Interesting approach to the Indirect Land Use Change issue:
Since ILUC is hard to quantify, the EU is trying to just raise the GHG offsets of qualifying fuels in hopes that this would eliminate fuels that may be causing ILUC. This doesn’t really seem to make much sense. You could just as easily have a crop with high GHG offset potential that could potentially cause massive ILUC, whose associated emissions would dwarf any GHG savings of the crop. You either need to attempt to quantify ILUC and regulate it (as California is attempting) or ignore it (as the RFS does). Trying to argue that direct benefits outweight indirect benefits that you never even tried to measure is at best greenwashing and at worse unethical.