*556Dissenting Opinion by
Judge Rogers :I respectfully dissent. In my view the Third Class County Assessment Law, Act of June 26, 1931, P.L. 1379, as amended, 72 P.S. §§5342-5350 supplies, a wholly adequate statutory remedy for these taxpayers’ complaint that their properties have not been uniformly assessed by the Board of Assessments of Berks County. Indeed in Long v. Kistler, 524 F. Supp. 225 (1981), these plaintiffs brought this same cause' to the federal court and their complaint was dismissed as barred by the Tax Injunction Act, 28 U.S.C.A. §1341 because in the judgment of that court the Third Class County Assessment Law afforded the plaintiffs a “plain, speedy and efficient” remedy for their complaint that their properties were not assessed uniformly with other properties in their school taxing district. A panel of the Third Circuit Court of Appeals which upheld the dismissal by a district court of the suit of other Berks County taxpayers questioning their assessments exhaustively reviewed the provisions of the Third Class County Assessment Law and recited in support of the court’s holding that the Law afforded a “plain, speedy and efficient remedy” for a claim of nonuniform assessment: that appeals to the board might be taken singly or by class action; that priority is given to assessment appeals taken to common pleas; that the right to de novo court review is allowed; and that the common pleas is directed to determine the uniform ratio used in the district, to order the application of that rate to the market value of the appellants ’ properties and to make changes in the assessment “as may be right and proper.” Garrett v. Bamford, 582 F.2d 810 (1978).
Nor does the Pennsylvania case law support the decisión of the majority that equity has jurisdiction to *557decide these claims of mere unequal assessments. A court sitting in equity has jurisdiction to decide a broad constitutional challenge to the validity of taxing statutes, including assessment statutes. It has no jurisdiction to decide the claims of improper assessments of individual properties. Borough of Green Tree v. Board of Property Assessment, 459 Pa. 268, 328 A.2d 819 (1974); Rochester & Pittsburgh Coal Company v. Indiana County Board of Assessment & Revision, 438 Pa. 506, 266 A.2d 78 (1970) ; Lynch v. Owen J. Roberts School District, 430 Pa. 461, 244 A.2d 1 (1968).
I do not agree that the Berks County Assessment Board and the Court of Common Pleas of Berks County are at a disadvantage to review the procedures and conclusions of the State Tax Equalization Board. Indeed, Boards of Assessment are required to “accomplish equalization with other properties within the taxing district.” Section 1 of the Third Class County Assessment Law, 72 P.S. §5344. On appeal, the court of common pleas is required to “determine from the evidence submitted at the hearing, what ratio of assessed value to actual value was used generally in the taxing district, and . . . direct the application of the ratio so found to the value of the property which is the subject matter of the appeal, and such shall be the assessment.” Section 9 of the Third Class Assessment Law, 72 P.S. §5350.
Finally, it seems to the writer that this litigation can be more efficiently and conveniently disposed of before the Berks County Assessment Board and on appeal by the common pleas court of that county. The board has expertise and is in possession of the records of assessments in the taxing district and the common pleas court has knowledge of local conditions not possessed by this essentially appellate court.