L Bií S", =1 *1 iy t- ¿J ; '—Í / . i.. % *"-i. ~. ^ --C-j BEFORE THE Interstate Commerce Commission Docket No. 12964. In the Matter of CONSOLIDATION OF THE RAILWAY PROPERTIES OF THE UNITED STATES INTO A LIMITED NUMBER OF SYSTEMS STATEMENT FOR THE NEW YORK, NEW HAVEN AND HARTFORD RAILROAD SYSTEM By E. J. PEARSON, President May 24th, 1923 \\A\- The statements which will follow and the data which will be intro¬ duced, are in response to the order of the Commission of March 3rd, 1923, in its docket 12,964, and relates to the New York, New Haven and Hartford Railroad System. Preparation has been aided greatly by the thorough and constructive work of Professor Ripley, which appears in the tentative plan of the Commission for the consolidation of railway properties of the United States into a limited number of systems. The magnitude and the importance of this problem is recognized. The study which has been given by those representing the New Haven has been with a view of affording the utmost assistance that is pos¬ sible, in reaching a solution which will be in the best interest of the public and of the owners of the property. Various features must be considered; physical character and transportation capacity; effi¬ cient and economical operation; means of rehabilitating credit; and relationship between New England and its railroads. In pursuance of the general directions relating to the furnishing of data, two schedules are submitted. The first (Exhibit A) a series of statements of statistical data; the second (Exhibit B) data which is displayed by a series of maps and charts. Whfie the exhibits which have been introduced give full detail with respect to the gradual building up of the New Haven System, through consolidation, leasing, and acquiring of ownership of securities in constituent lines, the general picture of these numerous and suc¬ cessive developments so far as the dates of origin of portions of the physical property are concerned, is shown by a blueprint which is submitted as Exhibit C. This print is dated February 16, 1920, and by ten year periods, shows graphically the approximate dates of opening of the various portions of the system. That part of the System from Atlantic toward West Quincy was opened in 1826; from Back Bay at Boston to East Providence, in 1834; from Mansfield to Taunton, in 1836; from South Providence to the Port of Stonington which is under the shelter of Long Island, in 1837; from Belle Dock, New Haven, to Hartford, and from West Stockbridge to State Line, in 1839; from Norwich to Worcester and from Bridgeport to Canaan, in 1840; from Read ville to Dedham, and from Canaan to West Stockbridge, in 1842; from Norwich to reach deeper water at Allyns Point, in 1843; from Hartford to Spring¬ field, in 1844; from Providence to Worcester, in 1847; from New Haven to Plainville, in 1848; from New Haven to Woodlawn, and Devon to Winsted, in 1849; and from Hartford to Willimantic, and 1 Dcdham to East Douglas, in 1849. The freight line to Harlem River was opened in 1873. The Shore Line was not connected up until the Thames River Bridge was opened in 1889, a transfer steamer, however, had been operated theretofore. The South Station at Boston was opened in 1898. The exhibit shows the successive additions. But little main track mileage has been added since the period 1880 to 1889. For practicable purposes the completion of the present system as now operated, was substantially effected under the administration of President Clark which terminated in 1901. The following tabulation illustrates for the twenty year period, that while the miles of road remained substantially the same, that population, traffic handled, and the provision of added tracks and facilities, all increased largely. Population of July, 1923—From estimate of Census Bureau on April 11, 1923. Population of July, 1903—(Approximated from Census of 1900 on same basis as Bureau estimate for 1923.) Control of Central New England by New York, New Haven and Hartford dates from 1903. July, 1903. July, 1923 P. C. Incr. Population Conn., Mass., R.I. (Approx.) 4,460,529 6,130,700 37 Miles of Road—^NH—CNE... 2,280 2,297 1 Miles of All Tracks—NH— CNE 4,336 5,438 25 Population Per Mile of Road Almost Exclusively Served (Conn. R.I. and 1/3 of Mass.) 1,077 1,500 39 Population of New England... 5,938,817 7,707,963 30 Population of United States... 81,762,521 110,663,502 35 1903 1922 Passengers One Mile— NH.—CNE.. 1,123,326,576 1,857,933,433 65 Passengers One Mile Per • Mile of Road 492,687 808,852 64 Rev. Ton Miles—NH.— CNE 1,657,580,727 3,020,409,682 82 Rev. Ton Miles Per Mile of Road 727,009 1,314,937 81 In many respects, so far as southern New England is concerned, there has been brought about through the various processes of merger, although in a lesser degree, a' consolidation of nearly all lines of 2 transportation within southern New England, much perhaps as is contemplated in a larger measure, by the Transportation Act of 1920. In the operation of the system, and this policy was established under President Clark, it has been the endeavor not only to meet the requirements of the territory served, but to afford its patrons what might be designated as terminal service, that is, free and unre¬ stricted opportunity to utilize the transportation of the New Haven System in connection with all other lines of connecting transporta¬ tion, rail or water; and similarly, to afford all connecting lines of transportation what might be deemed terminal service for them, for the purpose of reaching all points in the territory served by the New Haven System. As the situation exists today, the New Haven System comprises: The New York, New Haven and Hartford Railroad and leased lines: The Central New England Railway and leased line: The New York Coimecting Railroad—jointly owned with the Pennsylvania Railroad: The New England Steamship Company which now includes the New Bedford, Martha's Vineyard and Nantucket Steamboat Company; and. The Hartford and New York Transportation Company. The Central New England is operated as an integral part of the System. The New York Connecting is operated by the New Haven, for the joint account of