Federal Interests Should Receive More Consideration under the Forest Highway Program

Published by the Government Accountability Office on 1977-10-13.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                                DGCUMENT    ESUME

03969 -      B28741441

Federal Interests Should Receive More CoL.sideation under the
Forest Highway Program. CED-77-130; B-164497(3). October 13,
1977. 13 pp. + appendix (1 pp.).

Report to Secretary, Department of Agriculture; Secretary,
Departmnt of Transportation; by Henry Eschwege, Director,
Community and Economic Development Div.

Issue Area: Land Use Planning and Control: Federal Programs
    Ccncerning hon-public Lands and Related Resources (2307);
    Transrortation Systems and Policies: National Highway System
Contact: Communit+ ard Economic Derelopment Div.
Budgot Functicn: 'Cowmerce and Transportation: Ground
    Transportation (404).
O.-ganiza'icn Concerned: Federal Highway   dministration; Forest
Congressional Relevance: House Committee on Public Works and
    Transportation; Senate Committee on Public Works.
Authority: Federal Aid Hignway Act of 1970 (P.L. 91-605; 84
    Stat. 1713; 84 Stat. 1737; 23    .S.C. 101(a)). Federal Aid
    Road Act of 1916. Federal Highway Act of 1921. 23 U.S.C.
    244(b). 23 U.S.C. 205(b). 23 C.F.R. 660 et seq.

               The forest highway program, as currently administered
 by the Federal Highway Administration (FHA) and the Forest
 Service, is not meeting the Forest Service's needs for managing
 the national forest resources.        Findings/Conclusions: Forest
 highways total about 22,000 miles and are of special Federal
 interest because they link the ntional forests to the
Federal-aid highway system. The Congress, in establishing the
 fozest highway program, expressed a special interest in
providing access to Government-owned national resources as well
as for the benefits cf communities in or near national forest
boundaries. Incremental administrative and legislative changes
in the forest highway program between 1970 and 1'"7 have changed
the program's focus from Federal ccntrol to State control and
have lessened the Fcrest Service's input. As a result, forest
highway funds were devoted to roads of primary importance to the
States and had Little or no relation to national forest
transportation       needs.  Recommendations: The Secretaries of
 Ariculture and Transportation should direct the FHA and the
Forest Service to jointly develop and is:sue specific       c:iteria
for selecting projects meriting forest highway funding and
should     jointly   develop proposed legislation       to permit those
forest     roads that   were formerly ccrsJdered forest        highways to be
eligible      for funding under the forest        highway program.  (SC)

        \           .U                           S1-t/

            ,              .o} UNITED
                               ~      STA TEsi
    ยท                    ?              A CC OUNTING
                                      LGENERALC      OFFICE

                            Federal Interests Should Receivt
                            More Consideration Under The
                            Forest Highway Program
                            Frest highways tot3i about 22,000 miles
                               i' are oi specal Federal interest because  hey
                            link the nationa! forests to thIi Federal aid
                            highway system. However. the forest high-
                            way program is not nmeeti.        the U.S. Forest
                            Service's needs.

                            For exar;liple, some 3,100 mies ut forest
                            rcais now ineligible foi Federal fulldillg are
                            expected to deteriorate becduse oi legislative
                            and administrative changes tetween 1970
                            and 1977.

                            Althugh te         Fedeal Hil,\vav Aclllntlti
                            tion and he Forest Servic          a   jointly re
                            sponsible fnt (ievel oping p!yra
                                                          r      i r' yit l()t's,
                            they have not made slir that Fderal intri-
                            eSts ad cide(lUti., el y c)isidctiJd Vw!h:i   Stte
                            and Federal officials make !,roge':t selecti)ns.

