Taxation of Land Values in Practice

Joseph Hyder: The Case for Land Nationalisation
Chapter XVII: Taxation of Land Values in Practice


New Zealand

AS long ago as 1878 New Zealand imposed a State Land Tax, but it was repealed thirteen months later. In 1891 the Government again imposed a Land Tax of 1d. in the £1, and in 1893 it exempted improvements altogether. Owners whose unimproved land was worth less than £500 were exempted, and an extra rate was charged on those whose land was worth more than £5,000, the object of the tax being not only to secure revenue but to break up the big estates. Ten years later, the rate upon those estates was increased, and again still further increased in 1907, and heavy special taxes were levied upon lands held by absentees. And this was the result: 

It will be seen that the number of the big estates has only been reduced by 23 per cent., that the unimproved value per acre has gone up from £1 11s. 1d. to £1 19s. 5d., and that the average unimproved value of each holding has only declined from £46,565 to £45,481. It is true that the total acreage has been reduced by 3,135,660 acres, but of this reduction nearly one-third is due to the State acquisition of land, and only two-thirds to the operation of the Land Tax. And when we look at other figures we find the following interesting and significant facts: 

In the face of such facts it can hardly be claimed that the State Land Tax, heavily graduated though it has been against the monopolists of big areas, has achieved a very pronounced success. 

But, besides the State Tax, all the municipal authorities in New Zealand have, since 1896, had the power to levy their rates solely upon unimproved land values, and more than half the total of the local rates of New Zealand are now raised in that way, no exemptions being allowed. It is usually spoken of as a great success, and the prosperity of New Zealand is attributed by land-taxers to this and to the State Land Tax, as if there were no other contributing factors. The latter was denounced in the most extravagant terms when it was introduced, as “punitive,” “absolutely ferocious,” “grossly tyrannical,” “vindictive,” ” crushing,” and “murderous.” Time showed that it was none of these things (except in a minority of cases), owing to the peculiar conditions of New Zealand as a new country with the unearned increment growing faster than the tax, and to the consequent power of the landlords (speaking generally) to recover in increased rent what they had to pay to the State. In an old country like ours the unearned increment grows more slowly. And just as the fears of its enemies were not realised (except in individual cases), so also were the hopes of its friends disappointed. For both had left out of account the growth of the unearned increment, and the capitalised value of the exemption of buildings from rates, which enabled the taxed landlords to recoup themselves in one direction for their loss in another. 

Much has been made by special pleaders of the New Zealand revival of trade and increase of population from immigration during the last twenty years. Truly they have been remarkable. But how have the taxed landlords fared? 

Improvements to the value of £50,000,000 have been placed on the land between 1891 and 1909. But the value of the land, apart from all improvements, has risen by no less than £81,000,000 in the same time, and this in spite of the State Land Tax, and the local rating (in half the municipalities) of nothing but land values. 

Thus the industry of the whole people in a time of booming trade has produced new labour values to the amount of £50,000,000. And it has in the same period produced £81,000,000 in new unearned land values for the owners of the soil. 

The total national and municipal levy upon land value is even now only one million pounds, or only one-eightieth part of the unearned increment of the last eighteen years alone. If the land had been nationalised with fair purchase at the value of twenty years ago, the unearned increment would by now have gone a long way towards paying for it. 

Now, one of the chief arguments employed in advocating the taxation of land values is that it would cheapen land, and it is obvious that it actually has that effect in the case of some land. But the example of New Zealand proves most conclusively that it does not have that effect upon land as a whole. 

In Wellington every farthing of the local rates is levied upon land. And this is what the Secretary for Labour in Mr. Seddon’s Government wrote in 1904: 

“There has been no fair ratio between the rise in wages and the rise in prices. The fact is that there is a third hand in the game besides the employer and the employee, and it is this third man, the non-producing ground landlord of city and suburban property, who alone will rise a winner in the end. 

“The chief devourer of the wages of the worker and of the profits of the employer is excessive rent. That an equitable payment for the use of land and dwellings should be made to their owners is, under the present constitution of society, proper and desirable; but a greedy, rack-renting system, which transfers gradually almost the whole earnings of the industrial and commercial classes to the pockets of the non-producer, is indefensible. It partakes of three characters; it is unauthorised taxation by private persons, it is tribute to a conqueror, and ransom of a captive. 

