Presidential Documents

Federal Register / Vol. 64, No. 25 / Monday, February 8, 1999 / Presidential Documents 6183

Executive Order 13112 of February 3, 1999

Invasive Species

By the authority vested in me as President by the Constitution and the

laws of the United States of America, including the National Environmental

Policy Act of 1969, as amended (42 U.S.C. 4321 et seq.), Nonindigenous

Aquatic Nuisance Prevention and Control Act of 1990, as amended (16

U.S.C. 4701 et seq.), Lacey Act, as amended (18 U.S.C. 42), Federal Plant

Pest Act (7 U.S.C. 150aa et seq.), Federal Noxious Weed Act of 1974, as

amended (7 U.S.C. 2801 et seq.), Endangered Species Act of 1973, as amended

(16 U.S.C. 1531 et seq.), and other pertinent statutes, to prevent the introduction of invasive species and provide for their control and to minimize

the economic, ecological, and human health impacts that invasive species

cause, it is ordered as follows:

Section 1. Definitions.

(a) ‘‘Alien species’’ means, with respect to a particular ecosystem, any

species, including its seeds, eggs, spores, or other biological material capable

of propagating that species, that is not native to that ecosystem.

(b) ‘‘Control’’ means, as appropriate, eradicating, suppressing, reducing,

or managing invasive species populations, preventing spread of invasive

species from areas where they are present, and taking steps such as restoration

of native species and habitats to reduce the effects of invasive species

and to prevent further invasions.

(c) ‘‘Ecosystem’’ means the complex of a community of organisms and

its environment.

(d) ‘‘Federal agency’’ means an executive department or agency, but does

not include independent establishments as defined by 5 U.S.C. 104.

(e) ‘‘Introduction’’ means the intentional or unintentional escape, release,

dissemination, or placement of a species into an ecosystem as a result

of human activity.

(f) ‘‘Invasive species’’ means an alien species whose introduction does

or is likely to cause economic or environmental harm or harm to human

health.

(g) ‘‘Native species’’ means, with respect to a particular ecosystem, a

species that, other than as a result of an introduction, historically occurred

or currently occurs in that ecosystem.

(h) ‘‘Species’’ means a group of organisms all of which have a high

degree of physical and genetic similarity, generally interbreed only among

themselves, and show persistent differences from members of allied groups

of organisms.

(i) ‘‘Stakeholders’’ means, but is not limited to, State, tribal, and local

government agencies, academic institutions, the scientific community, nongovernmental entities including environmental, agricultural, and conservation

organizations, trade groups, commercial interests, and private landowners.

(j) ‘‘United States’’ means the 50 States, the District of Columbia, Puerto

Rico, Guam, and all possessions, territories, and the territorial sea of the

United States.
6184 Federal Register / Vol. 64, No. 25 / Monday, February 8, 1999 / Presidential Documents

Sec. 2. Federal Agency Duties. (a) Each Federal agency whose actions may

affect the status of invasive species shall, to the extent practicable and

permitted by law,

(1) identify such actions;

(2) subject to the availability of appropriations, and within Administration

budgetary limits, use relevant programs and authorities to: (i) prevent the

introduction of invasive species; (ii) detect and respond rapidly to and

control populations of such species in a cost-effective and environmentally

sound manner; (iii) monitor invasive species populations accurately and

reliably; (iv) provide for restoration of native species and habitat conditions

in ecosystems that have been invaded; (v) conduct research on invasive

species and develop technologies to prevent introduction and provide for

environmentally sound control of invasive species; and (vi) promote public

education on invasive species and the means to address them; and

(3) not authorize, fund, or carry out actions that it believes are likely

to cause or promote the introduction or spread of invasive species in the

United States or elsewhere unless, pursuant to guidelines that it has prescribed, the agency has determined and made public its determination that

the benefits of such actions clearly outweigh the potential harm caused

by invasive species; and that all feasible and prudent measures to minimize

risk of harm will be taken in conjunction with the actions.

(b) Federal agencies shall pursue the duties set forth in this section in

consultation with the Invasive Species Council, consistent with the Invasive

Species Management Plan and in cooperation with stakeholders, as appropriate, and, as approved by the Department of State, when Federal agencies

are working with international organizations and foreign nations.

Sec. 3. Invasive Species Council. (a) An Invasive Species Council (Council)

is hereby established whose members shall include the Secretary of State,

the Secretary of the Treasury, the Secretary of Defense, the Secretary of

the Interior, the Secretary of Agriculture, the Secretary of Commerce, the

Secretary of Transportation, and the Administrator of the Environmental

Protection Agency. The Council shall be Co-Chaired by the Secretary of

the Interior, the Secretary of Agriculture, and the Secretary of Commerce.

The Council may invite additional Federal agency representatives to be

members, including representatives from subcabinet bureaus or offices with

significant responsibilities concerning invasive species, and may prescribe

special procedures for their participation. The Secretary of the Interior shall,

with concurrence of the Co-Chairs, appoint an Executive Director of the

Council and shall provide the staff and administrative support for the Council.

(b) The Secretary of the Interior shall establish an advisory committee

under the Federal Advisory Committee Act, 5 U.S.C. App., to provide information and advice for consideration by the Council, and shall, after consultation with other members of the Council, appoint members of the advisory

committee representing stakeholders. Among other things, the advisory committee shall recommend plans and actions at local, tribal, State, regional,

and ecosystem-based levels to achieve the goals and objectives of the Management Plan in section 5 of this order. The advisory committee shall act

in cooperation with stakeholders and existing organizations addressing

invasive species. The Department of the Interior shall provide the administrative and financial support for the advisory committee.

