Chapter 8 ~ The Content Analysis Process

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Introduction

Public comments on the Draft Yosemite Valley Plan/SEIS were documented and analyzed by the United States Forest Service, Content Analysis Enterprise Team (Content Analysis Enterprise Team) in Missoula, Montana, using a process called content analysis. This is a systematic method of compiling, categorizing, and capturing the full range of public viewpoints and concerns regarding a plan or project. Content analysis is intended to help park management to clarify, adjust, or use technical information to prepare the Final Yosemite Valley Plan/SEIS. Information from public and employee meetings, letters, emails, faxes, and other sources is all included in this analysis.

In the content analysis process used for this project, each letter is given a unique identifying number, which allows analysts to link specific comments to original letters. All respondents’ names and addresses are then entered into a project-specific database program, enabling creation of a complete mailing list of all respondents. The database is also used to track pertinent demographic information such as the geographic location of the responder, the type of response, and the type of special interest group or federal, state, county, local government, if any, responding.

At each stage of the process, all input is considered and reviewed by two analysts. Each response is read, then discrete comments in each are identified by category and then entered verbatim into the comment database. All comments in each category in the database are then reviewed and sorted into concerns and themes used to write public concern statements. In preparing the final summary report of the analysis, public concern statements are reviewed again using database printouts. These reports track all input and allow analysts to identify a wide range of public concerns and analyze the relationships between them. The final summary report includes, for each category of public comment, a narrative description, the public concern statements addressing the proposal, and supporting sample quotes, all arranged by topic.

For this project, a National Park Service team of 14 Yosemite employees and consultants supported the Content Analysis Enterprise Team in the content analysis effort. After receiving training, the Yosemite staff spent several weeks working in Missoula. Of the more than 10,000 letters, email, faxes, and public meeting transcripts read and coded, over 6,000 were read and coded by National Park Service staff (the balance of letters was read and coded by the Content Analysis Enterprise Team). The National Park Service team also contributed to the data entry effort and provided the Content Analysis Enterprise Team with background and site-specific information for their report preparation. Using original letters and the comment database, Content Analysis Enterprise Team staff identified public concerns and prepared the analysis report, Summary of Public Comment: Yosemite Valley Plan Draft Supplemental Environmental Impact Statement (USFS 2000b).

After the Content Analysis Enterprise Team delivered their final report on August 8, 2000, it was discovered that additional letters needed to be included in the public comments and further analysis was undertaken (see Vol. Ib, Chapter 5, Consultation and Coordination). These were also read and analyzed by National Park Service staff and the Content Analysis Enterprise Team and the resulting concerns considered while developing the Final Yosemite Valley Plan/SEIS. After National Park Service and Content Analysis Enterprise Team staff completed this work, the Content Analysis Enterprise Team issued an update, Addendum — Summary of Public Comment: Yosemite Valley Plan Draft Environmental Impact Statement (USFS 2000b), July 8 to July 14, 2000 Letters, that was incorporated as Appendix I into their final report.

It is important to understand that the content analysis process makes no attempt to treat comments as votes. In no way does content analysis attempt to sway decision makers towards the will of any majority. There are many reasons for this, the primary one being a desire to prepare the Final Yosemite Valley Plan/SEIS in a way that best meets the purpose and need of the Yosemite Valley Plan and serves the interests of all the people–not just some. Content analysis ensures that every comment is considered at some point in the decision process.

Finally, the process of content analysis and the resulting summary report are not intended to replace comments in their original form. Rather, they provide a map to the letters and other input available to park planners and managers as they prepare the Final Yosemite Valley Plan/SEIS. All of this information is on file at the Yosemite National Park Research Library in Yosemite Valley.

What follows is an abbreviated description of the process used by the Content Analysis Enterprise Team to analyze public comment on the Draft Yosemite Valley Plan/SEIS. For a more detailed description, refer to their narrative summary report (USFS 2000b). For further information on this process, contact the Content Analysis Enterprise Team at United States Forest Service, Content Analysis Enterprise Team, 200 E. Broadway, Room 300, Missoula, Montana, 59807.

Coding

Coding public comment lies at the heart of the analysis process. Coding is the act of reading a public comment and breaking it down into different areas of concern. A letter may address many different things; the challenge is to capture all of these concerns and separate them into subject areas used in the database. The database can then be used to call up all comments regarding a specific area of concern.

It is important in this process that coders capture the emotion and emphasis of a letter. The "I think" or "I want" statement, alone, does not provide enough information. Coders search the letter for the "why" and "because." The explanations for why people think and want what they do are the true essence of their opinions, and are what allow park planners and managers to understand the point of the comment and evaluate it in the context of other information bearing on the issue in question. Thus, to accurately reflect a person’s sentiments, it may be appropriate to code a large portion of a comment. Analysts code as much as necessary to capture why someone feels a certain way.

Team members use the most specific coding category possible. However, they do not split paragraphs when doing so would result in losing the full meaning or emphasis of the comment. When in doubt, coders lump rather than split so that each concern will stand by itself and make sense.

