As a Virginia nursery grower and wholesale supplier, I support efforts to protect Virginia's natural resources from plants that cause demonstrated ecological harm. However, I believe the implementation of these signage requirements should be based on sound science and should recognize meaningful differences among cultivars.

My primary concern is applying the same invasive designation and signage to cultivars that have been shown to be sterile or to have significantly reduced fertility compared with the species. If credible scientific evidence demonstrates that a particular cultivar does not present the same invasive risk, there should be a practical process for evaluating and exempting that cultivar rather than automatically treating all cultivars of a species the same.

I am also concerned about the practical effect these requirements will have throughout the nursery supply chain. Although the signage requirement applies at retail, Virginia growers and wholesalers have substantial investments in plant material that may take several years to produce. A required invasive label at the point of sale can significantly affect demand for that inventory. VDACS should consider these downstream economic impacts when implementing this guidance.

I encourage VDACS to work closely with Virginia growers, wholesalers, retailers, and researchers as this program is implemented and to provide a clear process for considering new scientific information regarding individual cultivars.

Thank you for the opportunity to comment.