DOCUMENTARY HISTORY OF THE FLORIDA CANAL 71

features and value of the proposed enterprise within which to make a counter
showing and which we respectfully suggest would be a reasonable allowance of,
say, 60 days after the arguments are presented, and we ask that you treat that
as being an accepted order of procedure. Does the board desire the names of
the objectors of the different branches, or how shall that be recorded, as each
person addresses the board or the witness, or does the board desire to have the
personnel representing the railroads before commencing its presentation?
 Colonel JACKSON. I think that will be satisfactory.
 Mr. KAY. The interests who appear here are the Atlantic Coast Line Rail-
road, of which I am general solicitor; the Florida East Coast Line Railway,
prominently known as the Flagler System, represented here by Mr. Russell L.
Frink, general attorney; the Seaboard Air Line Railway and its receivers, rep-
resented by Mr. F. P. Fleming, district counsel; and the Southern Railway, ap-
pearing here through Mr. W. N. McGehee, commerce counsel. The others can
be supplied as and when the board, if at all, so requires. I will now introduce
Mr. J. E. Willoughby, chief engineer, Atlantic Coast Line Railroad, who will
present the points of objection which have been collected by the engineer talent
of those four railroads along the lines of a memorandum and where there may
be some additional thoughts amplifying the point under each appropriate head-
ing. In other words, we are trying to follow as logically as we can the order
of objection supplementing it at point 14 by the special testimony dealing with
navigability.
 Will you please state your name, age, address, and position?
 Mr. WILOUOHBY. J. E. Willoughby, chief engineer, Atlantic Coast Line Rail-
 road, 62 years, Wilmington, N. C.
 Mr. KAY. Mr. Willoughby, have you in hand a memorandum prepared cover-
 ing the joint thoughts of the engineer representatives of the four lines men-
 tioned?
 Mr. WrLxovnmY. Yes.
 Mr. KAY. Will you please proceed in this order: Mention the numbered para-
 graph as you take up each point, then add to that anything that you desire in
 the way of an addition or amplification of what has just been read as the
 real point of objection.
 (Mr. Willoughby reads the memorandum herewith marked "Exhibit 1.")
 ExHmBrr 1

 Joint statement of Mr. J. B. Akers, assistant chief engineer of Southern Rail-
 way Co.; Mr. W. D. Faucette, chief engineer for receivers of Seaboard Air
 Line Railway, Mr. L. C. Frohman, chief engineer for receivers of Florida
 East Coast Railway, Mr. J. E. Willoughby, chief engineer, Atlantic Coast Line
 Railroad Co.

 The United States War Department, through its Engineering Corps now
 investigating and making ready to report on the project of a ship canal between
 the Gulf of Mexico and the Atlantic Ocean across the State of Florida, having
 extended the railways certain general information, it is considered proper and
 suitable for said railroads to now come before your board of engineers and
 record at this time certain important observations, which, in their judgment,
 should be placed before you.
 1. The railways for whom this statement is made, own, operate, and/or
 control practically all the common-carrier railway mileage in Florida, and
 have large investments in Florida. These railways have in years long gone by,
 as well as during the decade 1919 to 1929, built many miles of railways in
 advance of the traffic needs of Florida so as to encourage the more rapid devel-
 opment of Florida and the Southeast, and have established excellent schedules
 for transport of persons to and from Florida, and of the products thereot
 Every encouragement has been given by these railways to outside capital to
 invest in Florida because these railways are vitally interested in the preserva-
 tion of and the future growth of the agricultural, forestry, mining, and manu-
 facturing Industries of Florida and of the real estate and trading interests of
 Florida and the southeast. These railways are peculiarly interested in the
 continued development of eastern, central, ond south Florida. It is their great
 interest which brings us before your honorable Board.
 2. It is submitted that the navigation interests of ocean-going craft are
 not the factors for the control of decision as to the net advantage, if any,
 of the proposed project but that the controlling factors should be: (a) The