Easements by Way of Necessity Across Federal Lands

Is an easement across federal lands implied when the United States has granted a tract of land to which the grantee would otherwise have no practical means of access? In the recent case of Bydlon v. United States, the Court of Claims implied an affirmative answer in holding that the ancient doctrine of ways of necessity applied to Government grants to create access easements by air. The purpose of this Comment is to determine the validity of that conclusion and the extent to which it may be utilized to give life to dormant easements. Particular attention will be given to the possible existence of such easements across national forest lands.