In 1989, the environmental impact statement (EIS) celebrates its twentieth birthday. The child of the environmental consciousness of the sixties and the legislative action embodied in the National Environmental Policy Act (NEPA) of 1969, the EIS process has grown rapidly, filling volume after volume and packing the archives of government agencies. It has risen to importance as the primary type of discourse connected with actions involving our public lands.

NEPA requires federal agencies, and in some cases private industries, to issue an EIS before effecting or allowing a change in a designated area of land, water, or air. During the drafting of NEPA, EISs "were invented in response to the anticipated administrative indifference or outright hostility toward" the new legislation (Dreyfus & Ingram, 1976, p. 251). The EIS should describe a proposed action, the reasons for it, and any short- or long-term effects. It must also consider, in the same terms and using the same methods of analysis, optional plans for managing the environment in question, There seems to be an unwritten law that requires "'equal time" for the presentation of each option, thereby enhancing objectivity.

The principal authors of the document are usually hired scientific consultants or government agents with scientific training. These "Resource Specialists," as they are called in the parlance of the Department of the Interior, are usually assisted by technical writers and editors. The research and writing are nearly always a team effort.

The primary audience for the EIS is people who make decisions about land use and air and water quality-executive administrators sometimes judges and legislators, But the intended audience also consists of invited commentators, related government agencies, and concerned citizens -- all of whom may in principle influence the final decision of the primary audience through testimony, advice, lobbying, and voting.

This unique combination of purpose, authorship, and audience creates considerable rhetorical problems. The authors must remain objective in their presentation and must embody in their style the ethos of detachment associated with scientific investigation. But this stance tends to block the effectiveness of their language, since it favors the static syntax of academic science or social science in a document that needs active syntax to be effective. The style is likely to make the information of the EIS less accessible to those who need it most - decision makers and the people who seek to influence them (and whose interests the decision makers represent).

This article offers a case study built upon our readings of a number of EISs developed for projects in central New Mexico and filed in the Socorro District Office of the Bureau of Land Management (BLM). The various authors and editors of these documents told us that they followed the United States Department of the Interior (DOI) Editorial Management Handbook for Environmental Impact Statement and Environmental Assessment (BLM, 1980), which we also studied. From the start, we recognized that the original legislation and subsequent practice has imposed tremendous difficulties on the writers of these documents. One of our first concerns, one that remains with us, has been to understand these troubles through rhetorical study. We, begin, therefore, with a treatment of the authorial stance suggested in the EISs we considered.

When trained humanists--English teachers who teach technical writing, for example, or journalists like Edwin Newman who comment on the abuses of language--confront texts produced by technical experts, they commonly disparage the intentions that lie behind this writing and, like the typical middle-class citizen suspicious about how tax dollars are spent, they assume the authors have something to hide. Does ignorance masquerade as knowledge in this jargon? Or, more probably, does the apparent contempt for ordinary language indicate a corresponding contempt for the ordinary reader untrained in technical matters? If, as the semioticists claim, one's social existence is determined and defined by the language one habitually uses, then the technical expert's refusal to produce discourse in ordinary language amounts to a refusal to recognize the presence-even the very social existence-of nontechnical readers.

In this hypothetical critique, there is certainly a grain of truth, for the tone for which the expert strives is one of disinterest. The perspective of the expert requires distance from subject matter and audience. The language of the expert therefore nullifies potential identifications with the ordinary reader and with the "environment" that is examined, and this means not only the "physical environment" (land, air, water, plants, animals) but also the "social environment" (people), both of which are thoroughly objectified. But the objective tone does preserve a social identification with the community of experts; the very "identity" of the expert depends on disinterest and distance. And, though we typically think of the writing of technical experts as alienating to audiences, we rarely recognize that the chief phenomenological move of such authors is self-alienation, a dehumanization that objectifies the self and those of one's immediate social group (other technical experts reduced to names attached to studies that compose the technical "literature) as surely as it objectifies the land, water, air, plants, animals, and people who constitute the environment under study. This implicit denial of the self replaces a subject-object relation with an ideal object-object relation between the scientist and the object of study.

