

7290. Does it go through beyond the line of the stem? I should have thought it was more in than that?
- The stem of the Storstad is almost vertical.

7291. Almost vertical, but if it inclines at all, doesn’t it incline inwards?
- No, sir, it goes the opposite way, because she was somewhat trimmed, and the stern of the Storstad was a little lower, which would turn the head of the stem inwards about an inch or an inch and a quarter. And besides, the side of the Empress -

7292. Never mind - the side of the Empress at present. I wanted to get at the construction of the Storstad itself. Now do you say it is not vertical, Mr. Reid?
- It is not. It falls in about an inch.

7293. It falls towards the bottom about an inch inwards?
- No, it falls in this way, my Lord, the head of the stem is somewhat towards the Storstad’s stern.

7294. Give me the model, please?
- Yes, my Lord.

7295. What is the bar in front intended to represent?
- That is the original stem bar.

7296. And it does go in at the bottom, there?
- Yes.

7297. Well how far is that point above the bottom of the stem?
- About twelve or thirteen feet.

7298. Then at that point it begins to turn in?
- Correct.

7299. That is what I mean?
- Yes, my Lord.

7300. And then from that point upwards does it come up absolutely vertical?
- No, it falls off an inch.

7301. In that way, that is towards the stem?
- Yes, my Lord, about an inch.

7302. Now then, this ship was, I suppose, down by the stern a little?
- Yes.

7303. Well would that fact cause the stem to be altered a little in its position?
- That is correct, my Lord.

7304. How much was the Storstad down by the stern?
- One foot.

7305. In what length?
- In 440 feet.

7306. Now does that make any appreciable difference in the position of the stem for the purpose of this case?
- It makes very little.

7307. Well I mean to say, if it doesn’t make any difference that is appreciable, we will dismiss it from our minds. I should have thought that in 440 feet it is of no consequence at all?
- What I am trying to point out, my Lord, is that the initial tendency was so short and slight that it was a very small thing, and you have to look for very small reasons.

7308. Well do you mean to say that this is of any importance, this fact that the Storstad was down by the stem?
- It is important in determining the initial entrance of the Storstad’s bow.

7309. Well if it is not important, we will not bother with it, but I understand that you think it is important?
- Yes, my Lord, I think it is of importance.

7310. Well then, how much would the fact that the Storstad was down a foot cause the stem of the Storstad to alter its position?
- In the full height of the stem from the keel, it makes a difference of about an inch and a quarter.

7311. But up there?
- The difference in the full length of the stem is about an inch and a quarter.

7312. Where, at the top of the stem?
- Yes.

7313. Now what is the fail-back where the stem begins to curve in, twelve or thirteen feet above the keel, is it appreciable?
- It is trifling, but we have to consider -

7314. Well how much is it?
- Well, it is one-third of an inch and a quarter.

7315. Well, how much is one-third of an inch and a quarter?
- That is 5/12 of an inch. We have to go up and see this other contact, which neutralizes that.

7316. But your opinion is the first point of contact was down here?
- Yes.

7317. Very well, I have the first point of contact. It was down here - (indicating)?
- Yes.

7318. Well how much does this fact that the stem was a foot down affect this point?
- Well only a little over a quarter of an inch.

7319. Well, if that is important, we will direct our attention to it, but if it is not I want to dismiss it from my mind?
- Well, it is not of very great importance.

7320. No, I am not asking you that, but is it a thing that we need not trouble ourselves about?
- It certainly is important, my Lord, to determine where the initial contact took place.

7321. Then is one of your calculations so fine that it is based on the assumption that at the bottom of the Storstad’s stem the position was affected by a quarter of an inch, by the fact that she was down at the stem one foot?
- I don’t work it that way, my Lord.

7322. Well how do you work it?
- I allow for the full extent of the fall-back, right up to the top of the stem, because it is up there the other impulse began to neutralize the earlier one.

7323. Well, I am only trying to understand it myself, and I am probably not looking at it from the same point of view as you are. Now, so much for the bottom of the stem, or I mean about twelve feet up. Now where do you say that stem, which, by reason of the fact that the stern is a foot down, poked out a quarter of an inch beyond what it would have poked out if she had been on an even keel - where does that point of the stem in your opinion strike the side of the Empress?
- Just upon the orlop deck stringer, which takes the place of the orlop deck in that neighbourhood.

7324. Now on that plan which you have did you indicate that spot?
- Yes, I did, my Lord.

7325. Well now, will you show it to us again?
- Yes, there is the position, my Lord (indicating).

7326. Here - it is somewhere about here?
- Yes.

7327. Which is slightly above the orlop deck?
- Yes, my Lord.

7328. How many feet above?
- A foot or eighteen inches.

7329. Then that in your opinion was the point where it first struck the Empress?
- Yes, my Lord.

7330. Well now, tell me this, taking the Empress from the orlop deck upwards to the rail, does the side of the Empress curve inwards or outwards?
- It goes up perfectly straight to about the loadline and then curves in.

7331. Now need we trouble about the load line for a moment?
- Only as indicating the place where the tumble-home begins, my Lord.

7332. Yes, but for the purpose of the idea which is running in my mind, it doesn’t seem to me to be material. You believe that the whole stem of the Storstad from the point where it touched the Empress at the orlop deck, ran up vertically?
- No, my Lord, you have projecting strakes of the plating, my Lord, sticking out.

7334. Sticking out from where?
- From the side of the Empress.

7335. I thought you said just now that the side of the Empress went up vertically?
- It does, my Lord, but the strakes of the plates stick out an inch or more, at certain places. These strakes were sticking out.

7336. Yes, and what are these things that stick out?
- Strakes, the shell of the plating.

7337. And do they protrude beyond what we call the shell?
- They form the shell, my Lord, but some are inside and some are outside, and it makes a difference of an inch or more.

7338. And the plates lap over?
- Yes.

7339. Causing some of the plates to be an inch or more in front of the other plates?
- Yes.

7340. And so it produces irregularities on the side of the Empress?
- Yes.

7341. Very well then, subject to the observation you have just made, the two lines, the line of the stem of the Storstad and the line of the skin of the Empress, above the orlop deck, were both vertical?
- That is right.

 

By Mr. Haight:

 

7342. But the vessel’s side begins to tumble home, as you say; do I understand that from the point of tumble-home it goes absolutely vertical, perpendicular to the line of the water?
- No, it is below the load line, it goes down perfectly vertical.

On the port side, my Lord, there is a very deep bay, extending right down the stem of the Storstad and corresponding to this bend on the starboard side of the Storstad. That bay comes about somewhat in this fashion: when you attempt to turn that triangular girder containing all those brackets over by pressure on the starboard side, and the plating cannot get away, for it is held by the longitudinals and cannot get aft, it must crush into this bay. Besides that? there was another tendency going on assisting this, which tendency was caused in my opinion by the rolling over of the broken plating of the Empress.

