Electric franchises in New York City

Front matter

' BY

LEONORA ARENT, M. A. ' /f<'^2 - \

Professor of Economics in Saint Mary-of-the-Woods Oollege

Preface

To ascertain the status of the franchises held by the electric-Hghting companies of New York City is the purpose of this study. In 191 o Mr. Milo R. Maltbie, then a member of the PubHc Service Commission for the First District, submitted to the Commission a report on the franchises of electrical corporations in Greater New York, analyzing the franchises granted by the different political subdivisions now consolidated in Greater New York, and setting forth the existing rights and obligations of the electric light companies. Since then litigation has been in progress regarding the validity of important franchises, and changes in intercorporate relations have been effected by a recent merger. This study devotes attention as well to the subjects of franchise by acquiescence and of the duration of grants in which no time limit is expressed.

Records in the Bureau of Real Estate of Corporations and Special Franchises in the Department of Taxes and Assessments of New York City and reports of the electric-lighting companies to the Public Service Commission have been consulted for data concerning the special franchise valuations discussed in the opening chapter. Mr. M. S. Howard, an accountant of the Public Service Commission, has rendered assistance in interpreting the reports of the companies. Helpful suggestions have been received from the Bureau of Special Franchises of the State Tax Department. In particular, the writer acknowledges indebtedness to Professor E. R. A. Seligman for the help received from his lectures on taxation.

FREf^ACE

Access to the Public Service Commission's files in its Franchise Bureau and Filing Department has facilitated the compiling of material. For the many courtesies extended by Mr. L. G. Benedict, of Counsel for the Consolidated Gas Company of New York, Mr. VV. J. Meyers, Secretary of the United Electric Light and Power Company, and Mr. Vincent Victory, Assistant Corporation Counsel for the City of New York, the wrif^r expresses appreciation. The writer is under heaviest obligations to Professor Howard Lee McBain, whose valuable time has been given with the utmost generosity in guidance and constructive criticism throughout the preparation of this study.

Contents

PAGE

CHAPTER I Electric Lighting Companies of New York City

Introduction i . . . . 15

National interest in government ownership 15

New York City and municipal ownership 15

Democratic platform and Governor Smith's speech. ... 15

Adverse comment on speech of Governor 16

Plan of present study 16

To keep neutral attitude toward relative merits of public

and private ownership • . . . . 17

To find present status of franchises of companies ..... 18

Franchises and franchise-granting authority 18

Definition of franchise 18

Supreme authority of State 18

Delegation of power to cities 19

Terms used to designate a municipal franchise 19

Boroughs of New York and companies operating in each 20

ERRATA.