the New Haven and Pennsylvania. The New England Steamship Lines are operated jointly with the New Haven for rail and water traffic, and supplementally, as is also the Hartford and New York Transportation Company, for port to port traffic. All of these lines are essential to a co-operative system of transportation, to the end that the New Haven System may meet the needs of the public which it serves. The System now serves, almost exclusively, the states of Connecti¬ cut; Rhode Island; the southerly portion of Massachusetts approxi¬ mately a third of the state; and the southeasterly corner of New York. This territory is densely settled, prosperous commercially, important, and highly developed industrially. It has a population of about million; approximately 3.2% of the United States. The value of all property in this territory (from the tax returns of 1920), is approximately 6 billion dollars. The annual production of agriculture, commerce and industry (from the United States Census of 1919), is approximately 3J^ billion dollars; roughly 5% of the 3 United States. The revenues of the System amount to about 2.5% of the revenues of the railways of the United States. As has been shown by exhibit C just referred to, the original transportation lines of New England comprised railways which were mostly located along portions of the seaboard and through the valleys between the tidewater ports and the centers of industry and traffic in the interior; these were operated in connection with steamers to and from New York. As the independent and disconnected railways and steamer lines were merged, and as capacity of western gateways was expanded, traffic tended to favor the all-rail movement. This has generally kept the all-rail route with its gradually increasing capacity, pretty well filled, and has at times caused congestion. In view of the impressions that appear to prevail from time to time, which improperly reflect the situation and conditions of the New Haven, and particularly because of remarks that have been made earlier during this hearing to the effect that the New Haven must be short of both facilities and equipment because of its weak financial condition, it is desirable to outline some of the matters relating to the New Haven in this regard, which on the contrary are favorable. This data is pertinent, in order that in considering consolidation plans, there may be a comprehensive understanding of what the New Haven System is in reality today. Beginning with the European War, freight traffic grew so that during 1915-10 the capacity of the road was severely taxed to care for the load that was imposed and congestion resulted. This was due very largely to unusually heavy buying and shipping, in part to anticipation of rapidly rising costs, and was at a rate not only more rapid than the railroads could handle with satisfaction, but also more rapid than consignees could receive. It has been frequently asserted that in this period the New Haven "broke down". The fact is, that while the New Haven suffered both as to capacity and operating costs, nevertheless, as a whole it furnished transportation enabling industry to grow and prosper as it never had done before in a similar period. The majority of its freight houses were filled with inbound freight much of the time, because of delayed removal on the part of consignees. For long periods of time its delivery tracks were filled to high records of cars in place for consignees, while at the same time the rate of unloading was no more than normally rapid. During this period the hiring away of its employees by private industries at the high rates justified by prospering commercial condi¬ tions, further crippled the railroad. It was a record period of diffi- 4 culty for both the milroad and the ehippera, but it ims also a record of a general fulfillment of transportation requirements, and not a record of railway breakdown. Realizing the situation so quickly imposed upon the road, and with a "dew to the future, the Directors took ñnmedkte steps to cause to be made a study of the requirements and the development of a program for miki^ing capacity, hnprodng serdce, remodelling operation, expediting the movement of cars, and reducing costs. This was with the dew of overcranii^ operating limitations due to various causes, including the inadequate terminals of the numerous small constituent railway whose facilitieB may have bmi adequate for their own former independent operation with a smaller voltune of traffioï and of prodding fadUtíes for system operation, which would at the same time remove overload and congestion at such terminals as Bridgeport, Waterbmy, Hartford, New Haven, Proddence, relieve the conditions at the New York gatesrays as well, and would be in accord with any furthra- development m the movement of the trafiSc of New En^and as a whole. This program was promptly and enej^etioally progr^sed. It was carefully conâdered by the Board of Directors, and then ap¬ proved as to portions from time to time, for procedure on the basis of the combination of, (a) funds that could be pro-ddol and, (b) first and preference attention to the itöns of greater necesâty and of immedmte benefit from the stondpránt of operation. Eadi improve¬ ment, títierefore, was carefully designed and provided to meet an opm'ating requirement. With the ¿lortage of fimds at all times, even during Federal con¬ trol; with the high costs of labor and material; and with imeertainty of the commercial and traffic future after the war; it is obvious that the proper course, whidi was followed, "was that of carefid attention at all times to the providing of only those items which were of greater and immediate operating necesrity and of maximum benefit. It was realized further that the improvements, even in the case of reduced traffic later, must then be found to be justified becaure of continued decreased costs for operation'—^in which there was marked success. In progressing this program, the Fedm'al Government assisted largely in the furnishing of funds. The Director General, made a personal inspection while the hea-vier work was under way, and affonied valued assistance. The result has been that in no instances have unnecessary expendi¬ tures been made for remote or doubtful requirements. They have been spread throughout the System; they involve nearly every dass 5 of work; they include signals and circuits for communication; re¬ moval of points of restricted clearances and bridges of inadequate strength; some freight stations and bulk yards; passing tracks and various freight terminals; water supply, fuel stations, coal storage yards, turntables, engine houses, shops, shop tools, and power plants; locomotives, cars, etc. The following is a Summary of Expendidtures for the Major Items, for the Years 1917-1922, inch Equipment $12,539,159. 