101212_96_group_letter_to_omb-ab096405f800ba79.pdf

A group of environmental and scientific organizations argues against the EPA's proposal to include Arundo donax (giant reed) as an approved advanced biofuel feedstock. They cite the species' status as a high-risk invasive weed that threatens native vegetation and endangered species, noting that the high cost of eradication makes the ecological and economic risks outweigh the benefits of its cultivation under the Renewable Fuel Standard.

• Arundo donax is identified as a high-risk invasive species that can disrupt hydrology, nutrient cycling, and fire regimes, while displacing native vegetation and harming endangered species like the Least Bell’s Vireo.
• The plant is officially listed as a noxious weed in Texas, California, Colorado, and Nevada, and is considered a serious risk or invasive in New Mexico, Alabama, and South Carolina.
• Eradicating Arundo donax is costly and difficult; in California, eradication costs are estimated between $5,000 and $17,000 per acre, with some estimates reaching $25,000 per acre.
• The authors argue that providing incentives for Arundo donax under the Renewable Fuel Standard violates the spirit of Executive Order 13112, as the environmental and economic costs of invasion likely outweigh the benefits.

APA

Environmental and Energy Study Institute (2012). 101212_96_group_letter_to_omb-ab096405f800ba79.pdf. https://www.eesi.org/files/101212_96_Group_Letter_to_OMB.pdf

Chicago

Environmental and Energy Study Institute. 101212_96_group_letter_to_omb-ab096405f800ba79.pdf. 2012. https://www.eesi.org/files/101212_96_Group_Letter_to_OMB.pdf.

Wikipedia

{{cite press release |author=Environmental and Energy Study Institute |title=101212_96_group_letter_to_omb-ab096405f800ba79.pdf |date=4 October 2012 |url=https://www.eesi.org/files/101212_96_Group_Letter_to_OMB.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{environmentalandenergystudyinstitute201210121296grouplettertoombab096405f800ba79pdf, author = {{Environmental and Energy Study Institute}}, title = {{101212\_96\_group\_letter\_to\_omb-ab096405f800ba79.pdf}}, publisher = {Environmental and Energy Study Institute}, year = {2012}, month = oct, url = {https://www.eesi.org/files/101212_96_Group_Letter_to_OMB.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }