f * * * [the utility's] bonds
and stock, the present as compared with the original cost of
construction, [replacement cost], the probable earning capacity of the
property under particular rates prescribed by statute, and the sum
required to meet operating expenses."
(2) Reproduction Cost.--Prior to the demise in 1944 of the Smyth _v._
Ames fair value formula, two of the components thereof were accorded
special emphasis, with the second quickly surpassing the first in terms
of the measure of importance attributed to it. These were: (1) the
actual cost of the property ("the original cost of construction together
with the amount expended in permanent improvements") and (2)
reproduction cost ("the present as compared with the original cost of
construction"). If prices did not fluctuate through the years, the
controversy which arose over the application of reproduction cost in
preference to original cost would have been reduced to a war of words;
for results obtained by reliance upon either would have been identical.
The instability in the price structure, however, presented the courts
with a dilemma. If rate-making is attempted at a time of declining
prices, valuation on the basis of present or reproduction cost will
advantage the consumer or user, and disadvantage the utility. On the
other hand, if the original cost of construction is employed, the
benefits are redistributed, with the consumer becoming the loser.
Similarly, when rates are fixed at a time of rising prices, reliance
upon reproduction cost to the exclusion of original cost will produce
results satisfactory to the utility and undesirable to the public, and
vice versa.
Notwithstanding the admonition of Smyth _v._ Ames that original cost, no
less than reproduction cost, was to be considered in determining value,
the Court, in the years which intervened between 1898 and 1944, wavered
only slightly in its preference for the reproduction cost formula, and
moderated its application thereof only in part whenever periods of
rising or sustained high prices appeared to require such deviation in
behalf of consumer interests. As examples of the varied application by
the Court of the reproduction cost formula, the following cases are
significant: San Diego Land and Town Co. _v._ National City, 174 U.S.
739, 757 (1899); San Diego Land & Town Co. _v._ Jasper, 189 U.S. 439,
443 (1903); Willcox _v._ Consolidated Gas Co., 212 U.S. 19, 52 (1909);
Minnesota Rate Cases, 230 U.
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