120 Steam locomotives, 5 electrics, 13G Passenger cars, 22 multiple units 1500 coal cars. Yard and Freight Terminals 14,973,279. Boston, Providence, Auburn, Worcester, Midway, Cedar Hill, Pawtucket, Springfield, Waterbury. Additional Tracks and Sidings 7,523,258. Running Tracks, Groton to Midway, Kingston to Slocums, New Haven,Pawtucket, AVestbrook to Saybrook, Spring field. Passing Tracks, new or lengthened: New Haven to Boston (24), Devon to Maybrook (18), Hawleyville to Hartford (5), Hartford to Boston (15), New Haven to Springfield (10). Engine Terminals and Shop Facilities 3,570,547. Boston, Bridgeport, Cedar Hill, Danbur>', East Hartford, Harlem River, Maybrook, Midway, Providence, South AVorcester, Springfield, AVaterbury, New Haven, Read\'ille. Bridges 5,175,519. Thames River, Poughkeepsie, Mystic, Connecti- dut River at East Hartford. MUford to Boston. Hartford to Boston New Haven to Willimantic. Derby to AVaterbury. Litchfield Branch. Coal Handling Facilities 468,613. Miscellaneous Items 738,997. Signalling at various points 1,699,063. Telephone Lines, etc 1,737,201. Total $48,425,637. These expenditures were carefully made to promote good and economical operation, with the very definite view of removing each point of restriction or of incapacity, and of producing an adequate 6 system, well balanced as to capacity, service and economy. It was clearly realized that in removing the points of restriction, capacity as a whole ^nmld be increased over that of former maximum demands or those then definitely in sight, but obviously that there would be limitations in the future as traffic continued to grow. Hence the plan followed in ^ch instance, was so deigned and deväoped that without incurring unnecessary expense at the time, proviaon would be made for such logical and econ(^cal expanáon as futura inamees of traffic mi^t dranand. The pro^am for enlarging capacity, spread over the entire System, was BubstanÄUy rannpleted with the putting into servi«^ of the last portion of the Cedar HiU Yard late in 1919. It has bœn the purpose of the foregoing to show how during the past few yeara the New Haven System has been developed into one of large and substantial transportation capacity. The results from the substantial completion of the program, together with the work of the Operating Department, are diown: By the fact that the capacity of the railroad has been such that there have beœ no general emtexgo restrictions since Jxme, 1918 mtcept for causes beyond the control of the management; By the handling in 1919 of the largest volume of gross ton miles of freight traffic dming any ymr; By the handling of the largest pmk during the month of October of that year; and, By the handling of. the three record pmhn of freight, occuring dming the months of July, 1918, October, 1919, and October, 1920, without embargoes. In consideration of the operating accomplMunents, conclurions from the statistics must not be clouded, because the conditions have never been normal in all respects for maximum efficiency. The broad operating accompUriunents are self-Bpeaking. The detailed statistics are of value, only when considered in connection with undra'lying conditiom the storm and outkw strike rituations of 1920; depreraed traffic, surplus cars standing imused on home rails; deferred maintenance in freight cars and power, because of the heavily running deficits; the strike of the shopmen; and tibe abnormal winter condi¬ tions just passed. The facta are that during 1916-19 the physical property has been rehabilitated as to transportation tapacity, which has nmde posrible more efficient and economical operation, as shown by the handling of traffic witii a large decrmse relativriy, in employee hours and train and switching miles. These accomplishments are entitled to con¬ sideration, m connection with the problem of rehabilitation of credit. 7 The future prospects of capacity, service, and income, constitute the real problems of today. There are two phases of the transportation problem of southern New England. The first is that of restoring the credit of the New Haven System, so that regardless of whatever consolidation may be adopted or plans developed, adequate transportation may be furnished promptly and at all times, and so that the true value of the property of the New Haven may be ascertained and fixed for use in considering any form of consolidation. It is essential that in the consideration of consolidations, the complete picture of the New Haven System be drawn. The second, is the determination in the interests of the New England public and of the stockholders of what will be the most beneficial disposition and future use of the New Haven System. This may be by consolidation with a Trunk Line or lines; consohda- tion with other roads within New England—which should include the Boston and Albany, Rutland and Central Vermont, and to these, the New York, Ontario and Western Railroad should be added; or by consideration of a northern New England group of roads and, separately, the component parts of the New Haven as a southern New England system. Under no circumstances should there be consideration of a northern New England—Trunk Line grouping, unless there is a similar plan made effective for southern New England. The following relates to the first and immediate problein; the restoration of credit and the performance at all times, of adequate and satisfactory transportation. IVhat has the management of the New Haven System accom¬ plished? With