82. We make this recommendation on two grounds, first in order to relieve the Main Board of the work of looking after these rivers and so leave them free to concentrate their efforts on the improvement of the tidal channel, and secondly in order to meet a strongly expressed desire on the part of many witnesses from the South Level that there should be an independent body in the South Level corresponding somewhat to the Middle Level Commissioners on the West.

83. The Board proposed for the South Level would not supersede any of the existing Internal Drainage Authorities, which would remain undisturbed throughout the whole of the Ousc Drainage District and its expenditure should be charged uniformly over the whole of its area. The right bank of the Wissey would form the northern boundary of the area and it would include all the lands south of that boundary which drain into any of the tributaries below Hermitage Sluice. As the right bank of the Wissey is a bank which protects the land beyond it, it would be reasonable that the Internal Drainage Authority of the area protected should make some annual payment to the South Level Board, the amount to be settled either by the Ministry or by agreement. On similar grounds, it would be reasonable that the portion of the land lying between the Hundred Foot River and the Old West and Ten Mile River which drains into the Hundred Foot River should make a contribution to the maintenance of the western bank of the Old West and Ten Mile River.

84. The Ouse Drainage Board should be given some general powers of control throughout their area, including the power of vetoing the execution of works which may affect the tidal channels until the works recommended above are completed.

6. AREAS BENEFITED BY WORKS AND PROPOSALS FOR RATING.

85. In Chapter 2 of this Report we dealt in detail with the works which we regard essential to place the river in a proper condition and to ensure against an otherwise inevitable inundation In accordance with our terms of reference we have carefully considered the question of the areas benefited, and whether any or all of those works can be said to be likely to prove of greater benefit to one area of the district than to another. We are satisfied that the lowering of the low-water level, which is bound to follow from the works recommended, will facilitate the emptying of channels draining into the tidal river and will therefore be of benefit in providing a greater storage for flood water during the periods when tidal sluices are closed. As this lowering would take place throughout the entire length of the tidal river, benefit would, in our opinion, be afforded wherever the drainage of the lands discharges through channels whose inverts are now below low-water level. Moreover, all areas which depend on the exclusion of tidal water would be benefited by the improvement of the

sides and banks of the tidal channel and the consequent reduction. of the risk of inundation.

86. In the circumstances we are unable to see how a differentiation of rating in respect of these works could be justified, and we recommend that, in so far as it may not be met by an Exchequer contribution or otherwise, the cost of these works should be defrayed by means of a flat rate levied throughout the whole of the Ouse Drainage District, as we propose that it should be defined.

7. THE BASIS OF ASSESSMENT FOR DRAINAGE RATES.

87. Section 4 of the Land Drainage Act, 1918, gives to Drainage Boards, &c., the option of levying rates on the lands liable to be rated by them either on the basis of acreage or on the basis of annual value. The Ouse Drainage Board, following the practice customary amongst the Drainage Authorities of the Fen area, adopted the basis of acreage. Rates levied on this basis are obviously a much greater burden on the owners and occupiers of poor land than of good land, and inasmuch as the values of agricultural land in this district differ widely, it is not surprising that we have heard a good deal about the inability of the poor lands to bear any further burdens.

88. We have discussed the question of the relative advantages of the two systems with a great many of our witnesses. They usually have admitted that the basis of annual value is the fairer, but nevertheless we find a good deal of disinclination to adopt that basis in place of the basis of acreage. Part of this is probably due to a natural unwillingness to change a system with which the ratepayers and the Drainage Authorities have become familiarised. One argument put forward is that it costs as much to drain the poor land as the rich, and that there is no reason why one man should pay for the drainage of another man's land. Another argument used by some witnesses against an assessment on annual value is that the poor land benefits by drainage to a greater extent than does the good land. If this be so, an increased assessment must follow improvement in bad areas, resulting in an increased contribution. It has also been alleged to us on various occasions that the methods of assessment adopted by the Assessment Committees of neighbouring Unions differ so widely that the Poor Law assessments are very far from being on a uniform basis, and consequently that they would not be a fair basis for drainage rates. How far this is well founded we are not able to say, but we should doubt whether the variations between the practice of valuation in different Unions would produce anything like the unfairness of burden entailed by an acreage rate. At any rate, if the Valuation Bill now before Parliament becomes law, much of the difficulty caused by the variation in methods of rating in various Unions will, we hope, be removed.

89. Even those who advocate the continuance of the system. of rating on acreage were impressed with the hardship of the burden on poor lands. One witness proposed that land rented at less than £1 an acre should be entitled to a rebate on a sliding scale. Others have suggested that "poor lands" should receive some relief, though they have not precisely indicated what is to be the definition of "poor lands," nor how the relief is to be afforded. We consider that the adoption of such a classification of lands would be a difficult, costly and lengthy proceeding.

90. We were given a number of instances in which the charges on the land were so great that it could not be kept cultivated. In one case we were informed that a ratepayer who was unable to pay had surrendered his land to the Drainage Authority and that the land was now derelict. The following figures relating to an estate of 2,197 acres were supplied to us. The gross rents, including sporting rights, amounted to £1005 12s. Od. The outgoings were:

In addition there was the rate of the Ouse Drainage Board amounting to £378 98. Od. Thus the two drainage rates alone exceeded the gross rents. These figures show well what a heavy burden is imposed on poor land under an acreage system of rating.

