The necessity for making lower rates to Columbia than to intermediate points is based upon the fact that the rate from Eastern cities to Columbia is made by the ocean rate to Charleston plus the rate of the South Carolina Railway Company, whose rates are made by the South Carolina Railway Commission, and which rate is worked by us.

The rate to Augusta is made by the ocean rate to Savannah plus the Georgia railway commission's rate to Augusta, which in turn is governed by the river competition from Savannah to Augusta.

The rate to Atlanta is made by the ocean rate to Savannah plus the authorized rate of the Georgia railway commission from Savannah to Atlanta. The same is true of Athens and Gainesville, which rates are worked by us. The maximum rates between Gainesville and Atlanta are none of them higher than the Gainesville and Atlanta rate. The distance between Gainesville and Atlanta is 53 miles, the volume of business being inconsiderable as compared with the Atlanta and Gainesville tonnage.

The rate to Goldsborough, N. C., is controlled by the lines working through the Chesapeake Bay by water to Portsmouth, Va., and thence by rail to Goldsborough. This line in turn is controlled by water to New Berne, and thence by the local rate of the Atlantic and North Carolina Railroad from New Berne to Goldsborough, which makes a lower rate than either our line or the line via Portsmouth.

It will be observed that the rates to Gainesville, Atlanta, Athens, and Augusta are made the same from Boston and Providence as from New York and Philadelphia, while stations north of Gainesville, north of Athens, and north of Augusta, are made 5 cents per 100 pounds higher from Boston and Providence than from New York or Philadelphia This results from the fact that the lines working through Savannah and Charleston

make the same rates from Boston and Providence that they do from New York and Philadelphia, while the points to which we make rates are 5 cents per 100 pounds higher from Boston and Providence than from New York and Philadelphia. Our Boston and Providence water connection is from West Point, Va., as is also our New York connection, the former demanding much larger proportions than the latter.

The through rates from the West to points on our lines are not made by us. We charge from all our junction points a fixed rate, which is lower for the long haul only in the case of Columbia, S. C., and Athens and Gainesville, Ga., and points between there and Atlanta. These rates are governed by the same causes as exist in the matter of Eastern rates, our Athens business being worked exclusively via Atlanta.

The rates from Eastern cities and Richmond to points south and west of Atlanta are made by the lines most interested in that traffic, according to the necessity of meeting competition by the water lines working into the South Atlantic and Gulf ports, by adding to the water rate to the ports the shortest rail rate to destination, we working the same rates through Atlanta and Paint Rock as are made by our competitors. The rates from Richmond to the points noted herein are made on the same basis as from Eastern cities, by deducting from such rates the differences that experience has shown to be equitable as between that city and the Eastern cities.

These differences have been fixed, either by agreement or arbitration, by the lines from and via Savannah and Charleston against the lines from and via Richmond.

The rates between the local points on our line and the above-named points are made on the lowest combination; but where such combination is higher than the Richmond rate that rate is used, so that no higher intermediate rate obtains.

We have been, and are, most desirous of complying with the terms of the interstate law, and have arranged our rates for this purpose by the best advice and consideration we have been able to give to the question, and believe that we have complied with its spirit and intent. We do not, of course, claim to have our rates absolutely perfect in this respect, as we find, daily, omissions and errors which are called to our attention either by complaint of shippers or by daily contact with the tariffs. As fast as these discrepancies appear we correct them; but in many cases it is impossible to quote rates from our smaller stations to all of the territory we reach by the lines beyond us, and in such cases, where the shipper omits to ask the agent for rates, shipments are occasionally made in which overcharges occur.

To reduce our local rates to the plane of the lowest competitive rate would result in the loss of such revenue as would make it impossible to sustain the property.

The accompanying diagram shows the changes and reductions we have made in our rates for the purpose of complying with the law, and are submitted as a part of this communication.

If our construction of the law is at any point at variance with that of your honorable body, we shall be glad to make any changes that you may direct.

Yours, truly,

SOL HAAS, Traffic Manager.

P. S.-In reference to passenger rates, there are none less for longer distances than short. C. C. MCCAIN, Esq.,

Auditor Interstate Commerce Commission.

RICHMOND, FREDERICKSBURGH AND POTOMAC RAILROAD.

DEAR SIR: In reply to your circular of the 20th instant, I beg to state that between this city and the cities of Baltimore, Philadelphia, and New York there are water lines of transportation which make the rates of carriage of freight traffic.

In order to secure a portion of this traffic we use rates that in some cases are lower than those charged to and from some intermediate points. To state elaborately the points so treated and rates so made to or from such points would be to quote the several tariffs of interstate rates, of which we have forwarded you copies.

The fourth section of the act to regulate commerce is strictly observed, and no charges for transportation on this line are greater for shorter than for longer distances in the same direction over the same line, except when the water competition renders the cir cumstances entirely dissimilar. Trusting this information may be satisfactory.

