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 National Carbon 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. The W3C's HTML standards are a good example of how to format a standard in HTML. There is no need to provide the standard in PDF and most readers will be reading and using the standard on a computer screen, not printed on paper. Therefore formatting for on-line use should be the priority. I couldn't wait for the Department to do this and have created my own HTML markup: Draft National Carbon Offset Standard.
Some minor corrections for the current draft:
- In "3. Terms and definitions" The entry for "businessas-usual" should be "business-as-usual".
- Number elements: section 4. Elements of the Standard lists the six key elements as bullet points. These should be numbered, one to six.
- 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.
- Footnotes: The use of footnotes, such as for "The Greenhouse Friendly Guidelines", should be avoided.
- 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.
- 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.
- 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.