I think that the RFS2 definition is arbitrary on defining direct and indirect effects for both gasoline and biofuels production.
1 - It does not include any direct land use change for surface mining of tar sands in Canada.
2 - It is clear that exploration, drilling, mining, and distillation of fossil energy is getting dirtier and more expensive over time. Conversely, biofuel production and feedstock preparation is getting cleaner and less expensive over time.
3 - In a Catch-22, biofuels are being judged on their measured dependence on fossil fuels. Huh? The whole objective of the industry is to generate a new paradigm that is progressively cleaner of fossil fuels. How will it be possible to improve on fossil inputs when they are the only source available?
4 - Wouldn't the indirect effect of slowing ethanol production in the U.S. cede the industry to Brazil - which would then be more likely to deforest the Amazon to grow more biofuel feedstock to feed global demand?
5 - How about adding to indirect land use change (iLUC) a new factor – “indirect cultural abuse change” (iCAC). The gasoline benchmark would be pushed up off the chart if we did and therefore biofuels would fall into the improvement range.
Our addiction to oil wreaks cultural abuse worldwide – military manufacturing and logistics expenditures and emissions to prosecute oil conflicts, war damage to existing utility infrastructure, and the transfer of wealth from democracies to tyrannies – who exploit natural resources and have much less stringent environmental and workplace controls than we do. Surely these add carbon to the atmosphere (not to mention carnage, health, environmental, and human rights abuse).
6 - Bottom line – until we deploy emerging technologies and a progressive infrastructure path to distribute alternative products we should build upon what already gives us options and makes us more self-reliant. Otherwise we remain pawns to those who profit from and control the status quo.