(Beyond Pesticides, October 19, 2020) The COVID-19 epidemic has made clear to the general public what we at Beyond Pesticides have been stressing since our inception—some populations have disproportionate risk of severe outcomes, exposures to toxic chemicals can affect susceptibility to disease, comorbidity increases risk, and bad government can kill you. As Trump declares that “unborn children have never had a stronger defender in the White House,” we are reminded of Erik Jansson, who ran the National Network to Prevent Birth Defects and helped to convene the founding meeting of Beyond Pesticides, and took on then-Administrator of EPA Anne Gorsuch, calling her a “baby killer” because of policies that allowed exposures to toxic chemicals—exposures that endangered children and fetuses. Those were harsh words in the 1980s even when the Reagan administration’s environmental and toxics policies were tied to elevated harm to people, and children in particular. In today’s world, scientists and medical doctors are regularly linking elevated death rates from coronavirus to the federal government’s inadequate coronavirus policy and its attack on science. And, they are pointing to those in charge. Policies and decisions under the Trump administration that threaten the health of children and the unborn include: COVID-19 misinformation. […]

(Beyond Pesticides, October 6, 2020) Despite the rapid rise of antibiotic resistance in the United States and throughout the world, new documents find the Trump Administration worked on behalf of a chemical industry trade group to weaken international guidelines aimed at slowing the crisis. Emails obtained by the Center for Biological Diversity through the Freedom of Information Act show that officials at the U.S. Department of Agriculture (USDA) worked to downplay the role of industrial agriculture and pesticide use in drug-resistant infections. “From everything we’ve seen, it’s clear that this administration believes rolling back regulations and protecting industry profits is more important than protecting public health,” said Nathan Donley, PhD, senior scientist with the Center for Biological Diversity, to the New York Times (NYT). “But what these emails show is that the Department of Agriculture isn’t just soliciting their input. They’re seeking their approval on what the government’s position should be.” Ray McAllister, PhD, of the pesticide industry trade group Croplife America, sent an email in March of 2018 to U.S. officials, wanting to “make certain” that the United Nation’s (UN) Codex Alimentarius, a set of international guidelines and standards established to protect consumer health, made no mention of how […]

(Beyond Pesticides, October 1, 2020) A federal judge on September 24, 2020 dismissed an  environmental lawsuit seeking to reinstate a U.S. Fish and Wildlife Service (FWS) rule, killed by the Trump Administration, which banned the use of neonicotinoid insecticides, genetically engineered (GE) crops, and adopted a precautionary approach to pest management. The decision comes on the heels of a Center for Biological Diversity (CBD) analysis that reports a 34% increase in the pesticide use on U.S. national wildlife refuge acres over a two year period from 2016-2018. This analysis is an update to CBD’s 2018 report, No Refuge, which is the first of its kind to offer comprehensive details of agricultural pesticide spraying in national wildlife refuges. Wildlife refuges act as a sanctuary, providing habitat and protection essential for the survival and recovery of species nationwide. However, pesticide spraying in or around wildlife refuges threatens the survivability and recovery of species that reside there as many of these pesticides are highly toxic to human and animal health. Analyses like these are significant, especially since the globe is currently going through the Holocene Extinction, Earth’s 6th mass extinction, with one million species of plants and animals at risk of extinction. In 2012, […]

(Beyond Pesticides, September 28, 2020) These comments are due by October 5 at 11:59 pm EDT. Separate comments to the National Organic Standards Board are due October 1 at 11:59 EDT. After hearing for years about inadequate enforcement of the rules governing organic production, USDA has issued a massive draft rule on strengthening organic enforcement (SOE). The draft rule presented to the public constitutes an impressive and far-reaching rewrite of the regulations implementing the Organic Foods Production Act (OFPA). However, unlike the process by which the initial regulations were established in 2002, the National Organic Standards Board (NOSB) was only consulted on a portion of the elements in this draft rule. Public engagement was, thus, also limited. USDA’s National Organic Program (NOP) is accepting comments on its draft rule via Regulations.gov. Please use this opportunity to remind USDA of the proper public process while commenting on the proposed rule itself. Please join us in asking for an extension of the pubic comment to facilitate fuller public scrutiny. Tell USDA that strengthening organic enforcement starts with the National Organic Standards Board. USDA must involve the NOSB and public as required by law. Section 2119 of OFPA states the Secretary shall establish […]