No contempt for the ordinary reader is necessarily intended in this approach. On the contrary, in the ElSs we examined, there is good evidence of the author's efforts to follow the injunction on terminology given in the

Editorial Management Handbook (BLM, 1980): "The necessity of maintaining the readability of an EIS …requires that the Resource Specialists must carefully ensure that only that level of technical language essential to the average reader's understanding is retained" (p. 7-3). To meet this goal of communication, in what seems a direct contradiction of the bourgeois critique, the authors courteously define technical terms, at least on first use, and provide glossaries of important words. Of course, saturation may still result from the introduction of too many technical terms in a short space. But, for the most part, familiar words seem to be preferred to technical terminology. Native plants, for example, appear as "saltbrush" and "mesquite" rather than as some Latin word unfamiliar to most farmers and ranchers, and to avoid confusion (how many desert plants are called "saltbrush"?) photographs are included.

But the approach to language of the Editorial Management Handbook is atomistic; it keeps the authors' and editors' attention focused on individual words, the treatment of which in fact increases identification with the public readership and decreases the characteristic detachment of scientific writing. That detachment and the general tone of cool ef6ciency are nevertheless preserved in the syntactic and structural features of the EISs. Not the individual words themselves but the combinations of them place this prose Into the category that Lanham (1983) has named 'voiceless" and that Killingsworth (1987) calls "thingish." The humanist approach to technical style that reifies voice" and privileges "human interest" is, admittedly, a rich relation of the bourgeois critique already noted (and dismissed). In a rhetorical analysis that recognizes a plurality of contexts and perspectives, it is wise to remember Feyerabend's thesis: "A tradition assumes desirable or undesirable properties only when compared with some [other] tradition [,] i.e., only when viewed by participants who see the world in terms of its values" (1978, p. 27). But, for now, it will prove useful to maintain the humanist perspective as a dialectical counterpoint in the description of the objectivist mode of writing and thinking in the EIS.

Translated into distinctions of style, the humanistic program becomes the "verb style" identified by Lanham (1983); this style favors expressions of actions ("I came. I saw. I conquered") over and against the objectivist stylistic program, the "noun style," which favors expressions of stasis ("Arrival; Reconnaissance; Victory") (p. 15). The humanist style pictures a world full of actors performing purposeful actions upon objects in an ever-changing scene; it is style that requires active verbs and human subjects, as well as a full range of adjectives, adverbs, and phrases and clauses that delineate subtleties of modification and relation. But the objectivist style -- expressive of a world frozen into stasis and broken ("analyzed"') into its odd components -- is dominated by features like passive voice, nominalizations, and strings of noun modifiers and is generally characterized by grammatical indefiniteness, impersonality, and high levels of abstraction.

A frequent target of humanistic reform (though the reformers rarely identify themselves as humanists but rather insist on their interest in general readability), the features of objectivist style have been diagnosed in bureaucratic and technical prose and have been treated with editorial antidotes elsewhere (see especially Killingsworth, 1987; Williams, 1985). Here we introduce them not as objects of revision but as the chief syntactical means by which the authors of EISs achieve distance from their subject matter and audiences.

Following is a list of examples of each of the major features of objectivist style that we discovered in our reading of the ElSs.

Passive voice (obliterates agents of actions and thereby obscures responsibility and/or authority):

But these editorial quibbles, like the atomistic focus of discussions of terminology, may well bog us down in details and keep us from seeing that to substitute humanistic expressions for objectivist ones would have far greater effects than improving "readability." Such a transformation would, first of all, undermine the identity of the technical expert. We might argue that this loss is necessary to effective action in a democracy. The technical experts may keep their ethos intact for writing that is directed to other specialists in their fields, but for public documents like EISs they should write to the average citizen in ordinary language, and, if they find this impossible because of the power of their habits of discourse, the BLM editors should do the job for them.

In fact, democratic and capitalist values have shaped both the need for experts and the styles and structures of such prose as we encounter in the ElSs of the Bureau of Land Management. The next two sections will develop this thesis.

In the sentence before last, We were tempted to write "the BLM's EISs" and thus to join the orgy of acronyms we found in the documents we read. (We submitted instead to Orwell's injunction never to use words and phrases -- or, in this case, constructions -- one is accustomed to seeing in print.) The problem with amassing acronyms is that not only do they cause the reader not imbued in government jargon the inconvenience of constant page-turning to locate original references or lists of abbreviations, but they also increase the density of information that must be absorbed in a short space. Most EISs are thick and dense and are therefore, amazingly intimidating to the average reader. In addition to proliferating acronyms, the authors favor high-density graphics such as long, multicolumned tables, elaborate technical mapping, and photographs, instead of low-density graphics like bar charts and simple line drawings. The EISs therefore compile information without necessarily communicating it effectively. An ordinary reader is quickly saturated. Reading becomes tedious and frustrating.