the confidence and support of representatives of the Federal Government, it has raised the funds and enlarged its physical property, to adequately meet present and prospective requirements. It has taken this course courageously, recognizing the needs of its patrons for transportation in order that their business may grow and prosper, confident of resulting recognition and co-operation which would so spread as to produce for the railroad, similar prosperity and a restoration of its credit; a hope which it still carries. It has developed an operating machine which has not only carried the necessary requirements of its patrons, but has provided trans¬ portation that has enabled the territory served to prosper during past years to an unusual degree. Its rate policy has been on the basis only, of the cost of service, of an income, if possible, that would afford a reasonable return on the valuation of the property used for transportation (not on outside investments), and of a relationship with rates in other and competing 8 territories which will not beár restrictively on New England industry and commerce as compared to adjoining eastern and œmpetitÏTe territory. It has imrticipated in the work of Federal valuation, with the result for the property used for transportation purposes only, of an apparent equity per share to the stockholders that stands muÄ above par. The importance of this valuation, is apparent in connection with the means by which a more rmsonable rate of return tlmn has heretofore been enjoyed may be brought about on the value of the property used for transportation. During the Trat Period, the New Havai earned a surplus of about $4,000,000 per annum. If the conditions of that period as to the relative baas of costs and revenues could Imve been retained, tire addition of the economies resulting from the improvements to the property and in operation, would have restored dividends at a hi^ rate. The magnitude of this accomplishment must not be over- lookrà. It wdl justifies every asástance toward the rehabilitation of credit. The economies, large and important as they are, have been submerged, however, because of the tremendous hunease in tte rate of unit costs, as compared to the rate of increase in the units of revenue. The défiât approaching $15,000,000 in 1821, has bran re duced to less than $5,000,00 in 1922. If a reasonable and adequate return can be secured, there is eaaly the posâbOity of a reasonable dividend rate, after the costs of carry¬ ing unprofitable outride investments have been taken from the sur¬ plus available for dividends. In this coimection, it must also not be overlooked that any unfortunate outride investments have never burdened the public which uses the road for transportation} that this entire burden has fallen on the stockholders. What are the factors necesraiy for this purpose? They are; first, a continuation of the present general spread between the base levds of revenues and of expenses; second, time necesrary for working out from imder the abnormal losses of approxinaately $4,500,000 during 1922 because of the coal strike and Ihe shop strike, and for an amount approximately similar in 1923 because of the continuation of the shop strike effects together with the several conditions of ad- verrity which combined during the recent winter, and induding also the heavier expenditures for recovering from equipment maintenance that was in arrears prior to the shop strike; third, time to bring about further reduction in operating costs which may aggregate upward toward $4,000,(WO per annum and involve largely, reductions in per diem; and fourth, added revenues aggregating $9,000,000 that may 9 accrue from the various items that are under consideration which we believe are justified on their merits, and none of which would impose any undue burden upon New England industry. These items may reach a total around S17,000,000 per annum. Each appears to us to be possible or justified. But cooperation from every direction is essential to their realization. The effect in rehabilitating credit, if these results can be accomplished, is readily apparent. The fairness of increased revenues, on the basis of what the traffic will bear and not on the basis of what the traffic will not bear, must be neither overlooked nor minimized. Compared with the Trunk Lines, the New England roads as to income, are on thin ice. The New England public demands a competitive rate basis that is non¬ discriminatory. The New England roads are in accord with this principle. In continuing on that platform, however, the New Eng¬ land roads must have public support to the extent necessary to main¬ tain proper credit, in adjusting all other rates to the full extent they are reasonable and justified. Industry and commerce cannot prosper without adequate trans¬ portation. Secretary Hoover has approximated annual losses throughout the United States, because of partial transportation inadequacy at §1,000,000,000. per year. Adequate railroad credit would enable the further development of transportation capacity that is desirable. With adequate credit, the railroad managements can be depended upon to increase their plant. The pressure of com¬ petition compels this course. The railroad managers take pride in the performance of service that is satisfactory. The influence of the Interstate Commerce Commission will constantly be in behalf of such a course. Moreover, there can be no question but that under the general provisions of the Transportation Act, the railroad with adequate capacity can be more efficiently and economically operated, and therefore, in the end will be the more profitable. Roughly, one-third of the billion dollars—estimated as an economic loss,—either through an increase in rates or through a lessening of decreases which may follow in time, would solve the transportation problem and in the end would enable the users of transportation to save the other two-thirds of the billion, or in other words, secure an annual benefit running at the rate of 200%. The fines of the New Haven system are logically and well located. Viewed from the standpoint of public necessity, there are but