The Valuation of Public Service Corporation Property: Transactions of the American Society of Civil Engineers,; vol. LXXII, June, 1911, ASCE 1190Riggs, Henry Earle
General
The Valuation of Public Service Corporation Property: Transactions of the American Society of Civil Engineers,; vol. LXXII, June, 1911, ASCE 1190
Second. That the basis for computing a fair rate is the fair
value of the property, which must be arrived at by a
computation or series of computations taking into account
many different factors.
Third. That while the Court mentions certain things that may
serve as indices of value, which are to be taken into
account and given due weight, the Court does not outline or
define any method of arriving at a value, but does recognize
it as an embarrassing question.
Fourth. That no such stress has been laid by the Court on
original cost as has been construed by some appraisers.
The principles enunciated in Smyth _vs._ Ames are reiterated by the
Court in San Diego Land Company _vs._ National City (174 U. S., 739),
with the further ruling:
"The contention of the appellant in the present case is that, in
ascertaining what are just rates, the Court should take into
consideration the cost of its plant; the cost per annum of operating
the plant, including interest paid on money borrowed and reasonably
necessary to be used in constructing the same; the annual
depreciation of the plant from natural causes resulting from its
use; and a fair profit to the Company over and above such charges
for its services in supplying the water to consumers, either by way
of interest on the money it has expended for the public use, or upon
some other fair and equitable basis. Undoubtedly, all these matters
ought to be taken into consideration and such weight given them,
when rates are being fixed, as under all the circumstances will be
just to the company and to the public. The basis of calculation
suggested by the appellant is, however, defective in not requiring
the real value of the property and the fair value in themselves of
the services rendered to be taken into consideration. What the
company is entitled to demand, in order that it may have just
compensation, is a fair return upon the reasonable value of the
property at the time it is being used for the public. The property
may have cost more than it ought to have cost, and its outstanding
bonds for money borrowed, and which went into the plant, may be in
excess of the real value of the property. So that it cannot be said
that the amount of such bonds should in every case control the
question of rates, although it may be an element in the inquiry as
to what is, all the circumstances considered, just to both the
company and the public."
In the case of Columbus Southern Railway _vs._ Wright (151 U. S., 479),
the Court quotes approvingly from Franklin Company _vs._ Railroad (12
Lea (Tenn.), 521-537-538-539), and shows that the doctrine quoted had
already been enunciated by the Supreme Court in the State Railroad Tax
Cases (92 U. S., 575-607). The Court quotes as follows:
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