Overlap or gray areas between codes do occur. In these instances coders talk to co-workers and arrive at a consensus as to where comments will be coded.

Coding Structure

Coding categories, which facilitate sorting and organizing large amounts of information, are derived directly from letters, the Yosemite planning team, and from earlier public comment on Yosemite plans (see Summary of Public Comment: Yosemite Valley Plan-Draft Supplemental Environmental Impact Statement, Appendix G, "Yosemite Valley Plan Coding Structure," USFS 2000b). The coding structure is arranged numerically. For example, all comments addressing the planning process for the Yosemite Valley Plan are assigned code numbers between 10000 and 15900, comments referencing plan alternatives between 20000 and 20500, and those related to cultural resources between 34000 and 37000. A comment specific to a particular resource, historic bridges, for instance, is coded to a specific number within the appropriate topical range. That code number defines the "bin" in the database where all similar comments are "collected."

When necessary, bullet statements or separate sentences are split out from within a paragraph and assigned different category codes. When needed to make sense, the text introducing a series of ideas or bullet statements is included with each when entered into the database. For example: "I feel you must strengthen the policy in the following ways or it will be ineffective: A . . . ; B . . . ; and, C . . .." The lead-in sentence is important in understanding the bullets. A note in the margin alerts data-entry personnel to type the lead sentence before each separate statement.

First and Second Reading

Each letter is read twice. The first reader codes the letter and initials the bottom of the first page. The second reader either concurs with the coding or revises the coding after discussing changes with the first reader. The second reader also uses colored highlighter markers to separate the different comments. This makes it easier for data-entry personnel to visually track comments. The second reader also initials the bottom of the first page. Two sets of initials indicate that a letter is ready to be entered into the database.

First Coder’s Responsibilities

Second Coder’s Responsibilities

Demographic Coding

Demographic codes, of the types listed below, identify where respondents live, their general affiliation to various organizations or government agencies, and the manner in which they respond. A report summarizing this information allows managers to form an overall picture of who is offering public comment. Once this information is identified in a letter, the appropriate demographic codes are written as a "header" at the top center of the first page of each letter.

The demographic information in the database can be used to isolate specific combinations of information about public comment. For example, as part of the review process for the Draft Yosemite Valley Plan/SEIS, the public comment database for the Draft Merced River Plan/EIS was searched for an alternative code indicating a concern related to Yosemite Valley planning. The resulting report allowed park planners to ensure that such comments were considered in developing the Final Yosemite Valley Plan/SEIS. If desired, demographic coding combined with the public comment subject categories allows managers to do more complicated analyses that focus on specific areas of public concern linked to type of respondent, geographic area, and response method. This was not done for Yosemite Valley planning.

Number of Signatures (authors)

The number of signatures is recorded for each response. Email messages count as one signature, even though there is no actual signature. If a letter has no signature, the letter will still be counted as having one signature. To be counted as two or more signatures there must be a distinction between the signatures. If Jane Smith signs her name and her husband’s name, John Smith, only one signature is generally counted.

Response Type

• Letter
• Email
• Petition
• Comment Form from Public Meetings
• Public Meeting Transcript

Petitions

This code is used only if the letter has five or more signatures of unrelated individuals or organizations. The number of signatures is counted and the response type "petition" is used. If complete addresses are included, each signature and associated address is entered into the database with its own unique mail identification number (Mail ID) and letter identification number (Letter ID) linked to the petition. Signatures without addresses are counted towards the number of signatures for the petition but do not receive a unique mail identification number.

Petitions or other letters with multiple Mail ID’s reflect the number of signatures. For example, a petition with 1,200 signatures will have that number in the header. If a multiple Mail ID petition has different organization types, the number of signatures is counted for each similar organization type.

Immediate Attention

An additional header code is reserved for letters that may be of special interest to the planning staff at Yosemite National Park. (See Summary of Public Comment: Yosemite Valley Plan Draft Supplemental Environmental Impact Statement Appendix C, "Immediate Attention" (USFS 2000b) for more information on the method of handling response required, also known as "red flag" letters, as well as the Immediate Attention (or "Red Tag") Report. The categories of "Immediate Attention" types include the following:

• Notice of appeal, litigation, or threat of harm - Any response that describes intent to appeal an action or bring legal suit to bear on the agency. Threats of physical harm to project or agency personnel are marked in this category.
• Freedom of Information Act (FOIA) - Official requests for information and documentation under the FOIA.
• Provides proposals for alternatives - Any letter that delineates an alternative to the proposed action. Does not include critiques of alternatives or partial changes of existing alternatives. Must be substantive letters.
• Especially Substantive letters - These letters provide readers with a well-written analysis of the issues. They are informative and help frame questions.
• Government entities- Letters from elected officials and employees of federal, tribal, state, county, and city governments. Official correspondence only.
• Extension of Comment Period - Requests for an extension of the comment period.
• Comments on the compliance and/or compatability between the Merced River Plan & the Yosemite Valley Plan
• Complaints/concerns about the cost, size or receipt of the Final Yosemite Valley Plan SEIS
• Nongovernment organizations- Letters written to express the view of Nongovernmental organizations, by the organizations not by their members.

