Note and Comment

Public Utility Valuations and Rates - In comparing the reports of the public utility commissions with the decisions of the courts on questions of valuation of public utilities, nothing is more striking than this-that as time goes on the commissions are growingly impatient of the cost of reproduction theory, while the courts still insist there is no inflexible method of fixing value, but continue to prefer largely figures as to supposed reproduction cost. This attitude of the commissions is remarkable in view of the fact that every finding may be carried to the courts for review and possible reversal. The Illinois Commission reluctantly obeyed the direct orders of the Supreme Court to consider cost of reproduction, but refuses to treat that as the only basis. Re Springfield Consol.

Ry. Co., P. U. R. Ig2o E. 474, 48o. The Interstate Commerce Commission ruled that it was practically impossible for it to find such value in the appraisal of lands of railroads as ordered by Congress in 1912. But the Supreme Court said it must do so because Congress had ordered it.

U. S. v. Interstate Coin.

Coin., 252 U. S.