P. 46, line 17, for "than" read "then".

P. 108, line 6, for " four " read " three ".

Commission's consent to issuance 01 oonas \e,/

Memorandum concerning merger and bond issue 29

Special franchises 32

Definition 33

269] 9

10 CONTEMS [270

PAGE

Total assessments in New York City • . . . 34

Assessments of electric-lighting companies .... 36

Valuation of intangible part of special franchises 38

Net earnings rule 39

Valuation of intangible part of special franchises of electric-lighting

companies 40

Data used 40

Table showing valuation 47

Discussion of table 48

CHAPTER II Franchises Claimed by Operating Companies

The report made by Mr. Maltbie 52

Table of report, showing area of electric-light franchise divisions of

Greater New York 53

The New York Edison, United Electric Light and Power, and

Long Acre Electric Light and Power Companies 57

Old political subdivision granting franchises 57

The New York Edison Company * . 58

The United Electric Light and Power Company and the Long Acre

Electric Light and Power Company 59

The Bronx Gas and Electric Company and the Westchester Lighting Company 61

The Edison Electric Illuminating Company of Brooklyn and the

Flatbush Gas Company ...... 63

The New York and Queens Electric Light and Power Company . 66

Transfers of franchises 72

The Queens Borough Gas and Electric Company 73

Existing rights of company ... 76

The Richmond Lightand Railroad Company (Electricity Division) 78

Existing rights of company .... 82

271 J CONTENTS 1 1

PAGE

Duration of grants and the charter of Greater New York 84

Franchise by acquiescence 85

Franchise by private contract 86

Franchise by annexation • - 86

CHAPTER III Franchises granted by the old city of New York 88

The Electric Lines franchise 88

The first Harlem franchise 88

The franchise of the Waterhouse Electric and Manufacturing

The Mutual franchise 89

" Franchises " granted by board of electrical control 89

Franchises in the Borough of Queens 90

Flushing village franchises 90

The Dykes grant 91

Grant of 1892 ■ 91

Town of Jamaica franchise ..... 91

Woodhaven Electric franchise 91

Village of Jamaica franchises 92

The American franchise 92

Jamaica Gas Light Company franchise 92

The Browne franchise • . . . 92

Jamaica Electric Light Company contracts 93

Rockaway Beach village franchises 93

The Seaside franchise 93

The Wainwright-Hammell franchises 93

Franchises in the borough of Richmond . 94

Introductory paragraph 94

Village of New Brighton franchises . 94

Village of Edgewater franchises 95

Village of Port Richmond franchises and contracts 96

Town of Northfield grants 98

Town of Middletown contract , 99

CHAPTER IV The General Manufacturing Corporations Act

Franchises in system of Edison Electric Illuminating Company of

Brooklyn 100

Franchise to Charles Cooper and Company 100

Franchise to Pope, Sewall and Company loi

12 CONTENTS [273

PAGE

The Edison franchise loi

The Kings County Franchise loi

The State Franchise loi

Litigation involving State franchise 102

Remaining franchises and general manufacturing corporations act. 107

Chapter 37 of the Laws of 1848 107

Chapter 40 of the Laws of 1848— the general manufacturing

corporations act .... 107

Chapter 512 of the Laws of 1879 108

Chapter 73 of the Laws of 1882 108

The case of Clements v. Edison Company 109

Vacating of injunction by Mr. Justice Scudder 113

City of New York and Brooklyn Edison Company, Inc 114

City's objections to merger of 1919 115

Hearings before public service commission 117

Effect of merger upon status of franchises 119

The transportation corporations act of 1890 120

Section sixty and amendments 120

Section sixty-one and amendments 121

Saving clause and construction clause 123

Schedule of repealed laws 123

The Brooklyn companies and the acts of 1848, 1879, and 1882. . . 125

The manufacturing act and the Brooklyn charters 125

The manufacturing act in relation to the acts of 1879 and 1882. 125

The acts of 1879 and 1882 and the Brooklyn charters 125

Relation of charters to the acts 125

Action of common council of city of Brooklyn 126

Governor's opinion , 126

Action of secretary of state . 126

Effect of act of 1882 upon act of 1879 126

Effect of transportation corporations law upon prior laws 128

The doctrine of acquiescence and estoppel 131

Mr. Justice Benedict's opinion 131

The Wyandotte Electric Light Company case 132

Summary of movement to invalidate Brooklyn franchises 134

Relation of other franchises to manufacturing act 137

The J. and J. Rogers Company case 138

CHAPTER V The Problems of Acquiescence and Perpetuity

Statement of the problem of acquiescence 144

Cases concerning the doctrine of acquiescence 144

Richmond Gas Company v. Cromwell 145

J CONTENl^S 13

PAGE

Flatbush Gas Company v. Coler 147

City of New York v. New York Railways Company 149

City of New York v. Central Union Gas Company; Same v. Northern Union Gas Company; Same z/. Westchester Lighting Company . 151

Holmes Electric Protective Company v. Williams 152

Public Service Commission, Second District, v. J. and J.Rogers

Old Colony Trust Company v. City of Omaha 154

Town of Essex v. New England Telegraph Company of Massachusetts 156

Cases concerning perpetuity of franchises 159

People V. O'Brien 159

People V. Commercial Telephone and Telegraph Company . . 160

Blair v. Chicago 161

Boise Water Company v. Boise City • 163

Owensboro v. Cumberland Telephone Company 164

Northern Ohio Traction and Light Company z/. State of Ohio. 166 Covington v. South Covington and Cincinnati Street Railway

Granting of perpetual franchises forbidden by charter of Greater

Argument against allowing public service corporations to occupy the streets in perpetuity and to derive returns upon the value of

the intangible right 172

Argument defending the companies 174

CHAPTER I Electric-Lighting Companies of New York City

With the national government's assumption of control of many industries after the entrance of this country into the war, public attention was directed toward the possibility or probability of permanent government ownership upon the return to peace conditions. Consideration of the relative merits of public and private ownership became charged with local interest for the citizens of New York City when the demand for municipal ownership of public utilities was made a plank in the platform of the Democratic party both in the mayoralty campaign of 191 7 and in the 19 18 campaign which resulted in the election of Alfred E. Smith as Democratic governor. Home rule for municipalities, including full right to own and operate their public utilities " was the Democratic slogan.^ Accordingly, in his inaugural speech of Januarjr i^ 191 9, Governor Smith presented the views of his party in the following words : ^

