December 13, 2012

TO: Lori Williams

Chris P. Dionigi

FROM: R. Timothy Columbus

David H. Fialkov

RE: Arundo Donax as a Feedstock under the RFS

INTRODUCTION

This memorandum discusses the best management practices Chemtex will follow in utilizing 

Arundo donax as a feedstock for its cellulosic ethanol plant in North Carolina. These practices 

derive from the State of North Carolina’s Voluntary Best Management Practices for Energy 

Crops,1(hereafter referred to as “N.C. Best Practices”) by which Chemtex abides and the 

relevant provisions of which Chemtex incorporates into its contracts with growers. 

Specifically, this memo illustrates the consistency between Chemtex’s practices and the Invasive 

Species Advisory Committee’s (“ISAC”) nine recommendations to reduce the risk of invasive 

species introduction and spread, as contained in its August 11, 2009 white paper, Biofuels: 

Cultivating Energy, not Invasive Species. ISAC’s recommendations are intended to be a “basis 

for standards of operation” regarding invasive species when the federal government engages with 

the private sector and other partners. Below, we address how Chemtex’s practices and the N.C. 

Best Practices comply with ISAC’s nine recommendations. Further, we show that the N.C. Best 

Practices supplement the white paper with additional requirements pertaining to transportation 

and storage.

 

1 North Carolina Department of Agriculture and Consumer Services, Voluntary Best Management Practices for 

Energy Crops: Minimizing the Risk of Invasiveness (“N.C. Best Practices”). See Tab 1.

R. Timothy Columbus

202 429 6222

tcolumbus@steptoe.com

1330 Connecticut Avenue, NW

Washington, DC 20036-1795

202 429 3000 main

www.steptoe.com
-2-

We applaud the Invasive Species Council for fulfilling its obligation to ensure Federal agency 

activities concerning invasive species are coordinated, cost-efficient, and effective.2 It is 

Chemtex’s hope and desire that the consistency between its approach and ISAC’s 

recommendations will facilitate a prompt resolution to the bureaucratic delay preventing 

Chemtex from beginning its work.

ISAC’S RECOMMENDATIONS AND N.C. BEST PRACTICES

Recommendation #1: Identify Federal authorities relevant to biofuels. Determine their likely 

influence on biofuel invasiveness (i.e., prevention or facilitation). Identify gaps and 

inconsistencies in authorities within and among Federal Departments or Agencies. As 

appropriate, develop policies and programs to minimize invasion risk.

N.C. Best Practices—itself a program to minimize invasion risk—shares the sentiment 

embedded in ISAC’s first Recommendation, and obligates all growers and landowners to 

“identify whether any prohibitions or regulatory restrictions exist for the species in question” and 

forbids planting crops when doing so is inconsistent with Federal law.3 Thus, both N.C. Best 

Practices and ISAC advise that the first step in minimizing the risk of invasiveness is to review 

existing authorities and determine their impact on the planting of any energy crop. 

In addition, Chemtex itself has completed a review of federal authorities relevant to biofuels and 

is unaware of any federal requirements pertaining to Arundo donax. We have identified three 

federal agencies interested in the crop’s potential—EPA, Interior, and USDA—and are working 

with them to address any concerns they may have. Chemtex also identified state agencies in 

North Carolina interested in Arundo donax and worked with them to develop protocols and best 

practices, including:

 The North Carolina Farm Bureau;

 The North Carolina Department of Agriculture and Consumer Service;

 The North Carolina State University Extension Service;

 The Nature Conservancy of North Carolina; and

 The Wildlife Federation of North Carolina.

Recommendation #2: In order to determine potential biofuel benefits and risks, the invasive 

potential of each candidate biofuel crop needs to be evaluated in the context of each region 

proposed for its production. Use/promote species (including unique genotypes) that are not 

currently invasive and are unlikely to become invasive in the target region. Choose species or 

cultivars with a low potential for escape, establishment and negative impact. Where 

appropriate, implement mitigation strategies and plans to minimize escape and other risks. 

This recommendation is really two different recommendations consolidated into one: 

 

2 Executive Order 13112, Sec. 4(a). See Tab 2.

3 N.C. Best Practices #1. 
-3-

(i) Evaluate each candidate biofuel crop in the context of the region proposed for its 

production and only use/promote species that are not likely to become invasive in that

region.