Sec. 4. Duties of the Invasive Species Council. The Invasive Species Council

shall provide national leadership regarding invasive species, and shall:

(a) oversee the implementation of this order and see that the Federal

agency activities concerning invasive species are coordinated, complementary, cost-efficient, and effective, relying to the extent feasible and appropriate

on existing organizations addressing invasive species, such as the Aquatic

Nuisance Species Task Force, the Federal Interagency Committee for the

Management of Noxious and Exotic Weeds, and the Committee on Environment and Natural Resources;
Federal Register / Vol. 64, No. 25 / Monday, February 8, 1999 / Presidential Documents 6185

(b) encourage planning and action at local, tribal, State, regional, and

ecosystem-based levels to achieve the goals and objectives of the Management

Plan in section 5 of this order, in cooperation with stakeholders and existing

organizations addressing invasive species;

(c) develop recommendations for international cooperation in addressing

invasive species;

(d) develop, in consultation with the Council on Environmental Quality,

guidance to Federal agencies pursuant to the National Environmental Policy

Act on prevention and control of invasive species, including the procurement,

use, and maintenance of native species as they affect invasive species;

(e) facilitate development of a coordinated network among Federal agencies

to document, evaluate, and monitor impacts from invasive species on the

economy, the environment, and human health;

(f) facilitate establishment of a coordinated, up-to-date information-sharing

system that utilizes, to the greatest extent practicable, the Internet; this

system shall facilitate access to and exchange of information concerning

invasive species, including, but not limited to, information on distribution

and abundance of invasive species; life histories of such species and invasive

characteristics; economic, environmental, and human health impacts; management techniques, and laws and programs for management, research, and

public education; and

(g) prepare and issue a national Invasive Species Management Plan as

set forth in section 5 of this order.

Sec. 5. Invasive Species Management Plan. (a) Within 18 months after

issuance of this order, the Council shall prepare and issue the first edition

of a National Invasive Species Management Plan (Management Plan), which

shall detail and recommend performance-oriented goals and objectives and

specific measures of success for Federal agency efforts concerning invasive

species. The Management Plan shall recommend specific objectives and

measures for carrying out each of the Federal agency duties established

in section 2(a) of this order and shall set forth steps to be taken by the

Council to carry out the duties assigned to it under section 4 of this order.

The Management Plan shall be developed through a public process and

in consultation with Federal agencies and stakeholders.

(b) The first edition of the Management Plan shall include a review of

existing and prospective approaches and authorities for preventing the introduction and spread of invasive species, including those for identifying pathways by which invasive species are introduced and for minimizing the

risk of introductions via those pathways, and shall identify research needs

and recommend measures to minimize the risk that introductions will occur.

Such recommended measures shall provide for a science-based process to

evaluate risks associated with introduction and spread of invasive species

and a coordinated and systematic risk-based process to identify, monitor,

and interdict pathways that may be involved in the introduction of invasive

species. If recommended measures are not authorized by current law, the

Council shall develop and recommend to the President through its CoChairs legislative proposals for necessary changes in authority.

(c) The Council shall update the Management Plan biennially and shall

concurrently evaluate and report on success in achieving the goals and

objectives set forth in the Management Plan. The Management Plan shall

identify the personnel, other resources, and additional levels of coordination

needed to achieve the Management Plan’s identified goals and objectives,

and the Council shall provide each edition of the Management Plan and

each report on it to the Office of Management and Budget. Within 18

months after measures have been recommended by the Council in any

edition of the Management Plan, each Federal agency whose action is required to implement such measures shall either take the action recommended

or shall provide the Council with an explanation of why the action is

not feasible. The Council shall assess the effectiveness of this order no
6186 Federal Register / Vol. 64, No. 25 / Monday, February 8, 1999 / Presidential Documents

less than once each 5 years after the order is issued and shall report to

the Office of Management and Budget on whether the order should be

revised.

Sec. 6. Judicial Review and Administration. (a) This order is intended only

to improve the internal management of the executive branch and is not

intended to create any right, benefit, or trust responsibility, substantive

or procedural, enforceable at law or equity by a party against the United

States, its agencies, its officers, or any other person.

(b) Executive Order 11987 of May 24, 1977, is hereby revoked.

(c) The requirements of this order do not affect the obligations of Federal

agencies under 16 U.S.C. 4713 with respect to ballast water programs.

(d) The requirements of section 2(a)(3) of this order shall not apply to

any action of the Department of State or Department of Defense if the

Secretary of State or the Secretary of Defense finds that exemption from

[FR Doc. 99–3184

such requirements is necessary for foreign policy or national security reasons.

THE WHITE HOUSE,

February 3, 1999.

œ–

Filed 2–5–99; 8:45 am]

Billing code 3195–01–P
1

November 20, 2012 

The Honorable Lisa Jackson 

Administrator 

U.S. Environmental Protection Agency 

1200 Pennsylvania Ave, NW 

Mail Code: 1101A 

Washington, DC 20460 

Dear Administrator Jackson, 

This letter is to summarize my research experience with growing Giant Reed (Arundo donax) for multiple uses over 

the last 14 years, with special reference to its yield, carbon sequestration and invasivity. By way of introduction, I have 

spent 25 years conducting research with numerous potential cellulosic biomass/energy crops, including switchgrass, 

and 14 years with Giant Reed. My work with Giant Reed has been focused on both its potential benefits as a biomass 

crop for multiple uses, including liquid fuels, electricity, pulp and paper, and pharmaceuticals, and its potential to 

become invasive in the eastern United States. These studies have involved detailed scientific research, as well as 

careful on-the-ground surveys and observations. 

