Somewhere in the basement of the U.S. Forest Service’s Washington office, seventy boxes of letters are gathering dust. They encompass the bulk of public comments received in response to the proposed Roadless Area Conservation Rule. Consisting mainly of post cards, the correspondence was parsed and processed within the agency’s bureaucratic labyrinth, converging at two facilities sequestered in the intermountain West.

With an increasing number of citizens sending letters, e-mails, post cards and faxes in response to land management proposals, the Forest Service has made a science of content analysis. A content analysis team now examines citizen input about small local projects along with high-profile proposals such as the roadless rule, which brought in more than 3 million pieces of correspondence.

In Salt Lake City, Utah, and in a similar facility in Missoula, Montana, content specialists and temporary workers analyze piles of responses, the official term for letters, post cards, e-mails, faxes, phone calls, petitions or presentations by members of the public. Individual responses might contain several quantifiable comments, distinct expressions of concern that are separately coded and entered into databases.

“We may get 100 responses but have 350 comments,” says Dave Barone, a forest planning specialist and member of the team that crafted the environmental impact statement for the roadless rule, now stalled by lawsuits.

Many individual Forest Service units still read and process their own mail, time permitting. However, Chris Wall, a team leader in the Missoula office, points out, “Content analysis takes a lot of time. We’ve developed a process that is very efficient.”

The National Environmental Policy Act of 1969 directed the federal government to involve citizens in environmental planning. Professor Lynton Caldwell, a primary architect of the act, told Congress in 1968, “What the nation requires are guidelines to assist the government, private enterprise and the individual citizen to plan together and work together toward meeting the challenge of a better environment.”

But did Caldwell and other NEPA authors envision the bulging mailbags (much less the e-mails and faxes) that arrive daily in Salt Lake City, Missoula and other Forest Service offices around the country? Does more efficient content analysis lead to better decision making? And with the reams of paper cascading everywhere throughout the modern process, can a single letter ever make a difference? Can 3 million?

“I’ve seen environmental analyses and [environmental impact statements] where a commenter pointed out something that changed the whole alternative,” says Rich Fairbanks, a forester for the Willamette National Forest in Oregon. But Fairbanks admits, “The whole thing is stacked against the public.”

The act’s regulations state that agencies must write impact statements for projects with significant environmental effects and circulate the draft environmental impact statement to other branches of government, American Indian tribes and concerned citizens. (Smaller projects demand only a shorter environmental analysis) The various parties must get a chance to comment on the draft document.

The act does not oblige the Forest Service to base its decisions on what members of the public want. Rather, regulations direct planning teams to “review, evaluate, analyze, and respond to” substantive comments in the final environmental impact statement or assessment.

Fairbanks says substantive is the key word. Forest planners pay more attention to relevant comments that make fresh points about a project. “The more specific it is, generally the more effective it is,” Fairbanks says. To be seriously considered, a letter should not be a “rant,” he adds. “It has to be substantive. It has to be specific. It has to say something about cause and effect.”

On the Cottage Grove Ranger District in Oregon’s Umpqua National Forest, interdisciplinary planning teams still do NEPA the old-fashioned way. Large binders hold scores of letters, mostly handwritten, along with telephone message slips and Post-It notes.

Laurie Bernstein, a fisheries biologist, says she and her colleagues carefully consider all letters and respond to those that express relevant concerns. “We’re making efforts to build relationships with local activists,” she says. “We appreciate their very specific comments and their effort.”

Recently, the Wyatt timber sale, which involves old-growth logging, elicited a great deal of input. Much of it concerned citizens’ distress over the cutting of older trees and the desire to preserve a sense of solitude in the forest.

“I am tear-eyed to think of a future without such places to behold,” wrote one citizen on tree-free kenaf paper. “I pray we can make a difference and maintain love for what has come about without man’s intervention.”

A phone message slip reads, “He wants the Wyatt timber sale cancelled because it provides wildlife habitat.”

Although such comments are not what most planners would call substantive—expressing emotion and individual preference rather than focusing on specific aspects of the sale in question—the concerns were noted, according to Bernstein. “We recognized that the cutting of old growth is a very big issue,” she says. In response, the district developed additional alternatives, one that relies on thinning rather than clear-cutting and one that preserves an unroaded band.

Bernstein says the district was able to change course because the comments arrived during scoping, a public process that takes place before the environmental assessment is written. Scoping follows publication of a notice of intent and usually involves field trips, public meetings and comment solicitations. It’s a phase when the interdisciplinary team formulates issues in the project and the course of action is still relatively pliable.

“We hope to pick up all the issues and concerns during the scoping process,” Bernstein says. “If it’s a perfect world, when the EA comes out for public comment there are no new surprises.”

