November 19, 2012

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 riparian 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Incomplete, outdated, misinformation dominate internet - Unfortunately the “well-documented reports” of 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. BP’s 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 Arundo. 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.

Sincerely,

Annette Mouton 

Corporate Counsel