                            CEo-77-1.o                                              OCTOBER 13, 1977
                                  WASHINGTON, D.C. 20548

                                                           IN RIMLY
                                                           RWVr TO$


       The Honorable
       The Secretary of Agriculture

       The Honorable
       The Secretary of Transpirtation
            We surveyed the Federal Highway Administration's
       management of the forest highway program and observed a
       need to:
              -- Issue specific criteria for selecting projects
                 meriting forest highway funding.
              -- Develop proposed legislation to permit those forest
                 roads that were formerly considered forest highways
                 to be eligi'le for funding under the forest highway
       Our recommendations, if implemented, should hlp make sure
       that greater consideration is given to Federal interests in
       financing forest highway improvements.

           We made our survey at the Highway Administration's
      headquarters, Washington, D.C., and its division offices in
      Oregon and Washington responsible for designing and super-
      vising forest highway construction. We reviewed (1) appli-
      cable Federal highway laws and regulations, (2) Highway
      Administration policies and procedures for managing forest
      highways, and (3) Highway Administration guidance to field
      offices for project selection, design, and construction.
      We interviewed U.S. Forest Service officials and reviewed
      their records and reports. We also interviewed State
      transportation department representatives responsible for
      administering forest highway programs in Oregon and Wash-

           In 1891, the Congress authorized the creation of forest
      reserves, now called national forests. Forests were to be

conserved to assure a permnanen. national timber supply, to
preserve scenic and wilderness areas for recreational use by
the public, and to safeguard the steady flow of streams that
supplied water for domestic, farm, and industrial use.

     Federal participation in forest road construction began
when the Congress passed the Federal-aid Road Act in 1916.1/
Under section 8 of this act, $10 million ($1 million .er year
for 10 years) was appropriated for the " * *   survey, con-
struction, and maintenance of roads and trails within or only
partly within the national forests when necessary for the use
and development of resources upon which communities within
and adjacent to the national forests are dependent * * * ."

     It was not until the passage of the Federal HiThway Act
of 1921 2/ that two types of forest roads were defined:

      -- Forest roads and trails of primary importance for the
         prctection, administration, and utilization of the
         national forests, now called forest development roads
         and administered by the U.S. Forest Service (Depart-
         ment of Agriculture).

      -- Forest roads of primary importance to the States,
         countie, or communities within, adjoining or adjacent
         to the ntional forests, now called forest highways
         and administered chiefly by the Federal Highway
         Administration, although the Highway Administration
         shares several administrative responsibilities with
         the Chief of the Forest Service.

     Currently, there are 22,000 miles of public roads in
40 States and Puerto Rico designated as forest highways.
(See app. I.)   These highways are also a part of other Fed-
eral-aid system;, such as the primary or secondary systems.
Forest highways and forest development roads form a system
essential to the orderly development, management, protection,
and use of invaluable forest resources.


     The Highway Administration anages the forest highway
program. The regulations governing the program, 23 C.F.R.
660 et seq., ae recommended by the Federal Highway

1/   Act of July 11, 1916, ch. 241, 39 Stat. 355.
2/   Act of November , 1921, ch. 119, 42 Stat. 212.


Administrator and the Chief of the Forest Service and jointly
approved by the Secretaries of Agriculture and Transportation.