Modifying a draft environmental assessment or environmental impact statement and affecting the final decision requires a sophisticated type of response. Bernstein points to a letter from Eugene activist James Johnston concerning a thinning sale as an emblematic example. It is four pages long and includes seventeen headers outlining each comment.

Comment 1 expresses “support for projects like Herman Thin.” Comments 2㪩 offer extremely specific feedback on project particulars, from variable density thinning to bark beetles to ground-based logging in riparian reserves.

Bernstein says the latter comment opened the district’s eyes to an unnoticed problem with tractor logging in a riparian area, triggering a change in the analysis.

As director of the Cascadia Wildlands Project, Johnston must rank as one of the great, marathon Forest Service letter writers. He commented on 116 timber sale projects last year, writing two to three a week, many more than fifty pages long. You might think Johnston believes in the NEPA process, but you’d have trouble finding a greater cynic. “The whole process is a sad joke,” he says.

Despite his relative success in gaining the Cottage Grove District’s ear, Johnston says the only reason he submits NEPA comments is to secure standing to sue the agency. He believes that on its own, citizen input does nothing to sway Forest Service decision making. “Maybe there’s a forest supervisor out there who cares what the public thinks about a timber sale,” he says, “but I haven’t met one.”

Johnston says that citizens can more effectively voice their opinions through other means—by writing to elected officials, organizing civic and church groups, educating the mass media and sitting in trees. “When a politician reads 1,000 letters from his or her constituents, they’re not going to ignore that,” Johnston says, “but the agency can and does ignore public sentiment.”

So does the Forest Service really care what members of the public think? Do piles of post cards, such as those mailed in response to the roadless rule, have an impact? Many citizens and activists believe that flooding agencies with correspondence is worthwhile.

Tom France directs the National Wildlife Federation’s northern Rockies office and has organized several public involvement campaigns, including one directed at the U.S. Fish and Wildlife Service in support of grizzly bear reintroduction, which generated about 25,000 comment letters.

“I think they do look at the overall weight of public opinion,” France says. He adds that the process of getting citizens to write letters can be a valuable organizing tool. “There is an educational process in even getting people to sign post cards,” France says.

That viewpoint has led to the explosion in NEPA comments over the last five years. Wall, Missoula’s content analysis team leader, attributes the increase, in part, to the Internet, which has sped the course of advocacy. Large controversial projects especially attract a high quota of form letters—up to 95 percent, according to a Forest Service spokesman.

The swelling volume of correspondence (which Wall says began with responses to the Tongass National Forest Plan revision in the early 1990s) led the Forest Service to establish the stand-alone content analysis program in 1995.

The program was the brainchild of Jody Sutton, formerly an employee on the Flathead National Forest in Montana. “Jody saw the need and filled it,” Wall says. “It’s more cost-effective for us to do that portion of the work.”

Today the program employs seventy-six regular employees and brings in detailers and contract workers for high-volume projects. “It takes a lot of time and effort to enter all those names into a database,” Wall says. “People are typing away on many, many computer terminals to handle it.”

The content analysis program takes no official position regarding the effectiveness of form letter and post card campaigns. “From a technical perspective, if we get one post card, we can capture the information. If we get 10,000, it’s a matter of capturing the demographics. There’s no new information,” Wall explains.

Interdisciplinary team members writing the environmental impact statements decide which comments are within the scope of the project, which are significant, and so on. “We don’t apply any filter to our products,” Wall says. “Our goal is to represent what the public is saying.”

Wall doubts that the authors of the National Environmental Policy Act foresaw electronic communications and the ability of so many people to become involved in forest planning. He thinks public input is a good thing, though its effect on decision making is uncertain.

“Technically, NEPA is not a vote,” Wall says. “But politics is involved in almost any land management decision.”

The statement “NEPA comments are not votes” is an oft-repeated refrain of Forest Service planners. The 1,200-page summary of public comments for the latest incarnation of the roadless rule makes the point: “Because respondents are self-selected, they do not constitute a random or representative public sample.” Thus, comments are consumed but rarely digested.

Cherie Shelley, director of ecosystem planning for the Alaska Region of the Forest Service, explains that the most useful (read: substantive) NEPA comments are those that

1) challenge the accuracy of the information presented in the document.

2) challenge the adequacy of the environmental or social analysis.

3) present reasonable alternatives, including mitigation measures, that have not previously been considered.

“Form letters and/or post cards usually do not provide this kind of information,” Shelley points out. She shares the opinion, widely held by Forest Service planners, that post cards don’t really count.

“While they may give some indication of public opinion on a particular project, they provide little useful specific information,” Shelley says.

