If a biomass feedstock currently serves a function that will need to be replaced if the feedstock is used for CDR, any emissions associated with the replacement must be considered. For example, if agricultural waste is currently used as animal feed or left on the fields to contribute to nitrogen, phosphorus, and potassium in soils, using that agricultural waste for CDR could result in new demand for feed or fertilizer, respectively. Current feedstock uses can be evaluated on a project-by-project basis, and the carbon impact of replacements can be estimated via lifecycle assessment. We recommend accounting for feedstock replacement emissions that involve existing feedstock uses rather than potential future uses. For example, agricultural feedstocks used for CDR should be evaluated based on their current uses (e.g. for animal feed or soil nutrients) rather than potential future uses that are not practiced today. The counterfactual for existing utilization should be flexible, and re-evaluated in the future if prevailing practices change. This component may not apply in cases where carbon is purpose grown.