 

Unfortunately, much of the information available on Giant Reed has been posted on the internet, but most of this 

information has absolutely no scientific basis at all, and much of it is not correct. Even federal agencies are guilty of 

providing seriously misleading information. For example, the USDA has published a map with a title of ‘Distribution: 

Arundo donax’ http://plants.usda.gov/java/profile?symbol=ARDO4 which suggests that over half of the United States 

is invaded by Giant Reed. Of course, this amounts to extreme exaggeration. A more scientific approach would be to 

place a dot on the map for the location of each acre occupied by unwanted Giant Reed. If this were done, the reader 

would find it difficult to find where Giant Reed is located, except perhaps for along the Rio Grande and in Southern 

California. 

Yield 

I have recorded the biomass yield of Giant Reed from small research plots (about half an acre) for 13 years at the 

Auburn University E. V. Smith Research and Extension Center in south-central Alabama. Results have recently been 

analyzed and included in a PhD dissertation. Specifically, average biomass yield for switchgrass was 10.46 dry 

tons/acre/year, while that of Giant Reed was 15.79 dry tons/acre/year, some 51% higher. In addition, Giant Reed 

received no fertilizer during this time, while switchgrass had to be fertilized with nitrogen, and the quoted yields were 

achieved with no irrigation. Finally, drought conditions in Alabama during 2000 and 2007 were among the worst on 

record, but they had virtually no negative impact on biomass yield of Giant Reed, while yields of corn in most of the 

state were so low that the crop was not worth harvesting. Clearly, this result demonstrates the exceptional drought 

tolerance of Giant Reed. Since biomass yield and the need for fertilization are the most important factors that 

determine profitability of a biomass crop for farmers, our results show that Giant Reed is substantially superior to 

switchgrass, which is the ‘model’ biomass crop chosen by the US Department of Energy. 

Carbon Sequestration 

Soil carbon sequestration is critically important for two primary reasons: it reduces greenhouse gases, thus mitigating 

climate change, and it substantially improves the productivity of soils by increasing water holding capacity and the 

ability to retain plant nutrients. Our research showed that Giant Reed sequestered 22.4 tons of carbon/acre in the soil, 
2

which was 8 times (800%) that sequestered by switchgrass. In addition, soil content of the key plant nutrients, 

phosphorus (P) and potassium (K), were increased by Giant Reed, but these nutrients were depleted by switchgrass. 

Invasivity and Fire 

It is true that Giant Reed has colonized riparian areas along the Rio Grande and in southern California. However, this 

is due to the total lack of management, and the fact that these watersheds are very different from those in the eastern 

United States. In particular, they are essentially in desert regions where the native vegetation is not competitive, and 

the rivers in question flood for a few months each year, seriously excavating their banks, and then subside to no more 

than a trickle for the rest of the year. When banks are excavated, Giant Reed that should never have been planted there, 

is also excavated and spread out downstream where it forms new colonies. 

In contrast, our rivers in the eastern United States are perennial, with a steady flow of water year-round, and are lined 

with highly competitive woody vegetation. Therefore, even though Giant Reed has been widely grown as an 

ornamental in the eastern United States for well over a century, there is absolutely no evidence at all of it becoming 

invasive in this region. I believe that the main reason for this is that Giant Reed does not grow well in shade, and 

therefore is not competitive with our forests in the east, including those that occupy riparian areas. Fourteen years of 

experience with multiple research plots of Giant Reed that are up to 30 acres in size, indicates that plants in these plots 

have not moved at all. While this is largely due to competition from native vegetation, it is also because the plant is 

sterile, producing no fertile seed. In addition, unlike bamboo that produces long (up to 20 ft) underground rhizomes, 

Giant Reed rhizomes are very short and continue to die off as new ones are produced, thus eliminating the possibility 

of spreading. Therefore, its potential to become invasive is almost zero, provided it is properly managed. Furthermore, 

based on our experience, it can be eradicated easily by plowing and application of Roundup. 

Claims are also made that Giant Reed is a fire hazard. This may be the case in the West at certain times of the year 

when it is dry, but it is definitely not true for the East. We have specifically tried to burn our Giant Reed research plots 

in Alabama, to avoid having to cut them by hand, but our repeated attempts to set them alight with blow torches have 

totally failed. 

Conclusion 

In conclusion: 1) there is absolutely no evidence that Giant Reed is invasive in the eastern United States; 2) even in the 

western states, if it is planted away from riparian areas and properly managed, the risk of it becoming invasive is close 

to zero; 3) it can be easily eradicated; and 4) it can play a major positive role in carbon sequestration, reclamation of 

disturbed sites such as surface mines, being used to produce electricity, liquid fuels or pharmaceuticals, and providing 

much needed income for farmers. Results and observations from research on Giant Reed conducted by colleagues at 

Virginia Tech and USDA at Tifton, GA, are consistent with ours in Alabama. In short, this plant could play a major 

role in advancing the emerging biofuel and bioproduct industries which promise to provide jobs, improve rural 

economies and enhance the environment – more so than switchgrass or miscanthus. Therefore, in my opinion, it would 

be a disservice to the United States to deny this plant the same opportunity as switchgrass to contribute positively to 

our future. 

Please do not hesitate to contact me at (334) 844-3935 or bransdi@auburn.edu if you need more information. 

