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I?PAsM La* Y«gi«i January 3: Mr. B.E. Sennetti ^s#; vA/M* „ J*H ^ « * JU1, Stoddard Welter E, Sou** Wra. Reinhardt W.H. Bulalaer R.M. Sutton. ) Replying to your lattar of December 21st, 1951, to Mr. Wattar IU Roues, I know of no raaion why the Union Land Company, a S«breaks Corporation, cannot ®# qualified to do business in the State of Heva&a, Baring been so qualified, the real estate holding* of the Lae Vega* Land and wfater Company in Bevada could be transferred to the Union Land Company. Section 6115 cited by you appear* to relate to concentration, commodity, transit and other special con-tract rates, all with reapect to "shippers". As statea by you, this section epplies to transportation and I do not believe a Public Service Commission would so construe:itas to permit e special contract rate of a publie utility to tell Its product to the Railroad Company at cost, Whether it be water or any other utility servioe. This section has never been interpreted by the Commission or the Court*. However, I believe it would not be interpreted to apply to water rates for the Railroad Company at coat, in view of Section 6134• the Intent of that section would not permit e special rate to be given to one el**« of consumer at coat or o*lcw cost with other consumer* of different classes paying a higher pro rate rets than their ehare in order to permit a utility to earve one class of consumer at coat. The next to the la*t sentence of this section provides "it shall likewise bs unlawful for any public utility to grant any refund, concession, or special privilege to any consumer or uasr, which directly or indirectly shall or sja£ heve the «ffsot of changing the retea, tolls, charge*, or payment*, and any violation of the provisions of this section shell subject the violator to the penalty prescribed in S e c t i o n 11 of this Act a c e s " , I am therefore of the opinion that even though Section 6115 is construed to permit a special contract rate forttthe delivery of water to the Railroad Company at coat, auoh a contract would not be approved by the Public Service Commission. E. E. D; JAN 19*? JAN 7 1952 Le C« C.