Cross, 21,662.

Wainwright, 21,877-83, and Vol. IV. of Min. of Ev,, App. No. V., par. 10.

Mathews, 22,094-101, 22,116-18, 22,122, and Vol. IV. of Min. of Ev., App. No. VI., par. 17.

Mathews, Vol. IV. of Min. of Ev., App. No. VI., par. 17.

"When no actual rent is paid, as when the builder is himself the occupier, then, unless the rent can be readily determined by comparison with adjacent rented buildings of the same kind, the valuer necessarily estimates it by a separate valuation of the site and building.

"Rent actually paid is a matter of fact, rent estimated or apportioned is a matter of opinion which is always disputable, and opinions will differ most widely on the value of the most valuable lands in and near the centre of large cities entirely covered with buildings. It is here that the site value is in itself most difficult to estimate, apart from the building, and is often complicated by claims of light or other easements made by adjoining and opposite owners.

"If, therefore, the site and building values are to be stated separately in the rate book with the object of assessing some person other than the occupier, then, even if the occupier agrees to the rate as a whole, both portions of it would be open to dispute by the person to be assessed on the site, and an increase in the number of objections and appeals would necessarily result."

Mr. F. W. Hunt, Architect, Agent, and Surveyor, of London, also stated that, though a separate valuation of site is possible, the proposal is not a practical one. To arrive at the value of a site, he says, "is a matter upon which we should differ very much indeed." "The friction and the annoyance in settling it would cause more difficulty than benefit" ... "I think that the only rateable value of land is the beneficial occupation - what is its use, and what is its value, having regard to its present use."

F. W. Hunt, 22,546, 22,549, 22,571, and Vol. IV. of Min. of Ev., App. No. VIII.,pars. 11,

12, 13, 17, 24

Sir A. De Bock Porter, Secretary to the Ecclesiastical Commissioners, stated that it would be possible to make a separate valuation of sites, but pointed out the difficulty of dealing with restrictive covenants and easements, the expense and friction involved, which, he thought, would be out of proportion to the advantage gained. It would, however, he said, be impossible to estimate the possibilities of the site; only the existing value in relation to the existing tenement as a whole could be properly valued. "When the site is put to its best possible use, then the Local Authority would get its share of the value which would accrue from the letting on the improved method."

Sir A. De Bock Porter proceeded to say: - "When the building is first erected, six per cent. on its selling value added to the value of the site would approximately equal the value of the premises as a whole, but when, from the house becoming unsuitable, or other causes, the value of the premises become greatly reduced, how is it possible to determine the relative depreciations in the building and site ? Moreover,where the value of property has greatly depreciated, the argument of the 'unearned increment,' by which it is sought to justify the tax, can have no possible application, for, if the tax should ever be established, it would be impossible to discriminate between improving districts and others. It has been urged, where such decrements have occurred, the site value should be considered to be the rent which the land would produce if the buildings were removed, and the land were used to the best advantage; and, in support of this view, it has been alleged that the landowner would find it advantageous to buy up the lessee's interest with this object. But it is only in extreme cases that the landowner would gain by adopting this course. Generally, there would be a sufficient profit rental remaining to preclude purchase with advantage. In all such cases the annual value of the site could only be determined with reference to existing uses. It has been suggested that in such circumstances the tax would have reference to capital value, instead of annual value, but the former would be no more realisable than the latter."

R.L.V. F

De Bock Porter, 22,722, 22,755-68, and Vol. IV. of Min. of Ev., App. No. IX., par. 11.

Mr. Sargant generally supports Sir A. De Bock Porter's views, and considers that the building and the site are inseparably united and form one whole. He says: - "I think there is always the difficulty of finding what the site value is, and I think that would be particularly the case if you are to estimate the site value, not in relation to its value as occupied by the building now standing on it, but in relation to the rent that might be obtained for it, if it were cleared and applied to some hypothetical purpose."

Opinions differ considerably on the question of what it would cost to make a separate valuation of sites.

Mr. Harper, Principal Statistical Officer of the London County Council, when he was examined on the first occasion by the Commission, stated, on an estimate made on the spur of the moment, that he expected that the ascertainment of the site value of London in any given quinquennial epoch once begun and started would cost less than 25,000l. Mr. Harper subsequently wrote to the Commission as follows: "I think an assessment of each separate site in the County of London, if carried out by expert surveyors - not necessarily of the most eminent rank - would probably cost 40,000l., if it had to be done under conditions similar to those governing the present quinquennial assessment. This is exclusive of any cost of litigation which might arise out of the valuation."

Subsequently Mr. Harper reviewed this estimate in the light of the first Report of the Commission which had since been published, and concluded that professional surveyors appointed as permanent salaried officials could prepare a site valuation for London at a cost not exceeding 25,000l., or rather less than 1s. apiece, beyond the ordinary expenditure upon valuation. This figure would not include the cost of appeals, but he thought that these would only amount to about five per cent. of the total.

Sir John Barton, Commissioner of Valuation in Ireland, stated that, in his experience, the cost of making a separate valuation of sites is not great.

Sargant, 23,365, and Vol. IV. of Min. of Ev., App. No. XI., par. 23 (4). Parliamentary Paper C. 9528 of 1899, p. 216. Bastable, ibid., p. 143. Price, ibid., p. 185. Blunden,ibid., p. 194.

Lord Farrer, ibid., p. 82.

Harper, 12,594-6.

Harper, 12.595-6. 12,601, 22,249-52, 22,253-60, 22,466, and Vol. IV. of Min. of Ev., App. No. VII., pars. 2-7.

Barton, 27.381.

Mr. Sabin put the cost of valuation, apart from the cost of litigation, at considerably higher than 40,000l. if the work was done by experts. The initial cost, he said, would be large, but the subsequent valuations would be moderate. The cost might be, he thought, 3d. in the on the site value of London.

Mr. Sabin added that the disputes would cause an increase in the total number of objections and appeals.

Mr. Cross pointed out that an independent survey and valuation of every separate property would have to be made and that the expense would be "very enormous" and that it would not be worth while to do it.

Mr. H. A. Hunt said it would probably cost several millions to value the sites in London if experts were employed. He also expressed the opinion that the cost of the litigation might come to as much as the primary valuation if it were indifferently done.

Mr. Wainwright asserted that it would be impossible to value sites at 1s. apiece, and that the valuation of half a million houses would cost over two millions.