November 5, 2010

Camelina: an Annual Cover Crop Under 40 CFR Part 80 Subpart M

In 40 CFR Part 80, Regulation of Fuels and Fuel Additives, EPA has designated applicable D codes for use 

in generating RINs dependent on feedstock and fuel pathway. Included as a feedstock are annual cover 

crops which are defined as:

“Annual cover crop means an annual crop, planted as a rotation between primary planted crops, or 

between trees and vines in orchards and vineyards, typically to protect soil from erosion and to improve 

the soil between periods of regular crops.”

Camelina sativa (camelina) is a flowering plant in the family Brassicaceae which includes mustard, 

cabbage, rapeseed, broccoli, cauliflower, kale, and brussels sprouts. It is native to Northern Europe and 

Central Asia and has been grown there for at least 3,000 years. Camelina is tolerant of low rainfall and 

needs little nitrogen to flourish; it can be grown on marginal agricultural lands and does not compete 

with, but is a complement to food crops especially dryland wheat cropping systems. Crop oil yields are 

double those of soybeans, and it may be used as a rotation crop for wheat fields to increase the health 

of the soil. It is cold tolerant and its oil is more resistant to cold temperatures than other oils.

Camelina fits the definition of annual cover crop that EPA has put forth in 40 CFR Part 80 Subpart M and 

therefore fuel derived from camelina should qualify for the applicable D codes to generate RINS. 

Additional information on camelina and its attributes is below.

 How does camelina fit the definition of an annual cover crop?

 What is the general geographic and agronomic fit for camelina production?

 What nutrients are needed for camelina production?

 What are the economics of camelina farming compared to wheat farming and what is the 

probability that camelina will take away wheat production?

 What is the energy required for camelina production?

 Are modifications to existing processing technologies necessary to process camelina?

 Is camelina food?

How does camelina fit the definition of an annual cover crop?

Camelina is an advanced generation biofuel feedstock targeted as a cover crop complement to dryland 

food production acres, especially cereals in the Great Plains. As per the definition above, camelina is:

 An annual crop; 

 Is planted in rotation with dryland wheat – the primary crop; 
 Protects the soil from erosion as these geographic areas are prone to wind and rain erosion; 

and,

 Improves the soil between periods as it provides organic matter to improve soil tilth.

In addition, camelina has the following additional attributes:

 Camelina is capable of being planted very early in the season when soil temperatures are much 

cooler than other potential crops. As a result, the camelina germinates rapidly and 

shades/chokes out the subsequent weed germination.

 Because it is a 90-110 day crop. Camelina complements spring wheat practices by being 

planted, and harvested earlier than the spring cereal crop. Cropping and growing practices in 

farming communities vary widely based on local conditions, and the same would be true for 

camelina. Camelina would be planted as a cover crop to improve land that is currently left 

fallow, so its incorporation into a rotation would be influenced, at least partly, by on-farm 

conditions, such as a need for pest control, desire to improve soil tilth and related needs. The 

below examples, however, capture a relatively ordinary wheat rotation that is common 

throughout the Northern Great Plains, and a standard wheat/camelina rotation.

o In a standard wheat rotation system, winter wheat is planted during the fall (Year 0), 

usually in October or November, and is harvested the next summer, in mid-August of 

Year 1. After harvest, that strip of land is left fallow for the remainder of Year 1, until 

the spring of Year 2 (as no-till farming becomes more common, wheat stubble is left 

standing and treated with chemicals; hence the term “chemfallow”). Depending on 

farm-specific conditions such as moisture and nutrient levels as well as the broader 

farm-wide rotation pattern, that strip of land may either be seeded with spring wheat in 

March/April of Year 2, or remain fallow for an entire 12-month period, until winter 

wheat planting in the fall of Year 2. If spring wheat were planted, after August harvest in 

Year 2, that strip would then be fallow for an entire 12-month period, August Year 2-

August Year 3. In fall of Year 3, winter wheat would be seeded and the rotation begins 

again. 

o In a camelina/wheat rotation system, winter wheat is planted during the fall, as above, 

and harvested in mid-August of Year 1. That ground would remain fallow until spring of 

Year 2, at which point camelina would be seeded in March or April and harvested in 

August. That ground would remain fallow again until spring of Year 3, at which point 

spring wheat would be planted. After spring wheat harvest in August of Year 3, winter 

wheat would be seeded in October, beginning the rotation again. Note that, based on 

moisture conditions in various regions of the country, a camelina/wheat rotation might 

require a full year of fallow land. For example, after the spring wheat harvest in August 
Year 3, a 12-month fallow period may be needed before beginning the rotation in the 

fall of Year 4, with winter wheat planting.