User Type

A series of codes used to identify respondents that explicitly characterize themself in some particular way as a commenter on Yosemite National Park (for example, "I’ve been visiting Yosemite National Park for over 40 years, and I think…" is a long-time visitor; "As a camper [or …climber, …resident of Mariposa County, …member of the Citizens to Save the Yosemite Onion, etc.], I think you should…" is a camper, climber, etc.).

Form Letters

The term "form letter" is used to refer to comments received under separate letterhead that are identical in content. Generally, the text of these letters is 100 percent identical; however, in some cases and at the discretion of the coder, letter text may paraphrase the content of a form letter with no changes in topics discussed, etc. For a complete description of the form letters received in this project see Summary of Public Comment: Yosemite Valley Plan Draft Supplemental Environmental Impact Statement, Appendix D, "Organized Response" (USFS 2000b).

Letters with largely, but not entirely, identical text are known as "form letters with additional comment." As an example, this term describes a letter of six paragraphs where one paragraph differs from a five-paragraph form letter identified as "form letter 1." The five "form" paragraphs are coded like the form and only the "additional comment" is coded separately.

Processing Form Letters

Each form letter is given a unique number and a name descriptive of the letter’s content. An Information Systems Specialist (ISS) Team Leader assigns this number and name. Each form letter receives a number preceded by the letter "f." Thus, f2 in the header means Form Letter #2 - "River Lovers United." The ISS Team Leader maintains a list of Form Letter numbers and titles for each project. Only form letters receive an f (for "form") number in the header.

Information Requests

Requests for additional information from the National Park Service that are not Freedom of Information Act requests are recorded in this category and marked for quick identification by a blue flag.

For the Yosemite Valley Plan there were four types of information requests:

Alternative Fields

Following the subject code (from the coding structure) are two specific "alternative" fields. The first references plans or projects referred to in a comment; the second notes specific locales when identified as a focus of concern.

The following is an example of a complete margin code for one discrete comment on the Draft Yosemite Valley Plan/SEIS that speaks to the purpose or need for an action from the Concession Services Plan in reference to concessions facilities at Curry Village:

PLANN-11000-B-A9

In this example, PLANN is the subject code for "Planning Process and Policy," 11000 is the category code for "Purpose and Need for Action," B indicates that the comment refers the Concession Services Plan, and A9 refers to Curry Village. For a complete description of different Alternative Codes used for the Draft Yosemite Valley Plan/SEIS, see Summary of Public Comment: Yosemite Valley Plan — Draft Supplemental Environmental Impact Statement, Appendix F, "Content Analysis Process" (USFS 2000b). To review the coding structure, see Appendix G of the same Report.

List of Preparers

Summary of Public Comment - Yosemite Valley Plan Draft Environmental Impact Statement (USFS 2000b)

Content Analysis Enterprise Team — Missoula Group

Project Coordination

Michael Schlafmann, Project Manager
Ray Vinkey, Team Leader

Writers/Coders

Buell Whitehead
Leaf Magnuson
Holly Schneider
Julie Lue
Barbara Ensor
Lisa Naas
Dave Strohmaier
Tyne Doty
Charles Ellis
Myron Holland
Roger Poirier
Mic X Metz
Jack Rowan
Steve Slack

Program Coordination

Jody Sutton, Coordinator
Ginger Hamilton, Personnel
Linda Thompson, Office Management Assistant
James MacMillen, Contracting

Information Systems Coordination

Shari Kappel, Coordinator
Kelly Gillette, Computer Programming and Support Specialist
Kelly Speer, Information Systems Assistant

Information Systems

Elise Bailey
Angela Concepcion-Willmott
Rich Darne
Kay Flink
Barbara Gibson
Sue Gibson
Katie Hatrock
Ted Hughes
Meghan Hunter
Ann Jensen
Lee LaRoche
Teresa Molitor
Verena Rattler
Shanna Robison

National Park Service — Assisting Staff and Consultants

National Park Service Project Coordinator

Jerry Mitchell, YNP/Superintendent’s Office

Letter Coding

David Ashe, YNP/Protection
Leslie Boughton, URS/BRW (YNP Consultant)
Leslie Carter, YNP/Protection
Sean Flynn, YNP/Concessions
Johanna Gehres, YNP/Maintenance
Susan Gonshor, YNP/Interpretation
Mark Harvey, YNP/Protection
Jessica Overmohl, URS/BRW
Deb Schweizer, YNP/Protection
Michael Thornton, YNP/Administration

Information Systems

Teri Angst, URS/BRW
Gina Bissmeyer, YNP/Project Management
Rose Laughter, YNP/Resources Management