Again, as noted by all, thank you to VDACS for the opportunity to provide feedback on the Guidance Document.  As many others have noted, we, too, want science to drive how cultivars are treated.  If a plant is truly sterile (i.e. produces zero fertile seeds) and has no other means of spreading then that plant should be looked at as a candidate for exemption.  But the science also needs to show that the plant will not revert and produce fertile seeds under future circumstances.  Furthermore, there are serious questions about the implications of reduced fertility.  Reduced fertility does not necessarily mean that a plant will not be invasive.  The science needs to show that the plant will not be invasive, not just that it has reduced fertility.  We look forward to working with all the stakeholders to make sure that the environmental goals are achieved while minimizing any impacts on the industry.