Competition and Markets Authority Annual Plan 2023 to 2024 consultation.pdf

Competition and Markets Authority Annual Plan 2023 to 2024 consultation, Response by Paul
Buckingham, Director ICPR 1200 Limited.
PREAMBLE
Prior to making my response, I wish to remind the CMA of it’s stated remit. As follows:
Our responsibilities
We help people, businesses and the UK economy by promoting competitive markets and tackling
unfair behaviour in a number of ways:
we investigate mergers that have the potential to lead to a substantial lessening of competition. If a
merger is likely to reduce competition substantially, the CMA can block it or impose remedies to
address those concerns
we take action against businesses and individuals that take part in cartels or anti-competitive
behaviour
we protect people from unfair trading practices, including in cases where unfair treatment suggests
there may be a systemic market problem
we investigate entire markets if we think there are competition or consumer problems
we encourage government and other regulators to use competition effectively on behalf of
consumers
we carry out regulatory appeals in relation to issues like price controls
we provide information and advice to people and businesses about rights and obligations under
competition and consumer law
we provide technical advice, reporting and monitoring in relation to the UK internal market, through
the Office for the Internal Market
as of 4 January 2023, we will provide advice, reporting and monitoring in relation to government
subsidies, through the Subsidy Advice Unit
The question I have for the CMA in this regard is, what if the market problem is Government?
WITNESS BRIEF
ICPR 1200 Limited is the central entity of an international network performing the role of developing
international markets for its clients, as the primary service, with related verticals to support the core
function.
WITNESS STATEMENT
My initial contribution will enter into the ‘consultation’ question of ‘other issues you think the CMA
should look at’, and then subsequently I will return to first two questions posed.
Of very specific responsibility, I would quote from the ‘CMA guidance on environmental claims on
goods and services’[1]
, which stipulates, amongst other principles, ‘claims must be truthful and
accurate’. This holds relevance to a number of issues raised within the CMA plans, and especially
in regard to the ‘Net Zero’ agenda of the UK Government.

I would at this point also remind the CMA of all relevant obligations, beyond remit, due to the fact
that too many Government Ministers, officials and general public servants seem to have lapsed in
recent years regarding these obligations:
Ethical standards for providers of public services [2]
Civil Service Code [3]
Human Rights: The UK’s international human rights obligations [4]
Universal Declaration of Human Rights [5]
Net Zero – Burden of Proof
I can state unequivocally that the premise of this ‘Net Zero’ agenda falls foul of the ‘truthful and
accurate’ obligation. The reason for my truthful and accurate statement is that I have pursued
various bodies to ascertain the burden of proof to substantiate the claims underpinning the ‘Net
Zero’ agenda, whereby the latest incarnation is ‘climate change’ (previously ‘Global Cooling’, then
‘Global Warming’ [AGW] and now ‘Climate Change’ [ACC] due to the constant failures of this
hypothetical claim). The common denominator in these malleable hypothesis is ‘human’s bad’ (with
convenient notable exception provided for the authors of this narrative).
There are two specific methods of ascertaining the burden of proof for the scientific credibility of
these claims, whereby the first is to produce the completion of the scientific method, and then failing
this, the evidence to support the precautionary principle. Not a single entity, organisation, institution
or qualified body is able to do so. This includes the UK Governments appointed ‘Climate Change
Committee’, and indeed all the way up to the most cited source of all, the IPCC. By default, the UK
Governments ‘Net Zero’ agenda, and all of its parallel programmes, are therefore not acting on the
basis of truth or accuracy. Subsequently, any responses to this consultation claiming actions on the
basis of ‘climate change’, emissions, etc. are also either acting on a false premise, in bad faith, or in
pure ignorance, none of which are acceptable nor lawful.
This is not a mere suggestion nor throw away comment, this is evidenced from written responses
failing to provide these basic burdens of proof (copies available on request), and hence if the CMA
is to abide by its principles, any ‘Net Zero’ related activities must be rejected outright. No other
course of action would be legitimate or legal.
Specific quotes from the responses I have gathered:
‘The extensive body of scientific literature determines that humans are the dominant cause of
climate change. This evidence base is regularly summarised by bodies such as the
Intergovernmental Panel on Climate [Change]’ – Climate Change Committee 17th
December, 2020
‘The questions you pose have been extensively answered in the IPCC’ – Professor Corinne Le
Quéré FRS, Climate Change Committee 31st
, December, 2020
‘The IPCC does not conduct its own research, we are unable to respond to questions seeking
information on primary research’ – IPCC WGIII 21st
January, 2021
In the event that the obvious does not leap from the page, we have authorities in the UK, including
‘experts’, failing to have any competent answer, and deflecting to an international body that is
political, and not scientific, who in turn will point the finger at researchers, resulting in a circle of
nobody having any burden of proof, just a spiral of Chinese whispers with zero facts. The reason
why? It’s because they have mere hypothesis and theories, acting as solid evidence to promulgate
a narrative. The IPCC also provides a ‘get out of jail free card’ by disavowing all of their own claims.
Specifically:
Climate Change 2021: AR6 The Physical Science Basis Full Report [6]
Box SPM.1 | Scenarios, Climate Models and Projections – Page 29