Fairbanks doesn’t think that raw opinion counts for much either during the process. He points to a Forest Service course handbook on forest plan implementation. It reveals the bureaucrat-speak necessary to be heard by planners struggling to identify relevant issues for an environmental impact statement.

A public letter might say: “I object to this project because you people are always messing up the environment. I have been fishing the South Fork for thirty years, and I have never had such bad fishing since those logging trucks started running up and down the Old Road. I just don’t know why the taxpayers have to put up with it. And there’s the logging. This area used to be a real wilderness. Now it looks like a tornado went through. No wonder the fishing is so bad anymore.”

The handbook instructs planners to translate this into the following issue statement: “The construction of Road 719 B, as proposed, crosses a 300-yard stretch of highly erosive soils on steep slopes in the NE 1/4 of Section 5, T4S, R8E. A proposed clearcut adjacent to that road lies on the same soil type. Sediment from the proposed road construction and timber harvesting could become imbedded in rainbow trout spawning gravels in the South Fork, reducing reproductive success and, consequently, fishing success.”

Fairbanks says the form comments take is not important (e-mails, typed or handwritten letters and faxes are weighted equally). What matters, he says, is substance. “If you want to get on board,” Fairbanks says, “if you want them to change something, specificity is the most important thing.”

But France thinks the various sorts of comments have a rightful place in the NEPA landscape. “There are different ways of commenting, and each has its own effect on the process,” he says. “Quantity and quality are not mutually exclusive.”

France acknowledges that it’s difficult for citizens to influence land management decisions in a meaningful way. “The agency usually enters the decision-making process with some idea of where they want to go,” he says. Perhaps public input can affect only the margins of a project. “The if or the whether is usually much harder than the how,” France says. “There’s a black-and-white go/no-go that’s associated with many decisions, and affecting that is difficult.”

It’s notable that many Forest Service critics agree with those inside the administration, including Chief Dale Bosworth, that the NEPA process is problematic. But the solutions that such various parties propose differ widely.

Shortly after he took over as chief, Bosworth complained to Congress about “analysis paralysis” in the agency. “The environmental laws and regulations we must follow have admirable objectives that I fully support,” he said, “but the processes we must go through have become so complex and cumbersome that often we can’t do what is needed for the health of the land.”

The solution, according to Bosworth and others in the Bush administration, is to curb the analysis. That includes NEPA pilot projects that limit public review, as well as charter forest initiatives, which would turn management of some public lands over to user groups. The Council on Environmental Quality, which writes NEPA regulations for federal agencies, has established a special taskforce to “seek ways to improve and modernize NEPA.” One of its objectives is to “facilitate timely planning and decision-making to reduce or eliminate redundant and duplicative analyses through the use of programmatic and tiered analyses.” Reportedly, a major concern is finding ways to abridge the overwhelming volume of comments.

However, some activists, citizens and on-the-ground Forest Service workers would deal with the problem from a different angle. Rather than subscribing to the view that “too many cooks spoil the broth,” they would bring in more people to plan the menu. France says the current process polarizes various interest groups and “elevates the agency into the role of final arbiter.” He feels there are ways to glean public opinion that are more constructive both to the agency and to the public. For instance, he suggests establishing a consensus approach, which would involve bringing people together to help frame various alternatives.

Perhaps the emphasis on scoping comments by some districts, such as Cottage Grove, is one way of using public input more effectively. When citizens see that their input matters, they are probably more likely to be constructive and less likely to oppose the project. Bernstein was recently heartened to read a comment letter from a staff member at a statewide environmental organization. The letter listed five specific concerns about a timber sale and made recommendations for dealing with them. “If the ID team looked to accommodate these concerns, there would be little controversy about this sale and it would not be subject to appeals, protests, and litigation,” the letter promised.

“That’s huge,” Bernstein says. Such comments and responses represent dialogue rather than unheeded rhetoric. But perhaps such dialogue can take place only on a local scale.

In terms of gargantuan public input on initiatives such as the roadless rule, the comments don’t seem to lead the agency very far from home. The Bush administration’s latest Advance Notice of Proposed Rulemaking elicited 726,440 responses. The comment period ended September 11, 2001, and the content analysis team released its lengthy summary of public input in late spring 2002.

Of the total responses, 52,432 were “original” and seem to support roadless area protection. But such numbers generate only a terse summary from content analysis: “Some respondents emphasize protection and preservation ... They request implementation of a national roadless area management policy that lays down strong restrictions from which no individual forests are exempt. Other respondents emphasize active management of natural resources É They request continuation of local decisionmaking, which allows for different management prescriptions for different roadless areas depending on condition and need. These different viewpoints are evident in nearly all the comments offered ...”

So despite the size of the roadless jury, it’s still out.