such powers. The New York courts in a leading decision involving extraterritorial powers by a city spoke as follows:15
The purpose must be primarily the benefit, use or convenience of the city as distinguished from that of the public outside of it, although they may be incidentally benefited, and the work (must) be of such a character as to show plainly the predominance of that purpose . . . . the thing to be done must be within the ordinary range of municipal action.
Thus extraterritorial activities are limited in various ways. They are justified within certain limits and up to certain points. They become objectionable when carried beyond them.
Intermunicipal coöperation in the sense of joint undertaking by two or more municipalities has made its appearance in some metropolitan areas and has helped on occasion to meet a particular situation or to promote more comprehensive arrangements for solving metropolitan problems but it has not succeeded in unifying the government of a metropolitan area sufficiently to make possible the comprehensive and effective solving of the problems of the area. It does not afford an adequate answer to the puzzle of metropolitan integration.
Intermunicipal arrangements by which one municipality, usually the main city, undertakes to furnish specified services to the other municipalities in the area for a specified price have been utilized almost exclusively in the field of the water supply and, in a smaller measure, in the field of public education. Arrangements of this nature have been helpful in fostering suburban development, but they cannot be considered as permanently satisfactory or capable of successful extension to other functions of government. Sooner or later they place the city which sells the services in an equivocal position with respect to the communities served. One part of the metropolitan region becomes too dependent upon the efficiency and good will of another. The relation of buyer and seller is not one which necessarily promotes accord. In a word, the scheme is of limited application. It does not afford a basis for real, democratic, comprehensive and permanent organization of a metropolitan community.
Schemes of extraterritorial jurisdiction are still more limited in their application and effect.____________________