It has been suggested that higher GHG thresholds for direct emissions are an adequate substitute for accounting for indirect land use change emissions. (news.mongabay.com)
I do not believe it is logically or practically legitimate to distinguish direct from indirect land use. (sciencemag.org)
There are uncertainties inherent in estimating the magnitude of indirect land use emissions from biofuels, but assigning a value of zero is clearly not supported by the science. (greencarcongress.com)