Maybe there could be a separate category for plants not on our own property. I can think of one person who took such fabulous photos in San Francisco, at the Palace of Fine Arts, and would hate to think they wouldn't be allowed. Others live in homes without gardens (condos, co-op's, apartments) and may only take photos in parks, nurseries, their children's homes, etc. that it would hardly be fair to tell them their photos do not qualify.
In the end, it's Dave & Trish's site and they get to make the rules.