Lord Mersey:
Well, I am afraid I don’t understand that.

- If you attempt, my Lord, to drive, not with a sudden blow but with an extraordinarily heavy push -

7343. Not a direct blow?
- No.

7344. But a slanting blow?
- Yes, and more a crushing than a hammering - if you try to drive a form like that into a steel plate, including for a moment the frames and the bulkheads behind it, you crush and deform that plating, and the bows bent the plating in a certain distance, and then burst the plating, and that plating on the starboard -side remains pretty much where you started. But the plating on the other side, that is on the port side of the bow of the Storstad, is driven forward, and inwards, and is rolled over, and that rolling of the plating of the Empress occurred on the port side in which is this bay on the side of the stem of the Storstad.

7345. That is to say, to put it in ordinary language, the nose of the Storstad is found inclined to the port side?
- That is correct. That plating, my Lord, that I speak of, is rolled over and couldn’t get out of the way, because I bring this vessel in near a place or at a place on the side of the Empress where there are heavy resistances. When I first made my contact, my longitudinal contact, I thought I was on a bulkhead, on one of the main bulkheads of the ship, and I assumed that was the case, because it had been stated so frequently that this bulkhead had been broken, so I assumed that I had struck it close up to the bulkhead, that is that the Storstad had struck the Empress there, and that the stem had gone on beyond it and punched that bulkhead and broken it. Althought I couldn’t understand why, again, this stem bar had ishown no marks upon its face, because a bulkhead is full of angles, it is crisscrossed with angles; and on the steel that is on the face of this stem, there was absolutely no mark, except a little plating torn away from it.

7346. Now, let me ask a question - assuming that the blow was not, as I take it clearly it was not, a straight on-end blow, but was a slanting blow?
- Yes, my Lord.

7347. Would you expect to have the edge of the stem affected?
- No, my Lord, not at an angle of 45 degrees, which I am taking for the entrance.

7348. And you did not find it affected?
- No.

7349. If it had been a blow at right angles you would have found it affected?
- I should have found it broken, my Lord, for certain.

7350. And it was not really broken, so therefore it was not really a direct blow at right angles?
- I did not so find it, my Lord.

7351. And the evidence shows, apart from the fact that the stem is not broken - this bar you have made on your model - it shows that the impact was not on the stem?
- Absolutely, I think.

7352. Then it was a side blow?
- That is correct, my Lord.

7353. Now will you proceed, Mr. Reid?
- After the anchor had done its work along the stem it was caught between the two decks and driven right through the hawse-pipe, and plating, and brought up all standing twelve feet six inches abaft its original position, as near as I could measure it, into a sort of pocket which it formed in the plating. I found the anchor-flukes projecting in a very ugly fashion, as if they had been in the wreck of the Empress on the starboard side of the Storstad.

7354. Now will you tell me about that - the anchor was presumably in the hawse-pipe before the collision?
- Yes.

7355. How big is the hawse-piping?
- Two and a half to three inches, my Lord, with a very heavy mouth.

7356. The anchor was on the starboard side of the ship?
- There is an anchor on the starboard and one on the port.

7357. But the anchor you are talking about is on the starboard side of the ship?
- Yes, my Lord.

7358. And that was driven in, I understand, into the hawse pipe, and the hawse pipe is broken?
- Yes, that is correct.

7359. Are you of opinion that it was the side of the Empress that drove that anchor into the hawse-pipe and caused the hawse-pipe to be broken?
- Certainly.

 

By Mr. Haight:

 

7360. Mr. Reid, will you please refer to the exhibits, the photographs, which show the position?

Lord Mersey:
Well, Mr. Haight, I don’t like photographs. They are most deceptive to me?
- I only wish to use them, my Lord, to show certain very prominent traces of certain parts of the Empress.

7361. Well, if you use them for that purpose, we shall be able to follow them, but I should be sorry to accept these photographs as demonstrations of what we would see if we were there?
- I shall not use them for that purpose, my Lord.

7362. Don’t you agree with me, Mr. Reid, that photographs are deceptive?
- Very deceptive, my Lord. I tried to scale some and I found it impossible.

 

By Mr. Haight:

 

7363. But the photographs filed as Exhibits D and E do show the position of the anchor and the hawse-pipe?
- Yes, they show it fairly well.

Lord Mersey:
My colleague on the left (Sir Adolphe Routhier) has not seen the stem of the Storstad, but my colleague on the right, (Chief Justice McLeod), and I have seen it. The witness described the look of this anchor very well, when he said it was a very ugly looking thing.

7364. Now, look at these photographs which Mr. Haight wants you to look at?
- Yes, this one that your Lordship has just handed to me is the other side of the ship.

7365. The other side?
- Yes, the port side.

7366. I was going to ask you about that - I thought that seemed to be a photograph of the port side?
- Yes, and it is the starboard side that I am describing, my Lord. When I looked at this I was wondering about it, and then I realized it was a photograph of the port side.

7367. Then, this one that I hand you now is a photograph of the starboard side of the Storstad?
- Yes, my Lord, that shows the position of the anchor on the starboard side.

7368. Yes?
- I consider, my Lord, that the position of that anchor, brought up, on the starboard bow of the Storstad, shows one of the limits of the penetration of the Storstad. That is to say, the anchor was caught in the side of the Empress and the Storstad pressed on. The Empress carried that anchor back, crushed all the plating up, and brought it to rest at a certain point, and there the Storstad came to rest on that side.

7369. Now, can you tell me how far the damage to the stem of the Storstad extends towards the stern?
- Not more than 14 feet, my Lord, from the original stem.

7370. That is on the starboard side?
- Yes, on the starboard side. That allows 12 feet 6 inches for the movement of the anchor, and two feet from the original stem, making altogether, about 14 feet 6 inches on the side of the ship.

7371. You know you have been assuming all the time that the blow was a slanting blow. I suppose you cannot fix with absolute precision the angle of the blow?
- Very closely, my Lord.

7372. Then taking your best judgment, as to what the angle of the bow was, how long, along the skin of the Empress, was the blow felt? In other words, for what length was the skin of the Empress opened?
- About twelve feet at this point. I have a drawing of the hole as near as I can make it.

7373. But I don’t understand that, because you say the stem of the Storstad is damaged to a length backwards towards the stem of 14 feet 6 inches?
- Correct.

7374. Well doesn’t if follow that to that extent the starboard side of the Storstad must have found its way into the hull of the Empress?
- In a diagonal line, yes.