The N.C. Best Practices requires growers and landowners to educate themselves about the 

energy crop and determine whether its planting is appropriate for a specific region. “After 

checking on the plant in question, the grower can then make an informed decision as to whether 

that particular plant is well suited to be planted in the region in question.”4

Chemtex evaluated Arundo donax in the context of eastern North Carolina. A Chemtex 

agronomic team evaluated the state of North Carolina based on soil and climatic conditions and 

estimated the average conservative yield of Arundo within a 35 mile radius of the proposed 

biorefinery would be 15-16 bone dry tons (“bdt”) per acre (as opposed to 20 bdt found in other

climates). Because Arundo’s seeds are non-fertile, and because our farmers will shred the 

biomass in the field at harvest (eliminating viable propagation material), accidental spread is 

particularly unlikely in this setting. 

Arundo donax poses a risk of invasiveness when it is planted in a riparian area. The literature 

and experience on this matter is clear. However, it is equally clear that Arundo poses a minimal 

risk of invasiveness when it is planted far away from riparian areas. Chemtex reached this 

conclusion after evaluating the crop in the context of eastern North Carolina. The most respected 

academics in the field were asked to comment specifically on the effectiveness of the N.C. Best 

Practices (which were naturally designed in the context of North Carolina), and the consensus 

was agreement that the crop could be safely grown utilizing the practices called for in that 

document. 

Professor David Bransby of Auburn University summarized his 14 years’ experience 

researching Arundo by saying:

It is true that [Arundo donax] has colonized riparian areas 

along the Rio Grande and Southern California. However, 

this is due to the total lack of management, and the fact that 

these watersheds are very different from those in the 

eastern United States. In particular, they are essentially in 

desert regions where the native vegetation is not 

competitive, and the rivers in question flood for a few 

months each year, seriously excavating their banks, and 

then subside to no more than a trickle for the rest of the 

year....In contrast, our rivers in the eastern United States 

are perennial, with a steady flow of water year-round, and 

are lined with highly competitive woody vegetation. 

Therefore, even though [Arundo donax] has been widely 

grown...in the eastern United States for well over a 

 

4 N.C. Best Practices #2.
-4-

century, there is absolutely no evidence at all of it 

becoming invasive in this region.5

Professor Barry Flinn, Director of the Institute for Sustainable and Renewable Resources at 

Virginia Tech University is currently studying Arundo and agreed that “concerns expressed 

about invasiveness, while relevant for riparian zones, are over stated for other sites.” 

Summarizing his literature review of Arundo’s invasiveness, Professor Flinn said:

Arundo donax shows a widely reported lack of seed and 

seedling production....Hence, inability to produce seeds 

represents a significant inhibitory mechanism to plant 

dispersion, and is not a contributing factor to the spread of 

the plant in the natural habitat. This is a positive trait for 

[Arundo donax], unlike other described weedy invasives. 

In a study of Arundo donax spreading inside and outside of 

flood zones, [one scholar] indicated that movement via 

fragmentation, rhizomes and layering occurred in the flood 

zone. However, it was also noted that in drier sites outside 

the flood zone, Arundo spreading was less dynamic, with 

slow expansion and similar stand appearances from year to 

year. These results further suggest that the invasive 

characteristic is dependent on site, and if careful selections 

are made to avoid riparian zones, and sites are managed, 

invasiveness can be avoided.6

Finally, Jacob Barney, Professor of Invasive Plant Ecology at Virginia Tech, agrees with his 

colleague Dr. Flinn. In summarizing his views on Arundo’s invasiveness, Professor Barney—

whose work was cited in a recent letter from scientists concerned about Arundo’s purported 

invasiveness—said: 

[W]hile I fully recognize the dramatic Arundo invasions in 

California and Texas, and the consequences on native 

species and ecosystem properties, it should not be assumed 

that Arundo will become invasive in all circumstances and 

locations. Nearly all research on Arundo has been 

conducted in California and Texas....The intentional 

planting of Arundo along riparian corridors was also likely 

its downfall, which should not be the case for bioenergy 

predication.7

 

5 Bransby, David I., Ph.D., Professor, Energy Crops and Bioenergy, Auburn University. November 20, 2012 

(emphasis in original). See Tab 3.

