rates, as heretofore, upon the basis established by the courts. It may then be claimed that Congress has conferred rate-making authority upon the Federal Power Commission and that such Commission, having entered the field, has exclusive authority. In that situation the reservation of the authority quoted above would prove to be a mere delusion.

Millions of dollars have been invested upon faith in the present method of regulating rates. This radical change with its uncertainties should not be forced arbitrarily upon the industry and investors.

HOLDING COMPANY PROVISIONS AFFECT OPERATING COMPANIES

The holding company provisions of the bill, although probably drafted primarily to reach holding companies in the usual accepted meaning of the term, will drastically affect many operating companies. Operating companies often find it necessary or convenient for a portion of their business to be conducted by a subsidiary company. Because of the control of a subsidiary electric or gas company, the operating company would be a holding company under the technical definition of title I, and, as such, would be subject to drastic regulation (sec. 3 (a) (7), and secs. 4 to 18 inclusive). It would be required to register as a holding company and reorganize under the supervision of the Securities and Exchange Commission (secs. 4, 5 and 11 (a) (b) (c)). The discretionary power of the Commission to grant exemption in special cases is narrowly restricted (secs. 4 (c) and 11 (b) (4)). Some of the companies would be forced to dispose of portions of their properties or securities which might be closely tied in and financed with their other properties (sec. 8). Such reorganizations might be dictated in the interests of any Government-nationalization plan. Thus, the local operating company, merely because of a convenient arrangement for the operation and financing of its properties, might be subject to the harsh provisions of the holdingcompany portion of the bill. The operating companies are penalized because of their affiliation with other companies (secs. 3 (a) (11), 12 (g) (h), 13 (b)). In many instances, operating companies, because of legal obstacles to mergers or for other legal reasons, are maintained as subsidiaries of other operating companies. Many of such subsidiary companies have only skeleton staffs aided by the personnel of their parent operating company. Companies which otherwise probably could not exist are thus able to function. Under the bill such a parent operating company is technically a holding company and is technically furnishing supervision or management services to its subsidiaries. This furnishes an illustration of how the bill would be seriously disadvantageous from the standpoint of purely operating companies. Many contracts under which operating companies are receiving supervision or management services, no matter how valuable they may be, would have to be terminated (secs. 13 (a) (b) (d)). Within a short period of years operating companies would also be deprived of the holdingcompany financial support upon which they have been depending for many years and which has assisted them in keeping pace with the rapid growth in their territories.

RELATIONS WITH HOLDING AND MANAGEMENT COMPANIES NOW REGULATED

Contrary to popular belief, the holding companies and affiliated interests in the public utility field are very generally regulated. Early in 1935 no less than 25 States had statutes dealing directly with various phases of the relationship between "holding companies,' ""affiliated interests" and local "operating utilities."

These statutes cover a wide and varied field, some being comprehensive and detailed while others are short and general in their terms. Contracts covering