‘socio-economic assumptions and the feasibility or likelihood of individual scenarios are not part of
the assessment’
Translation: The IPCC does not bother to examine the financial impacts (i.e. cost/benefit analysis),
nor social consequences of their bad reports, and simply demands taxpayer money.
1.6.1.4 The Likelihood of Reference Scenarios, Scenario Uncertainty and Storylines – Page 255
‘In general, no likelihood is attached to the scenarios assessed in this Report’
Translation: It’s not about climate anything, it is pure anti-human ideology at best, and a cult of
Malthusians at worst, with a healthy dose of financial scam.
Should the CMA wish to comprehend the most recent falsehoods claimed to have been caused by
humans (in addition to a 60+ year evidence trove of failed predictions), there has been a recent
‘Fact Check’[7]
compiled for the past year of 2022 by the Competitive Enterprise Institute (CEI), the
Heartland Institute, Energy & Environment Legal Institute, Committee for a Constructive Tomorrow
(CFACT), and the International Climate Science Coalition (ICSC).
I do have to drive these points home, not only due to the obligations of the CMA, and how the
proposed ‘plan’ is pandering to this agenda in point 5.10, but also in recognition of the pressures
being placed on the CMA to be complicit in these falsehoods, due to example such as the recent
House of Lords proposal ‘In our hands: behaviour change for climate and environmental goals’[8]
,
whereby the CMA not only contributed to this call for climate propaganda, but was also name
checked to demand leniency toward the agenda complicit, and enforcement against any heretics.
This was specifically called for by InfluenceMap [9]
and the British Standards Institute [10]
.
Obligation to be Truthful
When a narrative is so consistently proven wrong, it is beholden amongst those being influenced
toward complicity to be vigilant, conduct due diligence and to comprehend the actual intent sought.
Somewhat fortuitously, the same House of Lords call for ‘evidence’ (which contained no ‘evidence’),
did divulge the true nature of this narrative and the anti-human basis hiding behind ‘climate’. A UK
Government commissioned report published in February 2021, titled The Economics of Biodiversity:
The Dasgupta Review,[11]
written by Partha Dasgupta, with introduction by fellow Malthusian, David
Attenborough (evidenced through his patronage of ‘Population Matters’[12]
) delivered the ‘truth’ of
the intentions. This can be summed up via the Figure 21.1 on Page 488 titled ‘Summary of Options
for Change’, which includes a less than subtle hint, whereby there is a box that includes the
statement ‘Improve access to community-based family planning and reproductive health’. In simple
terms, abort babies.
This comes as no surprise, as a common colleague of Partha Dasgupta is the perennially incorrect
Malthusian Paul R. Ehrlich, who was demonstrated to be hugely incorrect in a bet with Julian Simon
which Ehrlich not only lost in 1990 (a 10 year period bet), but is still provably wrong beyond the bet
time frame, as per ‘The Simon Abundance Index’[13]
of 2018.
The purpose of the CMA to fully comprehend these actual facts (as opposed to created narratives
and deflection techniques) is a requirement in order to further recognise how this narrative has
infected additional areas of it’s remit, which I will go on to clarify.
Prior to doing so, it is also worth your understanding that the actual anti-human intent is not just
based on Net Zero, but all elements of the ‘Sustainable Goals’.
As points of reference I will suggest a start point of the paper ‘Sustainable development – historical
roots of the concept’ [14]
, with key statements such as ‘in the 18th century concern about population
growth and its consequences for the consumption of resources started surfacing … the most
famous work in this regard, Essay on the principle of population as it affects the future improvement