Very respectfully,

C. C. MCCAIN, Esq.,

C. A. TAYLOR, General Ticket and Freight Agent.

Auditor Interstate Commerce Commission, Washington, D. C.

ROME, WATERTOWN AND OGDENSBURGH RAILROAD.

GENTLEMEN: Your circular inquiry of October 20 is received. In reply I have to say that there are points on the railroad of this company from which interstate rates are made, such as are designated by the first paragraph of your circular above referred to. The points so treated and the rates made are disclosed in our letter to the Commission dated April 18, 1887. The circumstances and conditions of the traffic are therein fully shown.

The same circumstances and conditions still exist. Your letter dated April 27 gave permission to this company to continue for a time to afford to the places named that enlargement of facilities by a reduction of rates which this company must otherwise, as explained in its letter of April 18, have immediately withdrawn. The limit of time set by your letter of April 27 has been construed by this company as a limit fixed with a view to the possible discontinuance of that competition which its rates were especially to meet, and also with regard to probable convenience of the Commission in passing finally upon the question as to which the position of this company was regarded as prima facie correct. The published statement that upon the expiration of such orders of temporary permission the companies must exercise their own judgment, instead of applying for renewals, will account for this company's having followed the indication above mentioned.

GENTLEMEN: We respectfully beg to be relieved from the operation of section 4 of the interstate-commerce bill in the following cases:

The Grand Trunk Railway Company of Canada makes passenger rates from the undermentioned points, all of which are junction or terminal points on the line of the Rome, Watertown and Ogdensburgh Railroad, as follows: From Norwood, Ogdensburgh, Morristown, and Clayton to Chicago, Ill., first class, limited, $16; second class, $15; and to Detroit, first class, $12; second class, $9.50.

In the past it has been customary for this company to sell tickets for the same rates quoted by the Grand Trunk Railway from the above-named points.

The through lines to Detroit and Chicago over which our passenger business is forwarded are as follows:

(1) Rome, Watertown and Ogdensburgh to Syracuse, New York Central and Hudson River Railroad or West Shore Railroad to Buffalo or Suspension Bridge, and by connecting lines to Detroit or Chicago.

(2) Also Rome, Watertown and Ogdensburgh to Lewiston or Suspension Bridge, and from Suspension Bridge by connecting lines to Detroit or Chicago.

(3) Also by the same line to Lewiston and Suspension Bridge, thence by the New York Central to Buffalo, and from Buffalo by connecting lines to Detroit or Chicago. (4) Also via Rome, Watertown and Ogdensburgh to Rochester, thence via New York Central, via Buffalo or Suspension Bridge and connecting lines, to Detroit or Chicago. In the case of the first of the above-named through routes the first-class fare from Syracuse to Chicago is $17, while the rate quoted by the Grand Trunk road from Ogdensburgh, for example, is $16. The distance from Ogdensburgh to Syracuse is 142 miles. The first-class fare from Watertown to Chicago is $18.18, and will soon be increased to $19.18, on account of the difference in rates from Buffalo to Chicago, the Watertown rates being based on Buffalo. The aggregate of the business from intermediate stations is deemed by us to be of more value than the business at the above-named points directly in competition with the Grand Trunk road, and therefore, under the long and short haul clause, we are compelled either to relinquish the business at the points named in competition with the Grand Trunk railway or else reduce our fare from points south and west thereof to the same rate as is made by the Grand Trunk Railway at the firstnamed places, and even at that we would not have the right, under the provisions of the

bill, to reduce the fare at intermediate local stations on our line, because the fare from Syracuse, the principal junction point, to Chicago, over which we have no control, is $17 and we could not name any lower rate from points on our line for business going that way. At present our first-class limited rates from all the points named are the same, $18.18, and will soon be $19.18, as against $16, quoted by the Grand Trunk Railway.

It seems as if the traveling public of northern New York should be able to travel to Chicago via American lines for the same rate as via Canadian lines, and it does not seem to be a discrimination against the intermediate stations that we are compelled to make a lower rate from points on our line in competition with the Grand Trunk Railway of Canada, although the distance from such competitive points is greater than it is from intermediate stations, Syracuse and other places.

Furthermore, the rate via the Grand Trunk Railway from Brockville, Ontario, a station on their line opposite Morristown, N. Y., is $14.50, second class to Chicago, and the same from Gananoque, a station on their line opposite Clayton, N. Y., and from Alexandria Bay, a summer resort on the St. Lawrence River, the rates quoted via the Grand Trunk Railway are $16, first class, limited, and $15, second class, to Chicago, and from Kingston, Ontario, opposite Cape Vincent, N. Y., the first-class limited rate is $16 via the Grand Trunk Railway, and second class $14.20, to Chicago.