7375. Now can you determine for what length the skin of the Empress must have been cut?
- The distance between this point and the opposite point here, because the Storstad goes in to the Empress on this side, and gets the other side also into the hole in the Empress, that is the port side of the Storstad as well. The bow has already penetrated. Here is the line of the Empress in this direction (indicating).

7376. But I don’t think you understand what I mean - bring the model here and I can show you-

 

By Mr. Haight:

 

7377. If your Lordship will allow me - have you, Mr. Reid, prepared a drawing showing the malformation of the decks of the Storstad and the approximate angle of contact?
- Yes.

7378. Now, looking at the drawing, this is the starboard side here (indicating)?
- Yes.

7379. And according to the evidence, the starboard side of the Storstad you know, struck the starboard side of the Empress?
- Yes.

7380. And it penetrates into the Empress as far as that (indicating)?
- Yes.

7381. But it is not a blow that way, but it is a blow in the other direction - now then, can you tell me, it struck the Empress there, and it injures its own stem back to the point that you have indicated. Now in doing that, what length did it open the side of the Empress?
- It cut it open much less than that, because this is the final position of the Empress relative to the Storstad. Here is the other side over here, and the stem has penetrated at an angle of about 45 degrees, and the hole left is the distance from there around to here (indicating).

Lord Mersey:
Well, that may be so.

- It is rather important to get that right, my Lord, and I have a plan here which shows that.

7382. Well show it to us?
- Here is the original of that plan, my Lord, if your Lordshp would prefer to look at it.

Lord Mersey:
No, the blue print is very good.

Mr. Haight:
My Lord, there are seven copies of that plan made so that every member of the Board could have one. That is a blue print made from a tracing.

 

By Chief Justice McLeod:

 

7383. Which is the black dotted line there?

Mr. Haight:
The black dotted line, my Lord, indicates the malformation.

Chief Justice McLeod:
Yes, I know, but on the blue prints how are we to distinguish them? There is supposed to be a red dotted line as well.
- The red dotted line was copied off the original exactly, my Lord, we couldn’t colour the prints.

 

By Lord Mersey:

 

7384. Now what is this red dotted line which appears white on the blue print?
- That is the deformation of the decks below the top deck of the Storstad.

 

By Chief Justice McLeod:

 

7385. This is the Storstad?
- Yes.

7386. And you say that shows what -
- The limit of damage on the top deck, which was swept by the deck of the Empress that penetrated just under. In other words, the Empress deck shoved our forecastle head to one side.

7387. And the distance to the bow is 14 feet 6 inches?
- That is where the anchor came to rest, and from here to here is 14 feet 6 inches.

 

By Lord Mersey:

 

7388. Now, after that entered the Empress, is it not possible that after entering the Empress that might have made a wound in the side of the Empress much longer than 14 feet 6 inches?
- No, my Lord, it is not possible.

7389. Now, supposing I take a knife and put it into a piece of butter, and I put it in that deep and put it in sideways, can’t the knife come out and make a hole in the butter twice as long as the mark will show on the knife?
- The other side of the knife gives you the margin of the other side of the hole, unless you twist the knife.

7390. No, I don’t twist it, I just run it along?
- Then the other side of the knife gives you the other side of the hole you have made.

7391. I daresay you are right, you know, but I can’t quite see it. Now I take a piece of paper - there is the side of the Empress we will say, this piece of paper?
- Yes, my Lord.

7392. And I put a knife into the piece of paper. It enters there. Now my knife is damaged down there, but may not the piece of paper be damaged almost its whole length?
- You are not going in fair, my Lord. You are not going in straight on end.

7393. No, it didn’t go in straight on end. It went in slanting.
- But we have to think of the whole of the Storstad as a knife.

7394. Yes, and can’t the Storstad in running into the Empress run in that way, the way I have shown with the knife on the paper?
- There was no glance in that way.

7395. What do you mean by a glance?
- You are driving that knife along the side of the Empress, but the Storstad is a knife, and had carried on in her course.

7396. But is there any reason to suppose that she didn’t move as I suggest?
- Yes, every reason.

7397. Well, what reason?
- Marks on the side of the Storstad.

7398. But it is possible, never mind the marks at present - it is possible that the blow may have ripped open a great deal more of the side of the Empress than is represented by that diagram?
- Only if it was a glancing blow along the side.

7399. But wasn’t it a glancing blow?
- No, my Lord, it was a direct blow.

7400. What do you mean by a direct blow?
- A blow of 45 degrees on the side of the Empress.

7401. Well supposing it a blow of 60 degrees or 70 degrees, a blow that would become somewhat more of a slanting blow?
- Well in that case you would have ripped along the side of the Empress.

7402. I know, and what I would like to know is this. Isn’t it possible that that kind of blow was delivered to the Empress?
- Not on the evidence I have, my Lord.

7403. But could it have happened?
- Certainly, you could have had a ripping blow. It might have turned and ripped along the Empress side.

7404. Well that is what I am suggesting, but you say the evidence points to the fact that there was not such a blow?
- Correct.

7405. Now I am prepared to listen to your explanation with regard to that. I only wanted to know whether there was anything wrong with my idea?

Mr. Haight:
As I understand it, my Lord, that represents really the part of the stem of the Storstad which penetrated into the plating of the Empress, and the angle at which it pentrated - that distance there (indicating) would therefore be the hole through the side of the Empress.

Lord Mersey:
Unless it slid along.

Mr. Haight:
Yes, my Lord, unless it slid along.

Lord Mersey:
What I am putting to Mr. Reid is this:

7406. Isn’t it possible that it may have slid along?
- Not in my opinion, my Lord.

7407. You say the indications show that it did not?
- That is correct, my Lord.

7408. Now will you please explain to me again what are the indications that lead you to suppose the stem of the Storstad went in in the direction as drawn by Mr. Haight, and as shown by you on your plan, that is to that extent, and then came out again without moving - if you know what I mean by without moving, simply backed out - that it drove in and then drew back again.
- I don’t consider it did that, my Lord, it turned.

7409. But it didn’t advance?
- No, it didn’t advance.

7410. It didn’t go towards the rear, but it went in, and, if I may use the expression, wriggled out again?
- Yes, that is correct.

7411. Will you tell me what leads you to that conclusion?
- On the side here, at the point which I find for the contact of the Empress, on the stem, on the starboard side you have very prominent indications of the decks of the Empress. The Empress decks cut into us, and we cut in between them. They were very strong things with very heavy beams and did not give way as readily as the plating, and scored our side. First of all, the Empress shelter deck, passing over our forecastle, swept it right back to the black line I have shown on my plan. The upper deck was almost opposite to our upper deck, and ran the anchor back. The main deck scored deeply in her. The lower deck made a slight trace, and the orlop deck left an impression which is above the scarf of the stem which we discussed before.

