The following 24 major criticisms are of the Carbon Pollution Reduction Scheme Green Paper (GP) Summary and appended Fact Sheets. These criticisms have been formally submitted with detailed documentation to the Australian Government (for a detailed version with carefully linked documentation see: http://sites.google.com/site/yarravalleyclimateactiongroup):

1. Coal exports ignored. The Green Paper completely IGNORES the GHG pollution due to Australia’s world leading coal exports (426 million tonnes [Mt] CO2 in 2005-2006 as compared to 560 Mt CO2-e domestically i.e. it completely ignores 43% of the GHG pollution for which Australia is responsible each year and which is predicted by the Queensland Government to hugely increase by 40% in the short-term in Queensland alone. Elementary considerations of causality and culpability mean that Australia’s coal exports cannot be ignored (just law enforcement cannot ignore the robbery co-conspirator or the get-away driver).

2. NASA experts ignored over 350 ppm CO2 limit. In advocating continued, high level, GHG emissions the Green Paper IGNORES the acute seriousness of anthropogenic climate change due to greenhouse gas (GHG) pollution (in contrast, top US climate scientist Dr James Hansen and his colleagues at NASA’s Goddard Institute for Space Studies demand an urgent “negative CO2 emissions” policy to reduce atmospheric CO2 concentration from a present dangerous and environmentally damaging level of 387 ppm to a safe and sustainable level of no more than 350 ppm.).

3. EPA-style regulation ignored. The Green Paper IGNORES a “regulatory” course (e.g. it does not even consider actually progressively banning GHG pollution in the context of a Climate Emergency transition period and making GHG polluters pay the “true” environmental and human cost of pollution (a course which is responsibly adopted and EPA-inspected in relation to OTHER major industrial sources of environmentally and socially damaging pollution e.g. asbestos, heavy metals, heavy oils, acids, toxic organics, microorganisms).

4. Flawed quasi-market proposal despite “greatest market failure”. While both the Garnaut Report and top UK climate economist Professor Nicholas Stern describe the climate change crisis as the “greatest ever market failure”, the Green Paper opts for a highly-compromised and flawed “claimed market mechanism” to discourage GHG pollution – rather than “direct action” of regulation of GHG pollution and emergency implementation action to dramatically speed conversion to “clean energy”.

5. Biologically disastrous CPRS “cap” – Carbon Tax & new technology needed. The Green Paper opts for a flawed “cap and trade” Emissions Trading Scheme (ETS) with a “cap” (at least 450 ppm CO2) disastrously higher than that recommended for a safe environment by top climate scientists (less than 350 ppm CO2) and IGNORES active government involvement in actually building or promoting renewable or other non-carbon power plants (e.g. top US climate economist Professor Jeffrey Sachs, Director of the Earth Institute, Columbia University, rejects the ETS approach and has advocated that Australia should introduce a carbon tax as a simpler and less rort-prone system, and invest the proceeds in the development of new technology).

6. Coral goes above 450 ppm CO2, ocean phytoplankton go above 500 ppm CO2. The Green Paper is based one supposes on the immediately prior Garnaut Report which was predicated on an Australian Government proposed outcome of an atmospheric CO2 of 450-550 ppm. However world coral dies above 450 ppm, the phytoplankton and the Greenland ice sheet go above 500 ppm and the world is devastated at 550 ppm.

7. Australia per capita CO2 pollution 10 times worse than China and World, 40 times worse than India. The Green Paper admits that Australia’s world-leading coal exports represent a major component of Australian coal mining but extraordinarily IGNORES the contribution this makes to Australia’s annual per capita CO2 pollution (27 tonnes CO2 per person per year domestically but 47 tonnes CO2 per person per year including CO2 from coal exports) – 10 times worse than China and the World and 40 times worse than India.

8. Estimated 5,000 Australia deaths annually from coal-based power. The Green Paper IGNORES the estimated huge annual deaths from coal-burning and fossil fuel-burning for electricity in Australia (4,900 and 5,400, respectively) and the World (170,000 and 283,000, respectively). This carnage carries an economist-estimated price tag e.g. the US Environment Protection Authority (EPA) has recently re-estimated the risk-avoidance–based valuation of American lives at US$6.9 million each (US$ and A$ are close to parity) yielding 5,400 persons x $6.9 million per person = $37 billion.