The authors of the "Standards of Style and Usage' section of the Editorial Management Handbook, perhaps unwittingly, encourage such style. "The economical use of words is stressed in the new CFO Regulations," the manual reads, without indicating in the immediate context what the CEO is, "and every review looks for ways to shorten the text without sacrificing clarity and meaning" (BLM, 1980, p. 7-2). This passage, very typically, gives advice without examples of methods by which to achieve the goals it sets. Though it does not give examples, however, it certainly sets them in its own use of acronyms. Moreover, any technical writer knows that high-density charts and tables are powerful summarizing tools, highly efficient in their ability to display large amounts of comparative data in very little space. But several commentators on graphics (see Tufte, 1983, for example) point to the danger of reader saturation, which of course is a form of ineffectiveness. The authors of the "Standards" and their followers, the authors and editors of ElSs, or -- to depersonalize the process and thereby to avoid the humanistic tendency to place blame and to simplify causes-- the systems of management by which ElSs are produced, seem to prefer efficiency or stylistic "economy" to effectiveness: "Every word and every revision in an EIS, in effect, costs money, and this should be the prime consideration in EIS writing" (V. 7-2).

Not that the problem of effectively meeting to an audience is ignored in the Standards. Under the heading "Clarity of Text" appears this advice: "The EIS is primarily intended for the decision maker and the decision-making process; however it must also be written in a manner conductive to public understanding" (pp. 7-2-7-3). This seems to follow fairly closely the general advice an the style of feasibility studies given by Houp and Pearsall (1994) in their popular textbook on technical writing:

The Standards do advise, as we mentioned earlier, that "Resource Specialists must carefully review their written material to ensure that only that level of technical language essential to the average reader's understanding of the subject is retained" (BLM, 1980, p. 7-3). This suggestion requires a great deal of interpretation, especially the key terms "technical language," "essential," and "average reader." Again, no examples are given, so this advice joins the other goals such as "clarity, simplicity, objectivity, and consistency" at a very high level of abstraction that is of little use to the practical technical editor and "Resource Specialist" in the BLM regional office. As Joseph Williams (1985) writes, "We don't lack words to praise good writing: clear, direct, readable, precise. But words like these reflect only how we feel about writing: they don't tell us what good writing is" (p. 8).

Without guidelines about the exact nature and needs of their audience and without specific descriptions of appropriate style -- information that seems purposely obscured by the managerial system of bureaucratic government -- the authors of ElSs are left fairly much to their own devices, and they turn therefore to the style they find most comfortable and most congenial to the objectivist mode of thinking. They adopt the persona of the expert and write in the noun style.

Their use of acronyms and high-density graphics, moreover, is not only countenanced but encouraged by the emphasis on economics. We begin to see that "Resource Specialists" are, if not actually constituted by the requirements of their agencies, certainly cast into their stylistic role by those who oversee, edit, administer, and largely control their production of discourse. The next section demonstrates how the powers-that-be require the EIS to meet structural demands that further restrict the "voice" of the expert authors.

To get a sense of the overall structural limits of the EIS, let us consider a single example of the documents we studied. The East Socorro Grazing Environmental Statement (BLM, 1979) treats a topic of major environmental, economic, and social interest in the region -- the leasing of public lands for private cattle grazing. It was on this very issue that in 1974 the BLM was first challenged in court under the National Environmental Policy Act and was forced to begin producing EISs (Bardach & Pugliaresi, 1977).

In the East Socorro Grazing Environmental Statement, the BLM proposes a plan that would significantly tighten the management of leased grazing areas to improve, in the long run, "vegetative production, density, cover, and wildlife habitat" and, through the implementation of a system of resting and deferring use of pastures, to "eliminate competition of livestock with wildlife and wild horses for available forage" (BLM, 1979, p. i). In addition to the proposed action, the study considers five alternatives, which are given the following titles: No Action, Livestock Adjustment, Pasture Capacity Level, Enhancement of Sensitive Resource Values, and No Grazing.