Recent years have been marked by a great opening of the popular mind to the true scope of enlightened municipal administration. There is everywhere a recognition that it is only through the application of progressive conceptions of public duty that life can be made tolerable in our teeming cities, with their unprecedented growth in population, and the consequent living conditions. From every city in the state, represented by

1 Democratic state platform, adopted at Saratoga Springs, July 23, 1918. ^ The New York Times, January 2, 1919, p. 4.

275] 15 l6 ELECTRIC FRANCHISES IN NEW YORK CITY [276

their chief executives in conference, there comes the demand that the State confer upon the cities the power to acquire, own, operate, and control their pubHc utiHties. The supply of transportation, light, heat and power, is of the utmost importance to each local community. The services rendered have become a necessity to the life, health, comfort, convenience, and industry of the cities. These great services are monopolies, and whatever is of necessity a monopoly should be a public monopoly, especially where it offers a service of universal use. I therefore recommend that legislation be passed granting our cities the power to acquire, own, operate, and control their public utilities.

Decidedly adverse comment on the remarks of the governor v^^as immediately expressed by an independent Democratic paper of Nev^ York City : ^

Since Governor Smith has to deal with a Republican legislature, a sort of unreality makes itself felt in his first message . . . But how painful to find him talking about " the true scope of enlightened municipal administration," and approving the effort of the singularly bedarkened municipal administration of this city to set up municipal ownership and operation. This scheme, financially impossible, the governor recommends to the legislature, well knowing that it is the last thing the legislature will do.

This study makes no pretentious claim to set forth a general statement regarding the defects or merits of municipal ownership of public utilities with reference to all our cities or one. Apart from such theoretical arguments as the right of a city to control its own streets in the interest of its own citizens rather than to submit to the occupancy of its highways as a property right held by a private monopoly for private gain, it would be a barren task to attempt to arrive

^ The Nciu York Times, January 2, 1919, p. H.

at worth-while conclusions concerning the relative merits of private and public ownership of public utilities as a whole. It would be almost as fruitless to attempt to generalize on the subject as applicable to a single utility in all cities. Even when consideration is limited to but one class of public utilities and one city, judgment should be reached only after careful investigation of facts. Conclusions drawn from examples of municipal ownership on both sides of the Atlantic are used both in support and attack of the policy. Enthusiasts for municipal ownership of public utilities find excuses for every apparent failure of its application, and paint in glowing colors instances of its success which they allege show increased efficiency of service, improved conditions of the utility employees, and separation of the utilities from politics. Opponents array facts to justify conclusions inimical to the cause of municipal ownership. A middle ground is indeed held by some who hope for eventual municipal ownership of public utilities, but who appreciate the significance of differences among places as to social, economic and political conditions, and who hesitate, therefore, to concede that because municipal ownership succeeds in one section, it must in another. Each city must be studied by itself, in the light of its own particular problems. Whether or not the city of New York would promote the interests of its inhabitants by municipal ownership of electric-lighting utilities, is a question apart. In view, however, of the increased agitation for municipal ownership,^ the

1 Legislative Index Publishing Company, Record of all Bills Introduced in the Senate and Assembly during the I42d Annual Session of the Legislature of the State of New York, Beginning January i, 1919. Between January i, 1919 and March 6, 1919, five bills providing for municipal ownership of public utilities were introduced in the Senate, printed Senate numbers, 65, 179, 301, 805, 806, respectively; and five were introduced in the Assembly, printed Assembly num.bers, 180, 415, 434, 1 103, 1229, respectively.

l8 ELECTRIC FRANCHISES IN NEW YORK CITY [278

primary purpose of this study is to ascertain the present status of the franchise rights of the electric-hghting companies in the city of New York.

