340 ANALYZING DATA
idea that people wanted to provide a uniform structure for the EISs is not invalid, but it does not
address the direction or focus of the structural changes. This direction had the effect of raising the
status of wilderness values over and above the status of agency programs in the EISs. Internal
memos commenting on draft EISs addressed the question of the intent of the D.C. staff reviewers.
These comments indicated that the reviewers did, in fact, intend for the changes to go in a particu-
lar direction. For example, one comment stated: “We are evaluating the impacts of management
actions on environmental subjects such as wilderness values.. .” (Office of Environmental Project
Review 1986, 2). Wilderness values are located in and recognized through the delineation of land
as a wilderness study area. The comment indicates that the focus of the analysis should be on
wilderness values and study areas first and foremost. One might consider that FLPMA directed
the agency to review areas with wilderness characteristics and make recommendations about
their suitability for preservation as wilderness. This mandate directs attention to the study areas
and not to agency programs; it indicates a statutory basis for the direction of the change, which
was substantive in character more than it was format related for the sake of report conformity.
Irrespective of intentions and statutory justifications, the organizational structure of the docu-
ments exists as a part of their content and frames their subject matter. The change in some of the
EISs highlights a general principle: The structure of technical documents like EISs frames policy
issues. Potential sources of policy content for such framing include laws, agency guidance, and
individuals who generate the documents. Whether changes occur or not, we can examine the
structure of technical documents as narratives or story lines to identify how they frame policy
issues.^5 In this case, the structure of these documents frames the wilderness issue as a story
about causes and effects across various configurations of wilderness designations. The struc-
ture of the final EISs, along with changes in some drafts, provide evidence of movement in how
the agency as a whole framed the wilderness issue: The evidence is found in the shift in the
story line about what would be affected by designation decisions. This demand from the re-
viewers in the D.C. offices generated a structure for the EISs that could serve the political
purpose of highlighting how wilderness designation protects wilderness values in the study
areas from development impacts. The changes in framing may have provided a way to accom-
plish political objectives in seemingly nonpolitical ways, that is, by asking for uniformity of
structure in technical documents.
This change in frame had direct consequences for the BLM’s technical analyses because it
brings greater attention to some things (e.g., wilderness values) and reduces attention to others
(e.g., impacts on agency programs). As detailed in the next section, it had the potential to affect
the type of information that was included in and excluded from the EISs.Assessing Information Content and Issue Framing—Inclusion and
Exclusion of InformationIn my analysis, I considered what information was included in the documents and how these
inclusions and exclusions might be related to the story lines and framing of the issue. Internal
reviewers asked field personnel to remove irrelevant information from the documents (Interview
103). The basis for judging relevance, from their perspective, was whether the information was
related to the impacts of wilderness designation recommendations. If something would be af-
fected by the recommendations, then it was relevant; otherwise, it was to be omitted. Judgments
about relevance of information are tied to the cause-effect story line of the EISs: A shift in atten-
tion from resource programs to study areas would render some things relevant that had not been
so before, because the definition of what is being affected would change.