Yes, I agree the whole life cycle needs to be accounted for. The main approach to production biocoal is inteneded to require the use of production biomass feedstocks such as Giant King Grass or Switchgrass. These are perennial crops that need to be planted, fertilized, and harvested. They also need land.
Waste biomass can also be used, but this will come from varying sources, in varying amounts, and it needs to be collected and transported.
Statements by the promoters of biocoal indicate that the costs for the production and/or gathering of biomass feedstocks are largely variable, and therefore undefined.