ESSENTIALS OF VALUE ; 1 
just as the owner of land participates. He does so, of course, 
in a measure as his business increases, but if held down to earn- 
ings which will barely yield the ordinary interest rates on safe 
investments, the extent of doing this may fall far short of the 
advance in property value shared in by practically all the owners 
of the realty in the community. 
Application to Public Utilities. — Such considerations as this, 
although not thus expressed, have led the U.S. Supreme Court 
to hold that the owner of a public utility is entitled, in most 
cases at any rate, to have the present value of his property made 
the basis of the computation when rates are to be fixed. In the 
Consolidated Gas Co. case (Wm. R. Willcox et al. vs. Consoli- 
dated Gas Co. of N. Y., 212 U.S. 19, 29 Sup. Ct. Rep. 192) 
as already quoted the court says: 
“And we concur with the court below in holding that the 
value of the property is to be determined as of the time when 
the inquiry is made regarding the rates. If the property which 
legally enters into the consideration of the question of rates has 
increased in value since it was acquired, the company is entitled 
to the benefit of such increase. This is at any rate the general 
rule. We do not say that there may not possibly be an ex- 
ception to it where the property may have increased so enor- 
mously in value as to render a rate permitting a reasonable return 
upon such value unjust to the public.” 
The court has, perhaps, overlooked the fact that unearned 
increments are earnings and can be allowed without adding them 
to the investment. It may have been perfectly fair to make the 
valuation allowance to the full extent of the unearned increment 
in the Consolidated Gas Co. case and this allowance is not here 
made the subject of criticism. It is only the practical applica- 
tion of the ruling which is brought into question. It is believed 
that as these matters are better understood there will be a 
general acceptance of the view that appreciation had better not 
be included in the rate-base. 
In the case of farm lands the situation may obtain of a greater 
supply thereof than can be made use of by the inhabitants of 
7