Sincerely, 

David I. Bransby 

Professor, Energy Crops and Bioenergy 
February 11, 2012 

Air and Radiation Docket 

Docket No. EPA-HQ-OAR-2011-0542 

Environmental Protection Agency 

Mailcode: 6406J 

1200 Pennsylvania Ave. NW. 

Washington, DC 20460 

To whom it may concern, 

I have had a chance to review the negative comments relating to the use of Arundo donax in “Regulation 

of Fuels and Fuel Additives: Identification of Additional Qualifying Renewable Fuel Pathways Under the 

Renewable Fuel Standard Program”. These documents reflect a concern that Arundo donax has known 

invasive properties, having been documented in riparian ecosystems, coastal waters and floodplains. As 

a component of our current research efforts focus on the vegetative reproduction of Arundo donax, the 

potential for invasiveness of this crop is something we have thought about. 

Arundo was originally introduced in the U.S. during the 1800’s for erosion control along drainage canals. 

Unfortunately, this use for soil stabilization in aquatic regions reflected early human mismanagement 

and lack of knowledge regarding the plant, and has contributed to the current invasiveness issues. 

Problems have arisen due to the ability of Arundo to propagate vegetatively from rhizomes and stems, 

and the plantings in riparian habitats, where high environmental disturbances/soil erosion conditions 

caused by flooding, flowing rivers, etc., have catalyzed the fragmentation and transport of the plants 

from one location to another. However, while numerous studies of Arundo donax have focused on 

riparian habitats, this riparian focus also suggests that for terrestrial habitats, invasiveness is much less 

an issue. This was also indicated from results obtained during a recent weed risk assessment1

. 

The objections did not comment on the fact that Arundo donax shows a widely-reported lack of seed 

and seedling production2,3, which may be due to disruptions in both ovule and pollen developmental 

pathways3

. Hence, inability to produce seeds represents a significant inhibitory mechanism to plant 

dispersion, and is not a contributing factor to the spread of the plant in the natural habitat. This is a 

positive trait for this plant, unlike other described weedy invasives. In a study of Arundo donax 

spreading inside and outside of flood zones, Boland4

 indicated that movement via fragmentation, 

rhizomes and layering occurred in the flood zone. However, it was also noted that in drier sites outside 

of the flood zone, Arundo spreading was less dynamic, with slow expansion and similar stand 

appearances from year to year. These results further suggest that the invasive characteristic is 

dependent on site, and if careful site selections are made to avoid riparian zones, and sites are 

managed, invasiveness can be avoided. 
Due to concerns regarding riparian habitat colonization, efforts at control and eradication have been 

made. Arundo control can be mediated via stem cuttings and whole plant excavation5

 and herbicide 

treatments, such as 3%-5% glyphosate foliar sprays, are efficient and consistent methods for the killing 

of Arundo6

. Reports on the use of insect biocontrol agents have also generated promising results7. 

In assessing the objection documents, and additional scientific literature, I believe that the concerns 

expressed about invasiveness, while relevant for riparian zones, are over stated for other sites. It is 

apparent that the indiscriminate plantings carried out in the past have negatively impacted on the 

beneficial uses and potential of this crop for the development of U.S. energy self-sustainablility. We 

would expect that Arundo growers, like other farmers, would need to assess their site for suitability to 

grow the crop. Riparian habitats would be designated as inappropriate and high risk for the crop. 

Furthermore, best practices for management, as required by the growing States, which would eliminate 

risk of spread if followed. Furthermore, and worst case, the evidence is present that the plants can be 

killed by herbicide, or a combination of cutting with herbicide. The recent report by Virtue1

, while 

stressing the weed risk of Arundo donax in riparian habitats, also indicated that in non-flooding areas, 

Arundo has minimal lateral spread and humans represent the highest dispersal agent threat. He also 

provided several guidelines to be used for risk management1

, which should allow manageable 

containment of Arundo, and the development of a viable Arundo donax industry. Some of his key 

guidelines include: 

Location of plantings outside of riparian habitats; 

The establishment of containment and buffer zones; 

A survey for and control of any escapes; and 

Adequate harvest, transport and processing checks. 

Adherence to proposed guidelines would facilitate the growth of Arundo as a low-risk weed bioenergy 

crop in terrestrial habitats. 

Sincerely, 

Barry Flinn, Ph.D. 

Director – Institute for Sustainable and Renewable Resources 

Institute for Advanced Learning and Research 

Danville, VA 24540 
1

Virtue JG, Reynolds T, Malone J, Preston C, Williams C. 2010. Managing the weed risk of cultivated 

Arundo donax L. Proceedings of the Seventeenth Australasian Weeds Conference, pp. 176-179. 

2

Bell G. 1994. Biology and growth habits of giant reed (Arundo donax). In NE Jackson, P Frandsen and S 

Douthit, eds. Arundo donax Workshop. Riverside CA. pp. 1-6. 

3

Mariani C, Cabrini R, Danin A, Piffanelli P, Fricano A, Gomarasca S, Dicandilo M, Grassi F, Soave C. 2010. 

Origin, diffusion and reproduction of the giant reed (Arundo donax L.): a promising weedy energy crop. 

Ann Appl Biol 157:191-202. 

4

Boland JM. 2006. The importance of layering in the rapid spread of Arundo donax (Giant reed). 

Madroño 53(4):303-312. 

5

Lowrey J, Watson J. 2004. Tamarisk and Arundo control on Cache Creek. In Proceedings of the California 

Weed Science Society. San Jose, CA: California Weed Science Society, pp. 82-83. 

6

Spencer DF, Tan W, Lio P-S, Ksander GG, Whitehand LC, Weaver S, Olson J, Newhouser M. 2008. 

Evaluation of glyphosate for managing giant reed (Arundo donax). Invasive Plant Science and 

Management 1: 248-254. 