Before going intO' the fuller discussion of the franchises held or claimed by the electric-lighting companies of the city of New York, it seems desirable to consider the meaning of the term franchise. A franchise has been comprehensively defined as a right conferred by government of conducting an occupation either in a particular way or accompanied with particular privileges.^ It is correct to speak of the state as the primary franchise-granting authority. In the case of the electric-lighting companies of the city of New York, the original grantees of the municipal franchises now held by the operating companies received from the state the corporate or general franchise which conferred the right to be or to become and the right to do; and they obtained from the political subdivision in question the right to occupy the streets in the pursuit of their business. The last-named, intangible right is designated a municipal franchise. In the analysis of the franchises of the electric-lighting companies of the city of New York, attention will be constantly directed to the fact that the original grantee obtained rights to occupy the streets of a given territory from boards of aldermen, common councils, highway commissioners, boards of parks, town boards, or boards of supervisors. Clearly, the state has supreme authority over the use of the streets and public highways. Except as otherwise provided in the state constitution, this power is vested in the legislature, and the legislature, in turn, through statutory enactment or charter provisions, or both, delegates tO' the local authorities of the political subdivision the power to grant the municipal franchise.

In the case of the street railroads in the city of New York

1 Seligman, Jissays on Taxation, p. 221.

there has been, since 1875, a somewhat distinctive factor. Section 18 of the third article of the constitution of the state provides in part as follows :

No law shall authorize the construction or operation of a street railroad except upon the condition that the consent . . . also of the local authorities having control of that portion of a street or highway upon which it is proposed to construct or operate such railroad be first obtained.

Discussing the significance of this provision, a former attorney for the public service commission for the first district says in part : ^

The Constitution clothes the City with an independent legislative power and discretion, a delegation pro tmto of the State's sovereign powers. This is very different from saying that the legislature's powers L'ave been delegated to the city, as is the case where the delegation is by legislative act rather than constitutional grant. The City is by the Constitution made " an independent contractor " with respect to a street railroad corporation's invasion of public streets, and not merely " an agent of the legislature," as it is probably to be deemed to be when acting under a statutory provision for municipal consent.

Interpreted in the light of both the general character of the corporate franchise and the delegation of power by the state, the seemingly uncertain expressions frequently used in designating a municipal franchise gather more clarity of meaning. To use the term secondary franchise is but to stress the primary franchise-granting authority of the state. The term particular franchise merely emphasizes the general character of the authorization conferred by the corporate or general franchise. Needless confusion, however,

1 Ransom, Copy of brief filed in the court of appeals in the case of Quinby v. Public Service Commission, Second District, p. 79.

results from attempting to attach peculiar significance to the word consent, as though that word literally made the city's contract with the company something inferior to a real municipal franchise. To ignore or minimize the authority of the city to give or withhold its consent to the occupancy of its streets, and to emphasize only the state's or the legislature's indisputably important share in the process of franchise-granting is without justification. Sometimes the effect of the city's consent is explained by saying that the local authority is vested with the power to give the consent requisite to confer a franchise upon the corporation concerned. Others phrase their interpretation of the city's consent by maintaining that the consent, when given, becomes a franchise granted to the corporation. It would seem that the essential idea underlying the use of such expressions is to draw a distinction between the right to occupy certain streets or certain areas as made possible by the city's consent, and the right to become or do, as conferred by the corporate and general franchise. It is perfectly evident that the right to become or do is worthless without the right to occupy the streets.

There are five boroughs in the city of New York : Manhattan, The Bronx, Queens, Brooklyn, and Richmond. The area of the city is 314.75 square miles; the estimated population in 1918 was 5,872,143.^ Three companies furnish electric lighting in the borough of Manhattan,^ namely, the

1 Report of Taxes and Assessments of the City of New York, 1918, p. 16.

2A fourth company, the Riverside Light and Power Company, supplies electricity in the section bounded by 130th street, I32d street, Twelfth avenue, and the tracks of the N. Y. C. & H. ,R. R. R. Company. The board of <■ ,<inialc :md apportionment of the city of New York granted the compimy, on February 14, 1912, a franchise for the period of fourteen years, with the right to renew the franchise privileges for ten years at the expiration of the original term. igi6 Annual Report of the Public Service Commission for the First District, p. 605.

