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much evidence in support of their allegations that their present class rates to and from the South are unreasonable. Included are demonstrations of rate humps near the borders of these territories because of combinations on this interterritorial traffic, in contrast with the relatively lower joint rates to the intermediate border points. Instances are recited by other shippers of resort to trucks to and from border points in order to benefit from such joint rates. Combination rates to western trunk-line stations from the South are sometimes higher than the transcontinental rates over routes through such stations.

In addition to rate comparisons of the character previously shown herein, the State commissions named above introduced statistical exhibits designed to prove that operating conditions on railroads in their States compare favorably with those in official and southern territories. In many respects the nature of this evidence is similar to that introduced in the western class-rate proceeding but relevant also to the issues herein.

South Dakota says that the Southern States rank next in importance to official territory, and ahead of the Southwest, as sources of interterritorial traffic, and the same is apparently true of most other western States; yet joint rates are available to and from the Southwest but not to and from the South.

SUGGESTIONS BY STATE COMMISSIONS AND SHIPPERS

In view of the fact that interterritorial class-rate structures have now been prescribed between most major rate territories, it is not surprising that in this investigation shippers, seeking a basis which they might suggest to replace the one they assail, should pattern it after one of the structures which has had our approval. Most suggestions offered are based on the adjustment prescribed either between official and southern territories or between official and western trunk-line territories.

The Wisconsin commission and Wisconsin and Minnesota shippers offer as their basis the official-southern adjustment. Specifically, they ask that the basis prescribed in the southern class-rate investigation for application between southern and Illinois territories be extended to include the Northwest and zone C in Wisconsin. Under this proposal rates would be determined by combining the K-2 scale rate prescribed for intraterritorial application between a given point in southern territory and the official-territory gateway with the appropriate Q-1 scale differential for the distance north thereof. The effect would be to place this part of western trunk-line territory, as to traffic to and from the South, on the same rate level as Illinois and central territories.

The commissions of North Dakota, South Dakota, Nebraska, and Iowa, the Topeka Chamber of Commerce, and shipper organizations in those States, suggest rates based on the revised western trunk-line distance scales, applied in accordance with the western trunk-line formula. In applying the formula it is proposed to make use of western trunk-line zones as defined in the western class-rate revision, except that certain changes in zone boundaries are asked by Kansas interests. B-1 and B-2 territories in southern Missouri 10 would be treated as in zones II and III, respectively. Hauls through the Southwest would be considered as in zone III, and those through differential territory in Texas and Oklahoma, as well as through New Mexico, as in zone IV. The South would be treated the same as official-Illinois territories, taking the lowest or basic scale.

The North Dakota commission suggests as an alternative basis the so-called furniture formula used in Furniture, 177 I. C. C. 5. There joint rates on furniture between southern and western trunkline territories were made certain percentages of constructive class 1 rates. So far as western trunk-line zone I and extended zone C in Wisconsin are concerned, this formula would produce rates identical with those made under the southern formula advocated by Minnesota and Wisconsin interests. Rates to and from the other zones would be made by the addition of the zone differentials in accordance with the western trunk-line formula.

As indicated, the attitude of many southern shippers is that they do not desire the establishment of a joint class-rate structure, but that, if such rates are prescribed, they should, for competitive reasons, be on the same basis as those between official and western trunk-line territories. Certain southern interests, among them the Kentucky commission and shipper organizations in southern Virginia, specifically advocate that basis.

The New Orleans Joint Traffic Bureau suggests rates made on the formula set forth in the original report in Cottonseed, Its Products, and Related Articles, 188 I. C. C. 605, referred to as the cottonseed or rate-per-mile formula. In that report it was provided that rates for application through two or more regions would be the aggregate of the rates prescribed in each region "ascertained by applying the same rate per mile for the transportation therein as would be proper if the transportation services were performed by the carriers wholly within that region." Ibid., page 657. Proposals based on this formula are also made by certain shipper organizations of eastern Iowa. For the reasons stated in the supplemental report in the

This formula is set forth in footnote 4, page 600, of the sixth supplemental report in the western class-rate proceeding. It is used there and in the twenty-first supplemental report in the southwestern revision.

10 As defined in Interstate Rates in Missouri, 181 I. C. C. 259.

proceeding just cited, 203 I. C. C. 177, we abandoned the formula described and substituted rates made on a different basis.

A number of witnesses for shipper interests indicate as a possible basis the application of the western trunk-line formula, with southern territory taking the same rate level as western trunk-line zone II. This was the basis employed in the twenty-first supplemental report in the southwestern revision in fixing rates between the South and the Southwest.

In appendix A hereto is a comparison of the present class rates between representative points in western trunk-line and southern territories with those which would result from the application of certain of the formulas above described.

GOVERNING CLASSIFICATION AND EXCEPTIONS

As stated, most of the present class rates between western trunkline territory and the South are combinations, the southern factors being governed by southern classification and the northern factors usually by western classification. Where joint rates exist they are, with a few exceptions, governed by western classification.

Obviously, through one-figure rates, such as suggested by complainants and other shippers, must be governed by a single classification. The Minnesota and Wisconsin shippers advocate the use of southern classification, which governs the southern-official class-rate structure, upon which their rate suggestion is based. Most of the interests advocating rates made on the western trunk-line formula, including the commissions of North Dakota, South Dakota, and Iowa, and the Topeka Chamber of Commerce, urge application of the destination-classification principle which was largely applied in connection with interterritorial rates between official and western trunkline territories in the sixth supplemental report in the western classrate revision. In accordance therewith rates from the South to western trunk-line territory would be governed by western classification, while those in the reverse direction would be governed by southern classification.

The classes in the two territories and the percentages of the lower classes to class 1 fixed in the western and southern class-rate revisions are as follows:

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ation, considered of vital importance by upted by application of through interpposition was offered by either responest of these interests. Grain and grain 14 the application of the interterritorial southern class-rate investigation, alhave reduced existing combination comwill be taken here.

eatment come from shippers of textile ouse products, stoves, natural stone, of these we have prescribed or apty rates between western trunk-line rates would not be affected by the ates herein prescribed. As to other "ehend that if interterritorial class persede lower combinations on the lings will include a requirement ys shall be observed as maxima. when reasonable joint class rates instances, supersede present comle, make unnecessary the mainto and from the gateways, now

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ND CONCLUSIONS

(3) of the act to establish

joint rates, for the transleem it to be necessary or om unreasonableness demonisons with other interterrions between all adjoining and southern territories, would be greatly faciliclass traffic between the ch now moves on com

ible rate structure is freight. A showing for the maintenance ent may be a good al joint commodity > represent a basis

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