 

By Mr. Haight:

 

7412. Do the indications show that?
- Yes, but I will come to them a little later.

On the other side, my Lord, the decks acted somewhat similarly. They show also on the port side of the Storstad’s bow, and the marks they made in the plating point, as I explained, to the fact that the plating of the Empress rolled over, as I explained it before. The plating gave way, but the decks did not give way; they held as far as they could, and we crushed the hull and split the plating - that is my plating was split somewhat and the plating of the Empress was rolled up in the bay on the port bow of the Storstad, as I have explained.

7412½. Did you notice at a point where one of these decks comes a very prominent depression?
- Yes, I noticed a very prominent depression, which I was certain, if I could find out the meaning of, that is what had caused it, that I could know pretty accurately where this blow had taken place. I found later, by looking at the plans of the Empress, that this big depression at the level of the main deck was caused by a pad of iron and wood, which projects under one of the large gangways or coaling ports, and projects beyond the side of the Empress, I suppose about six or nine inches, but I haven’t that figure exactly. Then about five feet above that, I found an impression of a side-light very prominently stamped in under the port anchor. That light is of a smaller size, which indicates it was a main deck-light, and I know that of course anyway, by the position of the decks.

7413. You mean on the port side of the Storstad's bow, you saw this mark?
- Yes, on the port side. The Storstad, being driven aft, was crushed against the Empress, and this pad and the side-light were crushed across the ship into the centre of the ship, pointing to some very great force having squeezed the anchor through its hawse-pipe. It was also broken, as on the other side, and left the anchor sticking practically in the centre of the ship, which is not a very great diversion, because she is narrow here.

That points to this, my Lord, that the ship had gone in, crushed its way into the Empress, and brought up all standing, because the features I have referred to are on the far side of the point which I chose for my hole in the Empress. That was an arbitrary decision, that I chose, and I had a very small plan of the Empress, and didn’t know that the bulkheads were stepped, that is, I didn’t know that this bulkhead No. 5 was stepped at the main deck, and I thought I had found that bulkhead with the face of the stem.

It was only two days ago I found that the bulkhead was 15 feet further forward. That caused me to overhaul all my theory, and I found that I was right with that position, and on one of the figures I discovered the mark of that bulkhead. That is only a trace upon our stem, and it is a very faint one, of No. 5 bulkhead. It doesn’t make a depression in our side of more than an inch or an inch and a half. In other words, we didn’t hit that bulkhead except when the energy of this blow was being dissipated. It was partly spent in generating heat, partly in crushing in the Empress, partly in the Empress crushing us in, and partly in careening both vessels: I believe that blow pushed the Empress over bodily a little, and pushed the Storstad a little the opposite way, and that brought our lower portion against the side of the Empress, and we just got a trace of that No. 5 bulkhead, fifteen feet away from the point that I had considered was the point of contact, which is practically amidships, and which corresponds, I might say, with the room of which we found the tablet on the bow.

The nature of this damage, and the size of the hole caused by it, is best determined by looking at the damage done to the forecastle head, because the shelter deck of the Empress nipped off our stem, and swept this deck. The starboard side was crushed in and heaved up; the port side of the deck did not sustain any serious damage, kept to its shape, and the vessel is so heavily plated to carry the windlass and various other equipment there, that if there had been, any further penetration the damage would have extended back to the windlass.

I have drawn a line on that plan, showing the limit of the damage, but not to indicate the extent of the penetration, only the extent of the damage on the forecastle head.

The starboard anchor, I believe, shows the conclusion of the blow on this side. This point (indicating) shows the conclusion of the blow on the port side.

 

By Lord Mersey:

 

7414. Do you mean the conclusion of the blow or the conclusion of the damage, because I should have thought the blow hit your ship upon its starboard side, and I don’t quite see how, having a slanting blow, you can have a blow on both sides?
- This is the other side of the hole in the Empress, my Lord.

7415. But you are at present showing the Storstad?
- Yes, but this is where the hole in the Empress forced its marks on the bow of the Storstad. One side of the hole is here.

7416. But the way you put it is that the Empress caused the damage to the Storstad - isn’t it better to say that the damage was done by the Storstad to herself by driving herself into the Empress?
- It is a mutual affair, my Lord.

7417. Well, you rather put it as if it was the Empress that was destroying the Storstad, and isn’t it the right way to put it that it was the Storstad destroying the Empress - of course, that is a mere thought?
- I merely wished to illustrate the extent of the peneration along the line of the Empress' side.

7418. Yes, we were talking about the blow on the port side of the Storstad?
- Yes.

7419. Well, now, I know that the port side of the Storstad is damaged, but I should have thought the blow came first on the Storstad’s starboard side?
- That is correct, my Lord.

7420. And then I don’t know what other blow ever came. Of course I can understand that the port side was damaged. If I am wrong, don’t hesitate to contradict me, for I am just trying to find out?
- No, you are quite right, your Lordship. I am merely trying to show the cause of this result. I wish to show on the starboard side where the anchor came to rest, and that would be the limit of the effect of the blow on that side, and that would be on the forward side of the hole in the Empress. And here on the port side I am trying to show the limit on the Storstad of the aft side of the hole.

7421. And you say that is not so far back?
- No, your Lordship, not so far back. All these indications, your Lordship, bring me to the conclusion that I had given too large an angle at 45 degrees, that the indications do not conform to that angle. I believe that 40 for the angle of contact is right, or in that neighbourhood, and to pull her farther down the angle of contact is sensibly less than that, about thirty degrees along the ship’s side, and I attribute that fact to this careening of the Storstad.

7422. Would you take a piece of paper and mark down the two vessels? We have some little models here, and if you would put the two vessels in the position in which you now believe they were at the first moment of impact, I would be very glad.
- I cannot do it with these two little ships, my Lord, because they do not show what I want to bring out. I would rather try and draw it, because these are too small.

7423. Now, will you show me first what you really believe to be the relative positions of these two ships at the moment of the contact?

(Witness drew diagram on sheet of paper indicating angle.)

Lord Mersey:
Look at this, Mr. Haight. Is that your information?

Mr. Haight:
Yes, my Lord.

Lord Mersey:
Look at this, Mr. Aspinall.

Mr. Aspinall:
My Lord, may that be filed?

Lord Mersey:
Yes.

(Diagram filed and marked Exhibit No. 20.)

Lord Mersey:
I am going to ask you to make us another. Give Mr. Reid the pad again. Now, Mr. Reid, as I understand, the stem of the Storstad, driven in at this angle, remained in the side of the Empress without going along the side of the Empress either towards the stern or towards the stem, but somehow or other - you call it wriggling - it got out. Can you show us on that other piece of paper the angle at which these two ships were when they parted?
- (Witness). That is a very difficult thing to do at all accurately, my Lord.

