WASHINGTON In comments submitted today to the Oregon Department of Environmental Quality (DEQ) in response to the agencys September proposed rule for the states Clean Fuels Program (CFP), the Renewable Fuels Association (RFA) reaffirmed its staunch commitment to support performance-based low carbon fuel programs that are grounded in the principles of fairness, sound science, and consistent analytical boundaries. However, RFA stated that it could not support DEQs proposal because by introducing concepts that lack scientific integrity and balance into the regulatory framework, the agency was only creating stakeholder division and controversy. Among other amendments, DEQ proposes to add indirect land use change (ILUC) penalties to the carbon intensity (CI) scores for corn ethanol and other crop-based biofuels. RFA contends that by adding flawed ILUC factors developed by the California Air Resources Board, and ignoring indirect effects for other fuels, the DEQ proposal tips the scales in favor of certain fuels and effectively results in the policy choosing winners and losers. RFAs comments underscore the fact that the inclusion of highly uncertain and prescriptive ILUC factors creates an asymmetrical and discriminatory framework for the CFP. In closing, the comments urge DEQ to exclude indirect effects from CI scoring in the Oregon CFP until more robust methods and broad consensus exist for addressing these potential effects. To read RFAs letter to the Oregon DEQ, click here.