(Beyond Pesticides, September 21, 2020) The National Organic Standards Board (NOSB) meets online October 28-30 to debate issues—after hearing public comment October 20 and 22—concerning how organic food is produced. Written comments are due October 1. They must be submitted through Regulations.gov. Everywhere we look, we see signs of ecological collapse—wildfires, the insect apocalypse, crashing populations of marine organisms, organisms large and small entangled in plastic, more and more species at risk, rising global temperatures, unusual weather patterns, horrific storms, and pandemics. As we focus on one of the most blatant examples of environmental abuse—the dispersal of toxic chemicals across the landscape—it is important to seek a solution. Organic can be a big part of the solution, but only if it doesn’t stray from its core values and practices. Tell the National Organic Standards Board to support core organic values. From its very beginnings, the organic sector has been driven by an alliance of farmers and consumers who defined the organic standards as a holistic approach to protecting health and the environment, with a deep conviction that food production could operate in sync with nature and be mindful of its interrelationship with the natural world—protecting and enhancing the quality of air, […]

(Beyond Pesticides, September 1, 2020) In its new report, industry watchdog OrganicEye, a project of Beyond Pesticides, examines the rapidly expanding CBD market, uncovering numerous examples of gross violations flying under the radar. In its report, Spotting the Hackers of Hemp: The Value of Authentic Certified Organic CBD Products, OrganicEye offers examples of companies claiming organic status without going through the rigorous third-party inspection and auditing process required by federal law. As with food, organic CBD, produced from hemp/cannabis, eliminates the risks and hazards of environmentally dangerous farming practices, including the use of synthetic fertilizers, pesticides, sewage sludge, and genetically modified organisms (GMOs). Organics also shuns toxic food ingredients and food processing substances like volatile solvents. Since Congress charged USDA with protecting organic stakeholders from fraudulent practices, illegal organic marketing claims have been the most common violations reported to the agency. “In addition to representing conventional hemp products as organic, marketers have engaged in illegal subterfuge, including creating their own ‘organic’ logos because they can’t use the official USDA seal and using the word ‘organic’ in their brand names when the products do not qualify for organic labeling,” said Mark A. Kastel, a 30-year industry veteran and director of OrganicEye. The meteoric growth […]

(Beyond Pesticides, August 28, 2020) The Environmental Protection Agency (EPA) has granted “emergency” permission to the State of Texas to allow the use of SurfaceWise®2, an unregistered pesticide, as an anti-viral surface coating. The manufacturer, Allied Bioscience, says the compound can kill coronaviruses (including SARS-CoV-2) starting at two hours post application and for up to seven days, but it is not included on EPA’s List N, of disinfectants effective against SARS-CoV-2. EPA has permitted this use via the authority of Section 18 of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), which allows for “emergency” use of non-registered pesticides, typically to deal with extreme threats to agricultural activities. It is rarely used for public health emergencies. Beyond Pesticides recognizes the need for protection from transmission of the novel coronavirus, and maintains that it ought to and can be done without exposing people to toxic synthetic pesticides that have not undergone evaluation for safety. See Beyond Pesticides’ guidance on effective and safe precautions against the novel coronavirus. The Texas Department of Agriculture secured the EPA exemption, making the state the first to do so; Allied BioScience is pursuing this emergency waiver across all 50 states. The exemption grants American Airlines and two health […]

(Beyond Pesticides, August 24, 2020) USDA’s Farm Service Agency (FSA) announced on August 10 that it will be reducing reimbursement rates for the organic certification cost share program, which provides reimbursements to organic farms and handling operations. The August 10 Federal Register notice stated that FSA is “revising the reimbursement amount to 50 percent of the certified organic operation’s eligible expenses, up to a maximum of $500 per scope.” The 2018 Farm Bill clearly set reimbursement rates at 75% of the certified organic operation’s eligible expenses, up to a maximum of $750 per regulated activity. This change hurts the transition to organic production at a time when it is crucial that the organic sector grows—eliminating petroleum-based pesticides and synthetic fertilizers that are contributing to devastating pollution, the climate crisis, and biodiversity decline. This action by USDA is unwarranted and completely unacceptable. The 2018 Farm Bill provided new funding for the program and also directed USDA to use the program’s carryover balances from previous years to fund the program for fiscal years 2019 through 2023. Given these sources of funding, there should be plenty of funds available for the program’s operation in fiscal year 2020. Either USDA’s accounting for this program […]