7424. Do the best you can. I want your idea of what was happening to these ships during the short space of time the stem of the Storstad was inside the hull of the Empress.
- May I explain that with the two vessels together, the Storstad in the Empress, when the Storstad comes to rest it has almost hooked itself into this gap. The stem has turned over and it has gone in behind the rolled over plating and up the side of the gap and there is a hook action there. It is small on a ship of that size but it exists. Just when, as the Storstad swung away from the Empress and widened the angle between them, that hook action let go so as to allow the Storstad to get away is a very difficult thing to determine.

7425. Put the Empress in the same position that you have put her on the other piece of paper and then imagine what is the alteration of her position. Now put the Storstad in the position in which you believe she was when she unhooked herself from the vitals of the Empress?
- I imagine that if we allow a swing of about something like 100 degrees from the original position to the position at which she departed we are right.

7426. Well then put it in and show us.
- This is the original position and this is the position at which she departed. It is very difficult to get the exact point where she left (witness indicated on piece of paper).

7427. Where will you put the stem of the Empress?
- Here; this is the initial position of the stem of the Empress.

7428. No, the Empress.
- Oh, the Empress; this is the Empress here (indicating) .

7429. How have you got her stem?
- Here. Here is the original position of the Storstad at 45 degrees of the centre line of the Empress and here is the swing.

7430. The Storstad struck the Empress on the starboard side.
- Well, we will have to put the stem here and the stern there.

7431. Make the drawing again. (Witness made another drawing) and submitted it to Lord Mersey.)
- An angle of 3 in about 100 degrees.

7432. Then you think when she got clear there was nothing to prevent the Storstad backing staight away into the sea?
- There would still be a tendency to continue her swing.

7433. She would then swing out entirely. This picture shows us the stem of the Storstad still inside. What I really wanted was the position of the two ships when the Storstad first got quite clear of the Empress.
- That was not my understanding of your Lordship’s wish.

7434. I want, first, the position at the moment of impact and then I want the position at the time they parted: Here you show the Storstad still with her nose inside the Empress.
- I am giving you that point at which she was free in a way.

7435. There was the hooking operation inside of the Empress?
- Correct.

7436. And then there was nothing to prevent the Storstad from swinging right out into the sea.
- That is correct.

7437. And clear of the Empress - that is the meaning of it. Let that be marked. (Drawing filed and marked exhibit No. 21.)
- I have dealt with the extent of this penetration.

7438. I think very clearly.
- I wish now to say that I have had a little opportunity to measure that penetration from the side of the Empress square inwards and that to the best of my belief it does not exceed 8 to 10 feet from the shell plating of the Empress square inwards. I have got an angle of 40 degrees for the initial blow upon the Empress’ side measured -

7439. You mean, of course, measuring straight inwards from the shell of the Empress at right angles?
- That is correct.

7440. You say that any damage would not exceed 8 to 10 feet measuring at right angles from the shell of the Empress?
- That is my belief. I find an angle of 40 degrees for the initial blow measured between the centre line of the vertical plane of this ship and the vertical line of the centre plane of the Empress. Lower down I find contacts at a lesser angle - as low as 30 degrees - measured in the same way, which I attribute to the fact that as the boat hit so high up as she crashed into the Empress she still continued on her course but careened to a slight extent and this lesser angle would bring this side of the Storstad into contact with the Empress. Otherwise, she could not have reached No. 5 bulkhead at all; she could not havet touched it.

7441. As you, in your opinion, believe she did?
- We did touch it, I think.

7441J. No. 5 bulkhead is between the two boiler spaces?
- That is correct.

7442. And if you injured it even to the comparatively small extent that you suppose, it would have had the effect of destroying that bulkhead as a watertight bulkhead?
- I do not like the word destroying.

7443. What I mean to say is that it would no longer act as a watertight bulkhead?
- It might be deformed by our contact, but it was so light that I do not see how it could have injured, its watertight character.

7444. In your opinion, was there no breach between the two boiler compartments?
- I do not see how there could have been that breach with the contact that we had with the bulkhead.

7445. You know you have told me that the indication was very slight, but I assume that though it was slight, nevertheless it destroyed that bulkhead as a watertight bulkhead?
- No, I do not think so.

7446. Is your view that only one compartment of the Empress was at first flooded?
- The water entered one compartment at first only.

7447. And never flooded through any opening made by the Storstad between the two boiler spaces?
- That is my belief.

7448. Assuming that she was built so that she would float with any two compartments full of water, if you are right and there was only one compartment full of water - you agree that there would be only one?
- There would be one.

7449. There would be only one full of water and the remainder must have come in through the portholes that were left open?
-

 

By Sir Adolphe Routhier:

 

7450. Had the Empress inflicted some damage on the Storstad?
- Yes, my Lord. You see it on the large photographs. It might be described as a vertical mark.

 

By Lord Mersey:

 

7451. That is your suggesion?
- Yes, your Lordship.

Lord Mersey:
Speaking for myself, I think I understand it. Do you want to ask any further questions, Mr. Haight?

 

By Mr. Haight:

 

7452. Will you be good enough now, if the court will permit, to refer to the various photographs, not as mathematically accurate, but as showing approximately the marks on the decks and the other traces which you have described more accurately. Run through each exhibit in turn, Mr. Reid, beginning with ‘ F-8.'
- I would rather go backwards and begin with Exhibit '7-F.'

7453. The last photograph?
- Yes. This (referring to 7-F) is the starboard bow of the Storstad. You see the broken hawsepipe snapped through the middle of its mouth. That was doue by this anchor.

 

By Lord Mersey:

 

7454. I do not quite see in this photograph the hawsepipe?
- This is a fragment of the mouth of the hawsepipe and the anchor was hanging against that and smashed it. Going down one strake of plating from the hawsepipe you find a horizontal score very prominent from the bent, in side of the bow going aft of the anchor.

7455. Where?
- At this point. Just under the strake of the plating you find a horizontal score. This is the main deck of the Empress. The other decks are shown very faintly at their corresponding distances from that deck and there is the mark of the bulkhead at this point here.

7456. What is it on this photograph?
- It is that vertical line.

7457. Is there anything- in the appearance of this vertical line on the starboard side of the Storstad which would convey to you an idea of the extent and character of the damage done to No. 5 bulkhead?
- Yes.

7458. What is it?
- It is the fact that the trace of the contact is faint. The end of the bulkhead is an exceedingly strong thing, it is supported by very heavy angle bars and violent contact would have marked our vessel much more prominently - equally prominently with the deck - and there is only a trace of it.