As fallow acreage is a primary target, camelina as a cover crop replaces at least two chemical treatments 

to remove weeds.

What is the general geographic and agronomic fit for camelina production?

Research conducted since 1997 regarding camelina production in the United States indicates that the 

best production fit for the crop is likely to be as a complement to dryland wheat production systems 

(McVay and Lamb, 2008;. Wheeler and Guillen-Portal, 2007, unpublished document; Ehrensing and Guy, 

2008) There are several reasons for this conclusion:

Example A: Ordinary wheat (winter wheat/spring wheat) rotation

Jan Feb Mar April May June July Aug Sept Oct Nov Dec

Year 

0

WW 

Planting

Year 

1

WW 

Harvest

Year 

2

SW

Planting

SW

Harvest

Year 

3

WW 

Planting

Example B: Wheat/camelina rotation

Jan Feb Mar April May June July Aug Sept Oct Nov Dec

Year 

0

WW 

Planting

Year 

1

WW 

Harvest

Year 

2

C 

Planting

C 

Harvest

Year 

3

SW

Planting

SW

Harvest

WW 

Planting
 Economic. Camelina represents an additional cash crop for dryland wheat farmers who may 

not have alternative choices due to marginal climatic and soil conditions in their production 

area, by allowing those producers to grow a dedicated energy feedstock in lieu of idling land. 

 Economic. Camelina production utilizes the same equipment necessary to plant and harvest 

wheat, so it is not necessary to make significant capital investment for a wheat farmer to 

cultivate camelina while the utilization of the equipment can be amortized against additional 

revenues.

 Agronomic. Crop rotation is an essential practice as it allows the pest/disease cycles to be 

broken, moisture to be captured, and soil tilth improved for subsequent crop production. When 

an alternative crop is not available, as in the targeted dryland wheat production acres for 

camelina, the rotation is to fallow ground. Typically in current production schemes this means 

that the ground remains as wheat stubble for a crop season with at least two herbicide 

applications to kill weeds that germinate. Farmer’s decisions to rotate from wheat production 

are based on a number of factors and include considerations around the previously mentioned 

agronomic as well as economic drivers. In much of the targeted production area for camelina, 

where the rotational decision is commonly fallow (no viable alternative crop), we expect that 

one of three rotation scenarios will apply: 1) wheat-fallow-camelina-wheat; 2) wheat-wheatfallow-camelina; 3) wheat-wheat-camelina-fallow. Rotational choices such as these provide an 

additional crop within a 4-season cycle, allowing for up to 40% more revenue in the period from 

acreage that is frequently subject to drought, high heat, and other stressors that make 

generating revenue challenging. Other rotational minor crops currently available in the target 

region include lentils (Lens culinaris), flax (Linum spp.), peas (Pissum spp.), garbanzo (Cicer 

arietinum), and millet (Pennisettum spp.), although the total acreage devoted to these minor 

crops is comparatively very small, all of them together comprising no more than half a million 

acres of the annually available rotational acreage in dryland wheat production (estimated to be 

up to 20-22 million acres).

Camelina as a complement to dryland wheat production, and a substitute for fallow land fits generally 

into the highlighted areas in the map below.
The acreage potential for camelina is best calculated using the following from the USDA Agricultural 

projections:

Wheat plantings to be relatively stable over the next decade. Wheat plantings are projected to 

rise to 61.0 million acres in 2011 because of 1) additional land becoming available from expiring 

CRP contracts and 2) incentives provided by high expected net returns (expected farm price times 

projected yield minus variable costs). The projected farm price is above the loan rate for the entire 

projection period, so loan benefits do not enter into net returns or influence plantings. Plantings are 

expected to fall off slightly toward the end of the decade as land is switched away from wheat to 

more profitable crops.

As you can see in the chart, the acreage projections during the next decade for wheat are approximately 

60 million acres of production. Further USDA and wheat state cooperative extension reports through 

2008 indicate that 83% of that production is under non-irrigated, dryland conditions, and of the 

resulting 50 million acres at least 45 % are estimated to follow a wheat/fallow rotation. The remaining 

55%, typically in somewhat better agronomic climate and soils, follow a continuous crop rotation 

(wheat/barley/wheat; wheat/lentils/wheat, etc.) The resulting 22 million acres are therefore the prime 

target for camelina production and fall into the previously illustrated geography. Of those 22 million 

acres where there is an opportunity to grow camelina, only about a third, or 9 million acres, have the 

appropriate climate, soil profile, and market access to be economically desirable.