     Apportionment of forest highway funds among the States
is based on the value and area of national fo:est land with-
in the State, compared with national totals of the value and
area of federally owned national forest lands. Areas and
values currently in use are those certified by the Secretary
of Agriculture as of June 30, 1955. Sirce no State matching
funds are required, forest highway funds are generally not
turned over to the States for expenditure or reimbursement of
exper   ures as is done in the case of regular Federal-aid
highway funds.
     Forest highway regulations require Highway Administra-
tion division administrators to request that the States an-
ntally develop and'submit a list of proposed forest highway
projects. Highway Administration officials said that de-
velopment of a similar list of proposed projects by the
Forest Service is optional, and that, while some regional
Forest Service officials prepare a list of projects others
do not. Officials from the Highway Administretion, the
Forest Service, and the State highway departments meet
yearly to select forest highway projects for funding.
     Before construction is undertaken on any forest highway
project, the regulations require that an agreement be executed
between the States or counties and the Highway ,administration
to define the responsibilities of each arty. Today, the .Uigh-
way Administration directly designs and constructs approxi-
mately two-thirds of the forest highway projects. The Highway
Administration obtains Sate cooperation for construction of
the remaining projects. Under cooperative agreements, the
StateF generally provide all rights-of-way and maintenance
     The annual forest highway authorization has remained at
$33 million since fiscal year 1960. Forest highway improve-
ments may also be financed by a combination of forest highway
funds, regular Federal-aid highway funds, State and county
funds, emergency relief funds, and public lands funds---however,
they must compete with other highway needs.
     Forest highway funds expenditures averaged about $20 mil-
lion per year during fiscal years 1973-75. In fiscal year
1976 expenditures more than doubled to nearly $48 million.
Yet, despite this upward trend in forest highway expenditures
unresolved problems (that were first identified by the Forest
Service in 1974) have limited the program's effective operation.


     In March 1976 the Forest Service reported to the Highway
Administration that:

      "The most recent highway legislation and reclassifi-a-
       tion of systems has changed the Forest Highway Program
       and system into essentially a subsystem of the Federal-
       Aid Highway System and a program whereby 100 percent
       Federal funding can be used on State-selected Federal-
       aid roads. As a result, the states highest priority
       roads are not necessarily those of highest priority to
       meet the purposes of which the Forest Highway fund was
       was established."

The Forest Service's current position is that it cannot con-
tinue to support forest highway program procedures as they
now exist.

     We reviewed the House and Senate reports and hearings
leading to enactment of the 1921 Act. Forest roads were to
(1) link or connect State and county roads outside forest
boundaries with those inside forest boundaries and (2) en-
hance the value of national forest resources by providing
access roads for the protection and development of these

     The following statements from a June 1921 Senate re-
port 1/ fairly presents the philosophy underlying the special
Federal interest in forest roads.

     "Some 27,000 miles of road within the boundaries of the
     national forests, estimated to cost $130,104,791, are
     necessary to connect the State and county roads leading
     up to the boundaries of these forests from the outside
     and for the protection and development of the national
     forests * * * It seems only fair that the Government,
     as owner of these lands, should provide sufficient funds
     to construct roads through and along its own untaxable
     property * * *."

     Seltions 204(b) and 205(b) of Title 23 U.S.C. also re-
flect the fact that the Congress intended the Federal Govern-
ment to play a central role in the administration and opera-
tion of the forest highway program. These sections provide

1/   S. Rep. 67-334, 67th Cong., 1st sess. 13 (1921).


      "Cooperation of States, counties, or other local
       divisions may be accepted but shall not be required
       by the /respective Secretaries7."

     Our review indicated that the Highway Administration
and Forest Service had not developed specific criteria
assist the Forest Service and States in identifying      to
projects meriting forest highway funding.   Each
lowing describes how the forest highway program, section fol-
                                                  as presently
conducted, allows the States, rather than the Forest
or Highway Administration, to exert greatest control Service
project selections.                                    over
                     Because of this situation, projects
favored by the Forest Service to enhance the value
                                                    of Federal
lands and provide access to timber, recreational,
forest resources were not being funded. We also    and  other
                                                  noted the
existence of conflicting Federal-State views on
                                                 where forest
highway improvements should be made.

