The control of gas and electric rates and service by state public service commissions has, for many years, been a common phenomenon. In so far as interstate commerce in these commodities is involved, so as to be of special interest for the present discussion, the matter is of much more recent development. That the transmission of gas' and electric light and power current2 from one state to another is a transaction in interstate commerce is now definitely well established, although as to the latter, it is not a determination of very long standing.'
Robert L. Howard,
Gas and Electricity in Interstate Commerce - Part II - Regulation of Rates and Service,
50 Bulletin Law Series.
Available at: https://scholarship.law.missouri.edu/ls/vol50/iss1/3