Mr. R. Vigers, late President of the Surveyors' Institute, stated that sites and structures can be valued separately, if the building is suitably situated, but he pointed out the difficulty where this is not the case. He thought, however, that such a system is not advisable, as it would involve a double valuation, and lead to expense and friction.

Mr. H. A. Hunt thought that it would be very difficult to value sites separately, and very expensive. He stated that in making valuations he never divides site from structure.

Moulton, 23,018-21,and Vol. IV. of Min. of Ev., App. No. X., par. 7.

Costelloe,

20,057-62,

20,068,

20,205,

20,221-32,

20,292-9

Rickman, 21,161-87, 21,197-200, and Vol. IV. of Min. of Ev., App. No. II., par. 28. Harper, 22,300-3, and Vol. IV. of Min. of Ev., App. No. VII., par. 1, C. (ii.). Vigers,

19,500-4, 19,532-8, 19,609-10, 19,620-5

H. A. Hunt,

20,991

Mr. Rickman pointed out that each site would have to be valued separately, and that it would be very difficult to deal with the case of restrictive covenants and varying rights of adjoining owners.

Mr. Sabin, who expressed no opinion as to policy, thought that it is possible to make such a valuation, and worth while for the purpose of correctly ascertaining the proper amount of deductions to allow. The question of valuation, he said, was only a matter of skill.

But Mr. Sabin pointed out that "difficulties would arise where the ground rent of a leasehold was relatively large, and represented a first charge on the building, and not merely the value of the bare land. In such a case, the freeholder - if he were the party in receipt of the full ground rent - would desire not to be assessed on the whole annual sum reserved under the lease, while the lessee would hold that the whole was site value. Such disputes would be reduced in proportion to the closeness of the definition adopted. Other difficulties would arise which definition would not so readily avoid; as, where the capabilities of the site were not easily determinable; where the concurrence of two or more freeholders might be necessary to secure the best use; and where rights of adjoining properties to light and air might be undeterminable quantities."

Mr. Sabin would disregard all restrictive covenants. Site value, according to his definition, should be the bare value of the land, independent of either restrictions or conditions as to expenditure of money. The value "is one which a speculative lessee might give with the intention of getting a profit by the creation of an improved rent, or, in other words, the value which a purchaser or a lessee would consider it worth, with a free hand as to the buildings to be erected. The usual course is to require a lessee to expend a certain sum of money, and then to secure a ground rent on the land, plus an interest in the building which is erected, which building gives a security for the ground rent. I suggest instead that, if you take the bare value, you may treat it as worth so much capital money, and taking the ordinary rate of interest, 3 or 3 1/2 per cent., upon that, you get a site value for rating purposes, which is less than the ground rent which could be screwed out of a lessee who is required to spend money."

H. A. Hunt, 21,010, 21.014-9, 21,031, 21,088-91, and Vol. IV. of Min. of Ev., App. No. I., pars. 3, 4,

Rickman, 21,188-92, 21,195-6, 21,262,

21,334,43, and Vol. IV. of Min. of Ev., App. No. II., par. 28. Sabin, 21,358, 21,367,21,384, 21,481,21,495,

21,547-8, 21.562,

21,573. Sabin, Vol. IV. of Min. of Ev., App. No. III., par. 4.

Sabin, Vol. IV. of Min. of Ev., App. No. III., par. ib.

Sabin, 21,423-6.

Sabin, 21,426.

Mr. Cross, Surveyor and Valuer, of Manchester, thought that, though it would not be actually impossible to put a separate figure upon the value of a site, it would be extremely difficult; that it was not really a proposal which could be put into actual practice, and in any event that it would not be worth while owing to the cost. He drew attention to the difficulties of dealing with restrictive covenants and questions of rights of light, etc., and also to the expense involved in employing valuers, instead of simply taking the rent as the basis for valuation. He also pointed out that the valuer would have to take into account, not only the actual use to which the land is now put, but the use to which it might be put.

Mr. Wainwright. Architect and Surveyor, of Liverpool, expressed the opinion that, though it was not impossible to value site and structure separately, it would be a very difficult matter.

Mr. Mathews, Land Agent and Surveyor, of Birmingham, thought that though it was possible to put a separate value on site, it was not practicable, as it would involve an enquiry into the most productive use the land could be put to. He also thought that the proposed system would give rise to endless litigation. Mr. Mathews says: "All rates are levied on the occupier, and assessed on the rateable value of the hereditament, i.e., on the gross value, the rent which the occupier pays (or would pay, assuming the rates to be paid by him, and the cost of repairs by the landlord), less the average annual amount of such repairs, and the gross value is determined by the site value and the builder's interest on his expenditure.

"The assessment is simplified when an actual rent is paid, for then there is no necessity for a separate valuation of the site and building. If such a separation in the rate book is to be made essential, the trouble and expense of the general assessment would be very greatly increased, for every site must be measured and valued, every building must be measured and valued, and the actual rent then apportioned between the site and the building.

Cross,

21,586, 21,651-64, 21,665-7, 21,693-705,

21,757. 21,794, 21,801