jf TreeFree Biomass Solutions Inc. 

The Honorable Lisa Jackson, Administrator 

U.S. Environmental Protection Agency 

1200 Pennsylvania Avenue NW 

Washington, DC 20460

McKinstrylnno vat/on Center 

Advancing the future of energy technology 

210 South Hudson Street, Suite 328


Seattle, Washington 98134


Office: (206) 246-6277


www.treefreebiomasssolutions.com

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RE:	40 CFR Part 80; RIN 2060-ARO7; 77 FR 700; 77 FR 462; and 77 FR 13009; 

Dear Honorable Jackson, 

My purpose in communicating with you is that my company is seeking advice / help / direction on insuring EPA 

and other government officials and decision makers have the opportunity to consider updated, scientifically 

based information before ruling on proposed rule 77 FR 4620. We can provide accurate and broad based 

scientific information concerning the proposed energy crop "Arundo donax", common name "Giant Reed". 

Our information strongly supports expanding the energy crop list (a new pathway) to include Arundo donax. 

Based on the intent expressed in Executive Order 13112 concerning "invasive species", decision makers 

are directed to "consider" the "good" benefits as weighed against the "potential harm" in 

determining if a plant is eligible for use in government funded projects. Many of the negative comments that 

the EPA has received has also mentioned the Executive Order and this "weighing" of "good and bad" prior to 

making a final determination. 

Our Company has spent over 14 years studying Arundo donax. Equally important, we have spent 14 years 

studying the impact on our Nation's national security, economic, and domestic welfare issues if we fail to 

successfully meet the challenge of discovering safe pathways to energy independence, carbon sequestration, 

the balance of import and exporting trade, the rejuvenation of our Nation's industrial and manufacturing 

sectors as well as the economic welfare of our Nation's farmers. In our opinion, these issues are part of the 

broader scope of analysis intended by Executive Order 13112. 

In reading the many negative comments and letters submitted to the EPA and other governmental 

departments about the EPA's action last February to expand the energy crop list to include Arundo donax, we 

see no such "broad" viewpoint and/or analysis even though most of these communications actually mention 

Executive Order 13112.
We see a very narrow and one way position supported by a reference to "200 scientists." Yet, if you remove 

the negative comments and letters that make references to "wetlands", riparian", waterways, rivers and 

streams there would be no significant negative opposition at all to the EPA's expanded action. We believe this 

recognition is extremely vital to an honest and intended effort to meet the mandate of Executive Order 13112. 

These "scientists" have not considered or know of the fact that almost every nursery in the Nation sells an 

ornamental species of Arundo donax, and has been doing so for decades. Yet, this distribution has not 

resulted in any known harm or danger. 

Our impression from reading the negative comments and letters that support the negative outlook on Arundo 

donax is that most of these "scientists" seem to think that Arundo donax somehow "escaped" from 

somewhere and made its way to the riparian, wetlands, rivers and streams of where 99% of the "wild" growth 

Arundo donax is located today. However, this is not the case. Arundo donax was actually planted in these 

wetlands, riparian areas, and on the banks of rivers and streams as a soil erosion measure. 

The US territories that contain over 99% of the uncontrolled growth of Arundo donax were once owned by 

Spanish I Mexican interests. We believe that in these areas Arundo donax (also known as Spanish Cane and 

Carrizo) were intentionally planted there as soil erosion measure because this was a successful application in 

Spain and later throughout Europe. However, European rivers are mostly deep banked, have swift currents, 

and are seldom without water flow all year round and because of their high banks, seldom if ever flood. These 

features made using Arundo donax as a soil erosion measure safe and practical. Rivers and streams in the 

California and other territories where Arundo was planted are unlike the European rivers. They are very 

shallow in some parts, have low banks, and during part of the hot season become completely void of water 

flow, then during the rainy season because of their low banks, have annual flooding. These ecological 

characteristics made the use of Arundo donax as a soil erosion measure a disasterl 

After these territories / States became part of the United States, the population grew, especially in Southern 

California, "water" became a big issue; water for farming and to quench the thirst of a fast growing population 

base. The Army Corp of Engineers came up with the answer, "let's widen the river beds to get more flow". So 

the river banks of many streams and rivers feeding Southern California, starting up as high as Sacramento, 

were bulldozed and widened. At that time, the Army Corp of Engineers knew very little about Arundo donax. 