(Beyond Pesticides, July 13, 2020) Soil is central to organic production. Therefore, hydroponic operations should not be considered eligible for organic certification, and the National Organic Program (NOP) must take a clear position in opposition to hydroponics and other non-soil-based methods in organic production, including containers. Organic farmers and consumers strongly agree that organic production must be soil-based.  Tell NOP hydroponics is not organic! Educate your congressional representatives and senators. NOP authorizes the certification of hydroponic operations as organic. This undermines the authenticity of organic farming and creates unequal competition, market instability, and consumer distrust in organic certification. Organic farming and soil are inextricably linked. The microorganisms in healthy soils interact in a symbiotic manner with plant roots, strengthening the plant, enabling it to resist diseases and facilitating water and mineral uptake. The essence of organic production is maintaining and enhancing the organic matter content of soil by relying on environmentally beneficial methods such as green manure, crop rotation, and biological pest management. On March 3, 2020, the Center for Food Safety (CFS) filed a lawsuit challenging the USDA’s decision to allow hydroponics operations to be certified organic. Organic farmers and consumers believe that the organic label means two things: […]

(Beyond Pesticides, July 9, 2020) Conventional U.S. milk contains growth hormones, antibiotics, and low to elevated levels of pesticides not found in organic milk, according to a study published in the journal of Public Health Nutrition by Emory University researchers. Milk can bioaccumulate certain organic pollutants, making it a valuable medium to assess what chemical we might be ingesting daily. With milk being one of the most consumed beverages in the U.S., in addition to its use in other popular drinks (i.e., coffee and tea), this study discloses widespread contamination and highlights the need for improved regulation. Researchers in the study note, “To our knowledge, the present study is the first study to compare levels of pesticide in the U.S. milk supply by production method (conventional vs. organic). It is also the first in a decade to measure antibiotic and hormone levels and compare them by milk production type.”  The market for conventional milk, produced in chemical-intensive agriculture, is declining, but the demand for organic milk is increasing due to concerns over chemical contamination in consumer products from pesticides and other toxic chemicals. Although the U.S. Environmental Protection Agency (EPA) sets limits for pesticide residues in food products, the agency […]

(Beyond Pesticides, June 29, 2020) Bayer’s Monsanto is requesting non-regulated status for corn that will increase the use of drift-prone and toxic herbicides. This means that the planting of a new genetically engineered (GE) variety of corn, which requires substantial weed killer use, will not be restricted in any way. The syndrome of ‘more-corn, more-pesticides, more-poisoning, more-contamination’ must stop—as we effect an urgent systemic transformation to productive and profitable organic production practices. Because USDA is proposing to allow a new herbicide-dependent crop under the Plant Protection Act, the agency must, but does not, consider the adverse impacts associated with the production practices on other plants and the effects on the soil in which they are grown. Business as usual is not an option for a livable future. Sign the petition. Tell USDA we don’t need more use of 2,4-D, Dicamba, and other toxic herbicides associated with the planting of new GE corn. Bayer-Monsanto has developed multi-herbicide tolerant MON 87429 maize, which is tolerant to the herbicides 2,4-D, dicamba, glyphosate, glufosinate, and aryloxyphenoxypropionate (AOPP) acetyl coenzyme A carboxylase (ACCase) inhibitors (so-called “FOP” herbicides, such as quizalofop). Now the company wants this corn to be deregulated—allowing it to be planted and the herbicides […]

(Beyond Pesticides, June 15, 2020)  On May 7, President Trump issued an executive order (EO) purporting to “promote American seafood competitiveness and economic growth,” while, in fact, permitting offshore aquaculture in federal waters with reduced environmental safeguards. Instead, we need stronger federal regulation in order to protect the environment and public health. This EO adds to the Trump Administration’s shameful record of dismantling environmental protections, failing to enforce those that do exist, undermining science, and weighing agrochemical and other industry interests over those of the public and the environment. The EO will further erode regulations that have governed the operation of so-called “fish farms” and open enormous marine areas to exploitation by this industry. Tell Congress to save our oceans. U.S. aquaculture is a $1.5 billion industry, with almost 3,000 operations. Regulation of aquaculture is shared by a number of federal, state, and local agencies. Much of the regulation is at the state and local level because each state and locality may regulate permitting based on zoning, water use, waste discharge, wildlife management, processing, and other aspects of aquaculture operations.  Trump’s EO reduces federal regulation by designating the National Oceanic and Atmospheric Administration (NOAA) as the lead agency in the […]