“In Wellington the rents have not only increased during the last ten years, but they have acquired an utter disproportion to earnings. It is difficult for a clerk or foreman at £250 a year to get a decent house near the city under £1 l0s. a week, which means about one-third of his income. A labourer earning (taking wet days, illness, etc.) on an average £1 l0s. a week must pay at least l0s. or 12s. a week for a house; he, too, then, finds that a roof over his head costs one-third of his income. This may be accepted as a general rule in the capital city – viz., one third of the income goes to the landlord.” 

Similarly, Mr. Seddon, the Prime Minister, declared, shortly before his death, in 1906, that “up to the present the labour laws of New Zealand have benefited one class only, and that the landlord class.” And this despite a drastic policy of land taxation. In further proof of the fact that the transfer of rates from buildings to land values raises rent, the testimony may be here cited of the head of the Land and Income Tax Department at Wellington. He says: “The exemption of improvements leads to increase of capital value, and increase of unimproved value as surely follows increase of capital value; there are very rare exceptions to this rule.” And this, as will presently be shown, is the experience elsewhere. 


In Queensland the local rates have been levied on land values since 1890. The advocates of the new system predicted, just as they do here, that it would produce “the gradual extinction of the capital value of freehold land.” That prediction has been completely falsified. Indeed, so firmly is the system established that it is now taken for granted, and is regarded as non-contentious by the landlords themselves, although many of them “felt the strain severely, especially during the bad times” (videthe Memorandum by Mr. Leslie Gordon Corrie, ex-Mayor of Brisbane, printed in Blue Book Cd. 4750). 

Mr. Corrie is a very emphatic and exceptionally well-informed advocate of that system, and his Memorandum is very illuminating. He says that it resulted in “the immediate appreciation of the capital value of existing improvements owing to the sweeping away of so much of the hereditary burden of taxation from this class of property.” In other words, the landlords (or at any rate most of them) got back with one hand what they gave up with the other. And, again, he says: “That the rates raised thus from the land are spent again locally, it is believed largely to the enhancement of the land, doubtless carries with it the acceptance of what would otherwise be far from a popular mode of raising revenue.” He then goes on to say that, although the system has so far met with little objection, “manifestly there is a limit to the burden which will be accepted upon any single class of property.” As might have been expected, the landlords are quite willing that all rates should be levied upon land values so long as it does not hurt them, but they are not likely to acquiesce in any extension of the system which would seriously endanger their interests. The example of Queensland is therefore not calculated to recommend it to any one who really desires to abolish private property in land in the home country. 

South Australia

In South Australia the unimproved value of land has been taxed for State purposes since 1885. The amount was 1d. in the £, and it remains at that figure now after a lapse of nearly thirty years, a further 1d. in the £ being levied on estates worth more than £5,000, and an additional tax of 20 per cent. being imposed on absentees. So, evidently, there is no burning desire in that country to tax landlordism to extinction. Mr. Arthur Searcy, the Deputy Commissioner of Taxes at Adelaide, reports that “for years past there has been a gradual closing up of all vacant land round the city, a great deal of which may be attributed to the land tax, more particularly since the application of additional and absentee land taxes in conjunction with the increased rates of income tax imposed at the same time; but much of the movement would have occurred irrespective of taxation, with the gradual growth and advancement of the State. … To show that an all-round taxation is not a dominant factor in regard to values, witness the recent great rise in value of country lands throughout the State with the introduction of improved methods of agriculture, and more especially artificial manures; the values now being as high or higher than before taxation was introduced.” 

The Federal Land Tax In Australia

The evil of great estates in Australia was so serious that the Labour party made the breaking of them up by taxation the chief plank in their programme, and as soon as they got into power they passed an Act, which was aimed specially at those great amalgamations. The result seems to be exactly what it was in New Zealand – a decrease in the size of the largest estates, but no serious weakening of the land monopoly, and an increase in the number of people who have a stake in it to defend. 

The Second Annual Report of the Commissioner of Land Tax, printed on August 14, 1913, shows that the tax forced £11,500,000 worth of land out of the taxable held in the first year, £9,000,000 worth in the second, and only £2,000,000 worth in the first nine months of the year that has not yet closed. The Commissioner reports that a great part of the reduction in the total assessed value of the great estates is due to the completion of schemes of apportionment of joint owners and families who previously were jointly taxable, and, further, that the persistence of good seasons has made it easy for the landowners to hold the land in spite of the tax, and that, even where the burden was felt, they were willing to pay rather than break up holdings which they have owned for many years and to which they have a sentimental attachment. 