Evolution of State control
olver project selection -

      In an August 13, 1973, memorandum to division offices,
the Federal Highway Adminiistrator  expressed concern with the
decline in the forest hghway program from a high
lion in 1968 to $16 million in 1974. The memorandum $33 mil-
that, in view of continuing program decline and
adverse effects on the Highway Administration's  the  possible
                                                 direct  Federal
highway construction program staff (such as the necessity
a reduction in force), plans were being developed
ferring forest highway program responsibility to for trans-
                                                  the State
highway departments by 1980.   The memorandum further stated
that this proposed transfer was part of a concerted
stabilize the direct Federal hinhway construction     effort to
eliminate the undesirable effects of large unforeseen       and

     According to a Sptember 1976 Highway
report,l/ some States assumed this proposed Administration
                                             transfer meant
greater State authority, and they began exercising
thority by dominating project selection. The reportthis u-
that the States preferred to improve the heavier      stated
roads rather than the roads that serve and enhance
of Federal land.                                    the value

1/ "Direct Federal Highway Programs--An Evaluation,"
    Highway Administration, Department of Transportation,
    September 1976.


     According to Highway AdministratLon officials, the pro-
bJ]m was further aggravated in fiscal year 1975 when forest
? ghway funds were included in obligation limitations given
to the State highway departments. At that time, States were
particularly reluctant to use their limited obligational au-
thority to finance projects of low State importance regardless
of their value to the Forest Service. The 1976 report stated
that a solution must be found to enable the Government prior-
ities to be recognized in the selection of projects involving
100-percent Federal funding.

     Problems surrounding the forest highway program caused
the Highway Administration to defer further transfer of pro-
gram administration to 'tate highway departments in December
1976 until the program's future direction is settled. At that
time, program administration had been transferred to Alaska,
California, Nevada, and South Dakota. Two of these States--
Alaska and South Dakota---have subsequently transferred prcgram
administration back to the Highway Administration.

     A Highway Administration official stated that, while the
Highway Administration controls the program in all but two
States, the States continue to exert the greatest influence
over project selection.

     Other recent Highway Administration actions may have
aggravated the misunderstanding about who should control pro-
ject selection. For instance, when forest highway funds are
apportioned, certificates denoting the exact apportionment
amount are transferred to the State highway agencies. Until
fiscal year 1975 the certificate stated that the forest high-
way funds were " * * * apportioned for expenditure in the
several States * * * ." Highway Administration budget of-
fVcals revised the fiscal year 1976 certificate to read that
the funds wre " * * * made available to the participating
States * * * " to reflect the same wording that appears on
regular Federal-aid highway fund apportionment certificates.

     Also, a June   io0,   1977, Highway Administration report 1/
contained the following statement:

      "The selection of projects to be financed with forest
       highway funds is primarily the responsibility of the
       State highway departments and local political sub-

1/   "Report of Operations 1973-1976, Forest Highway System,"
      U.S. Department of Transportation, Federal Highway


      Both of these actions apparently gave States the impres-
sion that they had substantial control over project selection
and continue to adversely affect program management. For
ample, in an August 3, 1977, memorandum to the Chief, Federal
Highway Projects Division, the Executive Officer of the High-
way Administration's region 10 office reported that:
     "The Staces are continuing to interpret the apportion-
      ment letter* * * as authority for the State to control
      the expenditure of Forest Highway funds; although, in
      actuality, the Federal-aid Highway Act states that the
      Secretary will have control of the expenditure of funds,
      and not the State Highway Department."

The memorandum stated further that:

     "In at least one major incident in this Region and at
      least one other in another, the State advised both FHWA
      and the Forest Service that either FHWA and the Forest
      Service must begin playing a lesser role at the Annual
      Forest Highway Program meeting, or the State would not
      release any of their obligational authority for Forest
      Highway projects that were not of top priority to that

Unsystematic project selection

     Forest highway program regulations provide that projects
to be included in the forest highway program shall be based
on several considerations, including benefit to the protection,
development, management, and multiple use of the national
forest, and provision for the maintenance of forest highways
existing or under construction.

     The Highway Administration, the Forest Service, and State
highway departments do not make systematic comparisons among
proposed projects because regulations o not assign weight
priority to any of these considerations. Instead, represent-
atives of these agencies, when conducting final deliberations
on projects proposed for inclusion in the annual forest high-
way program, must rely on their own judgment about which con-
siderations receive top priority.

