Australian Carbon Pollution Reduction Scheme will INCREASE Carbon Pollution

Australian Carbon Pollution Reduction Scheme will INCREASE Carbon Pollution

by Dr Gideon Polya


Only a few weeks after the release of the Draft Report of the seriously flawed, pro-coal Garnaut Climate Change Review (4 July, 2008: ), the Australian Federal Government has released a Carbon Pollution Reduction Scheme Green Paper (16 July, 2008: ).


Unfortunately the Australian Federal Government Carbon Pollution Reduction Scheme (CPRS) Green Paper (GP) is FATALLY FLAWED and if adopted globally would be a DEATH SENTENCE for the planet’s biosphere.


In short, the Carbon Pollution Reduction Scheme:

(a) massively ignores leading scientific and economic advice on the urgent need stop greenhouse gas (GHG) pollution and indeed to REDUCE atmospheric CO2 from 387 ppm to a safe level of no more than 350 ppm;

(b) ignores two thirds of Australia-responsible greenhouse gas emission sources, notably coal exports (43% of the total Domestic plus Exported emissions);

(c) adopts a “cap and trade” Emissions Trading Scheme  with an atmospheric CO2 concentration “cap” above 450 ppm (450-500 ppm will kill world coral reefs including the Great Barrier Reef);  and

(d) hands nearly all of the collected pollution licence fees back to polluters, “dirty energy” users and the poor - rather than using it to urgently construct clean energy power stations using current technologies that can ALREADY provide power at a cost LOWER than the “true cost” of coal-based electricity (taking environmental and human costs into account).


Fundamentally, the Carbon Pollution Reduction Scheme (CPRS) FAILS because it will actually INCREASE Carbon Pollution in both the short-term and the long-term. The expected impact of the “tax-pollution-and-return-taxes-to-polluters-and-consumers” CPRS on domestic pollution will be small compared to the effect of currently huge global fossil fuel price increases because the CPRS taxes only ONE THIRD of emissions sources (at a once-off circa 17% level vastly lower than the continuing 1999-2008 world 5-8-fold fossil fuel price escalation) and then hands nearly all of the taxes back as subsidies. In contrast, Australia’s world -leading coal exports (43% of Australia’s 2006 Total Domestic and Exported GHG emissions of about 1,000 million tonnes CO2-e)  are expected to increase massively in the short-term due to new infrastructure in Queensland and New South Wales (Queensland Government estimate: 40% increase in Queensland coal exports:,25197,24024305-36418,00.html ).


Using US Energy Information Administration data (see: ), and ignoring huge new Australian coal export infrastructure developments, Australia’s total Domestic and Exported CO2 emissions from fossil fuel burning in millions of tonnes (Mt) are expected to climb from 698 Mt (2000) and 910 Mt (2007) to 1,277 Mt (2020, no mitigation) or   1,165 Mt (2020, based on “20% renewable by 2020”; an INCREASE of 67% over 2000) and thence to 1,371 Mt (2050, based on “60% reduction of 2000 Domestic pollution by 2050”; an INCREASE of  96% over 2000 CO2 pollution ).


 The following 24 major criticisms are of the Carbon Pollution Reduction Scheme  Green Paper (GP) Summary and appended Fact Sheets.


1. Coal exports ignored. The GP 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:,25197,24024305-36418,00.html ; ). Elementary considerations of causality and culpability mean that Australia's coal exports cannot be ignored (just a 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 GP 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 demands an urgent “negative CO2 emissions” policy to reduce atmospheric CO2 concentration from a present dangerous and environmentally damaging level of 387 parts per million [ppm]   to a safe and sustainable level of no more than 350 ppm: ; ).


3. EPA-style regulation ignored. The GP 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) (e.g. see US EPA:  ).


4.  Flawed quasi-market proposal despite “greatest market failure”. While both the Garnaut Report (see: ) and top UK climate economist Professor Nicholas Stern (see: ) describe the climate change crisis as the “greatest ever market failure”, the GP 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 GP 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 (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 GP 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 (see ).


7. Australia per capita 10 times worse than China and World, 40 times worse than India. The GP 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 (see: ) .


8. Estimated 5,000 Australia deaths annually from coal-based power. The GP 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) (see: ). 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 (see: ).


9. “True cost” of coal-based power 4-5 times “market” cost. The GP 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 (see: ; ; ; ; ).


