[LINK] Climate change department estimate out by 900%

[Tom Worthington]

I hope whoever is doing the greenhouse gas accounting at the 
Department of Climate Change is better with numbers than their 
web-master. A  National Carbon Offset Standard Discussion Paper has 
been released 
<http://www.climatechange.gov.au/nav/carbon_offset.html>. According 
to the web site, this is 5.48 MB of PDF. I thought this would be 
useful for my Green ICT students to look at 
<http://www.acs.org.au/cpeprogram/index.cfm?action=show&conID=greenict>.

When I downloaded a copy I found the discussion paper was 548 Kbytes, 
one tenth of the quoted figure. It is a little worrying when numbers 
associated with a standard for accounting are off by a factor of ten. 
If they get the savings for greenhouse gas that wrong, we could all 
end up underwater. ;-)

A more serious problem with the paper is that it is in the form of 
one hard to read, monolithic PDF file. Attachment C to the document 
is a draft offset standard. This deserves detailed analysis, but that 
will be difficult with it tacked onto the end of the PDF document. 
The climate change department should release the draft as a separate, 
accessible HTML document. I couldn't wait for the Department to do 
this and have created my own HTML markup:

* Draft National Carbon Offset Standard: 
<http://tomw.net.au/moodle/mod/resource/view.php?id=264>.

Some minor corrections for the current draft:

    1. In "3. Terms and definitions" The entry for "businessas-usual" 
should be "business-as-usual".
    2. Number elements: section 4. Elements of the Standard lists the 
six key elements as bullet points. These should be numbered, one to six.
    3. Several sections of the report, such as "5.3.1 Scope" have 
only one paragraph which is numbered: "(a) The ...". As there is no 
"(b)" there seems no point in numbering the section.
    4. Footnotes: The use of footnotes, such as for "The Greenhouse 
Friendly Guidelines", should be avoided.

More serious issues:

    1. No government arbitrary rights: Section 6.1. Eligible offset 
units says: "The Government reserves the right to amend eligible 
offset units as required in
       light the development of new international standards, and 
other policy developments." This arbitrary right to amendments by 
government will weaken confidence in the system.
    2. Definition of "permanent": The standard requires that emission 
reductions must be permanent. Specifically this requires that 
sequestered carbon will not be released into the atmosphere in the 
future. No time span is included. There would appear to be no way to 
ensure this, so ruling out sequestration.
    3. No legislative measures: Complaince with specific laws is 
outside the scope of a voluntary standard. Thus "The Australian 
Competition and Consumer Commission (ACCC) will assess compliance 
with the Standard. Incorrect claims risk contravening the Trade 
Practices Act 1974" should be moved to a separate document.



Tom Worthington FACS HLM tom.worthington at tomw.net.au Ph: 0419 496150
Director, Tomw Communications Pty Ltd            ABN: 17 088 714 309
PO Box 13, Belconnen ACT 2617                      http://www.tomw.net.au/
Adjunct Senior Lecturer, Australian National University