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Show locufl?i and auvantares possessed by the city if San Francisco over interior points within the United States the rates on traffic fronf'Missouri river and points thereupon to j the siid city of San Francisco are made by wateicompetition and by the ability of San Frajvfteeo shippers to deal at points where the? is water transportation, and said rates ! miW be met by rail lines, otherwise the said raitad lines must go out of the business I andjbandon participation in said Pacific eoasttrsfnc; whereas, the said city of Salt Lakds approached and reached from the Miss uri river, and common points there-upoi there-upoi solely by rail lines, and it therefore is nc favored by nature or its natural situ-alioi situ-alioi by the benefits accruing to San Fran-cisc Fran-cisc Ai this defendant on information and beli( alleges that the rates from Missouri rive: common points to San Francisco in nowise no-wise iffects Salt Lake City, or merchants or j any uarket for its merchants or shippers. I Tha Salt Lake City merchants have no tnari ;t between that city and San Francisco, i whi i can be reached by San Francisco mer- ehei s, unless for a short distance on the j Soul ern Pacific railroad westward from Og-den, Og-den, ind those points are thirty-seven miles nesi r to Ogden than Salt Lake City, and the i erchants there also ship directly from the . ist to these towns, and any difference in lltes from said common points t Salt Lakl City and San Francisco would not equa the local rate back from San Francisco to point at which Salt Lake City mer-c'rJMs mer-c'rJMs have a market. I'herefore, the defendant prays that the cApIaiut in this proceeding be dismissed. Robert Hakknisss, Attorney, fait Lake City, Utah. A WESTERN RETORT. The Rio Grande People File Their Answer to the Charges From the Chamber of Commerce. It Denies That Its Traffic is Under Common Control or That Its Rates are Unreasonable. THE COST OF MOVEMENT. It Admits That Salt Lake City is the Most Important Commercial Center Between Pointo. ( ZION IS AN INLAND CITY. i And Has Not the Advantages Afforded by a Seaport Town or Places Located on the Ocean Water Kates Must be Met by the KaiHvaya, The Rio Grande Western Railway company compa-ny lias tiled the following answer before the Interstate commission to the complaints lodged before it by the Chamber of Commerce Com-merce : The Salt Lake Chamber of Commerce, ts. the Union PacihV railway. The Denver & Rio (irande railroad, The Rio Grande Western West-ern railway. The Southern Pacific Co , The Burlington it Missouri River Railroad Co., The Atchison, Topeka ifc Santa Fe Railroad Co The Chicago. Rock Island & Paciuc R. R. Co. The defendant, the Rio Grande Western Railway company, separately answers the complaint in this proceeding, and respectfully respect-fully slates: 1 It admits the first paragraph of the complaint. 2 It admits it is engaged in interstate commerce by arrangements with the other defendants, or some of them, for transportation transporta-tion between the points named in the second paragraph of the complaint; but it denies that said trallic is conducted under any com-mon com-mon control or management of the lines of railroad of the defendant.-, or the railroad of this defendant and that of any other defendants defend-ants or defendants. 3 Answering the third paragraph of the complaint, this defendant denies that the! rates of defendants specified in the sched-1 ules and tariffs between the said Missouri common poinls or any of them, and 8ait Lake City, or between San Francisco and Salt Lake City, are either unjust or unreasonable, unreas-onable, or in violation of the first or any sectiou of said act to regulate commerce. And it denies that the actual cost of the movement of freight between said Missouri River common points to Salt Lake City, Utah, and between 8an Francisco and Salt Luke City, including the elements of cost properly chargeable thereto, does not exceed ex-ceed one-half of a cent per ton per mile, ou the line of road of this defendant, aud while this defendant cannot state the cost on the lines of the other defendants, on informa-J tion aud belief it alleges, that it, on thosej lines, exceeds the alleged cost; and it denies!! that the charges made and collected ate iaP no case less than three times the cost ofl movement, or in any case nine times the al- leged est, unless iu special cases on goods specially hazardous and where the charge is j largely tor risk. 4 Tiiis defendant denies the fourth para-graph para-graph of the complaint, and each and every j allegation thereof. 5 Answering the fifth paragraph of the! complaint this defendant denies the same, i and each of the allegations thereof, and al-leges al-leges that the traffic between said Missouri River common points and Sait Lake City, compared with the tariff between the same comm. in points and San Francisco, is carried I on under dissimilar circumstances and con- I ditions. i 6 This defendant answering the sixth i paragraph of the complaint a:'.' a Imitting the alleged distance between the points named iu said paragraph, and also admitting that Sait Lake City ir- the largett city between be-tween Denver and San Francisco, and an important center of trade, denies tlut it is the only important center of trade between the cities last named, or that it is favorably situated or has natural advantages for the supply of a large surrounding country, and admit ting that it has the largest local business busi-ness of any city between Denver and San Francisco, this defendant does not know whether it has a larger distribution of interstate inter-state traiHc than other points between said cities, and leaves the complainant to its proof thereof; and this defendant denies that the rates charged to Salt Lake City from the said Missouri river common points are excessive ex-cessive or unlawful or in violation f the said act to regulate commerce. 7 And further answering the complaint, tliis defendant alleges that of the haul between be-tween said Missouri river common points and Suit Lake City its line of railroad only includes about 899 miies of the distance; that about 100 miles of said distance is practically prac-tically a desert with almost no local business, busi-ness, and other parts of its line is constructed over mountain rang- and with steepgrades, and that that portion of its line which is in a tillable and settled district is parallel to un older competing 'ine of railway, and that the cost of maintaining and operating Its line of railroad, compared with the amount of traffic, is necessarily greater, aud requires higher rates, to be. reasonable, than on roads with a large local traffic and light grades. That this defendant's road is only a part of one line betweeu said Missouri river com- i mon points and Salt Lake City, aud there I are other competing lines from the same j points, and all the business is done under comp' tition, and the rates are as Ijwas they can be reasonably made and be compessa- : tory. That in the Utah valley in the northerly and southernlv direction, there are various towns and cities, each shipp ng directly from j the cast and west, and Ogden about thirty-! seven mile a north of Salt Lake City, and I Provo, about forty -even miles from Sait Lake City are common a:id distributing points in said valley. That the country east and west from .-alt Lake City is mouutuin-ous mouutuin-ous and has n. shipping points except along the railroad of the Southern Pacific and where there is no railroad Competition. That on traffic between Salt Lake City and San Francisco, the line of this defendant only includes about thirty-seven mile6 of the distance, and in p.irallcl to another and competing com-peting line with the same westward eoenec-tion eoenec-tion and this defendant further alleges that traffic from the Missouri river common points to San Francis) o is conducted under the com petion of several routes, some of which are not within the provisions of the said not to regulate commerce and the carriage car-riage is at unreasonably low ration, a id not under siniliar circumstance and cc n lition with traffic to Sait Lake City. That the eitv of Salt Lake. Utah is an inland city which does not enjoy the natural advantage afford d by a 'sea-port town, or one situated upon an important or navigable navi-gable river; that the said Salt Lake Citv, by reason of its natural location does not enjoy j any of the natural benefits accrueing to cities situated upon the ocean, or upou im- i portaut or navigable rivers within the boun-dries boun-dries of the United States. Defendant alleges that the said city of San Francisco, California, is situated practically upou the 1 Facihc ocean, and traffic destined to San S Iranciaco, California, can bt carried to that point from Missouri river points with passing over the line of this defendant, and can be delivered to the city of San Francisco, California, by through water connection, under circumstances and conditions entirely, dissimilar from those under which rail lines! are operated; that by reason oi the naturall |