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boroughs were subsequently issued. A petition praying for an alteration of boundaries of the Borough of Hastings was not granted. The boundaries of the boroughs of Devonport, Ngaruawahia, and Takapuna were also redefined. The boroughs of Morrinsville, Ngaruawahia, and Otaki were constituted, and petitions presented for the constitution of Avondale and Raetihi Boroughs arc still under consideration. The Borough of Miramar was united with the City of Wellington, the Borough of Spreydon with the City of Christchurch, and the Town District of Hampstead with the Borough of Ashburton. The alteration of boundaries of the City of Auckland involved the abolition of Point Chevalier Road District, a poll of ratepayers being first taken on the proposal. The Borough of Masterton, at the same time as it was altered, was divided into wards, and arrangements were made for the preparation of a district electors roll for each ward. Provision was made for the Ngaruawahia Borough Council to take over the assets and liabilities of the old Ngaruawahia Town Board, and for certain adjustments consequent upon the constitution of this borough, there being no specific provision in the Municipal Corporations Act authorizing this. Provision was subsequently made in this Act to meet such cases. The Dunedin City Council and the Green Island Borough Council reduced the number of members of their respective Councils. The Westport Borough Council adopted the system of proportional representation. The Ngaruawahia Borough Council adopted the system of rating on the unimproved value. Irregularities in connection with the alteration of boundaries of the City of Auckland and the abolition of the Point Chevalier Road District, in the polls taken on the proposals to constitute the boroughs of Morrinsville and Otaki, and in the district electors roll and supplementary district electors roll of the Borough of Hamilton were validated. In many cases irregularities such as this could be obviated if the local authorities concerned consulted this office before proceeding with the matter in hand. The Department is always ready to give advice as to the procedure to be adopted in connection with the alteration of local-governing areas and with other matters arising out of the administration of local government. Town Districts. The Cobden and Tahunanui Town Districts were constituted, and the necessary arrangements made for holding the first election and first meeting of each Board. The boundaries of the Manurewa Town District were altered; a petition was presented for the alteration of boundaries of the Manaia Town District; and the Tahuanui Town District was declared not to form part of the County of Waimea. The Hampstead Town District was amalgamated with the Borough of Ashburton. The Havelock North, Mangapapa, and Taradale Town Districts adopted the system of rating on the unimproved value. Legislation was provided authorizing the extension of the Manurewa Town District beyond the statutory two-square-miles limit. Owing to the serious financial position of the Huntly Town Board a Commission was appointed to recommend a manner in which this Board could be assisted. As a result of this Commission's report the Board was given legislative authority to convert its overdraft into a permanent loan, and its rating-powers were increased beyond the limits provided in the Town Boards Act. An adjustment of assets and liabilities was made between the Cobden Town Board and the Grey County Council as a result of the constitution of the Cobden Town District. It was subsequently found that the Town Board had no authority under which it could borrow money to meet the obligations imposed on it under the adjustment, and you have approved of a general provision being made in the Town Boards Act. The consolidation of the Municipal Corporations Act and amendments considerably affected Town Boards, inasmuch as a large portion of this Act is incorporated in the Town Boards Act. An important amendment provides that all amendments to those provisions in the Municipal Corporations Act which form also part of the Town Boards Act shall apply to Town Boards. Previously this was not the case. The Town Boards Act, however, is very obsolete, and it is recognized that it requires considerable remodelling. You have already approved of it being consolidated and amended, and this matter is now under consideration. It is very difficult to decide just where to draw the distinction between town districts and Borough Councils. The object of the Town Boards Act is to provide a means of local government for settlements which spring up in a county and become too congested for county control and yet not sufficiently large to be formed into a borough. These districts remain a part of the county until they obtain a population of 500, when there is power to declare them to cease to form part of the county. Town Boards possess a large percentage of the powers possessed by Borough Councils, but it is difficult to decide whether or not the majority of these provisions are of much value, inasmuch as a town district has neither the population nor the finance to engage in any works or undertakings on a large scale. I propose to submit later for your consideration suggestions as to the legislation which should apply to Town Boards, but meanwhile have to state that I cannot help feeling that the present method of applying portions of the Municipal Corporations Act is undesirable, as each local body should have as far as possible all its governing-powers contained in the one Act. A further matter is whether provision should not be made that a town district should be automatically declared a borough when it acquires the necessary population, in the same way as it can be at present declared not to be part of the county.

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