7

Wood M, Flores A, McGinniss L, Peabody E. 2007. Lassoing wicked weeds of the west. Agric Res 55: 16-

19. 
Feb	12,	2012

The	comments	regarding	the	use	of	certain	species	for	bioenergy	production	(via	

the EPA	ruling)	has	raised	concern	regarding	the	promotion	of	potentially	invasive	

species,	which	would	be	in	violation	of	Executive	Order	13112.	The	damage	caused	

by	invasive	species	is	well	documented	and	should	not	be	overlooked	when	

considering	bioenergy	crop	selection	and	production.	However,	it	is	my	opinion	that	

use	of	known	invasive	species	should	not	be	allowed in	areas	where	they	are	known	

to	be	problematic	(eg,	kudzu	in	the	Southeast),	but	that	outside	of	those	areas	the	

issue	becomes	much	more	complex.	Below	I	specifically	address	the	issue	of	giant	

reed	(Arundo	donax,	hereafter	Arundo),	but	the	same	principle	applies	to	all	species.	

Arundo is	a	state	listed	noxious	weed	in	Texas	and	California.	However,	several	

other	states	consider	Arundo	to	be	invasive,	or	potentially	invasive	(eg,	Tennessee).	

The	distinction	between	the	two	listing	types should	be	clarified:	noxious is	a	

regulated	taxon	in	that	state,	whereas	any	other	listing,	such	as	invasive,	is	an	unregulated	listing	by	an	unofficial	listing	organization	(unofficial	in	the	sense	that	the	

state	does	not	recognize	that	listing).		For	example,	the	Tennessee	Exotic	Pest	Plant	

Council	lists	Arundo	as	an	invasive	species,	but	this	listing	does	not	carry	any	legal	

restrictions	on	trade	or	control.		This	is	not	to	say	that	the	listed	“invasive”	species	is	

not	causing	economic	or	ecological	harm,	but	that	it	is	not	regulated	in	that	state.

Weed	Risk	Assessments	(WRA)	have	been	conducted	for	Arundo	in	some parts	of	

the	US,	including	Florida,	which	have	generally	resulted	in	“reject”,	which	means	it	

has	a	high	risk	of	invasion.	However,	it	should	be	noted	that	the	current	WRA	

system	(Pheloung	et	al	1999)	has	no	way	of	distinguishing	different	climates,	

regions,	or	ecosystems,	which	will	have	varying	levels	of	susceptibility	to	risk

(Barney	and	DiTomaso	2008).	The	“high	risk”	or	“reject”	outcome	for	Arundo	is	

driven	by	the	presence	of	invasive	populations	in	California	and	Texas,	where	

Arundo	is	displacing	native	flora	and	have	negative	ecosystem	impacts along	

riparian	corridors. For	example,	the	same	WRA	result	of	“reject”	would	be	found	for	

Arundo	in Texas,	where	it	is	a	state	listed	noxious	weed,	and	Maine,	where	it	is	not	

known	to	occur.	Therefore,	WRA	results	should	be	interpreted	in	the	context	of	their	

limitations.	Additionally,	the	WRA	was designed	as	a	pre-introduction	(ie,	the	plant	

is	not	in	this	country	yet)	screen,	which	of	course	is	not	the	case	for	Arundo.	My	

2008	(Barney	and	DiTomaso	2008)	paper	has	been cited	as	an	example	

demonstrating	that	Arundo	is	a	high	risk	in	Florida,	which	was	a	result	of	the	WRA.	

That	WRA	analysis was	done	as	a	first	step	in	evaluating	the	risk	of	three	bioenergy	

crops,	and	should	be	interpreted	in	the	context	of	the	screening	process	we	

proposed,	of	which	the	WRA	is	only	one	component	(Barney	and	DiTomaso	2008).	

WRAs are	good	first	steps	in	evaluating	invasiveness,	but	should	not	be	used	

exclusively	without	the	insight	of	field	tests,	which	that	paper,	and	others,	argues.

It	should also be	noted	that	invasiveness	is	not	a	universal	character,	and	that	

species	are	not	invasive,	rather	populations	of	species	are	invasive.	Also,	all	

populations	of	an	“invasive	species”	are	not	invasive.	For	example,	kudzu	is	a	
harmful	invasive	species	of	the	southeast,	but	populations in	New	England are	not	

invasive	or	threatening	to	become	invasive.	Additionally,	Arundo	is	harmful	in	

California	and	Texas	almost	exclusively	along	riparian	corridors	where	it	makes	

mono-clonal	stands (Ahmad	et	al	2008).	However,	in	the	drier	uplands	of	both	

states	Arundo	is	less	abundant.	Arundo	spreads	exclusively	via	vegetative	fragments	

(stems	and	rhizomes),	which	are	primarily	water	dispersed.	Therefore,	upland	

populations are	far	less	likely	to	spread. The	ability	to	spread	when	growing	along	a	

riparian	area	is	far	greater	than	when	growing	in	a	field	far	from	a	dispersal

corridor (Boose	and	Holt	1999).	

As	stated	above,	invasiveness	is	not	exhibited	by	all	populations	or	in	all	locations	

within	a	taxon.	Arundo	was	actively	planted	along	riparian	corridors	of	California	

for	bank	stabilization and	erosion	control (Boose	and	Holt	1999),	just	as	kudzu	was	

planted	along	roadsides	in	the	Southeast.	The	active	cultivation	along	dispersal	

corridors	led	to	the	large-scale	spread	of	both	species.	In	contrast,	the	active	

cultivation	and	management	of	a	bioenergy	crop	within	field	boundaries	will	

dramatically	decrease	the	likelihood	of	unintentional	escape.	This	is	especially	the	

case	for	Arundo,	which	does	not	produce	seeds,	and	is	therefore	relegated	to	

dispersing	via	vegetative	fragments,	which	greatly	reduces	the	probability	of	

moving	offsite,	especially	when	far	from	a	riparian	area.