A commercially viable renewable diesel facility would produce about 75 million gallons of advanced 

biofuel annually. Approximately 38 million bushels of camelina per year would be necessary to support 
that facility. Assuming 33 bushels/acre yield, on average, approximately 1.1 million acres of cropland 

would be necessary for a single facility. However, renewable diesel facilities, like other advanced 

biofuel facilities, will likely choose to use multiple feedstocks to mitigate risk.

What nutrients are needed for camelina production?

Camelina nutrient and moisture requirements are minimal, significantly less than wheat or other 

oilseeds. As a result, supplemental nutrients are low, soil moisture is managed and required production 

costs are low. Some application of nitrogen and phosphate improves yields. We advise farmers to apply 

25 pounds of nitrogen per acre and 15 pounds of phosphate per acre.

What are the economics of camelina farming compared to wheat farming and what is the probability 

that camelina will take away wheat production?

The scenario of an open market of camelina competing for acres currently targeted for cereal 

production is unlikely. There are three basic reasons why:

 Cereal markets (wheat, barley especially) represent the opportunity for much higher return than 

camelina because there is a significant open market opportunity for farmers to take advantage of 

market fluctuations. These market fluctuations can mean huge upside for the farmers, as in 2007 

and 2008 when wheat prices spiked to over $10/ bushel at times. Farmers have the opportunity to 

grow cereals with or without production contracts. Conversely, camelina markets as biofuel 

feedstock sources will be virtually 100% contracted acres. 

 Integrated companies with access to biofuel outlets will have economic incentive to both maintain 

and lower commodity values to reduce economic risk and increase predictability of the resulting 

biofuel. As such, camelina is priced such that farmers have economic incentive to plant it instead of 

leaving the acres fallow, but would not replace acres scheduled for wheat rotation with camelina.

 Farmers utilize Federal crop insurance for cereal production. To maintain their insurance base, 

farmers must plant annually a specified percentage of that basis. Therefore there is a strong 

incentive not to plant more than 25% of the cereal crop insurance base for fear of losing that 

important risk tool in subsequent years. Producers must plant at least 75% of their maximum 

potential crop acres with the primary crop – wheat, for example – to maintain the maximum 

available crop insurance. This leaves only 25% of the crop land, which would ordinarily remain 

fallow, for planting of camelina. There is no similar crop insurance in place for camelina.

A cost comparison of the value to farmer per acre of camelina versus wheat is below. These cost 

comparisons are based on Sustainable Oils production contracts, local seed (agents for Sustainable 

Oils’ seeds) who also supply chemicals and fertilizers, farmers accounts provided to Sustainable Oils, 

and Chicago Board of Trade wheat quotes. As one would expect from a cover crop, the cost per 

acre to produce camelina is about 1/3 lower than it is to produce wheat. The average annual yield 

per acre has been trending up but is still less than 800 pounds. Camelina contracts are paying 

$0.145 per pound so the expected revenue per acre is $116, netting the farmer $13.24 per acre. 
Wheat contracts are currently around $5.35 per acre (with yields around 40 bushels per acre), 

netting the farmer almost 5x more economic value per wheat acre than camelina acre.

Camelina yields are expected to improve significantly over the next 5 years. As this happens, 

contractors will lower the price paid per pound in order to gain some of the economic value of 

creating higher yielding germplasm, down to about $0.125 per pound. Even if camelina yields would 

increase 50%, to 1200 pounds per acre, the net value to farmers would still be less ($47.24 per acre 

– not including extra costs associated with harvesting and hauling the extra materials) than what is 

expected for wheat acreage.

Finally, wheat prices on the open market are relatively volatile. As mentioned above, in 2007 and 

2008 average wheat prices in Montana for all types of wheat were $7.14/bu and $6.55/bu

respectively (USDA), although prices spiked much higher than that in different months. In these 

exceptional years, wheat farmers are capable of more than doubling their net profit.