7459. Did you ever see such a thing before?
- I never examined such a proposition before.

7460. I understand you to say: I saw a mark on the side of the ship which is faint and therefore it was made, in my opinion, by a bulkhead, but I say that the blow upon the bulkhead did not destroy its character as a water-tight bulkhead. Is that what you say?
- That is my belief.

7461. I suppose it does not require any engineer to verify that?
- Anybody looking at this photograph would say that this is a very faint trace of such a powerful piece of material to be left upon the Storstad.

 

By Chief Justice McLeod:

 

7462. You come to that conclusion because you do not see any sufficient evidence on the stem of the Storstad that it broke that bulkhead?
- I do not.

 

By Lord Mersey:

 

7463. You say that it struck the bulkhead but you believe it did not break it?
- The side of the Storstad struck the bulkhead but did not break it. Exhibit m E ” is simply the same photograph from a slightly different standpoint.

 

By Mr. Haight:

 

7464. Please show the trace of the deck on the Empress. It is a clearer print than the others.

(Photograph Exhibit ‘E* shown to the Court).

 

By Lord Mersey:

 

7465. Where is the perpendicular line of No. 5 bulkhead?
- It is not shown on that photograph.

7466. Why not?
- Because the photograph has been taken from a different point and it does not appear.

7467. Does not the photograph include the part on which the perpendicular line was visible?
- No, it is not in that photograph.

7468. Are these photographs taken on the same scale?
- They are fairly on the same scale but I found it quite impossible to scale them except in the neighborhood of the stem where the Storstad's actual draught marks are still shown, but one can get an approximation of distances.

7469. You cannot tell us from these photographs how far the vertical line that you say marks the line of the impact with No. 5 bulkhead, was from the stem?
- I can get an approximation to it.

7470. Can you tell from the first photograph?
- About 16 feet, not from the face of the stem but from the bend.

7471. What bend?
- This bend here; this is the edge of the bend that the stem took. I am not measuring from the face of the stem because that is around the corner.

7472. How far is it towards the stern from the point you can see on the photograph?
- About 16 feet.

7473. Take photograph ‘E’ and tell me to what extent the photograph shows the starboard side of the Storstad from the stem towards the stern?
- It is about three-quarters of that.

7474. What is the next?
- Exhibit ‘D.' That indicates the contact of these decks but I wish particularly to refer to this indication of the striking of this pad which is shown on the port bow just below the second strake of plating going down from the deck.

7475. Then let us come to ‘C'?
- ‘C’ only shows this peculiar hooking of the bow. It shows the port side with the bay which I referred to.

7476. I should think that this is a photograph that might be very deceptive.
- Yes, that photograph is very deceptive; it is quite useless for practical purposes.

7477. Now ‘B’.
- ‘B’ shows the nature of the displacement of the port anchor, the driving of it into the centre of the vessel and also the traces of these various decks. They are quite faint.

7478. What is “A”?
- “A” shows practically the same view but indicates rather more clearly the fact that our upper deck space further back was not very much deformed nor very far back.

7479. I see some boards hanging from the stem of the Storstad. Are they attempting to repair the stem?
- No, these boards were put up so that we could make measurements.

7480. They were put up for your convenience?
- Yes.

 

By Mr. Haight:

 

7481. Do any of the photographs show the imprint of the dead light you spoke of?
- They are very faint. The dead light is seen but it is extremely faint.

 

By Lord Mersey:

 

7482. Where is that?
- On the port side. You get it on the first photograph. May I point it out?

7483. Yes, do.
- That is it in there; it is rather hidden by the shadow line.

Lord Mersey:
To my mind, these photographs are no good whatever.

Mr. Haight:
It is very hard to get the ship into court and so some photographs are better than nothing.

Lord Mersey:
In my opinion Mr. Reid’s plan is of far more value than the photographs.

 

By Mr. Haight:

 

7485. Will you please sum up, Mr. Reid, your final conclusions as to the angle of initial contact?
- 40 degrees.

7486. Second, as to the extent of penetration inboard?
- 8 feet to 10 feet from the side of the Empress measured at right angles.

7487. Third, as to the probable movement of the two vessels after they came in contact and before they separated?
- Relative to the Empress, the Storstad appears to have swung to about 100 degrees and then cleared.

7488. Are you able to form a judgment as to what caused the Storstad to swing around so much?
- It is not easy to form an absolute judgment, but I consider that the Empress must have had a motion through the water when struck.

 

By Lord Mersey:

 

7489. Are you able to form any opinion as to the rapidity of the movement?
- Of the Empress?

7490. Yes.
- No, I do not care to make any estimate particularly.

 

By Mr. Haight:

 

7491. Have you, Mr. Reid, examined the plans of the Empress particularly in reference to the shape of her stern?
- Certain of the plans which we obtained do show the form of the stern, but they do not enable me to make any conclusions or any estimate of an exact nature.

7492. Do the plans which you have examined give you an idea that her stern is, or is not, moulded as the stern of a vessel of that character is ordinarily built to-day or was built when she was originally constructed?
- I consider that the stern at certain draughts is much fuller than usual.

7493. Mr. Hillhouse yesterday admitted that the lines were fuller but could not give any further definite statement as to how much fuller. Can you give us a general idea as to how much fuller they are?
- No, I cannot give you any figures, which would be the only way to indicate the extent of this increased fullness.

7494. As I understand, the increased fullness beginning with the beam of the ship towards the stern at certain draughts is greater than you ordinarily find?
- That is correct.

7495. What effect does the fullness of the hull of the vessel at that point have upon her rudder?
- It is very apt to cause a drag which would interfere with the efficiency of the rudder.

7496. What do you mean by a drag?
- The water on the sides does not flow naturally to the rudder.

7497. Naturally it should flow how?
- So as not to cause any eddying or wake - eddies in which the rudder acts.

7498. And being full how does it flow?
- I cannot tell you how the water flows.

7499. You mean that fullness tends to cause eddies?
- Perfectly.

7500. From your knowledge of the designing and building of ships, and the study and examination of such plans as you have had, state in your judgment what effect the fullness of the Empress would be likely to have upon her steering. Are you able to say whether with lines such as that she would or would not be a well steering vessel?
- I simply say that she would not be a good steering vessel by the fact that it is a matter of common knowledge that she did not steer well.

 

By Lord Mersey:

 

7501. What do you say?
- It comes to one’s knowledge - one familiar with these ships - that they were defective in their steering qualities.

7502. Will you tell me the facts upon which you rely when you state that as your conclusion?
- I have looked repeatedly at the model of this vessel and I have noticed this extreme fullness which is very unusual in a boat of that height and speed. I judged that there might be this difficulty in steering her from the fact that the water would not flow evenly and naturally towards the rudder. One also realizes that these boats have been on the dry dock and their rudders changed.