The following passage shows how the EIS treats the successive alternatives according to the impact each will have on a given item of environmental concern. Here the concern is the human resource. Note that, instead of talking about people, the EIS deals with "jobs" and "operators," that is, people reduced to their productive functions:

The requirements of objectivity place two structural demands on the passage that account for both its dullness and the moral offensiveness experienced by many readers of the EIS:

The rhetorical effect of the reification, however, is startling to the humanist and maddening to the small-time rancher dispossessed in the interest of environmental protection and future ranching.' The IES predicts that in the "short term" -- in terms of nature ecology, 20 years is a very short time -- jobs lost will be restored, but of course any reader knows that many of those people who hold the jobs at the time the EIS is written will be dead by the time their jobs are restored. The clash of perspectives is more than adequately represented in the letters that appeared in response to the, East Socorro Grazing Environmental Statement when it was released in draft form in 1979. The next section deals with those letters.

The language of the letters is the polar opposite of the "voiceless" prose of the EIS. The "small operators" who stand to lose the most in the proposed plan mainly argue that the BLM is undermining the free enterprise of the ranching business and ignoring the longevity of those who would be hurt by the plan as well as the improvements they have made to the land on which they operate their ranches. One respondent writes: "I have reviewed the East Socorro Grazing Environmental Statement and found it very inadequate which could be described as a serious blow to ranching and private enterprise in these United States. Government bureaucracies have found another way to regulate our lives" (BLM, 1979, p. 4-94). He continues with a rhetorical flourish that dramatically humanizes the reifying prose of the EIS:

The shift to an economic argument aligns the letter with one from the Socorro Chamber of Commerce that takes a less impassioned but equally resistant tone and represents not only the small operator but the cattle industry in general:

The perspective of the large operator is presented by a letter from one of the most successful large ranchers in the area, who is also a leading banker in the town of Socorro. Again his interest is identical with the capitalist position defended in the Chamber of Commerce letter, but his critique, which emphasizes the inadequacy of the BLM's methodology, is far less forthright. He takes on the experts on their own turf and in their own terms -- or at least a reasonable facsimile thereof. As Larrain (1979) notes, "The dominated … spontaneously formulate their grievances in the language and logic of the dominant class" (p. 157). Though the author of this letter and others like him have dominated the economy of the region for many years, his rhetoric is that of one who is in the process of being dispossessed by the government expert as the dominant figure on the range of central Now Mexico. On the one hand, he complains that the language of the EIS is inaccessible to "the average layman"; on the other hand, his letter awkwardly mimics the stylistic features of that language in an unwitting (?) parody of the nominalized and passive style of the EIS, suggesting an effort to distance himself from the "average layman" by showing himself fully capable of approaching the BLM not from a level of lower education but on equal ground while maintaining noblesse oblige in defending the average cattleman (who is his colleague and customer):

A response from the Salado Resource Conversation District echoes the scientific objections with a cutting remark on predictability: "The constant predictions of vegetative response in 20 years is … questionable. When weather patterns can be accurately predicted ever a period of time it might be possible to predict the exact increase in density and cover the E.S. keeps referring to" (BLM, 1979, p. 4-113). The same letter raises the political objections and recommends an advisory board composed of "'local ranchers, range specialists from New Mexico State University, Game & Fish Dept. representative, Soil & Water Conservation Bd. member, etc." (BLM, 1979, p. 4-114).

Another letter cannily pits the conclusions of one government bureau against those of another. This comes from a representative of the tribe of Laguna Indians whose rangeland touches on BLM-controlled lands. "I find it difficult to understand a proposed reduction of 50% in cattle units on the data that the BLM Technicians have acquired," he writes, adopting, once again in the typical fashion of the dispossessed, the alien jargon of the dominant entity he resists. Over and against the 1976 finding of the BLM range survey that "the proper grazing capacity is 80 cow units," the letter cites a study conducted in the 1940s, in which "The Bureau of Indian Affairs Technicians … determined a 220 cow unit rating" (BLM, 1979, P. 4-106).