91. In addition to the example brought before us by witnesses we have, from our own inspection and tests, found that many similar examples exist to a greater or less degree, thus emphasizing the unfairness of an acreage basis of assessment.

92. Article 11 (v) of the Ouse Drainage Order, 1920, provides that, if the rates are levied on the basis of annual value, railways shall not be assessed on the basis of a higher value than that of the lands adjacent thereto, and that buildings and other hereditaments not being agricultural land shall be rated at one-third only at the rate in the £ at which the remainder of the lands in the area or sub-area are rated.

We are strongly of opinion that the rates of the Ouse Drainage Board should be levied on the basis of annual value on similar lines to the above, and we would offer the suggestion that the Internal Drainage Authorities should be given a statutory option of adopting this basis for their own areas, thus differentiating between the good and the poor lands.

8. COLLECTION OF RATES.

93. We have given much consideration to this subject. The difficulties experienced by the Ouse Drainage Board in the preparation of their rate books and the collection of their rates have been in large measure responsible for the unfortunate financial position in which they are at present placed. At the start they found themselves with a huge taxable area containing some 469,000 acres with 40,000 assessments liable to be rated, but with no machinery in existence for collecting rates. A staff had to be assembled, rate books compiled from materials which had to be collected, and many months were spent before the Board were in a position to make a demand for rates. When the demand notes were sent out, the response was very unsatisfactory. The rate was unpopular, a large proportion of the sum demanded was for administrative expenses or for works by which ratepayers did not consider themselves personally benefited, and the Board found themselves met with a large amount of passive resistance to payment. Summonses and distraint proceedings became necessary, and by these slow, unsatisfactory and expensive means some portion of the arrears on the three rates which have so far been made has been realised, but we were informed that at the end of October there was a large amount of rate still outstanding.

94. The difficulty in collecting the rates of the Ouse Drainage Board is in marked contrast with the experience of other Drainage Authorities in the District. For example, we were informed that the Middle Level Commissioners raise half-yearly rates, and do not serve demand notes on their ratepayers, but merely advertise in the local papers that a rate has been made and is payable by such-and-such a date. On the promulgation of this notice the rates flow in from the ratepayers and the amounts of arrears are quite insignificant. The experience of other

Internal Drainage Authorities is similar.

95. Many of our witnesses have expressed the opinion that the difficulties which the Ouse Drainage Board have found in collecting their rates are mainly due to the fact that they have not been given in the Order of 1920, what is known as " a penalty clause," that is to say, a clause under which, if the rates are not paid by a certain day, the amount due is automatically increased. Such a clause is found in almost all the Acts of Parliament under which the Internal Authorities of this area proceed, and we are informed. by many witnesses that, although it may be very rarely brought into operation, its existence acts as a most powerful incentive to the payment of rates. No doubt the clause is a valuable weapon. in the hands of a rate-collecting body, but we are informed that Committees of Parliament are not nowadays favourable to its insertion in Provisional Orders and Acts of Parliament. Whether it would have solved all the difficulties of the Ouse Drainage Board in the matter of rate collection is perhaps doubtful, but it would certainly have been a great assistance to them, and we

recommend that an attempt should be made to secure its inser tion in any new legislation if the Ouse Drainage Board are to continue to raise rates directly.

96. We consider, however, that a great economy of labour and expense would be gained if the Ouse Drainage Board, instead of collecting all their rates directly from their ratepayers by demand notes served upon them, were authorised to collect their rates through the agency of other rate-collecting bodies. The question arises which bodies should be asked to undertake the duty. The two alternatives seem to be (1) that the local rating authorities should do so and (2) that wherever there is an Internal Drainage Authority in existence in the area of the Ouse Drainage Board, that Authority should collect the rate, and where there is no such authority, the Ouse Drainage Board should collect the rate themselves. The former alternative would obviously be the preferable if it can be arranged. The local rating authorities cover the whole area, whereas the Internal Drainage Authorities do not entirely do so; they are solvent bodies, while some of the Internal Authorities are in difficulties with their own rate collection; and they rate lands and buildings on a basis of annual value, whilst we understand that the Internal Authorities do not rate buildings at all and rate land on an acreage basis.

97. The annual value basis upon which the drainage rate would be leviable would differ from the basis upon which the ordinary local rates would be raised, and this no doubt creates some difficulty, but it should not be insurmountable. If the Drainage Board were supplied with copies of the valuation lists or the rate books of the various parishes or parts of parishes in their district, they could enter in them the sums payable by the individual ratepayers and could send these copies so completed to the local rating authorities for them to collect the sums so entered. Subject to any provision which may be necessary with respect to railways and other exceptional properties, the net annual value shown in the valuation list of all hereditaments chargeable with drainage rates should be conclusive for the assessment of these rates.

98. Possibly some payment would have to be made by the Drainage Board to the local rating authorities. This might be settled by agreement or in default of agreement by the Ministry of Health.

99. We recommend that the new South Level Board should adopt the same method of rate assessment and collection as the Ouse Drainage Board, and it would be an economical course if the rates of the two bodies were prepared together.

(We employ the term "local rating authorities," as we observe that the Rating and Valuation Bill now before Parliament proposes to transfer from the Overseers their existing powers and duties in regard to the making, levying and collection of rates.)