circumstances, cannot be insisted on to the disadvantage of adjoining tenants and with no advantage on sanitary grounds.

By-law 3 deals with flushing cisterns to w.c.'s which are required to be of " adequate " capacity for the purposes of flushing. No content is specified; but if the L.C.C. can enforce their contention that three gallons, and not two, is the needful quantity, then, until the present water companies' regulations are amended, the "person" will be in a strait betwixt two. This by-law will tend to do away with closets of the "washout," form which, so far as my experience goes, no flush will effectually cleanse, and it is, perhaps, not beyond question whether the "valve " closet will not infringe the clause against "container or other similar fitting."

It will be noticed that the anti-syphonage pipe is required in all cases where two closets are on the same soil pipe. This, in certain cases, seems to me unreasonable and unnecessary to be insisted on.

By-law 4, dealing with soil-pipes, requires that all soilpipes to new buildings must be external. Many Members. will remember the late Mr. RYDE's experience of external soil-pipes, and his views thereon.

In the case of refitting a soil-pipe in connection with a building already existing, if impracticable to be fitted outside, it may be inside, and it is curious to see that the by-laws, so stringent in other respects, allow a cast-iron internal soil-pipe.

The regulation that the vent-pipe should in all cases be above the highest part of the roof of the building to which it is attached is unreasonable. It will result, in numberless instances, in vent-pipes being bent along the slope of roofs, thus greatly impairing their efficiency.

It would be interesting to know whether the horizontal distance of twenty feet from an open end of a soil-pipe to a window has been determined after experiment.

The provision as to wire-guard covering, to vent-pipe ends seems to preclude patent cowls, and, so far as I can judge, this is not to be regretted.

It is desirable, perhaps, to call special attention to the fact that By-laws 5, 15, 25, and 27 apply to existing waterclosets, earth-closets, privies, ashpits, cesspools, and receptacles for dung, and the accessories thereof; also that By-law 14 requires that a previous notice in writing shall be sent to the Clerk of the Sanitary Authority by every person who shall intend to construct any water-closet, earth-closet, or privy, or to fit or fix in or in connection with any water-closet, earthcloset, or privy, any apparatus, trap, or soil-pipe.

The above notes will suffice to show that these by-laws require to be carefully studied, and a perusal of the copy appended* will make it evident that the London County Council have availed themselves to the full of the powers given by Section 39.

It only remains to say a few words upon the practical application of these by-laws. How far can they, and how far are they likely to, be enforced? These are mainly lawyers' questions, and I only, therefore, tentatively suggest four points upon which it may, hereafter, be found that objections may be based.

1. That the by-laws were not made in time.

Section 142, sub-section 3, provides that the first bylaws made by the County Council or Sanitary Authority shall be submitted to the Local Government Board not later than 6 months after the commencement of the Act, therefore not later than the 1st day of July, 1892. The by-laws in question were not sealed by the L.C.C. until nearly a year after that date, and I do not remember noticing any extension of the period during which such by-laws were to be made, and should be glad of any information on the point. *See pages 303-315.

2. That all the by-laws are not within the scope of Clauses 16 and 39. For instance, can it be said that by-laws regulating the sort of top to be put to a soil-pipe extended as a vent-pipe, or the precise height to which such pipe should be carried, are by-laws with respect to "the proper accessories" of water-closets, &c. ?

3. A lawyer's point only: Do these by-laws comply with Section 114 of the Public Health (London) Act, 1891?

4. Are the by-laws all "reasonable"? If not, I take it that the same grounds under which other by-laws are held "bad" would render these inoperative.

As to how far they will be enforced. It is clear that up to the present moment they have not been generally enforced by the Sanitary Authorities. I had recently occasion to obtain the regulations of three different London Sanitary Authorities with regard to drainage, &c. In only one case did I see any reference whatever made to the L.C.C. Bylaws, nor did I gather that active interference was to be looked for if the work was generally satisfactory to the Vestry.

The London County Council can take action if the Vestry does not, and it is probable that they will bring pressure to bear upon the Sanitary Authorities, who at present, one is inclined to think, resent the interference of the Central Authority, to make them "obey orders." It is hardly likely, however, that the London County Council, with all the work before them, will concern themselves with individual cases of technical departure from the by-laws in question.

The high standard of the by-laws places a yet greater burden upon those who, as owners, fall under the liability imposed by the Act itself, especially in cases where they have no voice in, or control over, the work done, but are only called upon, when all is finished, to pay the cost.

It is quite time very serious consideration was given to

these questions arising under the Public Health (London) Act, 1891, with a view to some practicable amendment whereby a more equitable arrangement should be made for the apportionment of expenses among those interested therein and affected thereby.

C. HERBERT BEDELLS, Fellow.

SECTION II.

COMMUNICATIONS REFERRING TO PAPERS IN

THE "TRANSACTIONS," &c.

On Mr. Tom Bright's Paper on “Underwoods their Growth and Utilisation.”

("Transactions," Vol. XXV., pp. 347-368.)

In connection with this most important subject, a few notes of my own practical experience as to underwoods in Kent, may be of some interest.

The following figures show the amounts realised per acre during the past two seasons for underwood and timber, growing upon the same land, upon an estate under my management. The underwood, of 10 to 12 years' growth, was sold, standing, by auction in the month of November; and such oak trees and tellars as it was considered, for various reasons, proper and desirable to fell, were marked and sold, standing, with the lop, top, and bark, in the following spring. The sums given are net, less only sale expenses and the cost of repairing the wood and roads, and remaking the hedges.