6

Flinn, Barry, Ph.D., Director, Institute for Sustainable and Renewable Resources, Institute for Advanced Learning 

and Research, Danville, VA. February 11, 2012. See Tab 4.

7 Barney, Jacob, Ph.D., Assistant Professor of Invasive Plant Ecology, Department of Plant Pathology, Physiology 

and Weed Science, Virginia Tech University. February 12, 2012. See Tab 5.
-5-

Chemtex has worked in conjunction with the state of North Carolina in evaluating Arundo donax 

in the context of eastern North Carolina where Chemtex proposes to plant Arundo as a feedstock 

for its biorefinery. The results are clear and unmistakable: Because it is not near a riparian area, 

Arundo donax poses very little risk of invasiveness. Chemtex and the state-funded North 

Carolina Biofuels center have worked together to plant a 100 acre nursery of Arundo for use in 

commercial scale propagation. The two organizations’ independent research brought them to the 

same conclusion concerning Arundo’s potential for farmers in North Carolina.

This low risk of invasiveness is especially true in Chemtex’s case. Chemtex chose Arundo not 

only because it is the best source of biomass we could identify for producing advanced biofuels, 

but because it lends itself to being harvested in a manner that minimizes the already small risk of 

invasiveness. It has infertile seeds, and its rhizomes do not generate long underground runner 

systems typical of inherently invasive plants. Instead, Arundo’s rhizomes tend to be no more 

than 18 inches, and if left undisturbed in a non-riparian area, Arundo is unlikely to spread more 

than one foot beyond its original location.

Further, Chemtex contractually requires its farmers to minimize this already small risk of 

invasiveness: Farmers may not grow or transport Arundo near a river or stream; they must fieldchop the plant, thereby rendering everything that is removed from the field non-viable. (This is 

the opposite of what occurred in California, where Arundo—including cane and rhizomes—was 

bulldozed into the rivers.) Utilizing a direct field chop harvest, the soil is never disturbed more 

than once every ten-twenty years for replanting, and reeds are shredded to eliminate viability. 

Arungo will be harvested one foot above the ground, to minimize tire damage as well as to 

ascertain that the rhizomes stay safely embedded in the soil to be the source of the next year’s 

crop and the following ten to twenty years’ crop.

(ii). Where appropriate, implement mitigation strategies and plans to minimize escape 

and other risks. 

The N.C. Best Practices mandates harvesting methods that “eliminate or reduce viable 

propagules”

8

and “reduce propagule dispersal and establishment.”9 Toward that end, Chemtex 

will abide by the guidelines contained in that document to minimize escape, including:

 All planting, harvesting, and transport vehicles will be cleaned of all plant 

material prior to moving off site;10

 If viable seeds are produced, harvesting/baling methods (such as wrapping 

bales) will be used to reduce propagule spread;11

 If stem fragments are known propagule sources, harvest practices will 

reduce/eliminate propagule viability, e.g., shredding above-ground material to 

kill stem buds;12

 Human access to the field will be controlled;13 and

 

8 N.C. Best Practices #3. 

9 N.C. Best Practices #2.

10 N.C. Best Practices #3.

11 Id. Of course, Arundo does not produce viable seeds, so this requirement is not directly applicable to Chemtex.

12 Id.
-6-

 Field boundaries, buffer areas, and adjacent areas will be inspected regularly 

for propagules/seedlings.14

Further, Chemtex complies with the U.S. Forest Service eradication protocol, which has been 

shown to be 100% effective.15 In fact, we go beyond this protocol: When plants are no longer a 

productive source of biomass, we will remove the rhizomes from the field and dispose of them 

properly. 

All of this is done despite the fact that the Arundo’s risk of invasiveness when harvested in a 

non-riparian area is already minimal. Its seeds are infertile and its rhizomes are not long. Above 

and beyond the N.C. Best Practices noted above, Chemtex contractually requires its farmers to 

grow and transport Arundo far away from a river or stream; they must field-chop the plant 

thereby rendering everything that is removed from the field non-viable. The field will be 

surrounded by a buffer zone of native grasses and weeds against which Arundo does not compete 

effectively. Under Chemtex’s approach, the soil does not get disturbed more than once every ten 

to twenty years for replanting. 