Camelina Total Production Cost Wheat

Inputs Rates Cost Cost

Herbicides

Glysophate (Fall) 16 oz. ( $0.39/oz) $7.00 

$14.00 

Glysophate (Spring) 16 oz. ( $0.39/oz) $7.00 

Post 12 oz ( $0.67/oz) $8.00 

Seed

Camelina seed 4 pds./acre $5.76 $9.00 

Fertilizer

Nitrogen Fertilizer 25 pds ( $1/pd) $25.00 

Phosphate Fertilizer 15 pds ( $1/pd) $15.00 $90.00 

Sub-Total $67.76 $113.00 

Logistics

Planting Trip $10.00 $10.00 

Harvest& Hauling $25.00 $25.00 

Total Cost $102.76 $148.00 

Total Revenue at avg prod/current pricing $116.00 $214.00 

Return $13.24 $66.00 
Another scenario that could occur is that oil prices spike, causing contractors to pay more for camelina 

while wheat prices drop. However, looking at the price of wheat and oil futures contracts during the last 

5 years it is apparent that that is an unlikely scenario as wheat and oil prices are highly correlated.

Wheat Futures Versus Oil Futures 2004-2009

What is the energy required for camelina production?

Camelina production requires minimal energy inputs. As stated above, current guidance to farmers is 

that they apply 25 pounds per acre of nitrogen and $15 pounds per acre of phosphate. The additional 

energy input is diesel for the farming equipment. Compared to other feedstocks, the amount of diesel 

used to plant and harvest camelina should be the same or less because of the high ratio of seed to 

biomass for the plant.

Are modifications to existing processing technologies necessary to process camelina?

Commercial camelina production has been in place for several years. An advantage of camelina 

production is that the planting and harvesting equipment used for wheat can be used for camelina and 

that the existing crushing, extraction and processing infrastructure is suitable for camelina. No 

modifications to these technologies are necessary.

Is camelina food?

Camelina is most properly understood as a cover crop that complements existing food crops, such as 

wheat. Growing camelina exclusively as a dedicated energy feedstock, therefore, does not create a 

“food vs. fuel” scenario, as camelina has no role in the food chain and only a small role in the feed chain. 

The US Food and Drug Administration (FDA) is responsible for approving food additives. There are 

different routes for this, including being accepted as GRAS – generally recognized as safe – or going 

through a premarket approval process. Camelina has not received GRAS designation from the FDA nor 

has any organization petitioned for it or started a full approval process. Assuming canola would be the 
likely predicate crop for the route to GRAS status by the FDA, it is useful to look at its history to 

determine what camelina producers would need to do to achieve the same status. Canola was 

specifically developed in Canada to provide Canada with a cold tolerant, healthy oilseed crop. Rapeseed 

was the initial crop that was bred to get rid of the anti-nutritional components of erucic acid and 

glucosinolates. The allowable levels of those two components in canola are less than 2% erucic acid and 

fewer than 30 micromoles/ gram glucosinolate. (Camelina varieties typically contain over 2% and as 

much as 4% erucic acid while glucosinolate levels vary but can be as high as 36 micromoles/gram.) 

Canola, with the support of the Canadian government and strong trade groups dedicated to its 

development, received GRAS status after submission of a lengthy petition which detailed years of animal 

and human studies. It is highly unlikely that camelina will achieve the same status because (a) there is 

not a market need for another cold-tolerant oilseed as canola is a superior crop with attractive health 

benefits (b) camelina has an inferior profile compared to canola because of its erucic acid and 

glucosinolate profile (c) the trade groups developing camelina are focused on it as a energy crop, and (d) 

camelina oil has an off-odor and taste and therefore is not a desirable food. Camelina is not poisonous, 

however, and on-line searches may reveal examples of camelina oil being used in recipes, as one would 

also find recipes for pennycress, dandelions and other plants that are not regarded as “food.”

While camelina is not considered food for direct human consumption, camelina has the potential to add 

to the food supply because its meal can be used in some animal feeds. Camelina meal accounts for 

~62% of the seed (after the oil has been extracted) and while the FDA has approved its use in beef cattle 

and broiler hens it is only as a small percentage of the total ration (10% and 2% respectively).

Summary

Camelina has tremendous potential as a near-term feedstock that can contribute to reducing our 

nation’s carbon footprint and increase our domestic energy supply. Many of the advantages of camelina 

are derived through its use as an annual cover crop, grown by farmers in rotation with dryland cereal 

acres. Camelina provides some economic benefit for the farmer, protects the soil, and helps reduce the 

pest cycle. We respectfully request that the EPA confirm that camelina is included in the existing 

definition of “annual cover crop” under 40 CFR Part 80, Regulation of Fuels and Fuel Additives.

For further information, please contact Scott Johnson at scott.johnson@susoils.com or Margaret 

McCormick at mmccormick@targetedgrowth.com.