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tion would be so great that we assume that the Commission would not object to the continuance of first and second class rates.

But if we are limited to a maximum of 3 cents per mile as a first class rate, we must of necessity reduce our second class rate to at least 2 cents per mile, if it is really to effect a separation of the one class of passengers from the other.

Our passage statistics have not hitherto been kept in such a way as to enable us to separate the mileage of first and second class passengers and the relative amount of revenue from each class, but with the best information that we have at hand we conclude that the application of a uniform three cent rate would bring about a reduction of at least 17 per cent. in our local possage earnings. In asserting this we would not have you to infer that we have no local rates less than three cents per mile. Here, too, the same local competition exists that was mentioned in the discussion of the freight tariff. The phosphate mines, which furnish a large number of our passengers, are adjacent to navigable streams, and steamboats compete at low rates for the transportation of laborers between these mines and Charleston. To secure any considerable part of this travel our company is compelled to accept the rates offered by these boats; yet to apply the same rates uniformly per mile over our entire line would so materially reduce our local passenger earnings that we would prefer to abandon the competitive travel to the boats rather than to submit to the reduction generally.

For the reasons here given, we request that we may be allowed an advance of fifty per cent. upon the Standard Passenger Tariff for first class passengers only, and that we may be permitted to apply special excursion rates at points where we meet with competition by water.

If in the opinion of the Commission we have not sustained our argument by sufficient statistics, we respectfully request that they will not for that reason make a decision adverse to our petition. We submit that the time within which we have been required to prepare this argument has not been sufficient for us to collect the information necessary to the compilation of such statistics. We therefore ask, if such be the opinion of the Commission, that further time be allowed us to gather and prepare such statistics in any form that may be required. We are specially anxious about this so far as the passenger business of the company is concerned. It furnishes about one-half of the gross revenue of the company and is largely derived from local travel. A change of rates as radical as is contemplated by the Commission will, if the opinion of the management of the road have any weight, seriously diminish its earnings. If the proposed change should be insisted upon, with the result anticipated, the finances of the company will be seriously affected; a deficit will ensue that

cannot be made good, even though the Commission should put an end to the experiment and restore the existing rates.

We beg further to submit that there are other causes which we hope will move the Commission to guard carefully against the establishment of tariffs for the Charleston and Savannah Railway Company that will diminish its present revenue. We expect nothing better at present than to earn the interest on its first mortgage bonds. To do more than this we believe that the local business of the road must be developed. We hope to do this by providing special facilities for opening up the phosphate mining region and for transporting its products to market. The local management of the road has submitted to the stockholders the outlines of a plan for the construction of branch roads into the mining districts, and of wharves at Charleston, specially designed for the economical and speedy transfer of phosphate rock from the cars at ship's side. The successful accomplishment of this plan is dependent upon the investment of additional capital in an enterprise at present unprofitable. We hope and believe that a consideration of the facts and reasons contained in this argument will enable the Commission to determine upon such tariffs as will maintain the gross revenue of our company and sustain its stockholders in the hope that the prospect for a dividend has not been diminished by the establishment of a State Commission.

In conclusion, the management of the road would assert their intention to honestly carry out the wishes of the Commission, even though they should differ in opinion as to the effect of their regulations, believing that such regulations will be modified so soon as it can be shown that they prevent our company from earning a just and reasonable return on its investments.

Charleston, July 23d, 1883.

H. S. HAINES, General Manager.
C. S. GADSDEN, Superintendent.
S. C. BOYLSTON, G. F. & P. Agent.

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