The N.C. Best Practices require mitigation strategies and plans to minimize escape and other 

risks. Despite the already small risk of invasiveness, Chemtex will go above-and-beyond these 

strategies to ensure the crop does not spread. Annual inspections of growers will be performed 

in cultivated stands while native stands of Arundo will be documented. Signs of spreading will 

be sought outside of the fields in adjacent waterways and byways to and from the biorefinery.

Recommendation #3: Ideally, biofuel crops should be propagated in containable systems (e.g., 

terrestrial or aquatic sites constructed specifically to cultivate biofuel crops) and be unable to 

survive outside of cultivation. Use research findings to identify the most appropriate sites (e.g., 

unable to impact sensitive habitat or create disturbances that will foster invasion) for cultivation 

of biofuel crops within landscapes. Support for biofuel research and demonstration projects will 

require site selection that minimizes the potential escape of plant species or cultivars to sensitive 

areas and the loss of wildlife habitat.

Consistent with ISAC’s Recommendations, Chemtex was required by the N.C. Best Practices to 

ensure not only that the region (i.e., eastern North Carolina) is suitable to Arundo donax, but the 

specific site (i.e., the farmland near the proposed biorefinery location) as well. Thus, the N.C. 

Best Practices required Chemtex to choose a site wherein the production field “not be located 

directly adjacent to major dispersal corridors, such as streams, irrigation canals, major roads, or 

utility right of ways.”

16

 In addition, storage sites are required to be “placed in locations not 

adjacent to sensitive habitats.”17

 

13 N.C. Best Practices #2.

14 Id.

15 An investigation to test the effectiveness of glyphosate for control of Arundo was conducted in southern 

California by Caltrans, the state transportation agency. Results indicate that cut-stem treatments, regardless of time 

of application (May, July, or September), provided 100% control with no resprouting. See

http://www.fs.fed.us/database/feis/plants/graminoid/arudon/all.html#MANAGEMENT. 

16 N.C. Best Practices #2.

17 N.C. Best Practices #5. 
-7-

Chemtex has done precisely what is called for in ISAC’s third Recommendation. We worked to 

identify a site that whereby our work will not impact sensitive habitat or create disturbances that 

will foster invasion. The field will be surrounded by native competing plants against which 

Arundo does not compete well. It will not be located—and Arundo material will not be 

transported—near a river or stream or other riparian area. As described above, research 

demonstrates that when Arundo is grown in non-riparian areas, the potential for escape is 

minimal. Research findings lead to the unmistakable conclusion that our site location, combined 

with Arundo’s inherent characteristics and the steps we require our farmers to follow, minimizes 

the risk of invasiveness. 

Recommendation #4: Incorporate desirable traits (e.g., sterility or reduced seed production, 

inability to regenerate by stem fragments) into biofuel varieties to minimize their potential for 

invasiveness. Use information from plant research, agronomic models, and risk analyses to 

guide breeding, genetic engineering, and variety selection programs.

Because the seeds from Arundo donax are sterile, work in this area has been completed by 

nature. Although sterile seed is desirable from a biomass standpoint, it makes breeding programs 

difficult. Only genetic modification (by gene manipulation) of Arundo can be used to instill new 

traits. (Research programs are only now starting along these lines.) In addition, because of 

Arundo’s ability to stand in the field, regardless of the weather patterns, it lends itself to 

minimizing invasiveness because it is not making any contact with the ground (i.e., we have 

evidence that Arundo will not fall over or lodge during a hurricane). Despite all this, our farmers 

are required to follow rigorous steps to minimize the risk of invasiveness: they must grow and 

transport Arundo far away from a river or stream; they must field-chop the plant thereby 

rendering everything that is removed from the field non-viable. The field will be surrounded by 

berm with which Arundo does not compete effectively. Under Chemtex’s approach, the soil 

does not get disturbed more than once every ten to twenty years for replanting. 

Arundo’s inherent traits are desirable so as to enable Chemtex to minimize its potential for 

invasiveness. We have used information from plant research and risk analyses to substantiate 

this conclusion.