A handwritten letter from another Indian represents an entirely different perspective in an entirely different language. This is the perspective of the naturalized citizen of the land, the kind of person characterized in the EIS as the subsistence operator. He ostensibly speaks not as a "concerned citizen" of the state, nor as a capitalist interested in maximum production, nor even as a member of a tribe, but as one who identifies his interest with that of the land and sees no conflict but only unity:

The Proposed Action of the East Socorro Grazing Environmental Statement was approved by an appointed DOI executive, and it is now in effect. The current environmental coordinator of the Socorro Resource District of the BLM reckons that as many as 95% of the estimated 150 proposed actions studied by his office each year are approved and put into practice. This of course raises further questions about the connection between the EIS as a rhetorical form and the ostensible efforts to democratize the EIS procedure. In the next section, we will chart the perspectives from which potential insight into decisions on proposed environmental actions might be gained and will consider how the EIS process, at least insofar as it is represented in our case study and in the literature, has become a self-insulating government function.
 
 

In order to deal with the various people who have in interest in the production of the EIS, we can (in an act of reification of our own) classify their "perspectives" in two ways:

The scientist's main concern is understanding nature and perpetuating research. Government is interested mainly in controlling the flow of power among the various other interests and especially in retaining for itself enough power (whether in the form of knowledge ["intelligence" or information] or money) to be effective in its efforts to control. The corporate rancher, who is closest to the bourgeois capitalist ideal, seeks money enough not only for subsistence but also for what Marx called surplus value, gains on investments that will allow further investments, in an infinite spiraling of capital accumulation with no upward limits. The small ranch operator seeks subsistence above all, but the subsistence former as a pure phenomenon I rare entity in present-day America because of the tendency of capital practices and values to permeate a culture. The environmentalist, whose notable silence in the EISs we examined indicates what many critics (Fairfax 1978, for example) think is a misplaced acquiescence to current governmental practice, seeks also control of the various other interests, but control according to methods quite different from and (at the "greenest" extreme) in conflict with the centralization and power bartering of tradition government; we adopt the term "green politics" for this alternative interest in government. The Native American interest, at least in its traditional form in most tribal groups, is to preserve the land and thereby to preserve the people who are identified with the land. This tradition has been absorbed by the white proponents of "deep ecology," so it is not only a racial or minority perspective.

The already marginalized groups -- the small rancher, the environmentalist, the Native American, or the deep ecologist -- may have, at one time or the other, been made to feel a part of the American dream, but have now had the rug pulled from under them. Small-time ranchers, for example, have traditionally resisted the big-timers, but over the years, because of the adoption of capitalist practices and values, they have become dependent on larger interests. As one of our "small operators" complained in the EIS, he and his fellows are being pushed now into further dependence by government action. They are forced to sell out and are thereby literally dispossessed. They become a part of the labor force of farm workers who have never owned piece of the capitalist pie and who thereby are most susceptible to the plea of reformists and revolutionists. Now among the alienated, they join a motley collection of nature mystics, poets, Indians, and (until recently) underground green politicians. Likewise, environmentalists who, in the decade after the passage of the NEPA, basked in the glow of apparent victory, now see a disturbing trend unfolding. Though in principle ElSs "give environmental groups a legal and political instrument to cancel, delay, or modify development projects that they oppose," in fact "95 percent of draft EISs escaped legal challenge" in the first two years they were required, the very years they would most likely have been challenged (Bardach & Pugliaresi, 1977, p. 23). It used to be that the capitalists did whatever they wanted with the earth; now it may appear that the government technocrats take their pleasure, often with no better results.

In an orthodox Marxist reading of the EIS process we would expect the fringe groups to be marginalized further by government practices. But what is surprising is the degree to which both academic science and traditional capitalist interests (like the big-time rancher/banker we heard from in East Socorro Grazing Statement) have come to feel increasingly dispossessed. NEPA had freed government from capitalist interests. Moreover, the methodology of the EIS has slipped free of scientific influence. Mainstream scientists claim that no scientific research is likely to be used in or precipitated by the production, reading, and discussion of EISs. Schindler (1976) remarks acidly:

The government bureaus, then, have come to undisputed dominance. They have done so however, only by alienating two sectors of society -- big money capitalism and academic scientists (whose funding is more and more dependent upon federal sources) -- that have in the past contributed to the security of the American bureaucracy. The government risks serious reform or even revolution in its current dominant form.

