101212_96_group_letter_to_omb-ab096405f800ba79.pdf

A group of environmental and conservation organizations wrote a letter to the Office of Management and Budget (OMB) opposing the EPA's proposal to approve Arundo donax (giant reed) as a qualified advanced biofuel feedstock under the Renewable Fuel Standard Program, citing significant ecological and economic risks.

• The undersigned organizations oppose the approval of Arundo donax (giant reed) as an advanced biofuel feedstock because it is a non-native, highly invasive species. A June 2012 USDA weed risk assessment identified it as a "high risk species" and a "serious environmental weed" capable of altering fire regimes, nutrient cycling, and hydrology in established areas.
• Arundo donax is listed as a noxious weed in Texas, California, Colorado, and Nevada, and is considered invasive or a serious risk in Alabama, New Mexico, and South Carolina. Its presence displaces native vegetation and harms endangered species, specifically the Least Bell’s Vireo.
• The eradication of Arundo donax is described as difficult and expensive. In California, the cost to eradicate the weed is estimated between $5,000 and $17,000 per acre, with some estimates reaching as high as $25,000 per acre.
• The authors argue that providing incentives for Arundo donax cultivation under the Renewable Fuel Standard would likely violate Executive Order 13112, as the environmental and economic costs of invasion would outweigh the benefits. They request a full cost-benefit assessment and, if approved, the implementation of stringent best management practices developed with the National Invasive Species Council.

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} }