All	species	present	a	non-zero	risk	of	becoming	invasive.	The	vast	majority	of	

species	present	a	very	low	risk,	but	that	risk	is	still	not	zero.	For	a	successful	

invasion	to	occur	several	components	must	be	present:	an	introduction	event(s),	a	

susceptible	habitat,	an	available	(favorable)	microsite,	and	sufficient	time

(Theoharides	and	Dukes	2007).	Management	of	bioenergy	crops	will	include	best	

practices	to	minimize	several	of	these	components	to	reduce	the	likelihood	of	

invasion (NC	BC 2011).	

Lastly,	several	of	the	locations	where	Arundo	is	being	discussed	for	cultivation	is	far	

outside	of	the	warm	climates	where	Arundo	is	currently	problematic.	Cold-tolerance	

is	largely	unknown	in	Arundo,	and	it	should	not	be	assumed	that	behavior	exhibited	

in	one	region	represents	eventual	behavior	everywhere.	Much	research	must	be	

done	of	Arundo	biology	and	ecology	in	these	cooler	climates.

In	conclusion,	while	I	fully	recognize	the	dramatic	Arundo	invasions	in	California	

and	Texas,	and	the	consequences	on	native	species	and	ecosystem	properties,	it	

should	not	be	assumed	that	Arundo	will	become	invasive	in	all	circumstances	and	

locations.	Nearly	all	research	on	Arundo	has	been	conducted	in	California	and	Texas,	

and	we	know	little	about	Arundo	in	the	Southeast or	many	other	regions.	The	

intentional	planting	of	Arundo	along	riparian	corridors	was	also	likely	its	downfall,	

which	should	not	be	the	case	for	bioenergy	production.	The	precautionary	principle	

would	advise	us	against	using	Arundo	or	similar	species,	but	the	potential	benefits	

must	be	weighed	against	the	risks	(known	and	unknown).	We	have	learned	much	

about	how	Arundo	spreads,	and	can	use	this	information	to	guide	best	management	

practices	to	reduce	the	probability	of	unintentional	escape.
I	am	certainly	in	favor	of	reducing	the	promotion	of	invasive	species	in	any	context,	

and	am	interested in	protecting	our	natural	resources.	I	am	arguing	for	invasiveness	

to	be	viewed	in	the	context	of	each	species	and	location.	Invasions	are	an	extremely	

complex	phenomena,	and	due	diligence	should	be	done	to	protect	our	natural	

resources	while	also	supporting	bioenergy	production.

Respectfully,

Jacob Barney,	PhD

Assistant	Professor	of	Invasive	Plant	Ecology

Department	of	Plant	Pathology,	Physiology,	and	Weed	Science

Virginia	Tech

Blacksburg,	VA	24061

Ahmad	R,	Liow	PS,	Spencer	DF,	Jasieniuk	M.	2008.	Molecular	evidence	for	a	single	

genetic	clone	of	invasive	Arundo	donax in	the	United	States.	88:	113-120.

Barney	JN,	DiTomaso	JM.	2008.	Nonnative	species	and	bioenergy:	Are	we	cultivating	

the	next	invader?	BioScience	58:	64-70.

Boose	AB,	Holt	JS.	1999.	Environmental	effects	on	asexual	reproduction	in	Arundo	

donax.	Weed	Research	39:	117-127.

North	Carolina	Biofuels	Center.	2011.	Voluntary	best	management	practices	for	

energy	crops:	Minimizing	the	risk	of	invasiveness.	

Pheloung	PC,	Williams	PA,	Halloy,	SR.	1999.	A	weed	risk	assessment	model	for	use	

as	a	biosecurity	tool	evaluating	plant	introductions.	57:	239-251.

Theoharides	KA,	Dukes	JS.	2007.	Plant	invasion	across	space	and	time:	factors	

affecting	nonindigenous	species	success	during	four	stages	of	invasion.	New	

Phytologist	176:	256-273.
February 9, 2012

Ms Delane Richardson

Director of Research

Chemtex International Inc

6951 Ridge Road

Sharon Center, OH 44274

Dear Ms Richardson

Pursuant to our phone conversation this morning, I have reviewed the document “Voluntary Best 

Management Practices for Energy Crops – Minimizing the Risk of Invasiveness” published by 

North Carolina State University, the North Carolina Department of Agriculture and the Biofuels 

Center of North Carolina, and agree that the practices they propose for a) information gathering, 

b) planting and field management, c) harvesting, d) transportation, and e) storage, are feasible for 

the commercial cultivation of Arundo donax as a biofuel crop. These practices minimize the

chance of Arundo donax escaping from cultivated plantings.

I have conducted experimentation in Ohio with Arundo donax for three years and have some 

experience regarding it biology; namely:

(i) Arundo donax has a high yield potential (up to 20 tons/ac under ideal conditions), and as 

such, has potential for use as a biofuel crop in Ohio.

(ii) Arundo donax has been used widely as an ornamental species throughout Ohio, but has not 

been observed or documented to have “escaped” from these plantings. Although we have 

not measured the response of Arundo donax to cold temperature, I believe the cold winters 

in Ohio are a significant factor in preventing the dispersal of Arundo donax that is observed 

and reported in southern USA states.

(iii) I have a 1⁄4 acre nursery plot of Arundo donax in Columbus Ohio that is approximately 12 

years old. This area grows within 50 feet of a stream, but is separated from the stream by a 

regularly mowed grass buffer strip. We have not measured nor observed any spread of 

Arundo donax plants from this nursery area into the stream.