7503. When did you get to know that?
- I had put these two things together and I had judged that if this design was efficient in steering they would not have taken steps to make the change.

7504. These are the only facts?
- These are the only facts.

7505. I had rather judged that you were relying on some reports which you had seen to the effect that this was not a good steering vessel. You base your opinion on this admitted fullness at the stern?
- Correct.

7506. Which means as I understand the breadth of the stern. Then you say further that at one time that had to be corrected by an increase of the area of the rudder. I do not know, but I ask you would that improve her steering qualities?
- Yes.

7507. Therefore, she would be a better steering ship at the time she sank than she was when she first put out to sea?
- I expect that was so.

7508. But nevertheless, you say, judging from the plans, that she was not a good steering ship?
- That is correct. I find the rudder very small.

7509. Do you think that the rudder was not sufficiently large after the alteration?
- I have only had access to the plans which were taken from the working drawings of the ship and I expect that these plans do not show the addition to the rudder.

7510. Of course they do not because the addition to the rudder had not been made when those plans were drawn.
- It is the only plan I have had access to.

7511. Therefore, you do not know what the additional area of the rudder is?
- I have seen the figures which Mr. Hillhouse has given us.

7512. Is it, in your opinion, not sufficient?
- I think the area is still small.

7513. Did you ever know Mr. Elgar?
- I did.

7514. Was he not a very highly skilled man?
- The very highest in that line.

7515. A person whose judgment on a matter of this kind would be entitled to great weight?
- Absolutely.

 

By Mr. Haight:

 

7516. Was the moulding of the stern of the Empress a departure when she was originally designed?
- It was a departure.

7517. According to your knowledge of ship-building and designing have the ideas which were first tried in the designing of the Empress been subsequently made general use of?
- No, the Empresses had rather peculiar sterns which were not followed later although the same effects have been got in.

7518. Having obtained the same effects, just what has the difference been in the moulding?
- That would take quite a long time to explain.

7519. Roughly. You say the same effects have been obtained. I want to know how much the present moulding that gives you the same effects differs from the Empress?
- Simply they have carried all the stern lines of the ship much farther.

 

By Lord Mersey:

 

7520. That is what I understood you to say already?
- Not exactly.

7521. You have not said it in the same words but in effect already.
- No. This is relating to the nature of the arrangement of the sterns of the newer ships which has enabled us to get the same effects that they got in the Empress.

7522. What is the effect? Is the effect to increase the carrying capacity of the ship?
- This was not the intention primarily.

7523. What was the intention?
- The intention was to get in that complicated bossing arrangement in connection with the steering gear. They desired to get space for it and therefore they carried the lines out in order to get that space.

7524. I do not understand that. The object of this fullness is to find accommodation for the steering gear? Now, you say this telemotor - is it not?
- We are coming to that, I should say.

7525. I dare say we shall; but it was the telemotor -
- No, it was the main steam-steering gear.

7526. You say that they could not manage to accommodate this steam-steering gear in the later built ships without having this extra fullness?
- They have this extra fullness but they carry the fullness up to the deck and that is what is called the cruiser type of steamer.

7527. You have this extra fullness on the cruiser type of ship?
- Yes.

7528. But you think it does not work in in exactly the same position?
- (No answer.)

7529. Even to the present day?
- Especially at the present day.

7530. What was there wrong about this fullness that seems to exist in the cruisers still and which exists still in the Empress?
- They have greatly increased the area of the rudders in the cruiser, type.

7531. Then you do not object to the fullness, but you think that if there is fullness there ought to be a much greater area of rudder?
- That is correct.

7532. And if there is a much greater area of rudder this fullness does not matter?
- It neutralizes the thing, sir.

7533. If there is a sufficient area of rudder her steering will be all right and the only complaint I understand you have against the Empress is that her increased area of rudder was not sufficient?
- That is about so.

7534. That is really so; that is your only complaint?
- That is correct.

7535. Do you know how much they did increase the area of the rudder?
- I saw the figures this morning but I did not commit them to memory. They were handed to us by Mr. Hillhouse.

7536. Can you tell us what was the area of the rudder?
- No, I cannot give you absolute information on the subject.

7537. Then why did you say the area of this rudder that you do not carry in your head and which you are not prepared?
- You asked for the two areas. I have got one all right but I have not got the addition in my mind.

7538. If you have not got the figures in your mind why should you express the opinion that it is not sufficient?
- Because we have the percentages of the model area.

7539. Have you the percentage in yotur mind?
- I haven’t it in my mind.

7540. If you have not got the percentages of the areas in your mind how can you express an opinion?
- Because I made a study of it this morning before I came here.

7541. Where is the study; let us see it.
- It is on a piece of paper.

7542. Well, let us see the piece of paper.
-

7543. Mr. Haight: The original memorandum which Mr. Hillhouse was good enough to hand me this morning I left on my table and I have misplaced it. I asked Mr. Hillhouse to write out exactly the same figures on another scrap log. These are the figures (Mr. Haight handed witness a piece of paper).
- (Witness). Square feet of old rudder 185; new rudder 227; percentage - that is the percentage of the immersed vertical plane of the ship to the water line - 1.25 per cent; new rudder 1.53 per cent.

 

By Lord Mersey:

 

7544. That is 1½ per cent?
- Practically.

7545. Well?
- I should expect larger percentages.

7546. You think that percentage is not large enough?
- That is my opinion.

7547. Are there any technical works that show what the percentage ought to be?
- There are statements in one or two technical publications on this subject.

7548. Can you tell me what they are?
- I think that Sir William White’s work refers to it and there is also McCarrow’s work.

7549. Take Sir William White; what does he say?
- I would have to get the book to give it to you.

7550. Do you not remember it?
- No.

7551. You would not pass an examination?
- It is some time since I did, your Lordship.

 

By Mr. Haight:

 

7552. What, in your judgment, shofuld approximately be the percentage of rudder to the immersed plane of a vessel like the Empress considering the formation of her stern?
- Not less than two per cent.

 

By Lord Mersey:

 

7553. That is a very serious difference. It ought to have been one-third larger than it was?
- That is correct.

7554. You think Mr. Elgar made a mistake, and a worse mistake, because Mr. Elgar designed it before the alteration was made?
- That is correct.

7555. I suppose that you claim that it is apparent that there was a mistake when they changed it?
- That is what I believe.

 

By Mr. Haight:

 

7556. Do you know what is the average percentage of rudder area of the cruiser type which is more or less similar in shape at the stem?
- When I referred to cruiser sterns I did not refer to the sterns of cruisers, but I referred to the type called by that name.

7557. What is the average percentage on the cruiser type of vessel?
- On the latest vessels we have been getting 2.4 per cent.