The responses to the draft EISs we, read indicate that the public, though it may be cynical about its own influence, nevertheless reads the intent of the law as demanding instrumental power -- effectiveness -- for the EIS. But at least one legal specialist on the environment has argued that EISs "have little relationship to actual decision making…. Often they are done after basic development decisions have been made" (Friesema & Culhane, 1976, p. 339). In a probing and ultimately disturbing article, Bardach and Pugliaresi (1977) have argued that the intent of the law was not to offer information that would influence decisions, but that instead "the EIS was intended as an 'action-forcing' instrument, that is, a document that might demonstrate to all interested parties that the agency was in fact doing the mandated environmental analysis" (p. 24). These authors conclude, however, that the EIS has not succeeded in this objective, mainly because "agencies cannot be penetrating or creative when their analyses are directed and mobilized for primarily defensive purposes" (p. 24). Rather than ensuring the best use of land, then, the EIS becomes a means of proof, or certification, of demonstration. It is not intended to inform action but to forestall action -- legal action against the agency in question.

"Impact Assessment," as Rossini and Porter (1982) show, "'began without theory or method" with the passing of the National Environmental Policy Act in 1969 (pp. 24-25). In the short time since then, a monstrous "science" and "industry" have developed to fulfill the requirements of the law. Dreyfus and Ingram (1976) claim that the congressional authors of NEPA "never contemplated anything so extravagant as the multiple volume dissertations that are now commonly produced"; indeed "NEPA made no provision for funding extensive additional work by the federal agencies" (p. 256). The agencies have nevertheless absorbed the task and have grown with it as necessary. The NEPA manual on EISs that was distributed in draft form in 1987 (which prefers the expanded title of Resource Management Plan/Environmental Impact Statement-RMP/ElS!) feeds the monster by making this process of "impact assessment" ever more complex and demanding on the agencies. A strong case could be made that the agencies have responded to a perceived threat of legal action by producing enough paper to smother any efforts to contain or redirect bureaucratic action. In this sense, they have been quite effective -- 95% effective, according to Bardach and Pugliaresi, whose 1977 figure is identical to the estimated "success rate" given to us by the BLM official in Socorro in 1988.

The typical approach of rhetoricians in the field of technical communication is to construe effectiveness according to the needs of a specific audience that reads for a specific purpose -- and to assign responsibility for effectiveness to authors and editors. Cheney and Schleicher (1984), for example, conclude in an article that treats the editing of ElSs: "Because authors commonly fail to consider their audience and purpose, they turn out reports that their audience cannot use" (p. 336). What is the purpose of the EIS? The overt purpose is certainly "to provide a lucid summary of a proposed project and its alternatives," and no doubt "that purpose is poorly served by the encyclopedism, obfuscation, and poor focus rampant in many EISs which bury essential conclusions --- or obscure their absence" (Luccitta, Schleicher, & Cheney, 1981, p. 591). But what about the covert purpose or the purpose as seen from the vantage of the government bureau under siege by Congress and environmentalists? The main goal from this angle is to avoid legal action -- a purpose that is perhaps poorly served by clearly stated conclusions and the forthright earnestness of the traditional rhetorical approach. And, even if we could agree to name a single purpose, how could we develop a profile of a "specific audience" from among the proliferating perspectives on the environment? We finally must admit that the old "audience analysis" approach to rhetoric is impractical and indeed naive in the face of the institutional forces that shape the EIS process.

Far more suggestive is the approach through genre theory taken by Carolyn Miller. "For the critic," she writes, "genre can serve both as an index to cultural patterns and as tools for exploring the achievements of particular speakers and writers" (1984, p. 165). The approach that limits discussion to a "specific purpose and audience" may claim to rise above atomistic analysis in a concern for the rhetoric of whole documents (see Cheney & Schleicher, 1984, on "rhetorical editing"), but such analysis remains text-bound and fails to read the historical and cultural codes that constitute the document. If, however, we accept Miller's thesis that "a rhetorically sound definition of genre must be centered not on the substance or the form of discourse but on the action it is used to accomplish" (p. 151), then we arrive at a new understanding of the ineffectiveness of the EIS: "The difficulties am due, at least in part, to historical forces. EISs belong to at least three identifiable traditions: the public environmental movement, natural science, and administrative bureaucracy. Each has a set of values and a set of communicate patterns and requirements that influenced the development of the EIS" (Miller, 1981, p. E-68). Each tradition also has a particular set of actions it would hope to initiate or perpetuate actions that often conflict with those the other traditions. Our continuum of perspectives on the environment extends the list of traditions given by Miller and would thus seem to amplify the desperateness of the conflicted condition she describes.

