INTERPRETIVE CONTENT ANALYSIS 333these levels, personnel are hired into programs organized by resource and are known as resource
specialists (e.g., minerals specialist, recreation specialist, or wildlife specialist). These specialists
wrote the wilderness EISs during the 1980s.
The wilderness EISs represent a response to two pieces of legislation, the National Environ-
mental Policy Act of 1969 (NEPA) and the Federal Land Policy and Management Act of 1976
(FLPMA), and draw on a third, the Wilderness Act of 1964. Through NEPA, Congress required
federal agencies to generate EISs to assess the impacts of “major Federal actions significantly
affecting the quality of the human environment” (National Environmental Policy Act 1969, 4332).
EISs provide a mechanism for participants in policy debates to frame arguments and make deci-
sions about future federal actions through analysis of environmental impacts. The federal action
that the wilderness EISs analyze is the potential designation of public land as wilderness areas.
This action arises from FLPMA, which directed the BLM to review land in its jurisdiction (ex-
cluding land the agency manages in Alaska) by 1991 to recommend areas for wilderness designa-
tion (Federal Land Policy and Management Act 1976, 1782). The agency produced the wilderness
EISs as a part of its response to this mandate.
The EISs assess 855 wilderness study areas, comprising 24 million acres of public land, and
make recommendations for or against wilderness designation of the areas. They describe wilder-
ness characteristics of each area based on attributes defined in the Wilderness Act of 1964. Such
an area:
(1) generally appears to have been affected primarily by the forces of nature, with the im-
print of man’s work substantially unnoticeable; (2) has outstanding opportunities for soli-
tude or a primitive and unconfined type of recreation; (3) has at least five thousand acres of
land or is of sufficient size as to make practicable its preservation and use in an unimpaired
condition; and (4) may also contain ecological, geological, or other features of scientific,
educational, scenic, or historical value. (Wilderness Act 1964, 1131[c])The EISs I examined were generated during the second phase of a three-phase wilderness
review (Bureau of Land Management 1978). In the first phase, the BLM inventoried public lands
to identify areas with wilderness attributes. Land that passed on to the second phase, the study
phase, was assessed in parcels known as wilderness study areas, which were evaluated in the
wilderness EISs. In the third phase, the BLM produced reports to document agency recommenda-
tions. The EISs produced in the second phase also identified other resources in the study areas,
development potential for the resources, and impacts of wilderness designation and non-designa-
tion alternatives.
Production of the EISs themselves occurred in four steps: (1) BLM personnel in field offices
wrote draft EISs; (2) staff in Washington, D.C., in the Department of the Interior, Office of Envi-
ronmental Project Review (OEPR), and in the BLM Branch of Wilderness Resources (Washing-
ton Office), as well as members of the public, commented on the drafts; (3) reviewers from
Washington, D.C., and field personnel negotiated over changes to be made; and (4) field person-
nel wrote final EISs. In generating the EISs, field personnel worked in teams of resource special-
ists. Together, they characterized connections among their resource programs, the wilderness
program, and the study areas. They defined tradeoffs between wilderness designation and other
resource uses. Their initial efforts appeared in draft EISs. Comments from the OEPR and the
BLM Washington office often asked the field personnel to restructure their analyses. According
to the OEPR, many of the draft EISs contained vague, improperly focused analyses, irrelevant