     Decisions on where to make improvements are the result of
negotiating for favored projacts.  State officials generally
favor improvements designed to alleviate congestion on high-
volume highways serving through traffic while Forest Service
officials generally favor improvements designed to serve
traffic to national forests.


     Our discussions with Highway Administration, Forest
Service, and State highway officials revealed that there
are often wde and varying interpretations by State and
Federal officials about which roads should be improved.
For example:

   -- In Oregon, the Forest Service and State's disagreement
      on where to make improvements produced a tradeoff in
      which the State received a bridge on coastal route
      101 (estimated cost   3.2 million) while the Forest
      Service received an improvement to the Cascade Lakes
      highway in the Deschutes National Forest (estimated
      cost ;.8 million). The bridge is to improve traffic
      flow on a major coastal arterial highway predominantly
      serving a high nonforest-related traffic flow consist-
      ing mostly of residents, tourists and recreationists
     visiting the coast. The Cascade Lakes highway pri-
     marily serves a low volume of forest-related traffic
     such as logging trucks and vehicies visiting the
     forest for recreation.

   -- In Washington, $2 million is being provided for a
      new bridge and tunnel on State primary highway 20.
      This route is a major high-volume cross-State highway
      serving a low volume of forest-generated traffic.
      While the Forest Service concurred with this project,
     it identified two more critical forest highway im-
     provements that are not being funded because of State

A Highway Administration official stated that in instances
where the Forest Service and the State officials cannot
agree on projects through negotiation, the Highway Admin-
istration regional office representative will intervene
and cast the deciding vote as a last resort.

     Our examination of forest highway regulations, policies,
and procedures, and discussion with Highway Administration
officials, revealed that there are no specific criceria for
final project selection. As a result, no systematic basis
exists for selecting forest highway projects and, therefore,
no assurance exists that the selected projects are the best
candidates for funding under this program.

     Highway Administration officials stated that, after
considering the Forest Service's position and the program's
legislative history, they believe the provision of an ade-
quate road network serving the national forests is primarily
a Federal, ratheL than State, responsibility.  Both Highway


Administration and Forest 3ervice officials agree that the
Forest Service should play a greater role in forest highway
project selection. They recognize, however, that a certain
amount of State participation is basic to an effective pro-

     Highway Administration and Forest Service officials
stated that the Secretaries of Agriculture and Transporta-
tion have the authority to make the regulatory revisions
required to increase the Forest Service's role in project
selection. Highway Administration and Forest SPevice
officials said that they are reluctant to initiate such
actions because (1) they do not want to los^ the States'
support for the program, and (2) they prefer to have ad-
ditional congressional guidance before mak'ng major program
revisions. To date the Highway Administration and Forest
Service have not initiated actions along these lines.


     As a result of reclassifying Federal-aid highways, about
3,700 miles of highway connecting forest development roads
with other Federal-aid highways are no longer eligible for
funding under the forest highway program. The Forest Service
and the Highway Administration must rely on State and local
Governments to make necessary improvemerts on these roads.

     Prior to 1970 forest highways were funded through a High-
way Administration appropriation. During this period forest
highways were classified as fellows:

     Class 1--on the Federal-aid prim.ary system.
     Class 2--on the Federal-aid secondary system.
     Class 3--other forest highways (e.g., State and county
              roads not on the Federal-aid system).

     However, the 1970 Federal-Aid Highway Act 1/ changed
the funding source to the Highway Trust Fund. This funding
change meant that only those forest roads on the Federal-aid
system would be considered forest highways eligible for
Federal funding. As a result 2,850 miles of class 3 roads
were removed from the forest highway system.

1/ The Federal-Aid Highway Act of 1970, Pub. L. No. 91-605,
   Sec. 141, 84 Stat. 1713, 1737 (23 U.S.C. Sec. 101(a)).


