The federal-aid highway approval process is a labyrinth of which Daedalus could be proud. A series of Policy and Procedure Memoranda (PPMs), Instructional Memoranda (IMs), and Orders creates an administrative maze that the Federal Highway Administration had until recently managed to protect from presentation in the Code of Federal Regulations. Attempts to overlay the requirements of the National Environmental Policy Act of 1969 (NEPA)¹ on this complex and intricate procedure have not proven wholly satisfactory, in part because of the inherent inadequacy of a single comprehensive impact statement to embrace the ramifications of a 10- to 20-year construction program. In the course of litigation, the "timing" of an impact statement—that point at which a draft impact statement should first be made public—has emerged as a critical variable in the effectiveness of highway environmental assessment.

Now, to the consternation of those who felt that they were beginning to perceive the proper procedure and timing for highway impact statements, the Federal Highway Administration has shifted from the tactics of King Minos to those of the Queen of Hearts. On May 8, 1974, the Federal Highway Administrator announced that although the pre-1974 procedures for highway federal-aid approvals had worked well, "the State highway departments have reached a degree of maturity such that they no longer need careful and detailed scrutiny . . . in some areas of program administration,"² and for that reason, the existing federal-aid approval structure would for the most part be discarded.