The combination of widening the waterways and annual flooding are the two major factors that caused the 

uncontrolled growth of Arundo donax in these areas. As watersheds and other agencies began funding the 

"eradication" of Arundo, business entities discovered the lucrative business of bidding on "removal projects" 

even though they did not scientifically know how to remove Arundo without it coming back year after year. 

Bill Tidwell, now a retired Orange County manger developed and successfully employed methods that 

permanently eradicated inappropriate stands without any regrowth. Mr. Tidwell has served a consultant 

for our Company for over 13 years. The eradicators were using safe herbicides immediately after cutting 

down the growth only to see the growth come back. Mr. Tidwell was one of the first people who 

recognized that herbicide should not be used until after a cut stalk gave rise to a new "shoot". It is at 

this time that the plant is "taking in" its nutrients to continue growing. Applying herbicide at this point 

results in the plant "drawing in" the herbicide down to its roots and permanently killing the plant roots. 

Thanks to Mr. Tidwell's discovery, 95% of the "invasive" growth in the Orange County has been 

eradicated. 

Over the past 14 years our Company has worked with Washington State University, the University of 

Washington, Auburn University, the University of Delaware, North Carolina State University and numerous 

2 

EPA Proposed Rule Response
scientitic laboratories. We invested in planting Arundo plots at Auburn University and at the agricultural 

research center at Prosser, Washington operated by Washington State University. Almost every professor and 

scientist that has become familiar with Arundo donax has declared it to be the "miracle" plant. The plant 

earned this title because of the following attributes: 

1. Produces an amazing range of yields reaching up to 60 tons per acre depending upon climate; 

2. Is a perennial plant that need only be planted once in a lifetime; 

3. Is very drought resistant; 

4. Grows on marginal land rather than compete with food crop farmland; 

5. Sequesters carbon at a rate 15 times greater than Douglas fir trees; 

6. Can be irrigated with brackish water; 

7. Arundo donax has phytoremediation qualities with respect to air, water, and soil, like no other plant in 

the world. This could have great positive impact on America's brownfields and superfund sites. 

8. Arundo contains a unique source of sugars and chemicals; 

9. Its' fiber is a perfect alternative to fiber from trees and in most cases is a superior fiber than fiber from 

trees, capable of being used in existing facilities and mills without modification. 

10. Arundo is a very strong crop once established and history has shown that it is not disturbed by 

hurricanes and other such foil weather conditions. 

11. Arundo could be planted at the low point of America's farmlands and actually "filter" out the toxins 

from the use of fertilizers thereby preventing further pollution of waterways. 

When these attributes of Arundo donax are properly translated in regards to the impact on our Nation's ability 

to meet the challenges mentioned above, which sum up to national security as these attributes allow us to 

meet the challenge of energy independence as well as the rejuvenation of our Nation's economic welfare, 

please see a report titled "BIOMASS AS FEEDSTOCK FOR A BIOENERGY AND BIOPRODUCTS INDUSTRY: THE 

TECHNICAL FEASIBILITY OF A BILLION-TON ANNUAL SUPPLY", a report organized by the USDA and the DOE; 

and when the cause and cure of the wild Arundo growth in California and other territories are fully 

understood, there will be no doubt that Arundo donax is a safe plant and should be on the official energy crop 

list! 

Currently we have 14 year old test plots at Auburn University that provide documented evidence that Arundo 

by nature is not invasive, as the invasive weeds and plants that have been used in the many comment letters 

such as the references to Arundo being 'kudzu like". This is scientifically incorrect. Arundo does not seed, and 

does not spread like Kudzu. Additionally, by the trained personnel, Arundo can be killed in a short 30 day 

period while it takes up to 10 years to kill Kudzu. 

We have been developing a proposal to the EPA, DOE, DOD, and Homeland security to help fund a project to 

actually remove the 250,000 acres or less acres thereby eliminating all of this concern about Arundo's 

invasiveness. Complete removal could be achieved within five (5) years. If the estimate of 250,000 acres is 

correct, it is possible that over 5,000,000 tons of biomass could be available and used to jump start several 

green biotech efforts to produce biofuels, clean coal, and several other products which are currently being 

produced utilizing fiber from trees and/or that are in need of feed stocks. We have already identified over 30 

biotech and biomass users who would economically participate with such a removal effort. Additionally the 

concern of the 200 scientists could also be turned into a positive action plan to help with such a removal 

project. It is estimated that Arundo was planted here in the US over several hundred years ago, yet today 

there is only 250,000 thousand acres of unwanted growth. These facts alone should indicate that Arundo is 

EPA Proposed Rule Response
not in the same category as Kudzu and the other invasive species that are mention in the objection letters 

submitted by the concerned scientists. The removal project could also create approximately 1,000 jobs and 

generate approximately $250 million to help finance such a project. 