Recommendation #5: Develop and coordinate dispersal mitigation protocols prior to 

cultivation of biofuel plants in each region or ecosystem of consideration. Implement a 

comprehensive plan, appropriate to the specific crop, throughout the cultivation period. 

Examples of dispersal mitigation measures include the use of sterile cultivars, species not likely 

to genetically mix with other plants (different species or cultivars), harvesting prior to seed

maturity, cleaning equipment, and minimizing propagule dispersal throughout the biofuel 

production cycle.

The N.C. Best Practices contain a number of requirements designed to minimize dispersal. For 

example, in those instances where viable seeds are produced (which is not the case with 

Arundo), it requires that measures be taken to “minimize their dispersal, such as choosing lateflowering cultivars or harvesting prior to seed maturation,”

18 and harvesting/baling methods be 

 

18 N.C. Best Practices #2.
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utilized in order to reduce propagule spread (e.g., wrapping bales).19 Additionally, it requires 

that barriers (e.g., slit fences or berms) be installed down slope of production fields in order to 

intercept crop fragments such as inflorescences or stems if the field is slope >5%. 20

The N.C. Best Practices also require all planting, harvesting, and transport vehicles and 

equipment be “cleaned...of all plant material prior to moving off site.”

21

 Additionally, if stem 

fragments are known propagule sources, harvest practices should reduce/eliminate propagule 

viability (e.g., shredding above-ground material to kill stem buds).22

The fact that Chemtex is not planting a crop that will reproduce via seed eliminates great risk. 

By ensuring that we don’t have viable materials, we are inherently limiting the risk that 

Recommendation #5 seeks to minimize. Chemtex chose Arundo not only because it is the best 

source of biomass we could identify for producing advanced biofuels, but because it lends itself 

to being harvested in a manner that minimizes the already small risk of invasiveness. It has 

infertile seeds, and its rhizomes do not generate long strands typical of inherently invasive plants. 

Instead, Arundo’s rhizomes tend to be no more than 18 inches, and if left undisturbed in a nonriparian area, Arundo is unlikely to spread more than one foot beyond its original location. 

Further, Chemtex contractually requires its farmers to take a number of measures to minimize 

this already small risk of invasiveness, while subjecting them to regular inspection and 

verification. Farmers may not grow or transport Arundo near a river or stream; they must fieldchop the plant thereby rendering everything that is removed from the field non-viable. This is 

the opposite of what occurred in California, where Arundo was bulldozed into the waterways. 

Under Chemtex’s approach, the soil does not get disturbed more than once every ten to twenty 

years for replanting. Arundo will be harvested one foot above the ground, so that which gives

life (and by which it is propagated) is not disturbed.

In reality, Chemtex is using a crop where the risk of invasion is minimal, but is operating as 

though the risk were great. Even though science and experience suggests there is little to worry 

about regarding Arundo’s invasiveness in eastern North Carolina, we are making sure it is 

harvested in a manner that renders it non-viable once it is removed from the field, and 

transported in a manner that eliminates the chances of unintentional spread.

Recommendation #6: Proactively develop multiple year eradication protocols to plan for the 

rapid removal of biofuel crops if they disperse into surrounding areas or become abandoned or 

unwanted populations (e.g., those which persist beyond desired crop rotation period).

Consistent with the N.C. Best Practices, Chemtex must prepare an “eradication plan...prior to 

planting that provides treatment recommendations and procedures that are followed after 

confirmation of escapes or abandonment of the field.”23

 

19 N.C. Best Practices #3.

20 N.C. Best Practices #2. 

21 N.C. Best Practices #3.

22 Id.

23 N.C. Best Practices #2.
-9-

Chemtex complies with the U.S. Forest Service eradication protocol, which is considered 100% 

effective.24 In fact, we go beyond this protocol by picking up the rhizomes we cut off in the field 

and properly disposing of them. 

All of this is done despite the fact that the Arundo’s risk of invasiveness when harvested in a 

non-riparian area is already minimal. Even if Arundo’s seeds are “dispersed into surrounding 

areas,” by the time they are removed from the field the material is non-viable. Arundo’s seeds 

are infertile and its rhizomes are relatively short. Above and beyond the N.C. Best Practices 

noted above, Chemtex contractually requires its farmers to grow and transport Arundo far away 

from a river or stream; they must field-chop the plant thereby rendering everything that is 

removed from the field non-viable. Under Chemtex’s approach, the soil does not get disturbed 

more than once every ten years to twenty years for replanting. 