(iv) Arundo donax produces short rhizomes, however we have not observed spread of plants by 

more than 2 feet per year. This rate of spread makes it unlikely that Arundo donax will

escape managed stands.

(v) Although Arundo donax produces a spectacular flower head, we do not see any evidence of 

seed production from these seed heads, nor have observed any propagation of seedlings 

from seed. I believe this species is sterile.

Yours sincerely

Dr David Barker

Associate Professor, Grassland Ecology

Department of Horticulture and Crop Science

226 Kottman Hall Phone: (614) 247-6258

2021 Coffey Road Fax: (614) 292-7162

Columbus OH 43210-1086 E-mail: barker.169@osu.edu
Weed risk manageme

Arundo donax planta

Dr John Virtue

NRM Biosecurity Unit, DWLBC
SA Weed Risk Management S

Comparative 

Weed Risk =

Invasiveness 

×

Impacts 

×

Potential Distributio

Feasibility of Containment =

Control Costs 

×

Current Distribution 

×

Persistence (0
Weed risk of Arundo don

• Assessed for two land uses:1. Riparian

• river, creek and lake systems, 

including standing/flowing watbanks and adjacent floodplain

2. Terrestrial native vegetation

• native vegetation remnants in t

landscape that not subject to fevents
Weed risk of Arundo don

• Establishment• Tolerance to 

routine weed control

• Reproduction• Natural spread• Human spread

INVASIVEN

Riparian Ter

4.7 

- likes bare ground- no seed set, just 

reproduces vege

- greater establishm

dispersal in wet a
Weed risk of Arundo don

• Regeneration• Dominance• Biodiversity• Movement• Health• Ecosystem 

change

IMPACTS

Riparian Ter

6.8 

- low moisture & nu

and lack of watedispersal limits A. density in terrestria

- monoculture pote

riparian areas
Weed risk of Arundo don

• Climate match• Soil tolerances

POTENTIA

DISTRIBUTIO

Riparian Ter

6.0 

- wide climatic r- native habitat 

essentially ripar
Feasibility of control of A. d

• Detection• Accessibility• Treatment• Landholder 

cooperation

CONTROL CO

Riparian Ter

4.7 

- quite easy to fi- generally acce- treat with glyph

spray
Feasibility of control of A. d

• % of landuse 

infested

• Pattern of 

distribution

CURRENT 

DISTRIBUTIO

Riparian Ter

0.9 

- rare- scattered thro

region
Feasibility of control of A. d

• Ease of kill• Time to 

reproduction

• Propagule 

longevity

• Ongoing 

dispersal

PERSISTENC

Riparian Ter

3.6 

- glyphosate spr

effective

- no seed- short-lived rhizo

fragments

- still grown
Weed Risk vs. Feasibility of c

FEASIBILITY OF CONTROL

Riparian Terrestrial

16 4

WEED RISK

Riparian Terrestrial

192 4
FEASIBILITY OF CONTAINMENT 

WEED 

RISK Negligible 

>113 

Low 

>56 

Medium 

>31 

High 

>14 

Negligible 

<13 LIMITED ACTION LIMITED ACTION LIMITED ACTION LIMITED ACTION 

Low 

<39 LIMITED ACTION LIMITED ACTION LIMITED ACTION MONITOR 

Medium 

<101 MANAGE SITES MANAGE SITES MANAGE SITES PROTECT SITES CO

High 

<192 MANAGE WEED MANAGE WEED PROTECT SITES CONTAIN SPREAD 

I

Very High 

>192 MANAGE WEED PROTECT SITES & MANAGE WEED CONTAIN SPREAD DESTROY INFESTATIONS 

T

A

Floodplain

A. donax
Containing non-riparian A. d

Consider the following measures:• Declaration under NRM Act and us

to allow cultivation and movement stipulate certain management con

• No planting within areas prone to f

(e.g. River Murray Flood Zone)

• Plant a minimum of 20 m from natu

watercourses and constructed dra

• 10 m buffer zone around plantings 

contain any vegetative spread
Containing non-riparian A. d

Consider the following measures (con• Pre-planting survey of A. donax alre

present in the vicinity 

• 1km land radius, 5km drainage line

• Annual surveys to detect and remo

new plants

• Hygiene procedures for harvest, tra

and processing to minimise inadvespread of vegetative fragments
Conclusion

• Cultivation of Arundo donax away from ripariaareas poses a low weed • However, ongoing measures would need to taken to prevent spread riparian areas
1

McClafferty, Ryan

From: Quinn, Robin on behalf of Columbus, R. Timothy

Sent: Friday, November 02, 2012 2:44 PM

To: Fialkov, David

Subject: FW: A donax weed rating according to Sth Australian study

From: Delane.Richardson@chemtex.com [mailto:Delane.Richardson@chemtex.com] 

Sent: Monday, October 15, 2012 6:59 AM 

To: Columbus, R. Timothy 

Subject: Fw: A donax weed rating according to Sth Australian study 

Fyi

From: Virtue, John (PIRSA) <John.Virtue@sa.gov.au> 

To: Richardson, Delane SHC; peter.rowe@polygenomx.com <peter.rowe@polygenomx.com> 

Sent: Mon Oct 15 05:58:47 2012 

Subject: RE: A donax weed rating according to Sth Australian study 

Dear Delane and Peter, 

Thanks for your email. I have read the Voluntary Best Management Practices for Energy Crops document and it aligns 

well with the proposed risk management procedures for Arundo donax in Australia, as outlined in the RIRDC document 

and the associated Australasian Weeds Conference paper: 

https://rirdc.infoservices.com.au/items/10-215

http://www.caws.org.au/awc/2010/awc201011761.pdf

The weed risk assessment done for A. donax in Australia (refer above documents) shows major differences in risk of the 

plant in riparian vs. non-riparian situations. In the absence of seed production, the fundamental requirement for A. 

donax to disperse, invade and form monocultures is flowing water. Provided it is grown distant from waterways (with 

measures in place to prevent human mediated movement of fragments to such waterways, whether accidental or 

deliberate), then I consider it to be a manageable risk. Note that the document recommends a regulated approach 

under a jurisdictions noxious weed laws. 