New York

For many years land values have been taxed in New York. Mr. Lawson Purdy, President of the Department of Taxes and Assessments, says that “all real estate is assessed or valued at market value.” Land is not taxed on its rent, and exempted if it is unused, as with us; but it is taxed on what it is worth if sold, and, since 1904, the value of land has been separated from the value of buildings. The rate varies, according to local needs, audit is now 1.6140; that is, a piece of land worth $10,000 has to pay $161 40c., whether it is used or not. This is about eight times as much as the undeveloped land-tax of our own 1909-10 Budget. Yet it does not appear to have a very marked effect in cheapening land, for nowhere is land so dear as in New York; or in effectively checking land speculation, for that is still a very popular means of “getting rich quick”; or in reducing overcrowding, for there are slums in New York, and many thousands of sunless rooms, such as would not be tolerated in London for a day. The landlords seem, in fact, to thrive in spite of the taxation of land values, and land is so dear that they have to economise the valuable space by building up into the skies. 

The impossibility of generally cheapening land by taxation, or of preventing the landlord from reaping a very large share of the unearned increment, is manifest from the Report of Mr. Purdy. He says: “Where values are rising so fast that property is resold within the year for twice the amount of the first sale, it is evidently impossible for the assessments to keep pace. In some parts of the city it would be necessary to assess every three months, in times of rapid increase of value, in order to keep the assessments close to the actual selling price.” 

The late Mr. Pierpont Morgan was reported to have paid the enormous sum of £200 a square foot for the site of his new offices, and the total value of all the buildings in New York is considerably less than the value of the land they occupy. Evidently something much stronger and more direct than the taxation of land values will have to be done before the New York landlord can be extinguished. 


And now we come to that wonderful country, Canada, which is cited more frequently than any other by single-taxers as evidence of the virtue of their gospel. For in Canada there are cities, which have adopted the single-tax theory so far as their local revenues are concerned. Let us, therefore, see what has happened there. 

“Vancouver, the metropolis of the Province of British Columbia, is indeed a city set upon a hill, whose light cannot be hid – a beacon to guide the municipalities of the world into the haven of righteousness in raising public revenues.” In these glowing terms was commenced the May-June 1911 issue of the Single Tax Reviewof New York, which was specially devoted to the marvellous growth of Vancouver, due, it was claimed, almost entirely to its fiscal system of raising its revenues from land values and exempting all improvements. 

America is noted for the cities which, figuratively speaking, spring up in a night. But none are so marvellous as Vancouver. In 1885 its present site was a dense forest with mammoth cedars and firs towering two and three hundred feet high. Today there is a city of 180,000 people. 

During the spring of 1886 it was reported that the Canadian Pacific Railway would plant its western terminus there. That was the beginning. Streets were planned, the population rapidly increased, and buildings were put up as fast as the labour and the materials could be got together. Up to 1895 improvements were rated as they are in England. Then for ten years they benefited by a 50 per cent. exemption. For the next four years they were relieved by a 75 per cent. exemption, and in 1910 they were exempted altogether. 

We have already seen that the exemption of improvements from taxation has had the effect in New Zealand and Queensland of raising the value of land. Exactly the same thing has taken place in Vancouver, as it was bound to do, and as it would do in England under a similar system. 

The single-taxer points to the enormous activity of the building trade in Vancouver, and attributes it to the taxation of land values. But, admitting that it may be partly due to that cause, it is surely asking too much to ask us to believe that it is the chief cause, still less the only cause. No matter what the fiscal system had been, the growth of Vancouver would have been phenomenal, as the new terminus of one of the greatest of all existing railway systems, and in view of the wonderful opening out of that great new country, which has been attracting settlers from all parts of the world. Even under the old system of rating its population nearly trebled in the four years from 1887 to 1891, and it only doubled in the next ten years, although for the second half of that period all improvements were exempted from local rates, to the extent of 50 per cent. of their value. It must also be remembered that in Hastings Townsite, which lay outside the city, and which levied its rates on the old plan, “the building activity,” according to the Single Tax Commissioner himself, “kept pace with that of the outer districts of the city.” 