     It is not clear why the Congress limited Federal forest
highway program funding to those forest roads on the Federal-
did system.l/ n any event, class 3 roads that were once
consid..cd crest highways eligible for Federal funding are,
as a result of the legislation discussed above, no lon-r
eligible for funding under the .forest highway program.

     The 1973 Federal-Aid Highway Act 2/ called for realine-
ment of the Federal-aid system by June 30, 1976. To accom-
plish this legislation, the Highway Administration initiated
a national functional road classification study to classify
all Federal-aid roads (by volumes of traffic and function
served) as either principal arterials, minor arterials,
majot collector roads, minor collector roads, or local roads.
Only roads classified as major collectors or higher qualified
as Federal-aid roads, As a result, about 890 miles of forest
roads designated as minor collector or local roads lost their
status as forest highways and became ineligible for forest
highway fun-ling.

     We observed the road networks in several national for-
ests and noted that many of the roads no longer eligible
for foresc highway funds do not meet established road
standards and provide a reduced service level; however,
they generally provide access for hauling timber to market
or visiting recreationists.   Both Highway Administration
and Forest Srvice officials agreed that many of the roads
now ineligible for forest highway funding are adequate
for these current traffic volumes. The officials said that
continued neglect will devalue the service level of these
roads and create problems in the future (such as road
safety hazards and timber harvesting delays).   The Forest
Service and the Highway Administration, however, lack
specific information needed to measure the overall economic
effects of the lack of forest highway funding for these
minor collector or local routes on the development and use
of national forest resources.   The Forest Service has started
developing some information.

     Forest Service and Highway Administration officials
stated that because States and counties place low priority on
these roads needed improvements resulting from heavy timber

     The Federal-Aid Highway Act of 1970, Pub. L. No. 91-605,
     Sec. 141, 84 Stat. 1713, 1737 (23 U.S.C. Sec. 101(a)).

2/   The Federal-Aid Highway Act of 1973, Pub. L. No. 93-87,
     87 Stat. 250.


truck and recreational traffic will not be made and mainte-
nance will be minimized or neglected. In some instances,
however, States and counties have used their own funds to
maintain minor collector or local forest roads that serve
a public function (such as school bus and mail delivery

Efforts to resolve funding problems

     In February 976 the Forest Service and the Highway
Administration formed a committee to redefine forest
highways, eassess tile forest highway system, identify
needs, and prepare proposed changes to the law. This
committee requested the Western Association of State High-
way and Transportation Officials (WASHTO) to assist in
formulating policies and guidelines for a proposed new

     In late 1976 the Highway Administration and the Forest
Service developed a proposed legislative amendment that
would eliminate the requirement that orest highways be on
the Federal-aid system. Essentially, this proposal would
have restored the forest highway definition to its pre-1970
status. The WASHTO did not support the proposed amendment
because it believed the revision would have made Highway
Trust Funds available for non-Federal-aid roads, thereby
diluting the fund.

     The legislative proposal was included in the Department
of Transportation fiscal year 1977 legislative package sub-
mitted to the Office of Management and Budget; however, the
administration decided to not propose any new highway
legislation and dropped the proposal.  After reassessing
the forest highway system, Lighway Administration and Forest
Service officials said that they still believe a legislative
change is necessary, and they have resubmitted the same pro-
posal to the Federal Highway Administrator and recommended
its inclusion in the administration's Fiscal Year 1979 Fed-
eral-Aid Highway bill. As of September 1977 te proposal
was awaiting the Highway Administrator's approval.


     The forest highway program, as currently administered by
the Federal Highway Administration and the Forest Service, is
not meeting the Forest Service's needs for managing the na-
tional forest resources.


      The Congress, in establishing the forest highway pro-
gram, expressed a special interest in providing access to
Government-owned national resources as well as for the
benefit of communities in or near national forest bounda-
ries.   Furthermore, the Congress made Federal cooperation
with the States a program option rather than a requirement.
Therefore, we believe the Congress intended that Federal
needs be considered in selecting forest highway projects
for improvement.

