The UK Renewable Transport Fuel Obligation (RTFO) program requires fuel suppliers to report direct impacts, and asked the Renewable Fuels Agency (RFA) to report potential indirect impacts, including ILUC and commodity price changes. The RFA's July 2008 "Gallager Review", mentioned several risks regarding biofuels and required feedstock production to avoid agricultural land that would otherwise be used for food production, despite concluding that "quantification of GHG emissions from indirect land-use change requires subjective assumptions and contains considerable uncertainty". Some environmental groups argued that emissions from ILUC were not being taken into account and could be creating more emissions.
