thank you for the opportunity to comment.  

I would encourage VDACS  to coordinate closely with the Department of Conservation and Recreation on the risk assessment protocol that the VNLA, Nature Conservancy and others requested of the Invasive Species Advisory group 2-3 years ago.

this protocol seems to adequately respond to our request to clarify the science and process of delineating plants as sometimes, moderately or frequently invasive by physiographic region in VA, and can and should be used co sistently throughout VA rather than a patchwork of local regulations based on local lists of plants developed in a less than scientific manner.

I would encourage VDACS to pursue a memorandum of understanding with DCR on a coordinated use of this protocol to nominate as noxious , e.g. Regulated weeds, and therefore targeted for control or eradication if or when they appear in VA.