Kind regards 

Dr John G. Virtue 

Manager - NRM Biosecurity 

Biosecurity SA (a division of PIRSA)

Postal address: GPO Box 1671 Adelaide SA 5001 Location address: Building 1, Soil & Water Environs, Entry 4, Waite Rd, Urrbrae SA Phone: 08 8303 9502 Mobile: 0428 112 943 Fax: 08 8303 9555 Email: john.virtue@sa.gov.au Web: www.pir.sa.gov.au/biosecuritysa
2

From: Delane.Richardson@chemtex.com [mailto:Delane.Richardson@chemtex.com] 

Sent: Thursday, 11 October 2012 11:58 AM 

To: peter.rowe@polygenomx.com; Virtue, John (PIRSA) 

Subject: RE: A donax weed rating according to Sth Australian study 

Thank you very much for the introduction Peter. Dr Virtue, we are opening a 20 million gallon per year bio ethanol 

facility in Crescentino Italy, using Arundo Donax as a purpose grown feed stock. We began our Arundo research in 2006 

and have an Arundo “library”in Italy of 89 different eco types we have gathered from around the world. The 

economics for us as well as the farmer are heavily dependent on the great yields we see with Arundo. We are trying to 

get our Arundo pathway permitted in the United States, however fear of invasiveness may keep this great feedstock off 

the table for us in the US. Would you consider endorsing our use of Arundo in some way? The attached best practices 

are to be incorporated into our purchase contracts. A letter from a renowned weed expert such as you, stating your 

belief that the best practices would contain Arundo, would go a long way in helping us get the approval we need. Could 

you review our best practices and let me know what you think? 

Thanks in advance for your time 

Delane Richardson 

Vice President Proesa Technology 

Chemtex International 

From: Peter Rowe [mailto:peter.rowe@polygenomx.com] 

Sent: Wednesday, October 10, 2012 8:09 PM 

To: john.virtue@sa.gov.au

Cc: Richardson, Delane SHC 

Subject: FW: A donax weed rating according to Sth Australian study 

John 

Hi. Thanks for being available when I called yesterday – it was a lucky break to catch you between sessions. 

To keep this email on the issue, I’ll send you background on PolyGenomX separately as we are not the point of this 

communication. 

You’ll see below, from the request from Delane Richardson, VP for PROESA at Chemtex in the US, that she would very 

much appreciate any objective balance that you may be able to instil into the discussion that she is presently involved in 

with regulators in her area about the use of A. donax as a biofuels feedstock. 

Delane will now make direct contact with you and I’ll leave you two to have that conversation in more detail. 

Regards 

Peter Rowe 

Managing Director 

Level 4, 130 Bundall Road, Bundall Q 4217 

PO Box 6566 Gold Coast MC Q 9726 Australia 
3

P +617 5510 3166 | F +617 5510 3544 | M 0408 844 000 

Web: www.polygenomx.com Skype: PolyGenomX 

Follow PolyGenomX on: 

This e-mail and any attachments are confidential and may be protected by legal, professional or other privilege. If you are not the intended recipient you should not store it, copy it, re-transmit it, use it or 

disclose its contents, but should return it to the sender immediately and delete your copy from your system. Please note that while we scan all e-mails for viruses we cannot guarantee that any e-mail is 

virus-free.

From: Delane.Richardson@chemtex.com [mailto:Delane.Richardson@chemtex.com] 

Sent: Thursday, 11 October 2012 1:54 AM 

To: Peter Rowe - PGX 

Subject: RE: A donax weed rating according to Sth Australian study 

Thanks again for your time Peter and I forwarded the information to Michaela Roati, who will follow up with you from 

Italy. On the report below, this could be very helpful to us in our immediate need to get Arundo approved. Do you 

know the author well enough that perhaps he might send a letter on our behalf summarizing his findings? This is a very 

poltical issue for us just now and we could use some support very quickly. Delane 

From: Peter Rowe [mailto:peter.rowe@polygenomx.com] 

Sent: Tuesday, October 09, 2012 7:15 PM 

To: Richardson, Delane SHC 

Cc: 'Steven Burke' 

Subject: A donax weed rating according to Sth Australian study 

Delane 

Hi. It was great to meet with you, Steven, Mark and John yesterday and to scope out what you and we are doing and to 

explore a little of the potential overlap and synergy. 

I tripped over the attached study when searching for something else in our vast archive of material, and thought it may 

have some marginal relevance for you. 

I’ll look forward to talking further when you have some clarity around the management issues and strategies for donax 

in a large scale setting. 

Regards 

Peter Rowe 

Managing Director 

Level 4, 130 Bundall Road, Bundall Q 4217 

PO Box 6566 Gold Coast MC Q 9726 Australia 

P +617 5510 3166 | F +617 5510 3544 | M 0408 844 000 

Web: www.polygenomx.com Skype: PolyGenomX 

Follow PolyGenomX on: 

This e-mail and any attachments are confidential and may be protected by legal, professional or other privilege. If you are not the intended recipient you should not store it, copy it, re-transmit it, use it or 
4

disclose its contents, but should return it to the sender immediately and delete your copy from your system. Please note that while we scan all e-mails for viruses we cannot guarantee that any e-mail is 

virus-free.