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upon him, the executive officer must be given higher rank than that of an Executive Engineer and must be approximately on an equal footing with the Director of Public Works. The Board cannot possibly exercise any control in technical matters and their chief executive officer must have such a status as will enable him to do so.

The Commission refer in their report to the case of Singapore, but surely they must be aware that the Municipal Engineer there is an officer of high standing and is in receipt of a very high salary.

They propose to leave the control of public roads, sewers, &c. still in the hands of the Director of Public Works. This, I submit, would scarcely be practicable. Most building operations in a City like Victoria or a district like Kowloon involve interference with the public roads and the concentration which the Commission profess to aim at would not be attained by the adoption of their scheme as reference would still have to be made to the Director of Public Works in all matters affecting roads and sewers.

Again, a good many road improvement schemes have been carried out of late years which involved the resumption, in whole or in part, of lots leased to private individuals. It appears doubtful whether it would be prudent to coinmunicate such schemes to such a body as the Sanitary Board, but it is obvious that it would be almost absolutely necessary that they should be in the knowledge of the Building Authority. The same remarks apply to the resumption of Insanitary Property.

In some cases, lots are sold in undeveloped districts where no roads or sewers exist. Under the Commission's proposals, the levels in such cases must be determined by the Director of Public Works, introducing further cross reference.

From the foregoing, I think it will be gathered that the scheme put forward by the Commission, if approved, would require considerable amendment and, even then, it is doubtful whether it would attain its object.

The proposal I would submit instead of it is that the administration of practically the whole of Part III of the Ordinance should be vested in the Director of Public Works, the present reference of plans to the Medical Officer of Health, the issue of certificates by that officer and the supervision of certain items, such as concreting ground surfaces, &c. by the, officers of the Board, being abolished.

All powers of modification, except those of a technical nature, should be vested in a small Committee, consisting, say, of 5 members, including the Director of Public Works who should be Chairman. Reference to the Goverpor-in-Council should be limited to appeals from the decisions of this Committee, members of the Committee having the right of appeal in cases where a decision is the result of a majority vote.

Such an arrangement would greatly simplify the present procedure. All plans in con- formity with the Ordinance would be passed by the Director of Public Works and those in respect of which any modification was required would be considered by the Committee which would meet regularly, say, once a week.

It would be the duty of the Director of Public Works to notify the Medical Officer of Health of all modifications granted by the Committee.

All matters affecting cubicles and cock-lofts should be placed under the control of the Sanitary Board and should not come before the Building Authority in any way.

The Sanitary Inspectors should continue to inspect all buildings and should report to the Medical Officer of Health all infractions of the provisions of the Ordinance, which may come to their notice. All such reports, relating to matters other than cubicles and cock- lofts, should be passed by the Medical Officer of Health to the Building Authority for the necessary action.

Such is my proposal in outline and I believe it would be more likely to secure the objects of the Commission than the scheme put forward by them.

W. CHATHAM, Director of Public Works.

18th April, 1907.

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