Alabama, General Acts, 1932, Act No. 232; Arkansas, S. B. 294 (Apr. 2, 1935); Illinois, Smith-Hurd Revised Statutes, 1933, chap. 111 2/3, sec. 8a; Indiana, Acts of Indiana, General Assembly, 1933, chap. 189; Kansas, Revised Statutes, Kansas, 1923, 1933 supp., secs. 66-1213, 74-602a, 74-602b. 74-602c; Louisiana, Dart's Louisiana General Statutes, 1932, title LV, chap. 5, sec. 8005; Maine, Laws of Maine, 1933, chap. 213; Maryland, Ann. Code 1924, art. 23, sec. 394; Massachusetts, General Laws of Massachusetts, Tercentenary Edition, 1932, vol. II, chap. 164, secs. 85, 94A, 94B; Missouri, Pub. Serv. Com. L., sec. 74 (2) (L. 1917, p. 437); New Hampshire, New Hampshire Laws, 1933, chap. 182; New Jersey, Compiled Statutes, New Jersey, supp. 1911-1924, sec. 167-21; New York, Cahill's Consolidated Laws of New York, 1930, chap. 49, secs. 110, 111, supp. 1933, sec. 106, supp. 1934, sec. 110; North Carolina, Code of North Carolina, 1931, chap. 21, sec. 1037(e), supp. 1933, sec. 1112 (17); Oregon, Oregon Laws, 1933, chap. 441, Ibid., chap. 342, Laws, Second Special Session, 1933, chap. 98; Pennsylvania, Laws of Pennsylvania, 1933, No. 333; South Carolina, Acts of South Carolina, 1932, No. 871; Utah, Revised Statutes of Utah, 1933, sec. 76-4-28; Vermont, Public Laws of Vermont, 1933, chap. 250, sec. 6087; Virginia, Virginia Code of 1930, 1934 supp., secs. 3774b-3774i. inclusive; Washington, Laws of Washington, 1933, chap. 152; West Virginia, H. B. No. 473 (Mar. 12, 1935); Wisconsin, Wisconsin Statutes, 1931, secs. 196.02, 196.52, Laws of Wisconsin, 1931-1932-1933, chap. 440, Cf.; Ohio, Page's Annotated Ohio General Code, 1932, title III, div. II, chap. 1, sec. 614-9; Wyoming, Revised Statutes of Wyoming, 1931, 94–137.

management or services have been one of the principal objects of legislative action, having been the subject of statutes in 22 States. In the case of such contracts, legislation varies from requirements to file copies, to provisions for complete and continuing control over all such contracts.8 An examination of the laws and practices of the various States will disclose that the States have gone a long way in furnishing any necessary protection in the public interest with respect to these matters and that they have not been remiss in their activities concerning the regulation and control of these relationships.

The leading case on the subject of service contracts, Smith v. Illinois Bell Telephone Co., was decided in 1930. It may be helpful, however, to trace the development of the law prior to this decision. At least as early as 1915 the local regulatory bodies began to consider service contracts with central organizations for the purpose of determining whether fees paid under contracts were properly chargeable to operating expenses. The earliest case which appears in the Public Utilities Reports was decided in 1915.10 The Missouri Commission there found that the evidence warranted the amount charged. In the same year the Illinois Commission disallowed a service charge based on 3 percent of the gross revenue of a company."

The propriety of charges paid under contracts has been considered by various commissions from time to time during every year since then. Prior to the decision of the Supreme Court of the United States in the case of City of Houston v. Southwestern Bell Telephone Co. (1922)12 the treatment accorded the payments made under such contracts varied. In many instances the amounts paid were allowed in full as operating expenses.13 In other instances the charges were reduced, usually by allowing a lump sum in lieu of the percentage paid," while in some cases the charges were entirely excluded.15

The following tabulation of States and dates will afford an idea as to the extent and frequency of these decisions during the 7-year period preceding the first Southwestern Bell Telephone case in 1922:

Alabama, General Acts, 1932, No. 252, sec. 5; Arkansas, S. B. 294 (Apr. 2, 1935); Smith-Hurd, Revised Illinois Statutes, 1933, chap. 111 2/3. sec. 8a (3) (4); Acts of Indiana General Assembly, 1933, chap. 189, sec. 6; Revised Statutes Kansas, 1923, 1933 supp., sec. 74-602b; Dart's Louisiana General Statutes, 1932, title LV, chap. 5, sec. 8005; Laws of Maine, 1933, chap. 213; Massachusetts General Laws, Tercentenary Edition, 1932, vol. II, chap. 164, secs. 94A, 94B; New Hampshire Laws, 1933, chap. 182, secs. 2-6, inclusive; Cahill's Con solidated Laws of New York, 1930, chap. 49, sec. 110, par. 3; North Carolina Code, 1931, chap. 21, sec. 1037 (e); Page's Annotated Ohio General Code, 1932, title III, div. II, chap. 1, sec. 614-9; Oregon Laws, 1933, chap. 342, chap. 441, sec. 2: Laws of Pennsylvania, 1933, No. 333, sec. 5(b), 5(c); South Carolina Acts, 1932, No. 871. sec. 2(r); Revised Statutes of Utah, 1933, sec. 76-4-28; Public Laws of Vermont, 1933, chap. 250, sec. 6087; Virginia Code of 1930, 1934 supp., secs. 3774c-3774h, inclusive; Laws of Washington, 1933, chap. 152, secs. 2-7, inclusive; West Virginia, H. B. No. 473 (Mar. 12, 1935); Wisconsin Statutes, 1931, secs. 196.52 (3)-196.52 (7), inclusive; Revised Statutes of Wyoming, 1931, sec. 94-137.

