ESSENTIALS OF VALUE 73
While this circumstance may justify the inclusion of appreciation
 in the appraisal of the rate-base in some cases, there will
be others where the appreciation is out of all proportion to the
original investment. Furthermore, a strict analysis will show
that such inclusion would deprive the rate-payer of any share
in the unearned increment to which he, too, is a contributor. It
is, moreover, as already stated, difficult and oftentimes Impossible
 to ascertain the rate of appreciation which might fairly be
taken into account and finally, if appreciation is included in the
appraisal of land, it should also be included in the appraisal of
all other kinds of property. Such inclusion would greatly and
unnecessarily complicate every calculation relating to rates and
would introduce an element of much uncertainty. It will be
much simpler and yet fair to all concerned to exclude appreciation
 from the rate-base but, as already suggested, to allow
the owner of every utility to participate in the general prosperity
by allowing the rate of return on the rate-base to be higher than
it would otherwise be estimated.
If this practice coupled with the Unlimited Life Method of
procedure could be made general there would be no revision of a
rate-base, once established, except as made necessary by additions
 to the utility properties or changes therein, nor would
there be any need of determining present value, and yet the
unearned increment would not be ignored. It would appear in
the earnings and not in the rate-base, and the equitable apportionment
 of the unearned increment to the utility owner and to
the rate-payer would be facilitated.
If the unearned increment (appreciation) is estimated from
time to time and is treated as income and the total net return
on the rate-base does not exceed ordinary interest rates on safe
investments, the estimated appreciation should be added to the
rate-base in fairness to the owner of the utility.
If appreciation is estimated from time to time and added to
the rate-base but is not treated as income, the rate-payer will
be denied any share thereof.
If appreciation is ignored, and a rate-base, once determined,

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