few short stretches that can be considered for abandonment and they are immaterial considering the property as a whole. WhUe the New Haven does not carry a heavy overhead of through traffic, neverthe- 10 less it serves the high average of 1,490 in population per mile of its road, in comparison with an average of 409 of population per mile, of all roads in the United States. The following relates to the second problem; the determination in the interest of the New England public and the stocldiolders, of what will be the most benefidal use of the New Haven ^stem in connection with the project for consîlidations. Unfortumtely, when Professor Ripl^ was prejmring his report (I.C.C. 12964, August 3rd, 1921, Rige 309) complete data were lacking as to New England traffic interchange. In fact there was none except as to interchange with roads outside New England. There was a notable and regrettable lack of information as to inter¬ change between New En^and railroads and as to traffic originating and terminatiag on each railroad. Appar^tly the importance of sudi information and of haráig it fuxniáied Profesor Bipley was not then realized. The study of Prof®œr Ripley's report has empha- Hzed the importance of intra-New En^nd interchange in the solu¬ tion of the New England railroad problem. The statistics of interchange with reads outside New England during 1919 as shown on Chart 1 and 2 facing page 510 of Professor Ripley's report, apparently developed for the New England District as a whole under Federal oantrol, do not subdivide intorchange be¬ tween New England itmds. Further analysis indicates that about 35% of the œistbound treffic of the Boston and Albany is delivered to the New Hawn for local deliveiy on New Havai rails; and similarly, a large excess of the traffic from the Boston and hfeine, is for local New Haven delivery. From one of the statements in Exhibit A, entitled "Statistics show¬ ing trend or direction of carloads indicating existing routes and channels," which shows this data in more detail, the largely prevail¬ ing excœs of loads delivered and the wûie divergenœ as between the various eoimeetions, is brought out the following recapitula¬ tion; CentialNewJers^ (Parlvia Harlem Riv^) 29,186 17,829 192Î Received Delmred Boston and Albany. Boston arrd Maine. Peimsylvania 91,989 40,039 128,349 90,050 146,515 57,401 10,374 3,875 New York Central Lehigjh Valley. Long Island.. 50,022 9,307 4,284 8,156 11 ISËl Central Vermont 7,829 8,156 Erie n r r , - n n 47,929 10,383 Lehigh & Hudson (Includes B.&0., P.&E., D,L.&W. and part C.N.J.,) 86,135 20,933 Lehigh and New England 27,009 303 N. Y. 0. & W. 13,617 2,120 Miscellaneous 11,632 17,887 Total. 654,870 286,439 From these figures it appearsj first, that the intra New England interchange is heavy and important; second, that total of the East and West interchange preponderates largely; third, that the East and West interchange which includes the New York Central via the Boston and Albany, is spread throx;^ numocous gatermys; fourth, that materially enlarged concentration to and from any one trunk line would be impracticable; fifth, that no connection affords traffic in such great volume as to {mint to the desimbility of con¬ solidation on that account; and sixth, that it is to the interest of the New England public and the New Haven road to continue the best of cordial relations with each connecting road. For further illustration of the terminal fffiaracteiistícs, studies have been made and summaries derived for the New Haven—ONE. copies of which follow. (Freight received from and delivered to the New England Btmmship Company considered as local ficeight.) Summary op Seven Day Period of Interchange Carloads, October 16 to 22,1921, WITH ALL CONNECTIONS Date Reedjáa Local Overhead For deliv- For delivery ery on to another N. H. Baaread Deliveries Grig, on N. H. Percent. OS Over- hmd Traffù! October 16th 1804 131 466 5 October 17th 2031 176 580 6 October 18th 2048 234 700 8 October 19th 1860 153 767 6 - October 20th 2054 207 841 7 October 21st 2142 162 843 5 October 22d 2102 142 1013 4 Total 14041 1205 6210 6 12 Per mit. of Overhead (1205); to total of loads mîeived from con¬ nections for delivery on New Haven rails (14041), plus loads origina¬ ting on New Ifoven raife for delivery to connections (6210) ; i per cent. Summary of Seven Day Period of Interchange Carloads, October 14 to 20, 1922. WITH ALL CONNECTIONS Date Receipts Oserhead Far Miv- Fm- ddimp ery on to another N. H. Railroad Delimies Orig.m N. H. Percent. (^Over¬ head Traffic October 14th 2158 158 622 5 October 15th 2216 150 863 5 October 16th 2268 183 697 6 Oetobar 17th 2075 163 , 842 5 October 18th 2085 149 791 5 October 19th 2006 156 SOI 5 October 20th 2252 162 735 6 Total 16060 1119 6451 5 Percent, of Overhead (1119); to total of loads received from con¬ nections for delimy on New EÎaven rails (16060), plus loads origina- ing on New Haven Rails for delivery to connections (5451), 5 per¬ cent. ExMMt D, wHdi is suhmitted, shows the detaila of the two state¬ ments preceding. Exhibit E is a diagram illustrating carload inter¬ change for 1921 through all gateways. Without commenting on the ^eet of simflar statistics when applied to other New Bagland railroads, it is apparent that the New Haven is not only a terminal in a large degree for the Trunk Lines, but for other Imœ within New. England. This is obvious, when it is con¬ sidered that southern New England is a kr^ comumer of foodstuffs, feed, fuel, raw materials, rough stock, and materials for construc¬ tion; whereas the outbound shipments represent more largdy manu¬ factured goods. Because shippera in New Haven territory are so largely dependent upon Ihe New Haven for transportation, the polii^ has been devel¬ oped to pmmit tl^n to route traffic in both directions free from New Haven control or solicitation offering a fair field and no favor for tinffic agents of connecting lines, while the New Haven aims to provitk for patrons and Gonnœtûms a high chanmter of tm-minal service. This situation has been recognized in its policy with respect 13 to divisions, with a view to their adjustment on a basis not only otherwise