10. Morbidity and mortality cost due to coal burning-based power generation. The GP 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) (see: and ).

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 GP 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 (see: ; ).

12. Huge total economic value of sustainable biosphere use. The GP IGNORES Agriculture (9% of Total GHG Emissions) and Forestry and Land Use (4% of Total Emissions). The GP 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 (see: ) (see item #13 below in relation to the total economic value of the climate change-threatened Great Barrier Reef).


13. Huge economic and irreversible ecosystem and species loss from Great Barrier Reef destruction. The GP 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(see: ; ). Irreversible environmental vandalism aside, the adumbrated destruction of the Great Barrier Reef (i.e. above the Government 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 Reef each year (see: ). 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 (see: ).


14. International and National legal implications of GHG pollution. The Review 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 (e.g. see: )   (however the GP 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 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” (see: ).


16. Major technological advances in low-cost solar and other non-carbon technologies. The pro-coal GP Summary IGNORES the enormous advances made in already commercial solar energy technology, notably  silicon-based photovoltaics (notably improved efficiency, sliver technology, balloon-based solar energy collection), CIGS and other non-silicon thin film photovoltaics (California, Switzerland) and Concentrated Solar Power or Solar Thermal – all of which yield power at a cost LESS than the “true cost” of coal-based power and in many cases approaching the 4-5 times lower current, heavily subsidized  “market cost” of  the coal-based power favoured by the GP. Thus the new, large-scale, commercialized, Ausra  Concentrated Solar Power (Solar Thermal) Compact Linear Fresnel (CLFR) system technology is already HALF the "true cost" of coal-based power with lower cost to come with economies of scale: “Ausra claims that It can generate electricity for 10 cents/kWh now, under 8 cents/kWh in 3 yrs. It also claims that using Ausra’s current solar technologies, all U.S. electric power, day and night, can be generated using a land area smaller than 92 by 92 miles” (see: ; ; ; ; ; ).


17. Top scientific and economist advice ignored. The GP has clearly IGNORED detailed, expert, well-documented, scientific and economic representations about most of the above issues (e.g. see: ; ; ). It is extremely  unfortunate and indeed very dangerous  that the expert, public interest views of  top economists and scientists on man-made climate change can be simply ignored and sidelined. For an important analysis of this general problem (that in my view acutely endangers our society and the world in relation to the key problems of nuclear, greenhouse and poverty threats: ) see “Scientists know better than you – even when they’re wrong” in Scientific American: .

18. CPRS selectively ignores two thirds of Australia-responsible GHG emissions. The GP is absurdly INEQUITABLE in its selective targeting of sources of GHG pollution. Thus major areas excluded or effectively excluded from the CPRS are Agriculture (90 Mt CO2-e, 9.0% of Total Domestic and Exported GHG emissions), Forestry and Land Use (40 Mt, 4.0% of Total), Transport (tax and re-pay cent-for-cent; 80 Mt, 8.0%) and Coal Exports (426 Mt, 42.5% of 1002 Mt total). This goes against considerations of reasons, equity and economic advice (e.g. from the Garnaut Review: ).


19. Counterproductive and inequitable in return of licence fees to polluters and consumers. The GP is absurdly discriminatory and INEQUITABLE in its return of nearly all the GHG pollution licence fee monies to domestic and industry participants. Thus those FAVOURED by the GP through subsidies (variously including “free permits”) are the “dirty” energy providers, “dirty power” users, “emission-intensive trade-exposed industries” (this could conceivably include the un-taxed coal and liquefied natural gas exporters!)  and the poor and elderly (who are acutely discriminated against  through resolute non-provision of cheap, renewable technologies that are much cheaper than the “true” cost of coal-based electricity (see: ). Unjustly,  absurdly and counterproductively,  those NOT receiving non-transport subsidies include “clean” industries (including renewable energy industries) and middle-to-higher income consumers (who are generally opposed to GHG pollution).