The statement that eradication of Arundo costs $25,000 per acre is just not correct. Many watersheds 

districts and Counties have been victimized by profit seeking business concerns taking advantage of the lack of 

accurate information and science by these funding agencies. It is also sad that these funding agencies have 

funded the removal of the same areas over and over for years due to the lack of know-how and upon 

occasion, the ill-intent of business concerns winning bid awards. Our Company has been eradicating Arundo 

between a range of $450 - $5,000 per acre depending upon terrain conditions and whether or not machinery 

could be utilized. 

The utilization of Arundo as an energy / biotech feedstock would also be a win win situation for America's 

farmers and solve many of the ailments surrounding our farming industry. With a payment to farmers of $20 

per ton of growth, America's farmers could enjoy an income stream of approximately $600 to $800 per acre 

with no annual planting, herbicide, fertilizer, transportation, crop insurance and harvesting costs. Arundo 

plantations do not require rotation. Additionally farmers could use marginal land which may not he capable of 

producing income from other crop use. 

In the 14 years that we have been working with scientists, Universities, and laboratories, we have successfully 

developed "green" and safe solutions for 10 verticals, including biofuel and energy. We have discovered 

companies like Rico Reeds that have planted and properly maintained 50 year old Arundo plantations which 

have not moved or escaped from their original planting boundaries. 

The rest of the world, Europe, India and China, has now discovered the "champion of biomass" as stated by 

the EU, if we allow for "bad" science to halt or handicap the use of this "miracle" plant with such handicaps 

such as un-necessary bonding requirements, America will fall way behind the "8 ball" in regards to carbon 

sequestration, energy independence, and the rejuvenation of America's industrial and manufacturing 

economies. The Administration's goal of establishing a "green economy", reaching energy independence and 

job creation will be severability handicapped with the use of Arundo donax. 

We request that you lead us in developing the proper plan and way to share our information with the proper 

decisions makers concerning this vital issue and we remain available to submit evidence of the claims we state 

herein. 

Eulysses B. Lewis, President 

TreeFree Biomass SoIutons, Inc. 

EPA Proposed Rule Response
'I 

AUBURN UNIVERSITY AGRONOMY AND 

SOILS DEPARTMENT

COLLEGE OF AGRICULTURE 

Two whom it may concern 

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. 

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, 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. 

In conclusion: I) 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 3) 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. 

David I. Bransby

Professor, Energy Crops and Bioenergy
Arundo donax - Weed to Crop 

Good morning to all. My name is Bill Tidwell and I know a thing or two about Arundo. But first let me 

introduce myself. 

My credentials: 

• Pioneered first successful control of Arundo in Southern California in 1988. 

• Founding member and past president of Team Arundo in Southern California. 

• I have removed and controlled more Arundo than any man alive on the planet. 

• MS degree (Environmental Studies, CSUF), BS degree (biology), BS degree (social ecology, UCI) 

• Environmental topics teacher for 34 years at college level (ethics, habitat restoration, native 

plants, environmental internship, ecology, endangered species, etc.) 

• Initiated, developed and implemented a habitat restoration program in Galapagos Islands. 

• Speaker for Restoring the Earth Conference 1988 in Berekely, Ca. My topic was artichoke thistle 

control in California native grasslands. That was my first weed control project. It was the first 

successful control of that weed species in California. 

• Park Ranger in Orange County for 13 years. 

• Vegetation control specialist and County arborist for Orange County for 21 years. 

• Founding member and past president of Trees Society in Orange County. 

• Founding member and past president of Pesticide Applicators Professional Assoc. 

• ISA certified Arborist, Pest Control Advisor, Qualified Applicator license, C-24 Landscape license 

• USMC platoon Sgt. Viet Nam era. 

My observations about Arundo: 

• I have video footage of Arundo donax stands in 1938 in Santa Ana River. 

• I have personal knowledge that Arundo was introduced for flood control by region farmers and 

it was plowed when the cane became large. 

• Arundo produces no viable seed in the Orange County region. 

• Arundo is only reproduced by asexual cuttings of the root and outer edge stems of the clump. 

• Arundo does not send out a 'runner' from the root clump. It forms a nodule on the root clump. 