equitable, but such that equality of service can te given without occasion for interfering with the desir© of shippms, or of representative of connecting railroads, to handle all of the traffic in accordance with their wishes. It is obvious that no other course would either satisfy or afford, both shippers and connecting lines of transportation, freedom of opportunity for shippers to select, or representative of coimecting roads to solicit fm, participating rout®; this is eœentially in their inti3®t, where such a large, important and populous tatritory is exclusively served to such a large degree, as is southern New England by the New Haven System. Only through a continuation of this policy, can the patrons of the New England roads be guaranteed a continuation of that essential stated by the Transportation Act as a condition precedent,—that in con¬ solidations, "competition shaU be presen^d as fully as possible and wherever pactitfflible the existing routes and dbannels of trade and commerce, shall be maintained." "Whatever in a selfish sense might be to the mutual interest of the New Haven and some of the systems with which it connects— and this also applies to the B®ton and Maine—^the obligation of the New Hhven to its patrons and to its many connection is far greater, to maintain open terminal service for all. Assuming consolidation between the New Haven and a Trunk Line, this would inevitably result in an attempt to control the move¬ ment of traffic and restrict it as against other gateways and other routes. Privileges of shippers, heretofore enjoyed freely, would be¬ come restricted in part by the provisions of the Interstate Com¬ merce Act, permitting a systmn to refuse to ôiort haul itself, and in addition, shipperB would gradually find thmnsdves under new influ¬ ences. The tendencies could not be other than restrictive, in the desire to secure all of the traffic possible for the consolidated sys¬ tem. Consolidation, however, would neither enlarge the gateways nor materially-increase transportation capacity. The movement of traffic and development of the system of rail¬ ways in New England, has been in connection with the nmnerous gateways. The capacity of these gateways and of the connecting fines, and the volmne of traffic they have handled, have both grown commensurately with traffic conditions and dmnands. It must not be overlooked that a large volmne of New Eogjand traffic is to and from pointe upon only one of its connectiorm—^not points that are common with other roads. A continuation of this traffic and operat¬ ing policy is e®ential, in order that every avenue of transportation 14 may be used to its best advantage, and there may be opportunity for each shipment to follow the route of least resistance and maxi- mmn advantage. Because of these situations, East and West con¬ solidations might very probably tend to the gradual growth of bar¬ riers against what is now the normal and advantageous interchange and flow of traflac within New England, and consequently influ¬ ences, perhaps disadvantageous, might tend to the realignment of market conditions and trade within New England. No Trunk Line has indicated a desire to consider absorption of New England roads on a basis with encouragement to the holders of their stock. The Interstate Commerce Commission's tentative valuation indicates a minimum value of the New England roads. Means have been suggested which will again bring about the real¬ ization of those values and a fair return upon them. The many holders of railroad securities in New England should be safeguarded, particularly in view of the possibility that through the support and cooperation of every interest, market value can be again restored to a proper level. The competitive incentive heretofore displayed on the part of the Trimk Lines, to participate in New England traffic, would dis¬ appear if one of the Trunk Lines should control in New England. Also it is highly probable that after acquiring control such Trunk Line might so act as to bring about a relocation of industry outside of New England where the net resulting from the handling of the traffic might be a httle more attractive. It has been assumed that Trunk Line consolidation would produce the "pocket book" needed by the New England roads, but where is the assurance? Would not their greater interest be found in the industrial development out¬ side of New England, with consequently greater advantages to their traffic elsewhere? Inflexibility would gradually come about in respect to rates, divisions, etc., other than those confined to the consolidated systems. The use by New England of any and all routes, water as well as rail, would almost surely suffer restriction instead of encouragement as now. The value arising from consolidation, for the creation of an ex¬ clusive route for the movement of fuel into New England, is debatable. The New England market must be supplied from various fields. This is necessary in order that the market may be wide open and the best results be secured as to quality, price, and delivery. This is desirable for protection, in case of interferences in any mining field or of transportation difficulties on any railroad or through any partie¬ ls ular section. Eastern New England normally receives its fuel from the southern fields by water; northwestern New England, all-rail from the northern coal fields; and similarly, southwestern New England, all-rail from the coal areas located more southerly. It has been assumed that with respect to the New England section of a consolidated system, it could be placed under the requirement to continue to serve the public in all matters as heretofore. If this is the case, it is apparently the thought that the Trunk Line which consolidated with the New England system would forego certain advantages and rights but would assume the financial obligation. Is this reasonable? Should a trunk line, for example, merge the New Haven, is it conceivable that terminal service for the other trunk lines would thereafter receive the same treatment as now? Does the history of railroads bear evidence of such instances of al¬ truism? Is this contemplated by the