Criticism by the Environmental Protection Agency about the Bureau of Land Management wilderness reviews point up what may be a crucial failure: Perhaps the BLM wrongly excluded land from consideration.

In the BLM's final environmental impact statement on Utah wilderness, issued in December 1990 after a $7 million, 10-year study, the agency recommended that less than 2 million acres should get the protection of wilderness designation. Even worse, the Legislature voted earlier this year, openly relying on the same BLM study, to support no more than 1.4 million acres.The smaller figure derives directly from the BLM. It was the agency's "paramount wilderness" alternative, and the legislative committee cited that category.

Yet the BLM recommendation is fundamentally flawed, according to the EPA, because it left out land that should have been considered.

As the tree is poisoned, so is the fruit - in this case, the Legislature's resolution, the congressional bill introduced March 21 by Rep. James Hansen, R-Utah, embodying the resolution, and any other wilderness recommendation whose upper limit is based slavishly on the BLM findings, assuming that the EPA is right.

If so, the BLM flaw dates far back, to 1980, the time when it first tried to sort out which land should be studied. It threw out hundreds of thousands of acres on the claim that they lacked sufficient solitude. By law, solitude is part of the wilderness criteria. But the BLM evaluated solitude in an extremely narrow way, equating it with screening, charged the EPA.

Screening means to block from view, as a dense forest screens a hiker. If you're on a mesa-top in a lovely desert, the only person for 40 miles around, you might think you're in solitude, but not according to the BLM if screening is the only criterion.

On some units, environmentalists dragged the BLM to the Interior Board of Land Appeals and won overturns on the solitude issue. The board said screening wasn't the only relevant tool; the BLM had to consider the "interrelationship of size, screening, configuration and other factors that influence solitude."

It's as if you were considering moving. You want to go to a nice neighborhood; you define nice as having low crime, shady streets, well-kept houses, nearby schools, and easy access to public transportation.

What's easy access? Well, maybe it's within three blocks of a bus stop. But you don't automatically disregard all houses for sale that otherwise fit the criteria if they happen to be four or five blocks from the UTA bench: you're flexible. If other factors tip the balance, you're willing to walk the extra block or so. You weigh the relationship of several criteria.

If the BLM had applied the board's criticism to all areas under review for wilderness, "and not just those inventory units under appeal by conservation groups," the BLM might have significantly changed its results, say detailed comments by the EPA.

The comments were part of a criticism sent March 7 by Robert R. DeSpain, chief of the EPA's Environmental Assessment Branch in Denver, to Gregory F. Thayn, the BLM's Utah wilderness studies manager.

Thayn disputes the EPA's conclusion. "We did screening, we did topography, we did outside sights and sounds and influences," in considering solitude, he said. After the board rulings, "we added back 400,000 acres to what we were going to study at that point."

Thayn said the board refused to hear additional appeals "because they had been pretty well covered."

If the EPA is right, the BLM exclusions were a critical flaw at the very start of the process. According to the EPA, it could have been corrected but wasn't. The BLM was forced to accept the specific overturns but took the ruling only as far as the actual tracts under appeal; it didn't extend it to other potential wilderness units thrown out for the same reason.

"If BLM would further consider those changes made as a result of IBLA appeals since completion of the inventory, this would better provide for analysis of a full range of reasonable alternatives," says the report.

Thayn responded, "That's their opinion, but there's no call by the IBLA to universally apply this."

Any failure to study enough land would unfairly skew the findings against wilderness.

According to guidance from the Interior Department secretary, Thayn said, the wilderness inventory was final around 1984, "when the Interior Board of Land Appeals refused to hear any more appeals on the inventory." Thayn said it's too late to redo the wilderness recommendations, due on the president's desk by the end of October.

"If we're going to go outside the inventory . . . we wouldn't meet our deadline at all. I don't think it's necessary because we have a future process." That process is resource management planning.

Accepting the EPA's criticisms at face value, nobody could say whether the "paramount wilderness" alternative really does contain all the best wilderness areas in the state. Far from a "Utah BLM Statewide Wilderness" study, as its title announces, the environmental statement would be a fragment - a large chunk, but not the whole thing.

This is a vexing criticism by the federal agency in charge of reviewing environmental statements. At the least, Congress should look deeply into the matter before passing a wilderness bill.