Not only did Chemtex consciously choose a crop as its feedstock where the risk of invasiveness 

is minimal, but we have also developed effective eradication protocols to plan for the unlikely 

event that Arundo disperses into surrounding areas.

Recommendation #7: Develop Early Detection and Rapid Response (“EDRR”) plans that cover 

multiple years to eliminate or prevent establishment and spread of escaped invasive populations. 

A flexible funding source needs to be in place to support EDRR efforts.

Pursuant to the N.C. Best Practices, we will regularly inspect field boundaries, buffer areas, and 

adjacent areas for propagules and/or seedlings.25 This is in addition to the mandatory eradication 

plan providing treatment recommendations and procedures to be followed after confirmation of 

escapes.

26 As noted above, Chemtex also complies with the U.S. Forest Service eradication 

protocol, which is considered 100% effective.27 We even go beyond this protocol: when plants 

are no longer a productive source of biomass, we will remove the rhizomes from the field and 

dispose of them properly. 

To enhance our ability to detect unwanted spread, Chemtex established paths the trucks 

transporting the material must always traverse. This not only facilitates efficient inspection of 

the surrounding areas, but ensures the material does not ever go near streams or ponds (as we 

accounted for this in designing the transport route). We are also documenting pre-existing

strands of Arundo that are already growing naturally in North Carolina separate and apart from 

our cultivation. These have been there since the early 1800s without making their presence 

widely known. The control inherent to a spray field—a targeted planting area—will enhance our 

ability to recognize escaped populations and distinguish them from natural strands. This is all in 

addition to the fact that Chemtex intentionally chose a plant and site where the risk of 

invasiveness is already minimal. 

As far as a flexible source of funding, the N.C. Best Practices do not contain such a requirement. 

However, Chemtex is currently in the process of working with the state to create a fund and 

 

24 See supra n.15.

25 Id.

26 Id.

27 See supra n.15.
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monetize it in an effective manner to address escaped populations if necessary. Planting will not 

begin until this fund is established. However, small, widely dispersed populations of Arundo 

which have been present for many years must also be documented. Chemtex would have no 

objections to legally requiring the fund’s establishment as a prerequisite to beginning work. 

Recommendation #8: Disturbed environments are especially prone to plant invasion. Minimize 

the soil disturbance resulting from biofuel harvest by rapidly replanting, using cover crops, or 

employing other methods that will prevent the potential for future invasion of non-native plants 

from the surrounding areas into the harvested site.

In order to minimize plant invasion, the N.C. Best Practices require Chemtex to “establish a 

buffer area surrounding the production field of 20 feet, which should be maintained with a 

perennial cover (e.g., legumes, bermudagrass, tall fescue).” In addition, Chemtex is ensuring that 

Arundo will not be grown or planted in riparian areas. That is the only environment in which it 

is invasive. Every ton of biomass Chemtex purchases is traceable; the company can monitor 

growers to make sure they are observing best practices. This includes things like cutting reeds in 

the field to the point where they are not viable, keeping away from rivers, and washing transport 

vehicles’ tires when they leave spray fields. 

The fields will be surrounded by buffer strips of native species against which Arundo does not 

compete effectively to eliminate spreading and ease inspection of field border integrity. As 

described above, research demonstrates that when Arundo is grown in non-riparian areas, the 

potential for escape is minimal. Our site location, combined with Arundo’s inherent 

characteristics and the steps we require our farmers to follow, further minimizes the risk of 

invasiveness. 

Recommendation #9: Identify and employ cooperative networks (e.g., working groups and 

councils), communication forums, and consultation processes through which Federal agencies 

can work with state agencies, tribes, the private sector, and other stakeholders to reduce the risk 

of biological invasion via the biofuels pathway.

The N.C. Best Practices are a product of the very type of process envisioned in this 

recommendation. It was a collaborative effort by three agencies: The North Carolina 

Department of Agriculture and Consumer Services; The North Carolina State Extension Service; 

and the North Carolina BioFuels Center in collaboration with well-known invasiveness expert, 

Dr. Jacob Barney of Virginia Tech University. The North Carolina Farm Bureau and the Nature 

Conservancy of North Carolina were included in the process, ensuring multiple voices were 

heard.