7 Public Laws Vermont, 1933, chap. 250, sec. 6087.

• Wisconsin Statutes, 1931, sec. 196.52 (5).

Smith v. Illinois Bell Telephone Co. (1930) (282 U. S. 133).

10 Commercial Club of Charleston v. Missouri Public Utilities Commission (1915) (P. U. R. 1915C 1017). 11 City of Belleville v. St. Clair County Gas & Electric Co. (1915) (P. U. R. 1916B 24, 53).

12 City of Houston v. Southwestern Bell Telephone Co. (1922) (259 U. S. 318).

13 Re Colorado Springs Light, Heat & Power Co. (Colorado, 1916) (P. U. R. 1916C 464); Re Chesapeake & Potomac Telephone Co. (Maryland, 1916) (P. U. R. 1916C_925); Bogart v. Wisconsin Telephone Co. (Wis consin, 1916) (P. U. R. 1916C 1020); Re Mountain States Telephone & Telegraph Co. (Colorado, 1916) (P. U. R. 1917B_198); Re Uniform Telephone Rates (Pennsylvania, 1917) (P. U. R. 1917D, 259); Re Coos Telephone Co. (New Hampshire, 1918) (P. U. R. 1918F 592); Re Michigan State Telephone Co. (Michigan, 1918) (P. U. R. 1918C 81); City of Birmingham v. Southern Bell Telephone & Telegraph Co. (Alabama, 1918) (P. U. R. 1919B 791); Re Rates and Charges of Telephone Companies (Arizona, 1919) (P. U. R. 1920B 411); Public Service Commission v. Pacific Telephone & Telegraph Co. (Washington, 1919) (P. U. R. 1919F 131); Re Southwestern Bell Telephone Co. (Arkansas, 1920) (P. U. R. 1921B 516); Re Chesapeake & Potomac Telephone Co. (District of Columbia, 1920) (P. U. R. 1920D 614); Re Chesapeake & Potomac Telephone Co. (West Virginia, 1920) (P. U. R. 1921B 97); Re Chesapeake & Potomac Telephone Co. (Virginia, 1920) (P. U. R. 1920F 49); Re Southern Bell Telephone & Telegraph Co. (Georgia, 1921) (P. U. R. 1921C 833); Re Cumberland Telephone & Telegraph Co. (Louisiana, 1921); (P. U. R. 1921C 330, 363) Re Pacific Telephone & Telegraph Co. (Oregon, 1922) (P. U. R. 1922C 248).

14 Re San Diego Consolidated Gas & Electric Co. (California, 1916), P. U. R. 1917A 930; City of Mangum v. Mangum Electric Co. (Oklahoma, 1916), P. U. R. 1916E 764; Re Houghton County Traction Co. et al. (Michigan, 1919), P. U. R. 1920E 350; Re Pacific Telephone & Telegraph Co. (Oregon, 1919), P. U. R. 1919D 345; Re Rockford Gas Light & Coke Co. (Illinois, 1920), P. U. R. 1920E 461; Re Freeport Gas Co. (Illinois, 1920), P. U. R. 1920B 726; Re Central Union Telephone Co. (Ohio, 1920), P. U. R. 1920C 534; Re Central Union Telephone Co. (Indiana, 1920), P. U. R. 1920B 813; Buck v. New York Telephone Co. (New York, 1921), P. U. R. 1921E 798; Re Southern California Telephone Co. (California, 1921), P. U. R. 1922C 97; R Tucson Gas, Electric Light & Power Co. (Arizona, 1922), P. U. R. 1922C 658; Re Cumberland Telephone & Telegraph Co. (Louisiana, 1922), P. U. R. 1922E 86.