(Beyond Pesticides, June 12, 2020) New research finds that western monarch milkweed habitat contains a “ubiquity of pesticides” that are likely contributing to the decline of the iconic species. The research, published in Frontiers in Ecology and Evolution, provides a grim snapshot of a world awash in pesticides, and raises new questions about the U.S. regulatory process that continues to allow these toxic chemicals on to the market without adequate review and oversight. “We expected to find some pesticides in these plants, but we were rather surprised by the depth and extent of the contamination,” said Matt Forister, PhD, a butterfly expert, biology professor at the University of Nevada, Reno and co-author of the paper in a press release. “From roadsides, from yards, from wildlife refuges, even from plants bought at stores—doesn’t matter from where—it’s all loaded with chemicals. We have previously suggested that pesticides are involved in the decline of low elevation butterflies in California, but the ubiquity and diversity of pesticides we found in these milkweeds was a surprise,” Dr. Forister said. The researchers collected over 200 milkweed samples from nearly 20 different sites across the Central Valley of California, as well as from retailers that sell milkweed […]

(Beyond Pesticides, June 9, 2020) Use of the weed killer dicamba on genetically engineered (GE) cotton and soybeans is now prohibited after a federal court ruling against the U.S. Environmental Protection Agency (EPA) last week. A coalition of conservation groups filed suit in 2018 after EPA renewed a conditional registration for dicamba’s ‘over the top’ (OTT) use on GE cotton and soy developed to tolerate repeated sprayings of the herbicide. “For the thousands of farmers whose fields were damaged or destroyed by dicamba drift despite our warnings, the National Family Farm Coalition is pleased with today’s ruling,” said National Family Farm Coalition president Jim Goodman in a press release. First registered in the late 1960s, dicamba has been linked to cancer, reproductive effects, neurotoxicity, birth defects, and kidney and liver damage. It is also toxic to birds, fish and other aquatic organisms, and known to leach into waterways after an application. It is a notoriously drift-prone herbicide. Studies and court filings show dicamba able to drift well over a mile off-site after an application. Bayer’s Monsanto thought they could solve this problem. The “Roundup Ready” GE agricultural model the company developed, with crops engineered to tolerate recurrent applications of their […]

(Beyond Pesticides, June 2, 2020) During the April meeting of the National Organic Standards Board (NOSB), there was near-unanimous sentiment expressed by NOSB members and stakeholders that the failure of the National Organic Program at USDA to act on NOSB recommendations regarding so-called “inert” ingredients hurts organic producers and consumers and the environment. The NOSB has only one alternative left to force USDA action—denying relisting at the Fall meeting. Tell the National Organic Program and USDA Secretary Sonny Perdue to initiate action to begin NOSB review of “inerts” now. Dr. Asa Bradman, who summarized the issue for the NOSB at the Spring 2020 meeting, is an expert in environmental health, and as part of his day job, leads studies focusing on pesticides, flame retardants, metals, emerging pollutants, VOCs, indoor air quality and other contaminants. As he said at the meeting, “These are often active ingredients.” In fact, the ingredients not listed on a label of a pesticide product—which are not fully reviewed for their adverse effects—may be the most toxic chemicals in the formulation. Recent research, Toxicity of formulants and heavy metals in glyphosate-based herbicides and other pesticides (Toxicology Reports 5, 2018), by Defarge, de Vendômois, and Séralini demonstrates the need to […]

