egrity of the enterprise, SO as to maintain its credit and to attract capital." In SO holding, the Court made clear that the mere fact that a particular rate reduced the value of the utility's property is not by itself sufficient to render a rate confiscatory. As the Court acknowledged, "Rate-making is indeed but one species of price-fixing. The fixing of prices, like other applications of the police power, may reduce the value of the property which is being regulated. But the fact that the value is reduced does not mean that the regulation is invalid" (Hope Natural Gas, 320 U.S. at 601, 603; accord Duquesne Light, 488 U.S. at 312). Some Justices have emphasized that the Court's confiscatory rate-making jurisprudence occupied a sphere that was distinct and separate from its physi- cal takings jurisprudence. For example, Justice Brandeis's landmark concurring opinion in Missouri ex rel. Southwestern Bell Telephone Co. V. Public Service Com- mission recognized that the Court's decisions regarding the determination of value in condemnation cases played no part in determining value for rate-making pur- poses (262 U.S. 276, 310-11 (1923)). Justice Black offered a similar observation in Federal Power Commission V. Natural Gas Pipeline Co., stating that "[i]n con- demnation cases, the value of property, generally speaking, is determined by its productiveness, the profits which its use brings to the owner." In addition, "when property is taken under the power of eminent domain the owner is entitled to 2 R.R. Comm'n Cases, 116 U.S. 307, 331 (1886). See Covington & Lexington Tpk. Rd. Co. V. Sandford, 164 U.S. 578, 597 (1896). Networks in Telecommunications the full money equivalent of the property taken, and thereby to be put in as good position pecuniarily as it would have occupied if its property had not been taken." Those principles, Black pointed out, "have no place in rate regulation." All rate regulation necessarily reduces the value of the regulated property, but this fact does not "stay the hand of the legislature 