28l] THE ELECTRIC-LIGHTING COMPANIES 21

New York Edison Company, the United Electric Light and Power Company, and the Long Acre Electric Light and Power Company. South of 136th street all three companies operate, although the area supplied by the Long Acre Electric Light and Power Company is confined to the nineteenth ward/ North of 136th street the United Electric Light and Power Company operates alone. The territory covered by the franchises owned by each of the companies exceeds the actual area of supply taken over by each of them. The old city of New York included all of what is now the borough of Manhattan and that part of the borough of The Bronx which is west of the Bronx river; and the franchises granted by the old city of New York, now held by the three companies operating in the borough of Manhattan, covered the area, " The City of New York." Certainly, the franchises held by each of the three companies entitle the owners to extend the area of supply over what was the old city of New York ; and, with the annexation to the city of the territory east of the Bronx river, the franchise rights were probably automatically extended so as to include the city of New York with its enlarged territorial limits. The theory of franchise extension by annexation is not unanimously conceded to be correct; but it appears a reasonable theory. It could not, however, apply to the present city of Greater New York, since " section 1538 of chapter 378 of the Laws of 1897 (Greater New York charter) provided specifically against the territorial expansion of existing franchise rights." ^ In the borough of The

1 The New York Edison Company furnishes direct current, and the United Electric Light and Power Company alternating current. In the streets where both companies have mains, the competition is often veryvigorous. The New York Edison Company does furnish alternating current, as well, but not the alternating current suited for lighting purposes.

Bronx, three companies operate: the New York Edison Company, the Bronx Gas and Electric Company, and the Westchester Lighting Company. The New York Edison Company furnishes electric lighting in that part of The Bronx which is west of the Bronx river. East of the Bronx river, in what used to be the old town of Westchester, exclusive of the incorporated village of Williamsbridge, the operating company is the Bronx Gas and Electric Company; and in the remaining area of The Bronx east of the Bronx river, electric lighting is carried on by the Westchester Lighting Company. In the first four wards of the borough of Queens, the New York and Queens Electric Light and Power Company supplies electricity; ^ in the fifth ward of the borough of Queens, the Queens Borough Gas and Electric Company.

With the exception of the twenty-ninth ward of the borough of Brooklyn, and Ocean Parkway from Foster Avenue to the Atlantic ocean, territories given over to the Flatbush Gas Company, the Brooklyn Edison Company, Inc. has a monopoly of the electric business in the borough of Brooklyn. In the borough of Richmond, the Richmond Light and Railroad Company supplies electric current.

On May 21, 1901, the New York Edison Company was formed by a consolidation of the Edison Electric Illuminating Company of New York and the New York Gas and Electric Light, Heat and Power Company. On December 17, 1880, the Edison Electric Illuminating Company of New York had merged into itself the Harlem Lighting Company

1 Another company filing certain data with the public service commission for the first district is the Bowery Bay Electric Light and Power Company. This company has no franchise. It operates during the summer months only, when it supplies lelectric current to the tenants at the private summer resort of North Beach, in the borough of Queens, ward 2. 1916 Annual Report of the Puhlk Service Commission, pp. 353, 496.

and the Manhattan Electric Light Company. The Manhattan Electric Light Company was a consolidation of the Manhattan Electric Light Company, Limited, and the Madison Square Light Company. The Madison Square Light Company was a reorganization of the Thomas-Houston Electric Company (previously known as the East River Electric Light Company). The New York Gas and Electric Light, Heat and Power Company had, on February i, 1900, absorbed by merger six companies : the Mount Morris Electric Light Company, the North River Electric Light and Power Company, the Borough of Manhattan Electric Company, the New York Heat, Light and Power Company, the Manhattan Lighting Company, and the Block Lighting and Power Company No. i. The North River Electric Light and Power Company was a reorganization of the North New York Lighting Company. The New York Heat, Light and Power Company had been incorporated as a consolidation of the New York Heat, Light and Power Company and the Excelsior Steam Power Company.^ According to the last annual report of the public service commission for the first district of the state of New Yoiic to the legislature, the Consolidated Gas Company of New York is recorded as holding 602,918 out of 659,534 shares of the New York Edison Company, and is reported as owning 56,516 additional shares that represent certificates not in its own name.^

The United Electric Light and Power Company was incorporated on February 3, 1887, under the name of " The Safety Electric Light and Power Company." The company's name was changed to the present form on November

