Both tiers as proposed use the phrase “not widely disseminated in the commonwealth.” Ideally English Ivy would be on this list, but it is widely disseminated in the commonwealth. Does this mean all noxious weeds that are currently a severe problem cannot be added to this list? If so, this is more of an early detection and rapid response list and not a true noxious weeds species list. Therefore,a 3rd tier should be included:
"Tier 3 noxious weed" means any noxious weed that (i) is not native to the Commonwealth, (ii) is widely disseminated in the Commonwealth, (iii) for which successful localized suppression is possible but eradication is unlikely, and (iv) for which elimination of additional introductions and dispersal is a priority.
A list of invasive plant species for the state of Virginia can be found at the Virginia Department of Conservation & Recreation Division of Natural Heritage (DNH) website at http://www.dcr.virginia.gov/natural_heritage/documents/invlist.pdf All of these species need to be included at a minimum with additional, new species included as they are discovered. A great source for newly discovered noxious weeds is located at http://www.eddmaps.org/species/
There is no solid information included that adequately explains the economic impacts that could occur if this amendment is made. This needs to be addressed. The ecological health of our natural areas is being negatively impacted by many noxious weeds. The economic benefits provided by healthy, functioning ecosystems are immense and quantifying these benefits providese further justification for regulating these noxious weeds.
Who will be in charge of enforcement of this amendment? Proper enforcement will ensure that these harmful noxious weeds do not spread to new areas.
Who will be on the committee that implements a science-based assessment of possible plants for listing as noxious weeds? Experts in the field of noxious weeds and invasive species should be consulted to ensure proper listing of species.