• Arundo will not grow in deep water. It grows at water edges and in alluvial deposits in arroyo 

riparian settings. 

• Arundo will not grow without an ample supply of water. 

• Arundo has no insect attacks or diseases in the Orange County region. 

• Arundo occupied large areas of riparian habitat in Santa Ana River because it was planted and 

then dispersed by plowing in an alluvial plain with a tremendous supply of nitrogen fertilizer 

from the dairy farms in Chino basin. 

• Once controlled reintroduction is slow, native plants reclaim the habitat, and small clumps of 

Arundo can come back in only after a disturbance (flood scouring action). Vigilant control of 

those small clumps prevents reinvasion.
• I can show you a large area that has been recovered and is still under control from the Prado 

dam to the Pacific Ocean in the Santa Ana River. 

• The endangered bird species 'Least Bell's Vireo' has increased from 2 nesting pairs to over 146 


nesting pairs since Arundo was controlled. That species has benefited from the removal. 

• I am currently working today to remove Arundo from yet another watershed in Orange County. 

• My original vision was to remove all Arundo from Orange County property in the Santa Ana and 

San Juan rivers. That goal is now 99.5 % complete. 

• My vision has now expanded to remove all the Arundo from all watersheds in Orange County, 

California, and the entire United States. This is doable. I can show you how. It's already been 

done. I have done it and it has been replicated by others. 

• The biomass from Arundo is larger than any other terrestrial plant known. The removed 

biomass can be utilized for multiple purposes. 

• Biomass for paper and building materials will reduce the pressure on today's old growth forest 


and allow that habitat type to remain intact for endangered species such as the Spotted Owl. 

• Biomass for energy will reduce the CO2 increase currently being added daily by the use of fossil 

fuels. Arundo is carbon neutral and is in balance the atmosphere of today. This fuel will take 

the form of a coal substitute, ethanol production increase, biodiesel, and gasoline. This will 

directly affect energy independence of the United States. 

• Arundo for pharmaceuticals to produce organic insecticides to protect food crops without 

damaging other ecosystems. 

• Arundo is controllable in a crop situation just as sugar cane, corn or wheat. All are grass species 

and are of benefit to humans. Arundo has many uses and will be a paradigm shift in favor of the 

environment while preserving our current and future lifestyle. 

• I teach and live an environmental ethic. This plant can solve many of the problems we face 

today. My students we recognized from my environmental internship for putting in more than 

60, 000 hours of time in the Orange County regional Parks. That time was used for habitat 

restoration and Arundo removal. I talk the talk and walk the walk. If I thought for one moment 

that Arundo was uncontrollable in an agricultural crop setting I would be the first in line to kill it. 

Wait I was the first in line to kill it! I also know it has been and can be controlled. I see the big 

picture. This more than just helping out the 'Least Bell's Vireo'. This can work for the whole 

Earth. I see it. I hope others can too. 

Please call me at 949-533-2117 if you would like to talk or visit the recovered site. B t
$iOMAS OLUT*ONS WC. 

TO WHOM IT MAY CONCERN: 

This letter is in response to the claims that planting Arundo donax ("Arundo ", commercially for biofuel 

and other uses poses a significant risk of spreading as occurred in California and Texas. Over the last 7 years we 

have intensely surveyed available information to uncover reliable, scientific and substantiated facts to base our 

conclusion that Arundo is not invasive. Any other rhizome based plant handled in a manner similar to Arundo 

would result in similar instances of invasiveness. The risks described extensively over the internet and in various 

publications focus exclusively on nparian areas. Commercial enterprises cultivated Arundo for decades without 

incident. Right in California, the epicenter of invasiveness information regarding Arundo, Rico Reed's 80 acre 

commercial Arundo plantation was not plagued by escaping plants for over 50 years. Many who have actually 

grown and studied Arundo across the globe and in various US states clearly verify that Arundo is biologically 

incapable of aggressive spreading when planted in appropriate locations and employing a minimum of crop 

hygiene. Arundo did not invade California it was inadvertently propagated. 

