In Gramlich v. Lower Southampton Township, 838 A.2d 843, 844 (Pa. Cmwlth. 2003), petition for allowance of appeal denied, 578 Pa. 696, 851 A.2d 143 (2004), the Court considered "whether a concrete inlet and opening of a drainage pipe, constructed by a homeowner in the unpaved right-of-way adjacent to the paved portion of the street, comes under the 'streets' or 'real property' exception to governmental immunity." The Court "distinguished a 'right-of-way' from the paved portion of the street for purposes of the 'highway' exception to sovereign immunity." Gramlich, 838 A.2d at 846. The Court explained that "a highway, for purposes of sovereign immunity, encompasses the 'cartway,' that is, the paved and traveled portion of the highway, and the berm or shoulder, the paved portion to either side of the actual traveled portion of the road . . . not the right-of-way." Gramlich, 838 A.2d at 846-47. Thus, the Court concluded that neither exception to sovereign immunity was applicable.