Comment submitted by Steven W. Troxler, Commissioner, North Carolina Department of Agriculture and Consumer Services

The U.S. Environmental Protection Agency withdrew its direct final rule, issued on January 12, 2012, to recognize giant reed (Arundo donax) as an additional fuel pathway to meet the biomass-based advanced biofuels or cellulosic biofuels lifecycle greenhouse gas reduction requirements. This withdrawal was largely due to subsequent objections regarding risk of invasiveness. In response to a petition from several environmental organizations, the North Carolina Department of Agriculture and Consumer Services recently completed an in-depth review of giant reed and its impact to North Carolina. As a result of this review, the Department's Plant Industry Division concluded that giant reed does not warrant listing as a noxious weed. The North Carolina Board of Agriculture, which has rulemaking authority for this matter, unanimously agreed and declined to place giant reed on the North Carolina noxious weed list. The Department is continuing to work with state agencies and partners to identify and implement appropriate strategies to responsibly manage the commercial cultivation of giant reed as a biomass crop. EPA recognition of giant reed as a Renewable Fuel Standard approved feedstock for advanced biofuels remains important to a major project under development in North Carolina. In the interest of commercial decisions that must be made in the near term, I respectfully ask EPA to complete and publish its findings on giant reed as quickly as is reasonably possible.