The following figures enable us to see at a glance the leading features of the marvellous progress of Vancouver. 

According to Mr. Francis Neilson, a single-tax M.P., writing in the Single Tax Review(March-April 1913), the population has since grown to 175,426, and the value of land to $138,000,000. He does not state the present value of improvements, but, if the same ratio obtains, they are now worth about $53,000,000. 

It is obvious that there has been tremendous building activity, but it is also obvious that the activity of the land-speculators is even greater. Their offices are as thick on the ground as public-houses in a seaport, and the tax on land values has no more effect upon them than water on a duck’s back. The unearned increment of one year alone was $28,000,000, and their total contribution to the rates was less than $1,600,000. Under such circumstances it is quite plain that the Vancouver system of rating is powerless to abolish landlordism. 

But, says the single-taxer, this merely shows that the tax is not heavy enough. Make it 20s. in the £, and the whole difficulty would vanish. Of course it would, but there is no chance of it. The landlords are quite willing to be taxed, but they are not willing to be taxed out. They would be more than human if they were. 

It must be remembered that 75 per cent. of the artisans themselves are landlords, and sharers of the unearned increment. The assessments of land are notoriously low, even to the extent of being only one-third of the true value, according to Mr. Joseph Fels. And the rate of the tax has remained unaltered since it was first imposed. The city has found its present revenue insufficient for the carrying out of great public improvements, but instead of giving a turn to the taxation screw, by increasing the assessments or by raising the rate, they have actually had to borrow money just as other municipalities do. The reason is that the local opposition is too great to the landlords being taxed to any greater extent than they are now. If Vancouver were under a single-tax Dictatorship the thing could be done. On paper it is quite simple. But as it can only be done with the consent of the electors themselves, the majority of whom are landlords, we find that as a matter of fact it is so difficult as to be practically impossible. 

Mr. Taylor, the single-tax Mayor of Vancouver, says that “the landowners receive greater benefits from the single tax than even the builders and building owners themselves.” Of course this will not be regarded as a disadvantage by those who see no wrong in private property in land, but it is simply astounding that the Vancouver system should be recommended for adoption here by any man as a means of abolishing private property in land. Whatever other good effects it may have, that is the very last that can be claimed for it. 

And now let us take the example of one more Canadian city, the City of Edmonton, which entirely exempts buildings from rates, and taxes land values only. It was incorporated as a city in 1904, when its population was only 7,000. In seven years its population increased fourfold, and its site was valued at $27,521,000.[1]In 1900 the trustees of the First Presbyterian Church purchased three lots on Jasper Avenue, of a total frontage of 160 feet by 150 feet in depth. They gave $1,200 for the three lots. In 1911 they sold 30 feet of frontage for nearly six times what they gave for the whole site seven years before; they borrowed $80,000 on what was left, for the building of a church; and they have since actually refused an offer of $1,250 a foot for the 130 feet, or more per foot than they gave eleven years before for the whole 160 feet. Another plot was assessed at $8,000 in 1905, and in 1911 it was assessed at $67,460. And, as showing that the same undervaluing of land exists at Edmonton as at Vancouver, a plot, which was assessed at $50,000, was sold for $75,000. 

The exemption of improvements acts, of course, as a great incentive to industry, and has the same effect as a new invention. But, so long as land is private property, a very large part of the improvement, if not the whole of it, is bound to express itself in land values. And, where the unearned increment grows at such a phenomenal rate as it does in the cases cited, the landlords can afford to snap their fingers at the futile efforts of single-taxers to foster a system of taxing land values only in order to extinguish the private appropriation of them. If the land were public property everything would be altered. The unearned increment would then come to the right place, the public exchequer.

 The present criticism is not directed against a fair and reasonable measure of taxation of land values, nor even against a policy of exempting improvements from rating. For the first is necessary in order to arrive at the true value upon which the land may be equitably and profitably acquired by the community whenever it decides to resume the control of ownership for itself, to whom alone it rightfully belongs. And the second may be established as soon as that public control of land is obtained. 

As has been already stated, it is not supposed that exactly the same results would happen in an old country like our own, as have happened in the new countries, which have been above referred to. Those results would not be the same, but they would be similar. The only difference would be one of degree, not of kind. 