Unless we meet these rates made by the Grand Trunk Railway, the business will necessarily all go via that line. We therefore respectfully beg to be specially exempted from the operation of the long and short haul clause of the act so far as our business in competition with the Grand Trunk Railway of Canada is concerned, which may be briefly stated as follows:

We desire to charge from Norwood, N. Y., Ogdensburgh, N. Y., Morristown, N. Y., Clayton, N. Y., Alexandria Bay, N. Y., and Cape Vincent, N. Y., to Detroit, Port Huron, and Chicago the same rates which are made by the Grand Trunk Railway and are used as basing rates for making up through rates to the West; and also, in case the rate from Prescott, opposite Ogdensburgh; from Brockville, Ontario, opposite Morristown; from Gananoque, opposite Clayton; and from Kingston, opposite Cape Vincent, all of which are stations on the Grand Trunk Railway, is at any time made less than the rates in effect from stations in New York State opposite the Canadian points herein named, we desire authority to meet the rates from said Canadian points.

Furthermore, we desire authority for charging less for a longer than for a shorter distance from stations intermediate between those herein named as competitive with the Grand Trunk Railway and our several junction points at which we hand the business to our connecting lines, such rates in no case to be greater than would accrue from adding local rates from the intermediate stations on our line to the rates charged by the Grand Trunk Railway of Canada from points herein before named.

Your early consideration of our petition is respectfully requested.

For reference as to the location of this line of railway and its several connections, I inclose you herewith a map of the same.

Very respectfully, yours,

STATE OF NEW YORK,

County of Oswego, ss:

THEO. BUTTERFIELD,
General Passenger Agent.

I, Theo. Butterfield, being duly sworn, depose and say that the annexed petition is true to the best of my knowledge and belief.

THEO. BUTTERFIELD.

Subscribed and sworn to before me this 18th day of April, 1887.

F. H. MOORE,

Notary Public, Oswego County, N. Y.

The INTERSTATE COMMERCE COMMISSION, Washington, D. C.

SEA-BOARD AIR LINE.

DEAR SIR: Replying to your circular of October 20, 1887, there are no points on our line between which rates are lower for long distances than for short. There are, however, many points beyond our line controlled by the competition of other lines, both rail and water, but over which we have no control or authority, and the competition of which lines we have to meet as long as the revenue therefrom is remunerative.

These rates, we think, are in strict conformity with the law, as could be explained to your satisfaction should opportunity for such explanation arise.

We have made many changes since April 5 in order to bring our rates within the intention of the law.

Yours, truly,

C. C. MCCAIN, Esq.,

Auditor Interstate Commerce Commission.

SOL. HAAS,

Traffic Manager.

ST. LOUIS AND SAN FRANCISCO RAILWAY.

In submitting replies to the circular of October 20, the above company states that it makes certain exceptions to the long and short haul section of the act, and in connection therewith further states that:

"The reasons for making these rates are to meet water competition, and in a few instances to meet competition of a shorter direct route. In no case have we named rates in opposition to the short haul principle of the law except for these reasons, for which we feel that we are fully justified by the law and in accordance with the spirit of the decisions previously rendered by the Interstate Commerce Commission." H. L. MORRILL, Second Vice-President and General Manager.

ST. LOUIS, ALTON AND TERRE HAUTE RAILROAD COMPANY. DEAR SIR: Replying to your favor of the 20th, will state that we make no interstate rates by the road operated by this company, as they are located wholly within the State of Illinois.

In connection with the Illinois Central, a connecting line, we are making rates to Memphis, Vicksburg, New Orleans, and perhaps some other river points in competition with the Mississippi River, and which are somewhat lower than rates to intermediate points located on connecting lines.

To some junction points on the Illinois Central road in Kentucky, Tennessee, and Mississippi we are making less rates than are made to intermediate points on the same line. The rates to these junctions are made up of rates down the Ohio and Mississippi Rivers to Cairo, Hickman, Vicksburg, etc., added to the local rail rates from these points. These rates are made necessary by the roads in Louisville, which are regulated by the competition of the Ohio River. The junction points are Fulton, Ky., Martin, Milan, and Grand Junction, Tenn., Holly Springs, Grenada, and Jackson, Tenn.

But in this we are attempting to keep ourselves within what we understand to be the interpretations of the national law as promulgated by the Commission, our company receiving the same revenue for the junction points as it receives on intermediate stations, where the through rate is higher; and in no case does our company make a higher total rate from any point in Illinois, local or otherwise, to any of the points named above, than is made from Saint Louis or East Saint Louis, where water competition exists, although we are now of opinion that we would not be violating the law if we were to charge a reasonable freight rate advance over the rates prevailing from Saint Louis on shipments from our purely local stations in Illinois. If we are not correct in this interpretation of the law, please advise.

Yours, very truly,

C. C. MCCAIN, Esq.,

GEO. W. PARKER,
Vice-President and General Mana

Auditor Interstate Commerce Commission, Washington, D. C.

SAN ANTONIO AND ARANSAS PASS RAILWAY.

DEAR SIR: Your favor of November 23 was duly received, but the circular letver of October 20, to which it refers as remaining unanswered, was not, otherwise it would have had attention.