(Beyond Pesticides, June 1, 2020) The President issued another executive order, on May 7, that continues his administration’s dissembling on matters that affect the well-being of everyday Americans. This EO (executive order) purports to “promote American seafood competitiveness and economic growth.” The reality, as the Center for American Progress reports, is that the “bulk of the Trump administration’s new executive order sets up a structure for permitting of offshore aquaculture in federal waters with short timelines and few environmental safeguards.” This EO will further erode regulations that have governed the operation of so-called “fish farms,” and open enormous marine areas to exploitation by this industry. Beyond Pesticides has argued for more-protective regulation of the aquaculture industry, considering the variety of pesticides and chemical inputs it uses, and the impacts on local ecosystems. The U.S. Department of Agriculture (USDA) defines aquaculture as any “farming of aquatic organisms, including baitfish, crustaceans, food fish, mollusks, ornamental fish, sport or game fish, and other aquaculture products. Farming involves some form of intervention in the rearing process, such as seeding, stocking, feeding, protection from predators, etc. Fish, crustaceans, mollusks, and other aquatic products caught or harvested by the public from non-controlled waters or beds are considered […]

(Beyond Pesticides, May 22, 2020) For years, USDA has been looking the other way as giant corporate agribusinesses, primarily producing conventional eggs and poultry, have squeezed family-scale farmers out of the market and misled and defrauded consumers. Due to a lawsuit challenging the Trump administration on the scuttling of new rules that would make it harder for factory farms to qualify for organic status, USDA is seeking input on what was previously an error-filled and biased economic assessment of the rulemaking. Please sign the letter by noon on Tuesday, May 26, to include your voice in our response to the official proceedings. If you would prefer to write your own custom comment you can submit it on Regulations.gov. Letter to National Organic Program (Jenny Tucker, Ph.D. To the National Organic Program: Please include my comment below in evaluating the economic analysis report pursuant to the Organic Livestock and Poultry Practices rulemaking. Docket number: AMS-NOP-20-0037 Both the current and previous OLPP analyses include the following misstatements and omissions: It is a misconception to refer to, and judge, the economic impacts of the OLPP as if the requirement for outdoor access was a new and onerous regulation. In fact, from the beginning of the USDA organic […]

(Beyond Pesticides, May 6, 2020) The Trump Administration announced late last month that it is waiving a requirement that multinational chemical company Syngenta-Chemchina continue to monitor Midwest waterways for the presence of the weedkiller atrazine throughout 2020. While rationalized by the Administration as “due to the unanticipated impact of Covid-19,” the move will instead put residents health at increased risk. Atrazine is one of 78 pesticides that has been linked to the development of respiratory ailments like wheeze. “The public will now have no idea whether dangerous levels of atrazine are reaching rivers and streams throughout the Midwest. That’s absurd and reckless,” said Nathan Donley, PhD a senior scientist with the Center for Biological Diversity. “Syngenta should suspend the sale and use of this extremely toxic pesticide until it can safely ensure it’s not polluting Corn Belt waterways.” Syngenta, which merged with state-owned China Nation Chemical Corporation (Chemchina) in 2016, has been bound by EPA to monitor Midwestern waterways since a 2004 review by the agency. This is because atrazine is a potent groundwater contaminant. Just two years ago, an analysis by the Environmental Working Group found atrazine to be exceeding legal limits in drinking water for many Midwestern states. […]

(Beyond Pesticides, April 24, 2020) The Centers for Disease Control and Prevent (CDC) has released a study showing a sharp increase—62% in some cases—in calls to poison hotlines about exposures to toxic household cleaners and disinfectants. This poisoning comes with the advent of the novel Coronavirus pandemic, as public health and government officials, and many media outlets have sensibly recommended that people regularly disinfect “high touch” surfaces and objects in their homes and other surroundings, but have not issued warnings on toxic effects nor the availability of lower toxicity or least-toxic products. Compliance with cleaning (sanitizers) and disinfection recommendations is an important public and personal health undertaking, but in this Covid-19 rigor lies a poison problem: the toxicity, as Beyond Pesticides has explained, of some cleaning and disinfecting products that are permitted by the Environmental Protection Agency (EPA) for sale and use. There are safer ways to disinfect those light switches, TV remotes, doorknobs, faucets, etc. First, a basic distinction between cleaning (also called sanitizing)and disinfecting: EPA offers definitions of the differences. “Cleaning is done with water, a cleaning product, and scrubbing. Cleaning does not kill bacteria, viruses, or fungi, which are generally referred to as ‘germs.’ Cleaning products are used […]