20. GP damaging to Older Australians. In its resolute commitment to fossil fuel-burning at all costs, the GP is highly discriminatory towards older Australians in many ways, most notably because they are differentially threatened by elevated temperatures (see: ; ; ; ; ) and because they are threatened by the impossibility  of GDP growth in a continuing carbon-based  economy. Thus retirement benefits require GDP growth, carbon-based growth is no longer possible but cheap, non-carbon energy alternatives are already developed. For people who are self-funded retirees on superannuation schemes or government pensions it is necessary for GDP growth to compensate for outlays and inflation. However, the Climate Emergency requirement for urgent implementation of “negative CO2 emissions” means that the present carbon-based energy economy in which GDP is directly proportional to CO2 pollution has to STOP. However the solar energy hitting the earth each day is 10,000 times the energy currently used by man and can ALREADY be cheaply accessed  at a cost much lower than the “true cost” of coal-based electricity (for recent reviews of such already developed, low-cost, non-carbon solar and geothermal energy technologies see : ; ; ; ). For a detailed account of climate change impacts on older people see the Yarra Valley Climate Action Group website Fact Sheet “Global warming dangers and solutions for Older People”: . .


21. CPRS details not known till after Submission deadline. The GP is a fore-runner of more detailed document but more precise details from Treasury will apparently only be available in October i.e. AFTER the deadline for Submissions has closed in September 2008 (see: ).


22. GP policies reverse sensible feed-back inhibition and feed-forward activation. The GP Summary (p29) states that “The Government proposes to provide a limited amount of direct assistance to existing coal-fired electricity generators” but will effectively punish “non-carbon energy generators”, other “clean” industries and middle-to-higher income consumers who will bear the burden of increased costs due to the CPRS. This and other GP pro-coal policies are mathematically absurd and CONTRARY to sensible models of “feed-back inhibition” in relation to undesirable outcomes (e.g.  inhibition of GHG pollution by constraining polluters by the amount they pollute) and “feed-forward activation” to achieve desirable outcomes (e.g. promoting renewable and geothermal energy to achieve lowered GHG pollution, and lowered atmospheric CO2).


23. GP favours “dirty energy” and fossil fuel exports over “clean energy”. While the urgently-needed installation of “clean energy” is left up to “market forces” the GP departs from a “level playing field” “market forces” game by supporting “dirty energy” and coal exports on the one hand while imposing increased costs on the renewable energy industry and middle-to-higher-income anti-pollution consumers on the other.


24. GP violates Rational Risk Management. Rational Risk Management (that, for example, has made aviation so safe) successively involves (a) getting accurate information; (b) scientific analysis (science involving the critical testing of potentially falsifiable hypotheses); and (c) systemic change to minimize risk. Unfortunately this  protocol is typically perverted at all levels of society through (a) lying and incorrectness by omission and commission, censorship, intimidation, and propaganda;(b) anti-science spin involving the selective use of asserted facts to support a partisan position; and (c) blame and shame (which discourages requisite reportage) with typically no systemic change (which greatly increases the risk of adverse outcomes).  A fundamental flaw of the Green Paper lies in its departure from Rational Risk Management.

The Adverse Outcomes associated with man-made global warming are already happening (to the Arctic, Antarctic, the Tundra, Greenland, the Himalaya plateau, coral, ocean fisheries, tropical and sub-tropical agriculture, other systems and ecosystems). Biofuel diversion and famine are a reality. Crop-based biofuels are highly CO2 polluting and the global food price crisis (driven in part by US-, UK- and EU- mandated food diversion for biofuel, oil price rises, globalization, global warming and speculation) threatens “billions” with biofuel-driven famine according to UK Chief Scientist Professor John Beddington FRS (see:,25197,23336840-11949,00.html ; ; ).

16 million people already die avoidably in the world each year from deprivation and deprivation-exacerbated disease (see “Body Count. Global avoidable mortality since 1950”, G.M. Polya, Melbourne, 2007:  and  )  and this is already being significantly impacted by global warming according to the UN (see; and ). In December 2007 in Bali the three Rome-based UN Agencies – FAO, the World Food Programme and the International Fund for Agricultural Development – warned that climate change is a major challenge to world food security and will increase hunger and malnutrition unless immediate action is taken (see: ) . Unaddressed  climate change already threatens billions and will kill over 6 billion people this century according to Professor James Lovelock FRS) (see: ; ; ).