In final analysis, Miller finds it impossible to confer the status of genre upon the EIS, even though a "clearly defined class of documents" is at hand. The EISs produced in the first five years after NEPA (the period studied Miller), "did not achieve a rational fusion of elements -- in spite of obvious similarities in form and substance, and in spite of a recurring rhetorical situation that was, in fact, defined by law." She concludes that "the imperfect fusion of scientific, legal, and administrative elements prevented interpretation of the documents as meaningful rhetorical action" (Miller, 1984, p. 164). The refusal to classify the EIS as a genre means that "the rules" that govern its production and consumption "do not form a normative whole that we consider a cultural artifact, that is, a representation of reasoning and purpose characteristic of the culture" (pp. 164-165),

This judgment moves beyond the claim that the EIS is ineffective because it eclectically draws on a variety of traditions. In fact, as we have tried show, the category that Miller calls "administrative bureaucracy" has, in the more recent ElSs that we studied, moved effectively to control the process, eliminating (and often infuriating) competing traditions. The reasoning (control through edification) and purposes (forestalling of legal action) of this culture are inscribed in the EISs we examined. Genres, Miller (1981) suggests, cannot be legislated; they must evolve from tradition paradigms for social action. In an attempt to create an "action-forcing document," the authors of NEPA gave an unheard-of priority to a written document in an attempt to guide social action by creating a genre of written discourse. But the cultural tradition of administrative bureaucracy has reasserted the privileged status of tradition over genre by co-opting the EIS for its own covert purposes and in so doing may well have provided the conditions for the evolution of a new genre. As Walter Beale (1987) has suggested, "Not only do the characteristic motives and stylistic appointments of [genres] change over time; they are also subject to extension, transformation, and appropriation into alien territory" (p. 19).

A larger question remains. Can truly democratic genres of public discourse emerge among conflicting traditions and interests? Which is another way of asking, Can public discourse be effective? Richard Harvey Blown (1987) has argued the negative:

But at least rhetorical theorist -- Walter R. Fisher (1984), building on the work of Hayden White (1980) -- holds out hope for an emergence or reemergence of a "narrative paradigm" to challenge the currently dominant "rational world paradigm" (p. 3). To speculate on the potential effects such it revolution would have on ecological discourse is beyond the scope of this article. It is worth noting, however, that the seeds of narrativity survive within the EIS process -- in the practice of inviting the people of a region to respond to the EISs that affect them. They often respond with their own stories.
 
 

1. The best nontechnical account of dehumanization in procedures like environmental assessment is given by Commoner (1987), who finds the root of such discourse practices in economics: "The cost of the necessary controls [antipollution devicesl is compared with the value of the benefits (to human health, for example) generated by a reduction in the level of pollution. Such an analysis attempts to give a social aim -- the protection of the environment and of public health -- dollar dimensions. Transformed into a pseudo-economic value, the social values can then be compared, it is supposed, with other economic factors, like the cost of controls, and some 'cost effective' balance struck" (p. 63). Friesma and Culhane (1976) similarly argue that EISs "usually consider only one social consequence -- the economic impact or the project (p. 343). Commoner warns that the "apparently 'objective' cost-benefit approach" and the related "risk-benefit computation" used in impact assessment are "quickly engulfed in moral issues" (pp. 63-64).


The classic critique of this form of reduction is given by Marx and Engles (1947), who wrote of the commercial revolution in nineteenth-century England: "It destroyed natural growth in general as far as this is possible while labour exists, and resolved all natural relationship into money relationships" (p. 57). For a full exposition of Marx and Engels's argument that capitalism dehumanizes man and denatures nature" see Parson (1977. pp. 17-l9 and throughout). Parson understands Marxism as a humanizing system, while Callinicos (1985) reads it as realism. The latter is closer to the pole we call "naturalization." Marxism is a humanism only so far as it opposes, dialectically, reification, which Marx (1959) understood as a characteristic of the capitalistic mentalility: "In labour all the natural, spiritual and social variety of individual activity is manifested and is variously rewarded, whilst dead capital always shows the same face and is indifferent to the real individual activity" (p. 23). We thus depart from classic Marxism in identifying the interests of late capitalism with those of secular humanism (Eagalton, 1983, follows a similar path in his literary theory) and in defining their relation to nature as "humanization."

2. Does this grammatical slip -- "which" instead of "who" -- indicate an unconscious recognition of the effects of reification?