PUBLIC UTILITIES - METHODS OF VALUATION - PRUDENT INVESTMENT AS THE SOLE METHOD

The state board of railroad commissioners, in reducing the rates of the plaintiff utility, adopted a valuation based on the "'prudent investment" theory, claiming that under a statute of the state such method of valuation had to be used. Plaintiff urged that valuation should have been measured by reproduction cost minus depreciation. Held, valuation by the commission was improper, since the statute did not authorize the use of the "prudent investment" theory as the sole standard. Northern States Power Co. v. Board of Railroad Commissioners, (N. D. 1941) 298 N. W. 423.