It can be readily seen that the physical present value is not always—indeed, is not often—the "fair value." The "fair value" may be more, or less, than the present value of the physical property. It would seem to be reasonable to interpret the Court's meaning of the term "fair value" to be the value as a business or commercial property, taking into account the actual investment existing in the property, together with any favorable conditions which would enable it to earn, on rates which were fair and reasonable to the consumer, an income in excess of a usual rate of interest on the actual investment, or any unfavorable ones which under the same rates would reduce its earnings to less than usual interest. If such an interpretation be allowable, it would appear to be correct practice to use a "fair value" made up of two elements: a physical value, representing the investment, and a non-physical value, representing all the elements which affect that investment to give it favorable or unfavorable financial returns. Is it not, then, proper to conclude that the non-physical or intangible value, composed of all these various elements of value, can only be determined absolutely by a study of the earnings and operating expenses? Is not this clearly what the Court had in mind in the Nebraska Rate Case? Much of the argument on the subject of "going" values and other kindred elements of value consists of statements of theory and generalities, and may be said to be merely argument to support the theory that there is an intangible element of value. If work of valuation is to be of any real benefit, must it not give a definite result? Must not this result be based on absolute facts? In securing the present value of any physical property the fixed and certain facts are: The inventory of property owned.—This is absolute. The cost of reproduction of the different elements.—This is capable of determination within very close limits. The depreciation.—This is in a measure a matter of judgment, based on the experience, not only of the engineers making the appraisal, but of the entire scientific world; and, if properly made and properly checked, there should be no very wide divergencies in results. The items of general expense.—These, based on available statistics, must be estimated. The exact determination of these items will be made comparatively easy as statistics based on the uniform classification of accounts become available. It is believed that the physical values, when secured along the lines suggested, are definite enough to be accepted as a fair estimate of the amount of capital actually invested in the property, and that, if a sufficiently large force of men experienced in the construction, operation, and financial management of the kind of property under investigation is engaged on the work, the element of uncertainty due to errors of personal judgment can be largely eliminated.