"(7) A uniform price list for all materials was used, thus ignoring the source of supply and cost of delivery to point of use."

This, again, is not true. Differences were made between the Upper and Lower Peninsulas; and an exhaustive study was made of rates to different sections. It is believed that the prices adopted took all these points fully into consideration. It is true that no effort was made to use different unit prices as between counties, but, in a number of cases, differences in prices were made for different sections of the State, where either local conditions as to production of materials, or traffic rates, seemed to warrant.

"(8) No allowance was made for interference with work on account of labor troubles, condition of the weather, etc., which would vary materially in the different counties of the same state."

True. Nor is such allowance ever made in actual construction, beyond the contingency item. Such items are a frequent source of annoyance, delay, and sometimes of expense, but an expense difficult to separate and set up, and clearly belonging to contingencies.

"(9) No allowance is made for carrying charges until such time as the road was placed on a revenue basis."

True; and such item is not a part of a physical appraisal.

The foregoing nine points are classed as "among other things" open to criticism. The next two quoted paragraphs are introduced to indicate the "other things" as they appear. These are mainly non-physical or intangible elements of value, which, under the method of Professor Adams, are treated en bloc, and which, from their nature, it would be impossible to set out and value separately; therefore, no effort is made to answer them point by point, further than to say in general that, if there is any value attaching to these items, it was presumed to have been disclosed by the method of Professor Adams, and to suggest further that had Professors Cooley and Adams had such an advocate of intangible values ten years ago, their labors would have been lightened, as all arguments by railway officials at that time were against the use of any such elements of value in an appraisal.

"No consideration has been given to the leasehold interests.... Therefore it will be seen there remains to be determined many questions vitally affecting the value of the property without regard to its value as a 'going concern.'

"There should be no difference in the basis of arriving at the value, as a 'going concern,' of the property of a railway and any industrial establishment, nor should there be any difference in the basis of valuation for taxation [exactly what Governor Pingree maintained] or other purposes. There is common to both the value due to location, good will, etc."

While the remainder of the address in question contains no specific criticisms of methods of valuation, it does go into a discussion of sundry legal decisions; and conclusions are drawn quite at variance with those set forth elsewhere in this paper. The thing most noticeable in the entire address is the lack of a proper spirit of fairness, an apparent inability to state fully and fairly the position of the men whose views are being opposed, and an undue emphasis in quoting some public official whose views coincide for the time being with the theories which are being advocated. The fact that Mr. Williams quotes from an address of Hon. Robert H. Shields, President of the Michigan Tax Commission, a statement criticising the work of Professors Cooley and Adams, illustrates the latter point.