The Green Paper departs from the above Rational Risk Management protocol in all 3 key areas as described above: (a) it ignores major realities (e.g. Australia’s world leading coal exports that contribute 43% of Australia’s annual contribution to global GHG pollution; the estimated 5,000 Australians who die annually from coal burning-based power generation; the reality that the “true cost” of coal burning-based power generation is 4-5 times the “market cost”; the urgent need to reduce atmospheric CO2 from the present damaging 387 ppm to a safe and sustainable level of less than 350 ppm (according to top US climate scientist Professor James Hansen); the need for a carbon pollution tax and urgent implementation of clean technologies (according to top world economist Professor Jeffrey Sachs); and makes INCORRECT assertions (e.g. “the scheme will cover the bulk of Australia’s emissions” (p15)).


(b) as outlined  in (a) above, the GP has used information selectively to support a partisan pro-coal position; and


(c) the GP Carbon Pollution Reduction Scheme fails to significantly alter the system to the extent that “Carbon Pollution” from Australia’s domestic and exported GHG emissions is predicted to actually INCREASE  67% by 2020 under this prescription (see above). The GP fails to provide any substantial change in response to what eminent people now describe as a Climate Emergency. Thus on 17 July 2008 an outstanding Australian book entitled “Climate Code Red. The Case for Emergency Action” by David Spratt and Philip Sutton (Scribe, Melbourne, 2008) was launched in the Queen’s all of the plarlimanet House Hall Hall of Victoria’s Parliament House by the Governor of Victoria, the eminent medical scientist Professor David de Kretser, who warned of the acute seriousness of man-made global warming (see:  ).


“Climate Code Red” (see: ) sets out the details of the Climate Emergency facing the world: at 387 ppm atmospheric CO2 we face the loss of all Arctic sea ice in several years’ time with huge “positive feedback” implications for the Greenland and West Antarctic ice sheets, the tundra, global warming, sea level rise, mass extinctions and horrendous human mass mortality.  The authors advocate declaration of a Climate State of Emergency and urgent national action akin to that which galvanized the US, British and Australian economies in World War 2.


The first draft of this  very important book has already galvanized dozens of Australian Climate Action Groups (including the Yarra Valley Climate Action Group of which I am a member: )  to form a Climate Emergency Network (see: ) with the core values that “We have no right to bargain away the lives of others. Our goal is a safe climate future for all people, all species, and all generations” and an Action Plan for the Planet that “The Global Community must concurrently halt man-made greenhouse gas emissions, remove excess carbon dioxide from the atmosphere, and actively cool the Earth.” The required global action requires Declaration of a Climate Emergency  and, underpinned by legislation, governments must lead a large scale transformation of the economy to a post-carbon society.


Top US and World climate scientist Dr James Hansen is the Head of NASA’s Goddard Institute for Space Studies, New York; adjunct professor, Columbia University; member of the prestigious US National Academy of Science; was recently awarded the 2007 AAAS Award for Scientific Freedom and Responsibility of the prestigious American Association for the Advancement of Science (AAAS) (for speaking out forcefully about human influence on global climate despite pressure to alter his message: ); and  recently sent a detailed letter (with a very detailed scientific summary appendix) to the Prime Minister of Australia advocating urgent action to address climate change (see: ). Dr James Hansen commented thus about “Climate Code Red”: “A compelling case … we face a climate emergency.”


This has been written in the public interest.


Dr Gideon Polya

Macleod, Melbourne, Victoria 3085, Australia


Credentials: Dr Gideon Polya published some 130 works in a 4 decade scientific career, most recently a huge pharmacological reference text "Biochemical Targets of Plant Bioactive Compounds" (CRC Press/Taylor & Francis, New York & London, 2003) of acute relevance to preservation of biological diversity and all existing species and ecosystems. He has just published “Body Count. Global avoidable mortality since 1950” (G.M. Polya, Melbourne, 2007:  and  ); see also his contribution “Australian complicity in Iraq mass mortality” in  “Lies, Deep Fries & Statistics” (edited by Robyn Williams, ABC Books, Sydney, 2007): ). He is currently preparing a revised and updated version of his 1998 book “Jane Austen and the Black Hole of British History” (see: ) as biofuel-, globalization- and climate-driven global food price increases threaten a possibly 100-fold greater famine catastrophe (see: ) than the man-made famine in British-ruled India that killed 6-7 million Indians in the “forgotten” World War 2 Bengal Famine (see recent BBC broadcast involving Dr Polya, Economics Nobel Laureate Professor Amartya Sen and others: ).