On September 15, 2015, Oregon's Department of Environmental Quality (DEQ) proposed using hypothetical indirect land use change (ILUC) emissions while calculating the carbon intensity of biofuels under the Clean Fuels Program (CFP). DEQ proposed the rule to update the Oregon Greenhouse Gases, Regulated Emissions and Energy Transportation model (OR-GREET) to clarify elements before the CFP's first compliance year starting on January 1, 2016. The Renewable Fuels Association (RFA) released a statement expressing disappointment with the proposed rule, stating that the proposal creates "an inconsistent and unfair methodology for estimating the carbon intensity of competing fuel options under the CFP," by considering theoretical ILUC emissions for certain biofuels but not for all fuels. Oregon's DEQ is accepting comments on the proposed rule, which are due by October 21, 2015, and will hold a public hearing on October 19, 2015.

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