(Beyond Pesticides, April 20, 2020) As USDA takes public comments on its updated dietary guidelines, it important that sustainable, regenerative organic food production practices are an integral part. Since 1990, Congress has required an every-five-years review of its Dietary Guidelines — recommendations intended to promote public health and prevent chronic diseases. The next review and a draft updated version, the 2020–2025 Dietary Guidelines for Americans, is currently underway. USDA says that the dietary guidelines provide “information that helps Americans make healthy choices for themselves and their families.” In order to make healthy food choices, the guidelines must go beyond the traditional parameters to include how the food is produced. How food is produced affects the health of Americans not only as a result of the nutritional quality of the food, but also due to environmental contamination. Sign the petition to USDA and send a letter to Congress. Tell them that organic food must be emphasized in new dietary guidelines. Although research on the nutritional density of organic produce is equivocal, showing some higher levels of antioxidants, results are decidedly clear for animal products. Pastured organic animal products—including beef, lamb, pork, dairy, poultry, and eggs—have been shown to be superior to that of products of […]

(Beyond Pesticides, April 13, 2020) Since 1990, Congress has required an every-five-years review of its Dietary Guidelines — recommendations that are supposed, minimally, to promote public health and prevent chronic diseases. The next review and a draft updated iteration, the 2020–2025 Dietary Guidelines for Americans, are currently underway. The Union of Concerned Scientists (and several colleagues) have examined recent studies on dietary patterns and sustainability; their analysis reveals that the current federal guidelines on diet are unlikely to support sustainability of the food system in the long-term. Beyond Pesticides concurs, and maintains that a transition to sustainable, organic, regenerative agriculture is the path to both improved human health and long-term sustainability of the natural world essential to life. The Union of Concerned Scientists’ (UCS’s) report — In Support of Sustainable Eating: Why U.S. Dietary Guidelines Should Prioritize Healthy People and a Healthy Planet — identifies this next version of the federal guidelines as a critical opportunity to shift the direction of the U.S. food and agricultural system toward far greater sustainability. UCS asserts that such a shift is beyond due: the food system in the U.S. has huge environmental impacts on pollution, use of chemical pesticides, biodiversity, and emissions that significantly […]

(Beyond Pesticides, April 8, 2020) We are deeply concerned about the impact of COVID-19 on organic farmers, farmworkers, businesses, certifiers and inspectors, and consumers. We are mindful of the need to protect the health and safety of all who are involved in organic agriculture, certification, and compliance. We also seek to advocate for responsible actions that will protect the integrity of the USDA organic seal during this difficult time. Send a message to USDA Secretary Sonny Perdue asking for support to organic farmers, farmworkers, businesses, certifiers and inspectors, and consumers. The recently enacted CARES Act includes a $9.5 billion emergency fund: “to prevent, prepare for, and respond to coronavirus by providing support for agricultural producers impacted by coronavirus, including producers of specialty crops, producers that supply local food systems, including farmers markets, restaurants, and schools, and livestock producers, including dairy producers.” It is critical that organic farmers and others in the organic community are included in the emergency response actions taken by USDA. Beyond Pesticides, as a member of the National Organic Coalition (NOC), is asking USDA Secretary Perdue to take action to support USDA organic through the coronavirus pandemic.  Please note, our form letter to Secretary Perdue is close to the […]

(Beyond Pesticides, April 6, 2020) The Trump administration’s U.S. Fish and Wildlife Service (USFWS) is moving forward with a proposal to grow genetically engineered crops (GECs) on National Wildlife Refuges in the Southeast United States, including 131 refuges in 10 states, Puerto Rico, and the U.S. Virgin Islands. Ask Congress to help stop the dangerous proposal to allow genetically engineered crops on National Wildlife Refuges in the southeast United States. The proposal is the subject of a draft environmental assessment and opens the door to escalating uses of GE crops and harmful pesticides in wildlife refuges. In 2014, public pressure and lawsuits by environmental groups led to the Obama administration’s decision to phase out GE crops and ban neonicotinoid insecticide use on national wildlife refuges. On August 2, 2018, the Trump administration’s USFWS issued a memorandum that reversed the prohibition. The reversal allows the refuge system to make decisions on the use of GECs and neonics on a case-by-case basis in compliance with the National Environmental Policy Act (NEPA), which is also under attack by the Trump administration. The Center for Biological Diversity, Center for Food Safety, and others quickly challenged the 2018 reversal memorandum with a lawsuit. National Wildlife Refuges are federal public lands specifically designated to […]