     Incremental administrative and legislative changes in
the forest highway program between 1970 and 1977 have
changed the program's focus from Federal control to State
control and has lessened the Forest Service's input. As a
result, forest highway funds were devoted to roads of pri-
mary importance to the States and had little cr no relation
to natio-ial forest transportation needs.

     We believe he Highway Administration and Forest Service
should improve its forest highway selection procedures. Be-
cause of limited funds authorized for the program nationwide
($33 million annually), project development and the selection
process should be based on sound criteria to assure that
those projects that best meet the program's intent are given
top consideration.

     Many minor collector or local roads needed for access to
national forest resources are no locnger eligible for forest
highway funds a a result of the recent legislation discussed
in this report. These roads are still being used for forest-
related traffic (e.g., logging trucks and recreationists),
but many are not being maintained due to lacking funds.
These roads are expected to gradually deteriorate and cause
safety and economic problems to those dependent on them. We
believe the present forest highway definition that requires
that all forest highways be on the Federal-aid system should
be revised.  If the definition were revised to its pre-1970
status, it would facilitate the Forest Service's and Highway
Administration's development of a more integrated forest
road system by funding those links between forest development
roads and other Federal-aid highway systems.


     We recommend that the Secretaries direct the Federal
Highway Administration and the Forest Service to jointly
develop and issue specific criteria for selecting projects
meriting orest highway funding. we further recommend that


the Secretaries jointly develop proposed legislation to
permit those forest roads that were formerly considered
forest highways to be eligible for funding urder the
forest highway program.

     Copies of this report are being sent to the Hcuse and
Senate Committees on Appropriations; the House Commi.tee
on Public Works and Transportation; the Senate Committee
on Environment and Public Works; the House Committee on
Government Operations; the Senate Committee on Governmental
Affairs; the House Committee on Agriculture; the Senate Com-
mittee on Agri.culture, Nutrition, and Forestry; and the
Directoi, Office of Management and Budget.

     As you know, section 236 of the Legislative Reorgani-
zation ct of 1970 requires the head of a Federal agency
to submi a written statement on actions taken on our
recommendations to the House and Senate Committees on Gov-
ernment Cperations no later than 60 days after the date of
the report and to the House and Senate Committees on Appro-
priations with the agency's first request for appropriations
made more than 60 days after the date of the report.

                       Sincerely yours,

                      Henry Eschwege

APPENDIX I                                        APPENDIX I

                HIGHWAY SYSTEM (BY STATE)
              Region, State,
               or Territory         Mileage
              Alaska                  388.7
              Arizona               1,004.7
              California            2,135.3
              Colorado              1,299.1
              Idaho                   819.8
              Montana               1,014.4
              Nevada                  331.0
              New Mexico              701.4
              Oregcn                1,316.4
              South Dakcta            281.1
              Utah                    655.1
              Washington              726.6
              Wyoming                 559.7
                Total - West        1,233.3
              Alabama                   372.1
              Arkansas                  656.1
              Florida                   207.1
              Georgia                   397.4
              Illinois                  319.0
              Indiana                   101.2
              Kentucky                  300.0
              Louisiana                 290.8
              Maine                       32.7
              Michigan                1,162.8
              Minnesota                 814.6
              Mississippi               550.2
              Missouri                  909o9
              Nebraska                    3C.5
              New Hampshire             123.2
              North Carolina            684.5
               Ohio                       911.7
               Oklahoma                 11!.3
               Pennsylvania             237 .4
               South Carolina           548.1
               Tennessee                 436.1
               Texas                     416.2
               Vermont                   110.8
               Virginia                  817.1
               West Virginia             508.4
               Wisconsin                 466.5
               Puerto Rico                 31.5
                 Total - East        10,748.2
                 GRAND TOTAL         21,981.5