The Virginia Agribusiness Council appreciates the opportunity to comment on the proposed Guidance on Invasive Plant Species Signage Requirements at Retail Establishments. The Council represents agricultural businesses across Virginia, including nurseries and landscapers.

The Council supports responsible management of invasive plant species and providing consumers with accurate information. Additionally, we are thankful to VDACS for considering concerns from the public and professional trade associations regarding implementation of the proposed signage requirements.

Implementation of signage should be based on sound science and recognize meaningful differences among cultivars. The guidance currently requires cultivars and varieties of listed invasive species to meet the same signage requirements as the species itself. There are cultivars that have been demonstrated to be sterile or significantly less fertile than the underlying species and therefore may not present the same ecological risk. As new research comes to light regarding these plants, we encourage VDACS to take that information into account.

VDACS should consider the economic impacts throughout the nursery supply chain of signage requirements. Virginia growers and wholesalers make significant investments in plant material, often producing inventory years before it reaches the consumer. Reduced demand resulting from mandatory signage could affect the nursery economy well beyond the point of sale.

Thank you for considering these comments.

Sincerely,

Taylor Hubbard

Director of Government Affairs

Virginia Agribusiness Council