Virginia Regulatory Town Hall
Agency
Department of Agriculture and Consumer Services
 
Board
Department of Agriculture and Consumer Services
 
chapter
Regulations for Enforcement of the Noxious Weeds Law [2 VAC 5 ‑ 317]
Action Amend noxious weed list
Stage Proposed
Comment Period Ended on 12/8/2023
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12/8/23  2:58 pm
Commenter: Ben Adams

Counterbalance perspective
 

I would like to offer an alternative perspective on this topic.  I observe that all previous comments are highly in favor of the proposed list or would even like to expand it; and it is not my goal to start a quarrel (especially one I know I won't win!), but rather to add some context, inject some optimism, and push towards a more wholistic and symbiotic relationship with nature.  Thanks in advance for listening.  :)

  1. "Well-adapted" is a common descriptor of "noxious weeds," but I would like to view this as -- potentially -- a positive trait more than a negative one.  
  2. "Commercially viable" is a limited perspective which ignores other types of value.  I think every one of these listed species has specific uses and benefits -- here are a few examples I happen to know of:
    1. Autumn olive is a nitrogen-fixer which it improves the soil where it lives; the fruits are high in vitamin C, carotenoid antioxidants, and fiber.  Current species are of no commercial use, but they are very valuable to some folks, including me, who has learned to identify, forage, and freeze the fruits and include them in my diet.  They make a tasty fruit leather, a zippy addition to oatmeal, and a delightful soda -- and I would very much like to see what a good winemaker (not myself) could do with them.
    2. Japanese Knotweed is a crucial ingredient in a loved-one's management of chronic Lyme disease.  I don't forage this plant but I ought to learn how....  A few local wildcrafters in each locality could plausibly set up a business of harvesting the stuff and selling it to Lyme sufferers.  This would take effort but in the end would work towards solving multiple issues at once.  It is wildly medicinal and also apparently edible like rhubarb.
    3. Garlic mustard likewise is edible and highly nutritious and medicinal.  One expert speculates that its proliferation has less to do with its invasive nature and more to do with proliferation of deer due to the lack of large predators (which has also widened the vector for ticks... all of this is connected).  It also evidently thrives where conditions for native plants have declined.  (Which might be our fault more than the knotweed's.)
    4. Kudzu has serious potential medical applications in the treatment of alcoholism.
    5. English ivy leaf extract is a primary ingredient in certain OTC cough syrups, e.g. Zarbees.
    6. And practically every taprooted "weed" is doing hard work in hard soil, pulling valuable minerals up from deep down and composting them in leaf mulch at the surface.  (Dandelions thrive in compressed lawns, going through an inch of topsoil and down into nasty clay shale and such.  But they don't grow in forest loam.)
  3. Education is part of the way forward.  To the degree that we can learn to forage invasives, we derive food & medicine from them and (if we manage their seeds correctly) actually limit their self-propagation.  To the degree that we see the good in these plants and, through wise cross-breeding, select for desirable traits, we can make them less invasive, more productive, more tasty, and perhaps eventually even "commercially viable."

I could go on from my own knowledgebase, and with some additional research I could go a lot further.  But these examples should suffice to make the point.  And most of what I've said so far can probably be summarized in the old Emerson quote:

“What is a weed? A plant whose virtues have not yet been discovered.”
? Ralph Waldo Emerson

Emerson was naive in several respects, and I'm willing to allow that maybe I am too.  :)  But there is some wisdom in Emerson anyhow, which I think we should hear and heed.  There are virtues in these "weeds" which (as a general populace) we have not discovered: some of which might become "commercially viable," and others which are valuable in other, non-commercial ways.  

Now: nothing I've said above contradicts the idea that we should ban nurseries from selling items on the proposed list.  That may indeed be a very wise idea in some or all cases: I don't claim to know.  (Probably it's somewhat dangerous to sell anything to a person who doesn't know how to use it properly.)  But the language I've seen used here -- "noxious," "weed," "nuisance," "destructive," etc. -- exhibits a "man vs. nature" mentality that I think is unwise to embrace too tightly.  I certainly agree that many of these species are [currently] providing insufficient benefits, while creating costs.  I just think it's worth asking the questions: Do we primarily need to eradicate plants, or educate people? and Are the problems we observe coming from the plant itself, or from our (lack of) understanding, appreciation, and management of it?

Of course the ban under discussion is really just a management tool.  So that's fine as far as it goes.  But the plants are here, and they mostly cannot be eradicated (and probably making the attempt would be very expensive and not very effective).  So while banning sales may be a necessary immediate stopgap, I do not personally believe there is any long-term solution other than for us -- first as individuals, and then as a society -- to befriend these "weeds," learn their virtues, put them to use, improve them, reign them in, propagate them in specific ways and places, remove them from others, and, in short, do what God told Adam to do in the beginning: care for the Garden and keep it.  

Government cannot do that: it is up to the citizenry, each on their own little plot of land.  But I do hope the Board of Agriculture and Consumer Services can help shape the conversation in more helpful ways, and can open the door, through education and training, to guide the people of the Commonwealth in appreciating the "wealth we have in common" in our fields, forest, and wilderness -- natives, invasives, and all.

CommentID: 220802