Until the national valuation of land is completed no certain figures are known. But it is not difficult to take hypothetical and typical cases, and to observe the effects of altering the rating system while leaving private property in land untouched. 

At present we rate upon the income derived from land and improvements together. As there is no income from unlet land such land is not rated at all. And building land, which is let temporarily for farm or garden purposes, pays rates on a low annual income, instead of on its high capital value. Further, it is treated as agricultural land and pays only half the rates levied upon other property. 

Only annual values now appear in the rate-book. The proposal is that the capital value of the land alone should be rated, and that all improvement values should be ignored.

Let us suppose that the valuation has been completed in a given urban district. 

In the centre of the town the value of the land is high by comparison with the buildings on it. As we go towards the suburbs it decreases. In the centre the land, even when fully developed, may be worth more than the buildings. In the suburbs the buildings are worth much more than the land. Besides the fully-developed land there is the under-developed land and the undeveloped land. On the former kind the improvements are worth much less than the land, and on the latter they arc nonexistent. This varying ratio of land values and improvement values is most important to bear in mind. 

In our hypothetical town, a fully-developed site worth £10,000 carries buildings worth £5,000. Another site, worth the same amount, carries buildings worth £10,000. Another £10,000 worth of land carries £15,000 in buildings, and so on, till, in the suburbs, a site worth £10,000 may carry buildings worth £50,000. All these are fully developed. Then there is a valuable site, worth £10,000, which is not put to its best use, and carries poor buildings, worth only £5,000. The land-taxer would make the owner pay as much as if he had much superior buildings on it, and so cause the pulling down of the old fabric and the building of a finer structure more suitable to the site. 

Again, there is a site, worth £10,000, which is quite vacant, yielding no income to its owner and no rates to the local authority. 

Lastly, there are 100 acres of land, worth £50,000, which is only let for farm purposes, at £2 an acre, and pays half rates on that sum as agricultural land. 

The several kinds of property are represented in the above table. For the sake of convenience fractions are dropped. 

First, let us assume that landlords are unable to shift a land tax to their tenants; an assumption which is contrary to the teachings of Henry George himself (Progress and Poverty, Book vi., Section I), and which is completely disproved by Australian and American experience. In that case the tenants who now pay £6,181 would be entirely relieved of that amount, and it would fall entirely upon their ground landlords. And, as the total capital value of their land is £170,000 if put to its best use, their total income could only be £6,800 if it were all fully developed. Such a flagrant case of robbing Peter to pay Paul could hardly be exceeded by the worst exactions of the landlords themselves in the heyday of their power, and it needs only to be stated to be condemned. 

But the truth of the matter is, of course, that the landlords in most cases, although not in all, could shift the burden to their tenants. The relief the tenants expected would not be actualised, and in proportion as their rates were reduced their rents could and would be raised. They would pay no less than they pay now, but the sum total would be differently composed; it being immaterial to them whether they pay (say) £40 as rent, and £20 as rates, or £60 as rent and nothing as rates. 

The only check upon the landlords’ power to shift the burden would be the effect which the taxation of land values would have in increasing the available supply of land by forcing withheld land into use. To the extent that it did that, the above figures would have to be modified. But, although it would have a certain tendency in the direction of lowering some rents (a tendency which is usually very much exaggerated by its advocates), this would be more than counterbalanced by other tendencies, which would make for the increasing of land and property values as a whole. The hope that rents would be generally lowered in consequence of the taxation of land values is not encouraged either by a consideration of abstract economic theories or by the observation of the land tax in practice in other countries. 

In further reference to the power of landlords to increase rent on account of reductions in rates, the case of the Agricultural Tenants (Rating Relief) Act of 1896 may be cited. That measure was strenuously opposed at the time on the ground that it would really act as a bonus to the landlords although it was ostensibly designed as intended for the farmers. Now, if that criticism was sound, it applies with much greater force to the proposal now under consideration. If the landlords could intercept for themselves the remission of half the rates upon agricultural land, what is there to prevent them from intercepting for themselves the proposed remission of all rates upon both agricultural and building land together? 