18 Re City of Peoria and Receivers of the Central Union Telephone Co. (Illinois, 1918), P. U. R. 1918E 74; Re Missouri & Kansas Telephone Co. (Kansas, 1918), P. U. R. 1918C 55; Re Wisconsin-Minnesota Light & Power Co. (Wisconsin, 1920), P. U. R. 1920D 428; Re Helena Light & Railway Co. (Montana, 1920), P. U. R. 1920 D. CGS.

Even at this early period some of the commissions began demanding that the cost to the central service organization of rendering the service be shown in order to permit the commissions to determine whether an unreasonable profit was being made at the expense of the local operating company.16

As early as 1916, the California commission 17 called for the cost records of a central service organization showing the expenses properly allocable to all of the local operating utilities served by such company under the jurisdiction of the commission. These figures were furnished to the commission and were considered by it in determining that a small reduction should be made.

The requirement that the cost of rendering service be shown had theretofore made definite headway when, on May 29, 1922, the Supreme Court of the United States limited the right of regulatory bodies to make inquiry into the cost to the central service organizations of rendering the service under contracts (City of Houston v. Southwestern Bell Telephone Co.).18 A year later the Supreme Court decided the case of State of Missouri ex rel. Southwestern Bell Telephone Co. v. Public Service Commission of Missouri,19 further limiting the power of regulatory bodies over service contracts. Nevertheless, during the period between these decisions and the decision in Smith v. Illinois Bell Telephone Co. in 1930 (above referred to), the State commissions continued to scrutinize such contracts closely. As in prior years, the charges made under the contracts were allowed in many cases.20 In other cases only a portion of the amount actually 16 Re Central Union Telephone Co. (Indiana, 1920), P. U. R. 1920B 813, 844; Re Pacific Telephone & Tele graph Co. (Oregon, 1919), P. U. R. 1919D 345, 365; Re Chesapeake & Potomac Telephone Co. (Virginia, 1920), P. U. R. 1920F 49, 96; Re Pacific Telephone & Telegraph Co. (Oregon, 1922), P. Û. R. 1922Č 248, 254. 17 Re San Diego Consolidated Gas & Electric Co. (California, 1916), P. U. R. 1917A 930, 961.

18 City of Houston v. Southwestern Bell Telephone Co. (1922), 259 U. S. 318.

19 State of Missouri ex rei. Southwestern Beli Telephone Co. v. Public Service Commission cf Missouri (1923), 262 U. S. 276.

20 Re Northwestern Bell Telephone Co. (Nebraska, 1922), P. U. R. 1923B 112; Re Red River Power Co. (North Dakota, 1923), P. U. R. 1923E 534; Alpha Portland Cement Co. v. Lehigh Navigation Electric Co., et al. (Pennsylvania, 1923), P. U. R. 1924E 737; Re Mountain States Telephone & Telegraph Co. (New Mexico 1923), P. U. R. 1923B 352; Re Houghton County Electric Light Co. (Michigan, 1923), P. U. R. 1924B 32; Public Service Commission v. Mountain States Telephone & Telegraph Co. (Montana, 1924), P. U. R. 19240 545; Federation of Citizens' Associations v. Chesapeake & Potomac Telephone Co. (District of Columbia, 1924), P. U. R. 1924D 152; Re New England Telephone & Telegraph Co. (Maine, 1925), P. U. R. 1926B 247; Public Utilities Commission v. New England Telephone & Telegraph Co. (Rhode Island, 1925), P. U. R. 1926C 207; Re New England Telephone & Telegraph Co. (Massachusetts, 1925), P. U. R. 1925E 739; Wood v. Elmira Water, Light & Railroad Co. (New York, 1926), P. U. R. 1927 B 400; Re New England Telephone & Telegraph Co. (New Hampshire, 1926), P. U. R. 1926 E 186; Re New York Telephone Co. (New York, 1926), P. Ü. R. 1926E 1; Re Michigan Bell Telephone Co. (Michigan, 1926), P. U. R. 1926C 607; Re Indiana Bell Telephone Co. (Indiana, 1926), P. U. R. 1926C 785; Re New England Telephone & Telegraph Co. (Vermont, 1926), P. U. R. 1927C 348; Re East St. Louis & Interurban Water Co. (Illinois, 1927), P. U. R. 1928A 57; Re City Water Co. of Marinette (Wisconsin, 1928), P. U. R. 1929A 243; Re Mountain States Telephone & Telegraph Co. (Arizona, 1929), P. U. R. 1929D 414; Re Pacific Telephone & Telegraph Co. (Californía, 1929), P. U. R. 1930C 481.

