many cases impossible, to replace such employees at the rates of wages which our revenues permit us to pay.

Despite the fact that in many lines of industry wages are extremely high, there are many others in which they have not risen in proportion to the apparently unavoidable increase in living expenses, so that such attempts as have been made by public utilities to increase their net revenues through advances in rates have frequently been vigorously contested by consumers, and it appears to be necessary, therefore, to curtail expenses whenever practicable.

For a considerable number of years it has been generally felt by the executives of public utility companies that a large portion of the material called for in the annual reports required to be made by such companies to the Commissions is unnecessary from any standpoint with which the companies are acquainted. The material complained of is useless to the companies compiling it, and they are not able to find that it is useful either to the Commissions or to the consumers served by the companies. The companies observe that when cases arise affecting them specifically or individually, they very rarely, if ever, escape the requirement of extended special compilations, and that the mass of statistical material which they have already submitted in connection with their annual reports to the Commissions finds little or no application.

I take it that we may justly assume that the Public Service Commissions acting as trustees for the public interest will not require us to make any extended argument against a policy which results in useless expense or in expense which, if not entirely useless, produces no commensurate benefit; and that under the burdens which now oppress us, and in some instances threaten to overwhelm us, they will not take it amiss if we beg of them that they will make a critical and unbiased review of their annual report requirements, particularly of those in the statistical portion of the reports, with the purpose of eliminating therefrom during the period of the war and for a couple of years thereafter until the period of reorganization is substantially completed, every requirement which can not be clearly and positively shown

to be productive not only of interesting information but of essential information, information clearly of public importance and directly useful in facilitating the regulatory supervision of the public utility companies. Under the stress of war, we are constantly and properly being urged to eliminate all useless and unnecessary expense, and to draw a clear and sharp line of demarcation between essential and nonessential industries. Much of the statistical matter now called for in the forms for annual reports to Commissions seems to be only generally informative and not at all essential to the proper discharge of the regulatory or supervisory functions of the Commissions.

We make these suggestions in the interest of economy and efficiency and in the interest of conservation of man power. We are facing a most serious shortage in our clerical forces, which are much depleted by voluntary enlistments and by the requirements of the draft, also by competition of war industries, and although we are using women clerks wherever practicable, we find it impossible to secure sufficient clerical labor to do the essential work of accounting and statistics necessary for the administrations of the companies.

The National Electric Light Association's Committee on the Form of Annual Reports to Commissions has for several years had this matter under consideration, and it presented at the annual convention of that Association held in Chicago in May, 1916, an extended and valuable report on the subject. The report is shown beginning on page 21 of the volume of the Association's Proceedings for that year devoted to the sessions of the Accounting Section, and the discussion of the report is shown beginning on page 176 of the same volume. I presume that you will find that volume in the files of your Commission; if you do not find it there, please let me know and I will try to procure a copy for you.

You will recollect that about a year ago upon request of the railway companies and with the approval of the National Association of Railway and Utility Commissioners, the Interstate Commerce Commission very materially reduced its annual report requirements, withdrawing many

schedules completely and largely reducing many others. We hope that your Association will take similar action this year with respect to the annual report requirements imposed on electrical corporations by the Utility Commissions of the various States, and we should very much appreciate the privilege of a conference with your committee at an early date, at such place as may be most convenient for you, at which these matters may receive thorough discussion and careful consideration.

Very respectfully,

(Signed) W. J. MEYERS, Chairman,

Committee on Form of Annual
Reports to Commissions.

We were unable to secure any response to the letter, and the lack of action on the part of the Committee was called to the attention of the acting president of that Association, who was later elected its president. He promised that for the current year he would appoint a committee which would give the matter careful consideration.

When it became apparent that we would not receive from that committee consideration in time to enable us to secure any aid from the National Association of Railway and Utility Commissioners, we determined to act through the Executive Committee of the Accounting Section, and on October 4, 1918, the Executive Committee adopted the following series of resolutions on the subject and ordered that copies be sent to each Public Service Commission having authority to require annual or other reports from electrical corporations:

The Executive Committee of the Accounting Section of the National Electric Light Association is deeply concerned over the conditions prevailing generally in the offices of the member companies in regard to shortage of man power, and more particularly at the extent to which employees long in the service of the respective companies, experienced and in many instances specially educated by the companies to discharge their important duties, have, because of the war, sought or been compelled to take up other lines of work. These experienced, capable, reliable men have been replaced

by inexperienced youths and old men, but principally by women, many of whom have had no previous business experience whatever. As a result of this situation, the office work has been delayed, errors are frequent, and the time of the higher accounting officials has been almost entirely employed in engaging and breaking in new help, and the work of the office has been confined to only essential records which must be kept as long as the business is operated. Thus statistics in regard to physical property, details of current production, interesting but not immediately essential cost data, are no longer prepared and will not be while the war lasts. In seeking ways by which the time of the present depleted and inexperienced forces may be devoted to strictly essential matters only, the attention of the Committee has been called to the form of annual reports called for by the Public Service Commissions of the various States. The reports are voluminous and exhaustive compilations of minute facts of historical, financial, physical and statistical data, repeated year after year with but slight variation. The reports in these respects contain but little data which the companies for their own information and action would feel justified in preparing, the companies relying in necessary instances upon data accumulated in previous years. The times require the conservation of man power, the elimination of all records and data not necessary to the immediate operation of the enterprise, and the utmost economy in the use of paper and all office paraphernalia.

In view of the conditions here described, the necessary elimination of non-essential records and the need of the strictest economy in operation, the Committee is of the opinion that the Public Service Commissions of the various States should cooperate with the companies in their respective jurisdictions and that one way in which this cooperation may become most effective will be in cutting down the size of the annual report and confining its scope to cover only the financial transactions, including the Income Statement and Balance Sheet with suitable explanations of the variations disclosed by the report, and in addition a terse statement of Important Changes occurring during the year. In further

ance of these views the Executive Committee of the Accounting Section of the National Electric Light Association, at its meeting held in New York, on October 4th, unanimously adopted the following resolution:

WHEREAS, the needs of the United States in the prosecution of the war have made very serious drafts on the experienced forces of employees in the accounting and other departments of electric light companies and compelled their replacement by inexperienced and sometimes incapable employees, and

WHEREAS, the heavily increased expenses to which these companies are and have been for the last two years subjected through extremely high costs of material, high wages, and high taxes, make it necessary that every avoidable expense be eliminated,

BE IT RESOLVED, that the Chairman of the Committee on Form of Annual Reports to Commissions be directed to communicate with the chairmen of the various Public Service Commissions throughout the United States and to request that such Commissions reduce for the period of the war and at least one year thereafter their requirements with respect to annual reports so that they shall call for only a balance sheet, an income account, and a brief statement of important changes during the year, with such explanatory statements as may be necessary to make the statement of important changes intelligible.

BE IT FURTHER RESOLVED, that the said Chairman request all State and Geographic Sections of the Association to cooperate in securing relief from what are under present conditions the extremely burdensome requirements of the forms heretofore used by Public Service Commissions in receiving annual reports from electric light companies.

FURTHER RESOLVED, that copies of this preliminary statement and these resolutions be forwarded by the Secretary of the Association to all Federal and State Boards interested and whose cooperation may be helpful in bringing about the result which this Committee