This crop has the potential to provide energy needed by all the biotechnologies we rely on to defeat global 

warming and our dependence on fossil energy. Based on a complicated series of circumstances and reliance on 

recycled, narrow and incomplete misinformation the use of the only economically viable biomass crop available 

is in jeopardy. Before you take any action to block this rule I implore you to consider the following: 

Incomplete, outdated, misinformation dominate internet - Unfortunately the well-documented reports" of 

invasiveness all seem to be part of a closed loop of recycled information quoted from one source to another and 

back again. Government, quasi-government and reputable environmental sites lend credibility to reports found in 

their materials and on public information websites. While a portion of the information is accurate it does not tell 

the whole story. When Arundo was primarily used for erosion control, windbreaks and landscape ornamentation, 

the stakes were not high enough to expend the effort to correct the misperception as aggressively invasive. 

The most visible information on Arundo does not describe Arundo 's normal naturalization when planted and 

managed in appropriate locations. Arundo 's reputation as an aggressively invasive species is based on studies 

exclusively focused on riparian habitats where human "cultivation" and "mismanagement" created the problem. 

Arundo is incapable of spreading due to its sterile nature, dense clumping and slow rhizome expansion. 

The internet is flooded with information on the damage Arundo causes 'once established." What is either left out 

entirely or its impact minimized are adequate references to just how it got "established" in the first place. Studies 

going back decades by respected scientists verify that Arundo is now and has been commercially cultivated for 

decades without incident. It is hard to understand why this information is not considered when evaluating the risk 

Arundo actually poses. Delete riparian, riverbanks, rivers, streams from invasive reports and see what is left of 

the risk. 

How California inadvertently created such a problem. After use for erosion control without incident for 

hundreds and hundreds of years Californians changed how they interacted with the Arundo planted along 

waterways, and in riparian areas to stem erosion. With the objective of widening canals to accommodate 

increased flows the Army Corp of Engineers used bulldozers to knock stalks down, drove over them embedding 

them in mud while pushing chopped pieces into the river as they widened the canals.
Presumptions rather than facts have driven the creation of the problem and impeded efforts to eradicate and 

control Arundo. The problem didn't arrive so much from misunderstanding the information on Arundo as it did 

from not understanding it in a changing context. This has resulted in making the problem worse in California. A 

multimillion dollar industry sprang up to eradicate Arundo. Government entities pay millions of dollars to 

purchase ineffective methods to eradicate Arundo although there are proven strategies that really work when 

applied appropriately. 

Commercially available as an ornamental plant in nurseries - Arundo is available for purchase as an 

ornamental plant in commercial nurseries across the US and has been for over 30 years. It has not spread as much 

as other species such as Kudzu which is frequently mentioned in reports on Arundo. Spanning several decades 

and across the globe you can easily find examples proving the ability to commercially grow, harvest and remove 

acres of Arundo without incident. 

Does not fit invasive definition in Executive Order 13112 - The available verifiable facts do not support 

defining Arundo as an invasive species under Executive Order 13112 or the Invasive Species Definition 

Clarification & Guidance White Paper. 

Passes the invasive species balancing test - Using the invasive species balance test set out in the above 

references Arundo 's benefits greatly exceed the ecological costs. Arundo meets or exceeds all of the 

characteristics of an ideal biomass crop described in the National Biofuel Plan. BPs recent abandonment of its 

biomass program illustrates the challenges. Arundo addresses the four fundamental criteria BP says are required 

for a biofuel: it is sustainable and scalable, it provides substantial carbon savings, and it is capable of becoming 

competitive with crude oil over time without dependence on subsidies. High Yields per acre make Arundo one of 

our best options as an economically feasible biomass crop. Without Arundo the likelihood of the US reaching its 

cellulosic and advanced biofuels goals using currently available biomass crops are dismal. 

Biomass feedstock for a wide variety of major industries - Unlike suspect species that provide little or no 

benefit Arundo has applications as a biomass feedstock for the pulp and paper, forage, composite materials, green 

coal, chemicals and green plastics industries with more coming as research continues. It is proving to be a 

versatile, environmentally friendly plant with properties that improve the environment on many fronts. New 

technologies provide growers a quick and economical method to propagate scalable quantities up to millions of 

acres. 

There is substantial information in existence today drawing from experienced growers, historical records and 

scientific fact based studies to conclude that it is against public policy to block A rundo. Arundo will prove to be 

one of the most environmentally significant plants on the planet. Several countries are far ahead of us in 

embracing Arundo and using it as a major biomass crop. Arundo is essential in any biofuel plan implemented to 

reduce energy dependency. Whether we get on board at the present time or not - we will eventually. 

For the sake of brevity and due to the short notice we did not include the references supporting the statements we 

make in this letter. We are happy to send them under separate cover if you are interested in reviewing them. 

Annette Mouton 

Corporate Counsel
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