9. “True cost” of coal-based power 4-5 times “market” cost. The Green Paper IGNORES the “true cost” of coal-based electricity generation which is estimated from an Ontario, Canada Government study to be 4-5 times the “market cost” – a reality that makes all existing, best-practice non-carbon energy sources cheaper than fossil fuel-based power.

10. Morbidity and mortality cost due to coal burning-based power generation. The Green Paper ignores the huge annually added cost to Australia due to coal burning- and fossil fuel-burning-related deaths (at $5 million per person [EU estimate], $25 billion and $27 billion, respectively) and the 6-fold greater cost of morbidity (illness).

11. Top US, UK, France climate scientists want “negative CO2 emissions” policy. There are 3 clear options: (a) negative CO2 emissions, (b) zero emissions and (c) positive emissions (more emissions). The Green Paper prescribes MORE CO2 pollution and IGNORES the position of top UK, US and French climate scientists from top institutions who argue that we have already reached a disastrous “tipping point” and must reduce atmospheric CO2 from the current 387 ppm to no more than 350 ppm i.e. a “negative CO2 pollution” policy that can be implemented by energy efficiency, cessation of fossil fuel burning, implementation of best-practice existing non-carbon energy sources, re-afforestation, return of biochar to soils, and (if necessary) use of global dimming sulphur oxide aerosols.

12. Huge total economic value of sustainable biosphere use. The Green Paper IGNORES Agriculture (9% of Total GHG Emissions) and Forestry and Land Use (4% of Total Emissions). The Green Paper specifically excludes de-forestation from consideration (p18) and the findings of top biologists and environmental economists that the total economic return from major biomes (ecological systems) studied can be typically about 50% greater when there is sustainable use and that the economic return from preserving what is left of wild nature is over 100 times the cost of so doing.

13. Huge economic and irreversible ecosystem and species loss from Great Barrier Reef destruction. The Green Paper IGNORES the enormous current rate of species extinction that is ALREADY 100-1,000 times greater than normal and which is impacted severely by climate change. Irreversible environmental vandalism aside, the economic cost of the adumbrated destruction of the Great Barrier Reef (i.e. at atmospheric CO2 above the Government’s proposed minimum target of 450 ppm CO2) has been estimated by a prestigious Access Economics report prepared for the Great Barrier Reef Marine Park Authority. Access Economics provides quantitative estimates of the economic and financial value of tourism, commercial fishing and recreational activities undertaken in the Great Barrier Reef Marine Park Catchment during 2005/06. The Great Barrier Reef is a significant element in the Australian economy which, along with other attractions in the region, contributes $6.9 billion annually. This comprises $6 billion from the tourism industry, $544 million from recreational activity and $251 million from commercial fishing. This economic activity generates about 66, 000 jobs, mostly in the tourism industry, which brings over 1.8 million visitors to the Great Barrier Reef each year. A 1997 report in the prestigious science journal Nature estimated that the resources and economic benefits derived world-wide from coral reefs are worth $375 billion a year.

14. International and National legal implications of GHG pollution. The Green Paper IGNORES International and National Law in relation to illegitimate commercial impositions on other people (especially when mass suffering and death are involved) and IGNORES the real prospect of litigation, Sanctions, Boycotts, Green Tariffs, Reparations Demands and national and international criminal prosecutions (however the Green Paper does advert to the possibility of international Tariffs).

15. Moral and legal implications of incorrectness by omission or commission. People are “entitled to their opinion” as with politics (political freedom), religion (religious freedom) and scholars (academic freedom). However there are certainly moral constraints in relation to statements that are incorrect by omission or commission. Further, legal constraints on “freedom of speech” exist in relation to Courts (e.g. perjury), other law enforcement (e.g. perverting the course of justice) and in commercial law. Thus insider-trading and anti-price collusion legislation prohibit deception of investors and consumers and indeed apply draconian penalties. Similar legislation would dramatically clarify the Climate Emergency debate in Australia and the World in general which is heavily influenced by industry and politicians to the exclusion of expert climate scientists. Indeed Dr James Hansen in a recent address to the US National Press Club and a briefing to the US House Select Committee on Energy Independence & Global Warming Congressional Committee raised the issue of criminal prosecutions:

“CEOs of fossil energy companies know what they are doing and are aware of long-term consequences of business as usual. In my opinion, these CEOs should be tried for high crimes against humanity and nature”.

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