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Old 01-11-2011, 10:35 PM   #23
northtexas55693
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Default Form Letter for TPWD Employees - From IWWGS

Send the following form letter from IWWGS to these two people:

< Earl.Chilton@tpwd.state.tx.us >
< Ken.Kurzawski@tpwd.state.tx.us >


September 12, 2010


I am writing to you to express my concerns over your Department’s approach to regulating HB3391, the new legislation on aquatic plants.

Texas grows and supplies many aquatic plants for the nation’s water gardeners. I am concerned that an overly restrictive white list will negatively impact my business as well as the companies in Texas I do business with; further, I see an overly restrictive list as a mistake that will unwittingly be copied by other states.

I say overly restrictive because I have seen the list of plants that have thus far failed your review process, and I do not think many of them belong on that black list, but belong on the white list instead. Several of them are primarily terrestrial in origin, and are not under your jurisdiction. Most have been in the state for a number of years with much evidence of economic benefit and little or no evidence of invasiveness so should not even be questioned.

What are the qualifications of your staff to use Pheloung’s Risk Assessment to rate all these plants? Also, what directions were they given in dealing with the risk assessment protocol? And why are the risk assessments then passed on to the Lady Bird Johnson Wildflower Center (and/or the Texas Invasive Plant & Pest Council, who use the same botanists) to have their botanists review the assessments? I understand they may be better qualified than your own staff, but a Wildflower Center botanist is inclined to a natural bias against exotics and toward natives—how can they be objective, whatever their intent? And apart from bias, how much experience do they have with exotics, and especially with aquatics? I also question the scientific and practical validity of Pheloung’s Risk Assessment model for aquatics in Texas, as modified for aquatic plants. Just one example of this is mosaic plant (Ludwigia sedioides). Even in Texas growers view it as an annual, one that water gardeners must replace in their pond every season--most professional aquatic growers have given up on it, as it can prove difficult even in heated greenhouses. Mosaic plant is a valuable, highly prized plant by many water gardeners and should be on the white list.

The Texas Legislature has directed the TPWD to balance the legitimate needs of businesses that sell aquatic plants with the need to prevent the introduction into Texas of aquatic plants that could cause environmental, economic, or health problems. The approved list would supposedly automatically include an exotic aquatic plant that was widespread in this state and was not a cause of environmental, economic, or health problems.

Please consider my concerns—your actions here will have significant and long-term effects on our hobby and our industry, both inside and outside the state of Texas.


Thank you
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