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 survey ed available information to uncover reliable, scientific and substantiated facts to ba se our conclusion that Arundo is not invasive. Any other rhizome based plant handled in a manner similar to Arundo would resul t 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 Arund o plantation was not plagued by escaping plants for over 50 year s

. 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 misinfor mation 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, o utdated, m isinformation d ominate i nternet

- 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. G overnment

, q uasi

- government and reputable environmental sites lend credibility to reports found in their materials and on public information web sites

. 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 mis perception as aggressively invasive.

The most visible information on Arundo does not describe Arundo ’s normal naturalization when plant ed and

manag ed 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 i nternet is flooded with information on the damage Arundo causes "once established.” What is either left out entirely or its impact minimized are adequate reference s to just how it got “established” in the first place

. Studies

go ing back decades by respected scientists verif y 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 ripari an, riverbanks, rivers, streams from invasive reports and see what is left of the risk

.

How California i nadvertently c reated such a problem

. After use for erosion control without incident for hundreds and hundreds of years California ns 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 bulldozer s to knock stalks down

, dr ove over them embed ding them in mud while push ing 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 st rategies 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 K udzu 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 id eal 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 provide s substantial carbon savings, and it is capable of becoming competitive with crude oil over time without dependence on subsidies

. High Y ields per acre make Arundo one of our best option s as an economically feasible biomass crop

. Without Arundo the likelihood of the US reach ing 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 applica tions as a biomass feed stock 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 econom ical 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 Arund o

. Arundo will prove to b e one of the most environmentally significant plant s 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
reduc e energy dependency . W hether 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