Transportation Act? Can it be conceived that other connecting carriers would antici¬ pate such a situation with equanimity? Would they not, and in all fairness to their point of view should they not, as in the recent case of the Belt Line in Chicago, take into the courts those questions relating to the probable restriction of their free open opportunity to receive hereafter that character of terminal service in New England that they have enjoyed heretofore? The operation by the New York Central of the Boston and Albany, has been cited as an instance, but in respect to the Boston and Albany, what has happened? The New York Central was obliged to finance large improvements. It was to their advantage to do so, because the Boston and Albany is a main stem of heavy traffic, serving not only populous centers en route, but bringing the New York Central into Boston, and consequently offered many advantages. The Boston and Albany is not loaded with the large proportion of light traffic lines, such as the Boston and Maine and the New Haven; lines which are largely non-productive in net, but which must be continued and operated in the pubhc interest. The principal traffic centers on the Boston and Albany are also served by the Boston and Maine and the New Haven. It was apparent that under such conditions, the Boston and Albany could be made profitable to the New York Central so far as its individual opera¬ tion is concerned, as an extension of the New York Central rails to Pittsfield, Westfield, Springfield, Worcester, Framingham and Boston. Enjoying a large degree of prosperity, because of concen¬ tration in a heavy traffic main fine, the New York Central was able to establish what is substantially an independent management, 16 located in New England and co-operating directly with the people of New England in all matters of joint interest. Should the Pennsylvania take the New Haven, or the New York Central take the Boston and Maine, it is inconceivable that public opinion in New England would countenance any other less favorable arrangement than an independence of management, with which the people of New England could directly handle their own affairs, and a continuation of the direct relations in this regard heretofore and now existing. Financial, physical and operating conditions of the Boston and Maine and the New Haven are so entirely different from those of the Boston and Albany, they are not an incentive to a Trunk Line which might effect a consolidation, to take a similar and popular course of estabUshing detached and independent managements; but would the New England public accept any other or less satisfactory course? The Boston Tea Party stands forth prominently in New England history. One of the important underlying motives in the program for the consolidation of railroads is that of diminishing gateways, unifying terminals, decreasing parallel or duplicating service, and consequently the bringing about of reduction in the costs of operation but without disadvantage to the pubhc. Consideration of each of New England's gateways and of the operation of the carriers both East and West of the same shows very clearly, that there are no beneficial prospects of this character with respect to New England; moreover, if a national system of railways should be brought about, it looks to us that the situation in regard to these matters, would be no different after than before. Concerning a remark that has been made at times, that New England.may be provincial; consideration must be given to the pos¬ sible effect that would follow a consolidation of part, or all, of the New England railroads on the East and West basis. Would not this create, for a portion, or all, of New England, a tendency toward provincialism, regionalism, or localism, as compared to the present status or that following a continued control by New England of its railroads? New England control enables the use of the fines of trans¬ portation in the best interests of New England; for connected use with each and every Trunk Line and the Canadian fines; and with the water routes; coastwise, via the Panama Canal, and trans-ocean. These opportunities to New England are a heritage, which undoubted¬ ly it will not willingly surrender. Instead of a tendency toward provincialism, home control is a large and valuable asset; of advan¬ tage not only nationally, but world wide. 17 In no other locality in the United States is there such an important concentration of population and industry. The transactions be¬ tween the public and the railroads are largely detail and much in excess of those of any other territory. They are essentially of a character requiring local control and home management. In no other section of the United States is there a locality such as New England within which the property and the operation of the serving carriers, is both located and owned within the same geo¬ graphical boundary; in which the character of transportation is of greater importance; and in which so many of the financial institu¬ tions, local to the territory, are so directly and so largely interested. From no viewpoint does it appear that practicable advantages can be brought about through East and West consolidations; from every angle, however, advantages appear from a continuation of home control and the promotion of home support. With the foregoing facts in mind, what plan has the New Haven with respect to the consolidation of New England railroads? Natural¬ ly the New Haven System, which should include the New York, Ontario and AVestern Railroad, prefers to continue to work with and to help and be helped by the public whom it serves, and their repre¬ sentatives. The New Haven System is the creation of economic and social forces operating through the last 85 or 90 years. Its growth has been logical. Its service is shaped and operated to the necessities of its patrons. It is home owned. Any consolidation is bound to produce alterations, adjustments and possibly some friction which will disturb and temporarily arrest or divert, the development of the transportation facilities. Moreover, the present management has a justifiable pride, in proving that its policy of intensive cultiva¬ tion will bear fruit. To bring back the New Haven System to its former high estate, is an ambition worthy of every effort and would entitle all who participate, to the highest encomiums of a grateful body of security owners and a well served pubhc. So far, from the record before the Commission, no other system seems anxious to have the New Haven until it has become prosperous, and its management, confident of the future, may be pardoned for not wishing to force an unwilling partnership. In point of mileage, if the routes of the steamship lines be included (and they really are additional tracks of the New Haven System between New York and their respective New England ports), the New Haven System is substantially as large as Professor Ripley's proposed Chesapeake and Ohio System and much larger than his Florida East Coast System. 