ADDITIONAL REQUIREMENTS IN N.C. BEST PRACTICES

Beyond those requirements noted above that align with ISAC’s recommendations, the N.C. Best 

Practices contain a number of additional components that supplement ISAC’s white paper. Most 

notably, the N.C. Best Practices contain explicit requirements regarding transportation and 

storage that the white paper does not directly address.
-11-

Transportation – The N.C. Best Practices note that land along the route from the harvested fields 

to the bioenergy facility may be susceptible to inadvertent escapes. As such, Chemtex will be 

required to transport feedstock material “in a manner that reduces unintentional propagule loss:

 Trucks and trailers should be covered;

 Routes that minimize crossing of highly sensitive habitats (e.g., riparian 

areas) should be utilized; and

 Right of way along transport routes should be visually inspected to ensure 

no escapes.”

Chemtex will ensure that all trucks and trailers transporting Arundo will be cleaned of all 

planting material prior to leaving the fields and covered to prevent the material from exiting the 

traveling vehicle. Further, Chemtex established paths the trucks transporting the material must 

always traverse. This not only facilitates efficient inspection of the surrounding areas, but 

ensures the material does not ever go near streams or ponds (as we accounted for this in 

designing the transport route). 

Storage – The N.C. Best Practices treats storage sites as being “analogous” to production fields 

in serving as a stationary source of propagules, and thus requires:

 Storage sites be placed in locations not adjacent to sensitive habitats;

 Storage sites be inspected on a regular schedule for seedlings; and

 Stored plant material be covered.

Of course, Chemtex is targeting the Arundo portion of the supply chain to be direct chopped in 

the field and does not anticipate storing Arundo beyond run inventory, minimizing storage as a 

potential invasive risk. As the biomass is the targeted raw material, all plant material will be 

utilized as feed in the process once it leaves the field. Chemtex chose Arundo not only because it 

is the best source of biomass we could identify for producing advanced biofuels, but because it 

lends itself to being harvested in a manner that minimizes the already small risk of invasiveness. 

CONCLUSION

The N.C. Best Practices propose feasible practices for the commercial cultivation of Arundo 

donax as a biofuel crop. “These practices minimize the chance of Arundo donax escaping from 

cultivated plantings.”28 The program in fact is very similar to risk management procedures in 

Australia29 that when followed, have been shown to result in minimal risk of invasiveness.30 Of 

course, to the extent that its plan to minimize invasiveness can be reasonably improved to 

account for additional potential risks, Chemtex would support such additions, as the company’s 

desire to minimize the risk of invasiveness is second to none. Indeed, Chemtex has proposed a 

 

28 Barker, David, Associate Professor of Grassland Ecology, Department of Horticulture and Crop Science, The 

Ohio State University, February 9, 2012. See Tab #5.

29 Virtue, John, Ph.D. Manager – NRM Biosecurity, Adelaide, South Australia, Presentation, Australian Weeds 

Conference. See Tab #6.

30 Virtue, John, Ph.D. Manager – NRM Biosecurity, Adelaide, South Australia, October 15, 2012. See Tab #7.
-12-

scheduled evaluation of the effectiveness of these measures be scheduled at after five and ten 

years to identify beneficial procedural changes based on experience.

In the end, The N.C. Best Practices is exactly what the ISAC white paper encourages. Under 

Executive Order 13112, the Invasive Species Council is charged with ensuring that Federal 

agency activities concerning invasive species are coordinated, complimentary, cost-efficient, and 

effective. Cultivation and processing of Arundo donax in conformity with those Best Practices 

will assure that the objectives of the Renewble Fuels Standard can be achieved in a manner 

which minimizes any risk of invasiveness, thereby assuring that the legitimate interests of all of 

concerned Federal agencies. We hope that this memorandum, by documenting that the analytical 

steps recommended by ISAC have been followed and that the appropriate control measures 

suggested by that analysis have been adopted, helps finalize this exhaustive effort as it pertains to 

Arundo donax and its use as a source of biomass for the purposes of the 

Renewable Fuels Standard.