a Re New York Telephone Co. (New York, 1923), P. U. R. 1923B 545; Department of Public Works ex rel. City of Seattle v. Pacific Telephone & Telegraph Co. (Washington, 1923), P. U. R. 1923D 113; Re Indiana Bell Telephone Co. (Indiana, 1923), P. U. R. 1924A 1; Re Southern California Telephone Co. (California, 1924), P. U. R. 1925Č 627; Borough of Knoxville v. South Pittsburgh Water Co. (Pennsylvania, 1927), P. U. R. 1928B 204.

paid was allowed," while in some instances the amounts were excluded entirely from consideration in fixing rates.22

In Smith v. Illinois Bell Telephone Co., the Supreme Court not only released the restrictions placed upon the regulatory bodies by the two Southwestern Bell cases, above referred to, but affirmatively placed the burden of showing the cost of rendering the service upon the operating company. In this connection it is interesting to note that the statutory regulation of the management or service contract began in the same year (1930) in which the Smith case was decided." If there could be any doubt that these Southwestern Bell cases are no longer the law with respect to charges made by the central service organization against operating utilities and that the State regulatory bodies now possess ample power to examine and pass upon charges to the fullest extent, it has been dispelled by other decisions of the Supreme Court.24

Full effect to the Smith case has been given by the State and Federal courts. Since this decision, there have been published in the public utilities reports 24 decisions of various State commissions wherein service contracts were considered and action was taken thereon. The minute detail with which commissions may examine into service and supply contracts was well illustrated in re the Ohio Bell Telephone Co., (1934),25 in which case the Ohio commission devoted 11 pages of the printed opinion to a consideration of the various services rendered and supplies furnished.

In summary it may be said that during the past 20 years the State regulatory bodies have continuously examined into and approved in whole or in part or rejected the fees paid by local operating utilities to central service organizations and that during the past few years the courts have tended strongly to decisions which would aid the State bodies in their examination rather than to restrict or limit them.