18 Its operating revenues last year exceeded the operating revenues of ten of the twenty-one systems proposed by Professor Eipley, as shown on the basis of 1917, on Page 655, I.C.C. 12964. Its population per mile of line is more than three times that of the average in the United States. All in aU, it is a system by itself which its management has confidence, may be made to earn a fair return upon the value of its property devoted to the service of transportation, and with rates to promote the industries which it serves with the result of a mutual prosperity of the public and the carrier. And yet this hearing is to consider the consoUdation of railway properties of the United States into a limited number of systems. The facts evolved from the experience of Federal administration and war conditions, have bred in the public mind an opinion in favor of consolidations. The Congressional hearing which led to the passage of the Trans¬ portation Act, emphasized this fact. One of the strongest reasons for abandoning the provisions of compulsory consolidation, was the hope and expectation that the carriers would voluntarily do what Congress did not then force them to do. If this public opinion is to prevail, the New Haven then, in all the circumstances, concludes that a complete consoUdation of all of the New England railroads, except the two northern Canadian lines traversing Maine, is one which should if possible be brought about. This New England system should include the following: Bangor and Aroostook Maine Central Boston and Maine Boston and Albany Central Vermont Rutland New Haven Central New England New York, Ontario and Western And their respective leased, operated or controlled rail and water lines. These lines together, form a group performing a distinctive terri¬ torial service. They are not substantially competitive with each other. There is but little competition within New England. Such competition as there is between New England lines is substantially between New England points and points outside of New England, and this competition should and can be best promoted and continued, 19 through a consolidated New England system. Such a consolidation will insure to a degree not even now attained, the freedom of routing to all points beyond New England. In connection with the Ontario and the Rutland, it will afford New England the advantage of pos¬ sible rail and lake service to Chicago, Duluth and intermediate lake ports. In connection with the Central Vermont, Boston and Maine, and the Rutland, it will preserve Canadian connections. It will keep New England's face to the sea and enable her industries to eon- tinue to enjoy the advantage of water transportation to Atlantic and Pacific ports, and to exercise their choice of trading with all the world by sea as well as by land. There is value enough in the New England lines as the tentative findings of the Commission have already proved, to entitle them to a return which will be appealing to any of their investors. There is business enough in New England to bring that return There is money enough in New England to finance them. There are brains enough in New England to run its transportation systems and direct their policies. It is recognized that the lines to be included within a New England regional consolidation as proposed, are somewhat different from those proposed in system No. 7—New England, in that it includes the Boston and Albany, the Central Vermont and the Rutland, and excludes the Lehigh and Hudson River and the Lehigh and New England. The Central Vermont and Rutland are essential to the enjojunent of Canadian connections and one of them aids in the development of lake and rail operation. The two latter are only bridge roads which may well be continued under their present man¬ agement to perform their present functions. They form no part of a New England terminal system. They add nothing of substantial advantage to the New England group, so long as they continue to be operated as at present. Under New England grouping. New Eng¬ land will continue to be supplied through its present gateways and ports, with anthracite and bituminous coal from the many fields competing for its business. There is therefore no advantage, either traffic, operating, or other¬ wise, to add to the New England systems the roads in System No. 7A —Great Lakes. Those additional roads will bring to New England nothing, that is not already brought or can be brought by the other lines in the proposed grouping. System No. 3 does not commend itself to the New Haven. To restrict New Haven territory largely to the routes afforded by the Baltimore and Ohio, however eflnciently such a system may be man- 20 a^, would to a mistake, and the New En^nd public would not view with favor any policy which would restrict its complete freedom of routing, by any line b^nd the Hudson Biver. Our condxision, therefore, if ccmsohdations must be broi^ht about, is similar in most respects to that reached by Professor Ripley, excepting that it includes some New En^tand roato which he has not included, and excludes two of the lines west of the Hudson which he has included. The reaaons which he u^es in his able advocacy of a New England consolidation, seem to apply with even greater force to the grouping herein recommended. 21