Response or Comment
It has been so often remarked that the "valuation" of public utilities is determined by no rule of thumb, that there are no fixed rules or formulas to guide courts or commissions, that determination of value as a rate base is matter of judgment and discretion in each case, Minnesota Rate Cares, 230 U. S. 352, 434, that the statement has come to be believed by reason in part of its much repetition. It is usually accepted as axiomatic. The glorious uncertainty resulting from such an admission will continue so long as judgments of one man or set of men differ from those of another. On such an uncertain foundation it is hardly possible that either reason or justice can be attained. Returns in any business enterprise are discovered by methods of accounting, and correct accounting is governed by fixed rules and formulas, not primarily by the judgment and discretion of the accountant. Not that human judgment can ever be eliminated from any question involving human relationships, but that in questions of earnings on investments fixed rules and formulas so far from being eliminated in favor of judgment and discretion should be resorted to as far as possible. Whether a contemplated investment will yield attractive returns is largely to be determined by judgment and discretion, but what an investment has yielded, and even what in future, it will yield under given conditions, is largely matter of accounting, and therefore largely subject to fixed rules and formulas.
Goddard, Edwin C. "Public Utility Valuation." Mich. L. Rev. 22 (1923): 147-51.