1 Maltbie, Franchises of Electrical Corporations in Greater New York, pp. 44-5.

2 Public Service Commission, First District, Annual Report for iQi^y p. 520.

ELECTRIC ERANCHISES IN NEW YORK CITY [284

8, 1889. It has acquired control through stock ownership of the Ball Electrical Illuminating Company and the Brush Electric Illuminating Company of New York, two dormant companies. It absorbed by merger the United States Illuminating Company. According to the report of the commission the Consolidated Gas Company of New York is recorded as holding 51,139 out of 53,180 outstanding shares of the United Electric Light and Power Company, and is reported as owning 1,819 additional shares that represent certificates not in its own name.^ The Brush Electric Illuminating Company of New York retains ownership of its franchise, as does the Ball Electrical Illuminating Company. The New York Edison Company took over the plant of the Brush Electric Illuminating Company of New York, and, in accordance with an agreement renewed for ten years from May i, 19 14, continues to supply the former consumers of the Brush Company with electric current.

The Long Acre Electric Light and Power Company was incorporated on April 24, 1903. The franchise under which it operates v/as originally granted to the American Electric Manufacturing Company, passed by various transfers to Martin Minturn, who sold it on March 21, 1906, to the Long Acre Electric Light and Power Company. Although the company conducts but limited operations, its franchise territory legally extends throughout the borough of Manhattan and at least that part of the borough of The Bronx which is west of the Bronx river. As its name implies, the Bronx Gas and Electric Company supplies both gas and electricity. It was incorporated on August 16, 1893. The Westchester Lighting Company, incorporated on November 5, 1900, (operates both within the city of New York and outside the city limits. This study is concerned with the city operations only. The corporate history of the company in-

' I'ublic Service Commission Report, 1916, p. 617.

eludes about thirty predecessor companies/ Three are of interest because of their figuring as original grantees of franchises under which the Westchester Lighting Company carries on its electric lighting business in the city of New York : the Pelham Bay Park Electric Light, Power and Storage Company, the Eastchester Electric Company, and the Pelham Electric Light and Power Company. The present operating company holds all of the capital stock of the Pelham Bay Park Electric Light, Power and Storage Company, and merged into itself the Eastchester Electric Company and the Pelham Electric Light and Power Company. The Flatbush Gas Company was incorporated on April 2, 1864. It was originally incorporated as a gas-light company; but after filing an amended certificate of incorporation allowing for the m.anufacture and distribution of electricity, it purchased the franchise of the Knickerbocker Electric Light and Power Company. The Brooklyn Union Gas Company, which owns the capital stock of the Flatbush Gas Company,^ furnishes to the latter company the gas it distributes.

The New York and Queens Electric Light and Power Company, incorporated on July 21, 1900, absorbed by merger the New York and Queens Gas and Electric Company, the Jamaica Electric Light Company, the Electric Illuminating and Power Company of Long Island City, and the Long Island Illuminating Company. The New York and Queens Gas and Electric Company had absorbed by merger the Newtown Light and Power Company, the New York and Queens Light and Powder Company, and the Flushing Gas and Electric Light Company.^ According toi the last

2 Public Service Commission Report, 1916, p. 447.

2 Maltbie, Franchises of Electrical Corporations, pp. 123-127.

annual report of the commission, the Consolidated Gas Company of New York is reported as having stock control of the New York and Queens Electric Light and Power Company. Out of the outstanding 12,500 shares of common stock in 191 3, the Consolidated Gas Company of New York held 9,659 ; and out of the outstanding 12,500 shares of preferred stock, 7,612. 4,883 shares of preferred stock, and 6,683 oi common stock were recorded as held by the Consolidated Gas Company of New York in 1916, together with 3,090 shares of preferred stock and 3,417 shares of common stock owned, but representing certificates not in its own name. ^

The Queens Borough Gas and Electric Company, incorporated on May 29, 1902, absorbed by merger the Town of Hempstead Gas and Electric Company and the Queens Borough Electric Light and Power Company. The Queens Borough Electric Light and Power Company had purchased the franchises of the Citizens Lighting Company, and "certain electric lighting rights, held by Van Wyck Rossiter personally." ^ Van Wyck Rossiter was the president of the Citizens Lighting Company.

The Richmond Light and Railroad Company, as its name implies, operates both as a lighting company and an electric railroad. Its name was changed on August 18, 1902, from that of Richmond Light Company to the name it now bears, ^ and its corporate powers extended to include the operation of an electric railroad. The corporate history of the electricity division of the Richmond Light and Railroad Company may, for the purposes of this study, be narrowed down to those companies that were original grantees of the franchises now held by the company. The Richmond