Loans and advances between operating utilities and their holding and affiliated companies have also been the subject of legislation. The principal thing sought to be prevented is improper advances made by an operating company to its holding company, although occasional instances have arisen where it is alleged that the operating company has made improvident borrowings from the holding company. Ordinarily funds advanced by the operating company to the holding company are raised either by the sale of the former's securities or by borrowing from some other affiliated interest. Rather effective control of this source of money with which to make advances is provided in statutes existing in a majority of the States giving commissions control over the issuance of capital stock, bonds, notes, or other evidences of indebtedness by a public utility.26 The statutory language is very similar in most of the States, and is probably broad enough to to cover all borrowing transactions, including those on open account. In practically all of these statutes, short-term obligations (usually those maturing 22 Dunn et al. v. Rutland Railway, Light & Power Co. (Vermont, 1923), P. U. R. 1923 C 316; Re Western States Gas & Electric Co. (California, 1924), P. U. R. 1924 D 681; Public Service Commission v. Chesapeake & Potomac Telephone Co. (Maryland, 1924), P. U. R. 1925 B 545; Buck v. International Railway Co. (New York, 1925), P. Ú. R. 1925 D 782; Re Cumberland & Allegheny Gas Co. (West Virginia, 1927) P. Ú. R. 1929 B 20; Re Wisconsin Fuel & Light Co. (Wisconsin, 1927), P. U. R. 1927 E 212; Re International Railway Co. (New York, 1927), P. U. R.1927 D 630; Re St. Croix Valley Telephone Co. (Wisconsin, 1929), P. U. R. 1929 B 597; Re Wisconsin Public Utility Co. (Wisconsin, 1929), P. U. R. 1930 A 119; Public Service Commission v. Great Northern Utilities Co. (Montana, 1929), P. U. R. 1929 B 176; City of Polson v. Public Utilities Consolidated Corporation (Montana, 1929), P. U. R. 1929 E 557; Re Los Angeles Gas & Electric Corporation (California, 1930), P. U. R. 1931 A 132; Re Cambridge Home Telephone Co. (Ohio, 1930), P. U. R. 1930 E 65. 23 45 Harvard Law Review, 729, 732.

24 Western Distributing Co. v. Public Service Commission of Kansas et al. (1932), 285 U. S. 119. Dayton Power & Light Co. v. Public Utilities Commission of Ohio (1934), 292 U. S. 290. Columbus Gas & Fuel Co. v. Public Utilities Commission of Ohio et al. (1934), 292 U. S. 398.

15 Re The Ohio Bell Telephone Co. (Ohio, 1934) 2 P. U. R. (N. S.) 113.

Alabama Code, 1928, sec. 9744, Supp. 1932, sec. 9824 (3); General Acts of Alabama, 1932, no. 232, sec. 12, Arizona Code, 1928, sec. 708; Crawford & Moses, Arkansas Digest, 1921, secs. 1657-1662, S. B. 294 (Apr. 2, 1935); California General Laws, Deering, 1931, title 464, act 6386, sec. 52; Georgia Code, 1926, sec. 2665; Cahill's Illinois Revised Statutes, 1933, ch. 111 a, sec. 35; Burns' Indiana Annotated Statutes, 1926, sec. 12761, Acts of Indiana General Assembly, 1933, ch. 169, sec. 7 A, 8; Revised Statutes of Kansas, 1923, ch. 66, sec. 125; Baldwin's Kentucky Statutes Service, 1934, ch. 104a, sec. 3952-24 (Kentucky Acts, 1934, ch. 145, sec. 4k); Revised Statutes of Maine, 1930, ch. 62, sec. 41; Bagby's Annotated Code of Maryland, 1924, art. 23, secs. 581, 392; Massachusetts General Laws, 1932, ch. 164, sec. 14; Massachusetts Acts, 1932, ch. 290; Michigan Compiled Laws, 1929, ch. 208, sec. 11077; Revised Statutes of Missouri, 1929, ch. 33, secs. 5194, 5196, 5198; Nebraska Compiled Statutes, 1929, sec. 75-1201; New Hampshire Public Laws, 1926, ch. 241, sec. 1; Compiled Statutes of New Jersey, Supp. 1925-30, sec. 167-24 (e); Cahill's New York Consolidated Laws, 1930, ch. 49, sec. 69; North Carolina Code of 1931, 1933 Supp. ch. 21, art. 9, secs. 1112 (17)-1112 (27); North Dakota Compiled Laws, 1923 Supp. sec. 4609c20; Page's Annotated Ohio General Code, 1932, sec. 614-53, 614-55; Oregon Laws, 1933, ch. 441, sec. 10; Laws of Pennsylvania, 1933, No. 333, p. 1530; South Carolina Acts, 1932, no. 871, sec. 2(m); Tennessee Code, 1932, sec. 5452(d); Public Laws of Vermont, 1933, ch. 242, sec. 5953; Acts of Virginia Assembly, 1934, ch. 145; Laws of Washington, 933, ch. 151; Wisconsin Statutes, 1931, sec. 184.03.

