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Plan No. 2.

Shows in black three sections taken from the Government Map of Victoria dated 1867 which gives the soundings all along the City. It also shows in blue the same three sections traced from the Government Sections of the Praya Recla- mation and signed by J. M. Price, dated 1st June, 1888, and further it shows in red the two sections taken by mne on 27th April last.

The first two sets of sections show that in the 21 years between 1867 and 1888 the foreshore in the neighbourhood of plaintiffs' Lot increased very conside- rably in depth.

The last set of sections taken now show that in the 8 years between 1888 and 1896 a very considerable silting up has taken place to as much in some places as 7 feet, and there must be some cause for this sudden change.

The first cause I attribute to the pressing out of the mud and silt by depo- siting the pierre perdue embankinent of the Praya wall.

That this displacement takes place is shown on all the Government sectious of the New Praya, where the pierre perdue is shown as sinking over 20 feet into the bed of the harbour, and these sections were made after careful borings had been taken. This displaced material must be deposited elsewhere and is squeezed out on both sides.

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Anyone putting their foot on a muddy road, and seeing how the mud is pressed out will at once be able to see on a very small scale what takes place when this immense mass of thousands of tons of pierre perdue is deposited on the sea bed close alongside the plaintiffs' foreshore, (within 50 feet) Govern- ment Section No. 6 of the Praya Reclamation, which is the section where the Reclamation has been stopped shows no less than 250 cubic yards or over 300 tons of material displaced for every yard of sea wall. The length of the return wall is 90 yards and taking it at the same rate something like 22,500 cubic yards or 27,000 tons of material would be displaced, half of which would be forced outward on to plaintiffs' foreshore.

The Wharf being forced up is a proof of the very large mass of material that was being displaced

The next cause is owing to the groin formed by the square end of the Praya Reclamation (see Plan No. 1).

The diagrams attached to Chadwick's report showing the result of the float experiments shows that the flow of the tide at this point is very strong and parallel to the Praya wall, it is clear therefore that any projection into the harbour which stops the flow of the tide must act as a groin, the action and use of which is well known to every Engineer. Groins are used for the purpose of reclaiming land from the sea or rivers and are projections built out of stones, wood, piles or other suitable materials and the New Praya Reclamation stopping off at right-angles to the line of the flow of the tide forms a perfect groin; no better means for the natural reclamation of the foreshore at this point could have been constructed and this silting up will continue to go on so that in a few years the corner formed by this groin will be dry land.

D 28.

PALMER & TURNER,

(Sd.)

R. K. LEIGH.

1st May, 1895.

Architects and Surveyors.

J. HOWARD, Esq.

HONGKONG, August 29th, 1895.

Dear Sir,-As requested by you, we on the 19th instant inspected the Fore- shore in front of your Godowns situated on M. Lot No. 184 West Point.

Our inspection was made at low water ordinary Spring tide at 2.57 p.m. We found that the foreshore was exposed to view taking a line from the East Boundary of Godowns 23 feet, on the West Boundary 22 feet and some 26 feet in the centre of Godowns (see sketch plan attached). The foreshore consists on the West side

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