7558. Mr. Keid, will you please state, from your knowledge of the telemotor system, what is meant, as far as the efficiency of the system is concerned, by the loss of fluid in the pipes of the system?
- Of leakage?

7559. What would be the effect on the efficiency of the system of leakage?
- Intermittent working; I should expect intermittent working of the steering valve.

7560. The quartermaster of the Empress, on cross-examination, said that sometimes when he put his wheel over on the Empress her head would not swing, then, after putting his wheel back again to amidships and putting it over the same way a second time, she would swing; would such behaviour indicate anything to you as to the condition of the system?
- A discontinuity of the fluid in the connecting pipes, I should imagine.

7561. What, from your knowledge of the system, would be the result of any possible obstruction in the pipes?
- A total breakdown.

7562. Lord Mersey: Mr. Aspinall, do you think yo ucould finish with Mr. Reid in a quarter of an hour?

Mr. Aspinall:
I might have if it had not been that Mr. Reid has made these suggestions about our rudders and matters of that sort.

Lord Mersey:
I am not going to ask you to finish in a quarter of an hour.

7563. I have been asked to put this question to you, Mr. Reid: Would the stem of the Storstad swing and describe a 100 degree angle if her screw was going full speed astern?
- No, it would not.

7564. Would it tend in that direction?
- Yes, absolutely.

 

By Mr. Aspinall:

 

7565. Mr. Reid, I gathered from what you have told us that you have been for some years practising on this side of the Atlantic?
- Both sides.

7566. Before?
- I am practising still on both sides.

7567. For how many years have you been practising on this side?
- I have been practising ten years on this side.

7568. What is the biggest ship you have designed in this practice?
- I have not designed big ships on this side.

7569. I asked you what was the biggest. You have not designed big ships. Is your practice in tug boats?
- Not exclusively.

7570. A good deal in tug boats?
- Quite a good deal.

7571. In what other class of craft have you been engaged?
- Large dredges and cargo vessels for the lakes.

7572. I want you to tell me which is the largest cargo vessel for the lakes that you have been interested in.
- I have constructed up to 260 feet long on the lakes; that is the biggest.

7573. That is the class of work that you have been engaged in?
- Partly.

7574. Do you ever give evidence in the Courts and act the part of what we sometimes call in England the professional witness - the expert witness?
- I do not; not for twelve years.

7575. You used to do so?
- Occasionally.

757G. You used to do it in England? I do not think I have had the pleasure of meeting you in the Admiralty Court.
- I never had that pleasure but, I have been before his Lordship.

7577. Not twelve years ago?
-

 

By Lord Mersey:

 

7578. Were you a witness before me?
- Yes, your Lordsship.

 

By Mr. Aspinall:

 

7579. Not in the Admiralty Court?
- On a salvage proposition.

7580. I shall not pursue that because I know how long ago it was that we lost Lord Mersey in the Admiralty Court. However, that is another matter. Does your experience lead you to this conclusion that unless you have the two ships left so that you can see the damage done to them any conclusions which you can draw from one ship alone are very unreliable?
- Will you kindly repeat that question?

7581. Assuming that two ships have been in collision, that one is lost, that only one ship is left, and that you only have an opportunity of seeing the damage suffered by that ship, does not that give you very limited data to enable you to arrive at any certain conclusions?
- Not in this case.

7582. This is a peculiar case?
- A very peculiar case.

7583. But my proposition, I repeat, is an accurate one; you want to see the damage done to both to enable you to draw any safe conclusion?
- It helps very materially.

7584. This, for some reason, you say, is a very peculiar case?
- That is correct.

7585. And in this case I suppose your proposition is that you are expected to draw safe conclusions?
- Within the limits of accuracy I would look for.

7586. Within what?
- That I would look for; that I would wish for.

7587. We want the whole of it; we do not want you to limit it in any way. I do not quite appreciate what you mean by the last answer: Within the limits of accuracy I would look for.
- You cannot make measurements as to inches and come to conclusions as to what has actually happened, but you can get a general idea.

7588. Your meaning is that you are giving a general idea?
- That is correct.

7589. I want to deal with this particular viewpoint of giving a general idea. I want to be sure what your views are in regard to the Storstad. You spoke of the Storstad crushing into the Empress. That was one phrase and when his Lordship spoke of a wriggling motion you used this phrase “when the Storstad comes to rest.” Is it your view that the Storstad drove herself into the side of the Empress?
- It is.

7590. Do you appreciate my question?
- I think I get the drift.

7591. I want your view; I want more than the drift of it. It is a plain question.
- It is a plain question. I have given you the answer.

Lord Mersey:
I understand Mr. Aspinall’s question perhaps in a different way from what you understand it. I may be understanding Mr. Aspinall’s question in a different sense from that which you understand it and I want you to be very careful about your answer. Mr. Aspinall, will you put that question again?

 

By Mr. Aspinall:

 

7593. Was it your opinion that the Storstad drove herself into the side of the Empress?
- She did.

7504. I pass away from the Storstad and I am now going to the Empress.
- May I make an explanation for a moment, your Lordship?

Lord Mersey:
Certainly.

Witness:
I stated that this contact was a mutual affair, that the Storstad drove herself into the Empress and that the Empress drove herself into the Storstad.

 

By Lord Mersey:

 

7595. No she did not. The Empress might have made a hole in the Storstad, but she did not drive herself in?
- She drove her decks into our side.

7596. She drove her decks against your side -
- And inwards.

7597. Do you mean to say that the decks of the Empress penetrated the Storstad?
- They gripped hold and pushed in.

7598. They gripped hold of the Storstad but they did not drive themselves in?
- They cut in.

7599. Now I understand you to qualify a little what you said just now.
- That is correct.

7600. Mr. Aspinall asked you if the Storstad drove herself into the Empress?
- That is correct.

7601. You say: Yes she did?
- That is correct.

7602. Now I understand you to say that the Empress contributed to that by going herself up against the stem of the Storstad?
- Up against the starboard bow of the Storstad.

7603. But your answer, as I understand, involves the idea that the Storstad was moving in the direction of the the side of the Empress at the time of contact?
- That is correct.

 

By Chief Justice McLeod:

 

7604. Do I understand you to mean that both vessels were moving?
- That is my idea.

 

By Mr. Aspinall:

 

7605. What he said in regard to the Empress was that it is impossible for him to form any opinion as to the speed at which the Empress was travelling?
- (Witness) I do not care to make any estimate on that point.

7606. It is impossible to do that?
- That is correct.

7607. I want to pass away from the Storstad and I want to hear what are your reasons for coming to the conclusion that the Empress had headway upon her?
-

Lord Mersey:
We will rise now.