27 State v. New Hampshire Gas & Electric Co. (N. H., 1932), 163 Atl. 724.

in 1 or 2 years) are exempted, but commission control over refunding of such obligations is such, in most States, that effective control is possible. In some of the States the exemption of short-term securities is limited to a percentage of the issuing company's outstanding securities.28 Some of these statutes, in addition to making a violation thereof a penal offense, provide that securities issued with.out commission approval shall be void." Others specifically provide that the securities shall not be void, but contain heavy penalty provisions for violations.30 In addition to these statutes giving commissions control of the source of supply, there have been enactments in many States requiring commission approval of all loans or advances by a utility to affiliated interests. The payment of dividends, purchase and sale of stock, and other similar matters have also been extensively regulated by State statutes.

It is impossible in a brief presentation to give a complete picture of how far the relations between the local operating companies and affiliated companies have in fact been regulated through State commissions. Careful study of the field of nonstatutory regulation, plus a consideration of the numerous statutes bearing upon the subject, will convince an unbiased observer that the holding company, despite its nonutility status, despite its usually foreign domicile, and despite its alleged legal insulation, has come more and more within the sphere of operation of the State regulatory bodies. At the present time a holding company is a regulated company. The States have asserted power over it both directly and indirectly and in this assertion of power the States have received such support from the judiciary that today it may truthfully be said that if any State fails to regulate the relations between local utilities and holding and affiliated companies, it is due to lack of desire and not to lack of power.

From the foregoing it is obvious that the need of drastic Federal regulation with respect to affiliated and service company contracts and relationships with operating utilities is not necessary.

CONCLUSION

It seems reasonable to urge that, until the Supreme Court shall more definitely establish the boundary line between Federal and State jurisdiction under the Interstate Commerce clause of the Constitution, Congress should delay its attempt to enter a field already occupied by the States and which has always been regarded as reserved solely to them.

APPENDIX

STATEMENTS OF LOCAL COUNSEL SUMMARIZED IN THIS PAPER

'What would happen to local regulation in Wisconsin if Rayburn bill is passed." By W. P. Crawford of Crawford & Crawford, Superior Wis.

"Effect of Rayburn-Wheeler bill upon the regulatory power of the State of Iowa over public utilities." By Folsom Everest of Tinley, Mitchell, Ross & Everest, Council Bluffs, Iowa.

"Effect of nonaction by Federal Power Commission on powers of State commissions." By Ralph B. Feagin of Baker, Botts, Andrews & Wharton, Houston,

Tex.

"Fundamentals of the electric light and power business as affecting the problems of regulation." By Ralph B. Feagin (in collaboration with John P. Bullington and F. G. Coates) of Baker, Botts, Andrews & Wharton, Houston, Tex.

"Public Utility Act of 1935 as affecting Minnesota Power & Light Co. under home rule regulation in Minnesota." By Donald D. Harries of Mitchell, Gillette, Nye & Harries, Duluth, Minn.

"Rayburn bill-Effect on Nebraska jurisdiction over electric utilities." By J. A. C. Kennedy of Kennedy, Holland & De Lacy, Omaha, Nebr.

"Rayburn Bill-The effect of 'Public Utility Act of 1935' (Rayburn bill) and particularly 'Federal Power Act' (title II thereof) upon (a) regulation of electric companies by State of Nebraska, (b) control of such companies under home rule or other charter powers by cities and villages, (c) guidance of management and policy by the utility company's officers, with particular reference to the Nebraska Power Co. of Omaha, Nebr." By J. A. C. Kennedy and Ralph E. Svoboda of Kennedy, Holland & DeLacy, Omaha, Nebr.

Burns' Indiana Annotated Statutes, 1926, sec. 12763; New Hampshire Laws, 1929, ch. 136; Alabama Acts, 1932, no. 232, sec. 12. 29 Arizona, California, Illinois, Oregon, and Pennsylvania.

30 Alabama and North Carolina.