cils control schools and charities, which in Great Britain are under two sets of quite independent authorities, but while the German councils are in some respects subject to the board of magistrates, including the head magistrate, the burgomaster or mayor, and while the latter has other important functions, the English council has full local control within its sphere. The French municipal councils, unlike those of Germany and Great Britain, have few or no administrative powers, their control being limited chiefly to the appropriation of money and questions of policy. In the United States the councils formerly closely resembled those of Great Britain, and frequently had control of charities and of other municipal activities, but one by one many of their powers have been taken from them and bestowed on the mayor or else on independent boards. Among these boards may be mentioned water, sewerage, street, park, fire, police, and health boards, or combinations of two or more of these into a single board. Again, single-headed departments, more or less independent of the council, have been created by municipal charters or by special legislation. The financial control of some of these new bodies has been left with the city council, at least to the extent of making or withholding appropriations, and borrowing money by means of bond issues. In Great Britain and the United States the councils are restricted to the exercise of those powers specifically or impliedly authorized by the State, and implied powers are seldom so construed as to warrant permanent loans, purchase of land, erection of buildings, or other public works. On the Continent of Europe grants of municipal authority are far more general and limitations specific, but the central government exercises a general control and supervision over the municipalities unknown in the United States, and rarely if ever practiced in Great Britain. In the latter country, however, the Local Government Board, in sanitary matters, and the Board of Trade, in the case of municipal enterprises which produce revenues, pass upon loans, and by their power of granting or refusing authority for these they exercise no little control over municipal councils. The council in the United States, particularly in small cities, is generally a single-chambered body, elected by districts, but there are numerous instances of a select council, or Upper House, the members of which are frequently elected by a larger constituency than those of the Lower House, or by the city as a whole, and sometimes serving for a longer term. In England the council sits as one body, but it is composed of councilors elected by the people and of aldermen chosen by the council, usually from its own membership. (See Great Britain.) In Continental Europe there usually is but one chamber of councilors, and frequently the members are elected on a general ticket. As a rule, the councils in European countries are far larger than those in the United States, containing from 50 to 130 members, and in one case, Budapest, 400 members. In the United States, even where two chambers exist, there are rarely over 50 to 150 members, but Philadelphia is a notable exception, with nearly 200 members in both branches. The tenure of municipal councilors is from one to four years in the United States; three years for councilors and six years for aldermen in Great Britain; four years in France and Spain; five years in Italy; six years in Austria, Prussia, Hungary, Holland, Belgium; and nine years in Bavaria. In most of the European countries provision is made for periodic renewal of the council. The usual rule is renewal by thirds or halves, annually, biennially, or triennially, according to the length of the term. The most universal legal qualification for councilmen, aside from age, is residence. In America councilmen must not only reside in the city which they represent, but, by written or unwritten law, within the district which elects them. In France any taxpayer is eligible, even though not a voter, provided the number of non-resident councilmen does not exceed one-fourth the whole. In England taxpayers residing within fifteen miles of the municipality may be elected for any district thereof. Property qualifications for a portion of the members of the council are required in European countries, but in a few cities, including Dresden and Leipzig, half of the membership must be from non-property-holders. In the United States property qualifications for membership in the council were formerly quite common, but are no longer required. In all countries the work of councils is largely done by committees, and this is particularly true of those countries where the council has large powers and duties, which doubtless accounts for the large bodies in Great Britain and elsewhere in Europe. In Chicago and in most small cities the presiding officer of the council is the mayor. In other large American cities there is usually a president of the council elected by the city at large. In Europe the council usually elects its own presiding officer. Generally speaking, members of municipal councils receive no salary and frequently service is compulsory. In a number of the large cities of the United States, however, members receive pay ranging from a small per diem allowance to $2000 a year, which is the amount paid to members of the New York Council.
Executive Boards and Officers. These range from the mayor and council committees to the more or less independent boards and commissions so common in the United States, and on down to minor officials acting under these officers. The number and variety of services which these boards and officials perform has been partly indicated in the enumeration of the city's functions. In cities where the council is supreme, the committees of that body exercise large executive powers. Great reliance, however, is placed on trained executive officers selected by such committees or by the council as a whole for the various departments of municipal activity. Outside of the United States such officials are seldom chosen by popular vote, but in this country it is not uncommon to choose many of these officers by popular election. Minor positions are, of course, filled by the board concerned or by the chief executive officer responsible for the work undertaken by the appointee, rather than by popular election or by the council. The town clerk is the most important official in an English municipal corporation. Besides his duties as recording officer of the council and general secretary of the municipality, he acts as legal adviser of the council and as custodian of records. His tenure of office is frequently for life, he receives a high salary, and he is a trained official much as is the mayor of a German city. The city clerk in the United States is never an officer of such training and importance. Generally he is simply a record-