There remains a further objection to the taxation of land values when put forward as a means, and the only infallible one, of abolishing private property in land. It is favoured by many on account of its supposed drastic character. It appears to them to be an easy way of getting the land or its value without payment. Land reformers of this type oppose compensation as the con-donation of a great injustice inflicted upon the people. They profess to take their stand on high principle. They will not compromise with the evil thing. Yet even they are driven to compromise when they propose, as all of them do, to take only a part of the land values at first, although proclaiming that it would be quite equitable to take them all at once if only they had the power. 

Such men always assume that it would be quite easy to keep on turning the taxation screw when once it has been inserted. The experience of Australia and America ought to have taught them better. For, in proportion as landlords are numerous, they are strong. And it cannot be too strongly insisted upon that the very first application of the taxation of land values has the effect of increasing the number of landlords. 

The feature of British landlordism that makes the strongest impression on men’s minds is the prevalence of great estates, and the avowed object of a land tax is to make the landlords put them on the market so that they may be cut up. In so far as this policy succeeds, it results in a multiplying of landlords. It is true that they are taxed, and their holdings are smaller, but a little landlord has all the instincts of a big one. 

Now, it is the desire of the Conservative party to multiply freeholders by State-aided purchase, avowedly in order to strengthen the institution of private property in land by giving more people an interest in its maintenance and defence. The taxation of land values produces exactly the same result. The motives and methods of the two policies are diametrically opposed, but their immediate effects in that important respect are absolutely identical. And as the one is avowedly reactionary, so also is the other. 

We have seen how powerful the land system is when the land is held by only a small minority of the people. But it might easily become practically invulnerable if landlords were to become as numerous as they would be under either the Conservative policy or that of the single-taxers. The land monopoly in Ireland is immeasurably stronger now than it was before the Ashbourne and subsequent Land Purchase Acts. Consequently, the forcing of land upon the market would have to be supplemented with a large general power of public land acquisition, or, otherwise, it would only create fresh obstacles to the recovery of its land rights by the community as a whole. 

But, says the single-taxer, public ownership does not matter; let the landlord have the shell of ownership, we will take the kernel, the value, by progressive taxation. Easier said than done. It would be impossible, in the face of a greatly-increased, compact, and solidly organised body of landlords. For the taxation of land values increases the powers that resist change, and, by the redress of the most obvious grievances, reduces those, which demand it and work for it. 

For these reasons it offers no hope of success. It is as plausible as Protection, and as misleading. It is big with fair-seeming promises, which it can never fulfil. It offers a short cut, but it is not even the longest way round, for it doesn’t get to the goal at all. It is not a thoroughfare, but a blind alley. Its road would be blocked by an impassable barrier of a new landlordism far more powerful than the old one, and produced by the very process that was designed with the ostensible object of sweeping landlordism away altogether. The motives don’t count; the results do. 

Honesty, after all, is the best policy in this as in all things. The attempt to get either the land or its value without recognising the legitimate interests, which the State has allowed to take root and establish themselves is foredoomed to ignominious failure. It is as unfair in its intention as it is likely to prove futile in its operation. It is the broad and easy road that leads to disappointment and destruction. 

If ever the nation is to gain possession of its own land it will have to take the straight and narrow path of justice, and act towards landlords as all civilised Governments always do whenever they determine to take over any property, which they have previously sanctioned and recognised by their laws. While, however, the taxation of land values is both inequitable and futile when it is designed as a means of extinguishing private property in land, it would be both just and effective if levied in moderation, for it would tend to prick the inflated values which arc now placed upon undeveloped land, and which act as a serious check upon industry. And in giving compensation for land on the basis of the net rent received by the landlords, plus prospective values where such exist, the amount of such taxation would have to be taken into consideration. For, obviously, the net income from land is the gross income from it, less, not only all expenses of management, but also all taxation to which it happens to be subject at the time it is taken over by the state. 

[1]Since writing the above, the City of Edmonton has raised £909,700 by 5 per cent. Sterling Bonds, and it states that the gross assessment of its land alone is now (October 1913) £41,745,612, while total value of its property, which is exempt from taxation, is £2,932,148. The extraordinary difference between the value of the property of the land-speculators and that of the land-improvers is worthy of special attention. Further, its forty-one millions’ worth of land is only taxed to yield £410,900. Instead of raising the tax on the land it prefers to raise money by borrowing, and this seems to show that, while the landlords of Edmonton are quite willing to pay all the taxes and exempt all the buildings, they are never likely to support a tax that really hurt them. Human nature is much the same in England.