of society, by Thomas Robert Malthus [hence, Malthusianism], was published in 1798’. The
previous evidence provided determines this falsehood to remain pervasive.
Additionally, there is ‘Woke eugenics’ [15]
, where reference is again made to one David Attenborough,
but with a much more informative piece of information relating to the main protagonists of the
‘Sustainable Goals’ agenda, the UN, in which the article states ‘Last year (2019), the UN announced its
support for Thriving Together, a collaboration of more than 150 organisations committed to the
‘recognition of the importance of family planning to conservation’’. This anti-human double speak group,
‘Thriving Together’ [16]
, remains active, and continues to hold the support of the UN, and various other
well known Malthusians.
Understanding these facts, it therefore requires considerations to areas of the CMA’s intended aims.
Resolutely deter anti-competitive behaviour (5.7)
This is an area of focus where the CMA must recognise and act on existing anti-competitive
undertakings, which I will now expand upon.
There are three specific organisations I will refer to here, whereby it is highly recommended for the
CMA to pay close attention:
Mission Possible Partnership [17]
– Based on the false climate narrative evidenced above, the
critical industries are under attack from the external bodies (i.e. not UK, but operating within the UK)
behind this ideological agenda, and are doing so with zero pushback from the relevant bodies,
whether due to ignorance or cowardice, and the specific attack is stated as ‘transforming’: ‘concrete,
steel, aluminium, and chemicals—as well as the ships, planes, and trucks that move them’. As my
company is directly involved in the steel sector, I can state unequivocally once again that this attack
on steel is dangerous, as they are messing with material structural integrity.
It is further a clear case on anti-competition that some external body is influencing, or more
specifically coercing, entire sectors to act on matters that they clearly know nothing about, and have
zero comprehension of consequences.
Task Force on Climate-related Financial Disclosures [18]
– Here we have yet another external
body, but I will combine this foreign body with a domestic (UK) entity acting in similar bad faith,
which is the UK Sustainable Investment and Finance Association (UKSIF) [19]
– Where we have
an activist organisation driving the financial sector of the UK into anti-competition practices.
This is made worse by the complicity of the Financial Conduct Authority (FCA) [20]
as the problem
being faced is an ideological takeover, where the citizens of the UK have given zero mandate to
these organisations to implement an ESG (Environment, Social, Governance) command and
control economy.
As the CMA makes reference to energy systems, it would bode well for the CMA to become
educated as to the consequences of these anti-competitive command and control influences via
prime example such as Germany and their ENERGIEWENDE [21]
programme.
On a practical perspective example, Thomson Reuters have written about hiding ESG in their article
titled: ‘Convergence of AML sanctions regulations & ESG risk’ [22]
, where my company has direct
experience of this, due to my bank using the 'Money Laundering, Terrorist Financing and Transfer
of Funds Regulations 2017, sections 27 & 28' to threaten closure, with zero accusation or evidence
to justify this.
The fact that I have had to fly regularly over the past 7 months has triggered these actions, created
by ideologues that use private jets, and by default are insinuating a ‘crime’ on my part for merely
flying, in the ‘one rule for thee’ agenda being further enabled by the UK Government and their

‘Absolute Zero’ [23]
programme. In this respect I would again refer the CMA to the Universal
Declaration of Human Rights [5]
, specifically Article 13.
This form of anti-competition, and ideological attack on business is being recognised outside of the
UK, and as it is clear that the UK Government is being led by the nose by external bodies, it may
prove wise to understand how a more democratic nation (i.e. not the EU) is advancing actions,
where the example would be the House Republicans of the US are raising question of violations of
antitrust laws [24]
.
I can also recommend further reading as to how anti-competition laws will be invoked in regard to
banking and financial discrimination by way of two papers provided by the Heartland Institute [25] [26]
.
In essence, if the CMA complies with the UK Government ‘Net Zero’ agenda, it will be acting
unlawfully across multiple obligations.
Help emergent sectors to develop into high growth, innovative and competitive markets (5.9)
Here we also run afoul of obligations, and directly into command and control economics.
We are currently witnessing a delusional perspective of ‘innovation’, whereby Government seems to
believe that by wearing ruby skippers, clicking the heels together, and saying ‘innovation’ three
times, they will miraculously see the country land in innovation wonderland. This is economically,
historically and intellectually illiterate.
To have an aim to deter anti-competitive activities at the same time as aiming to pick the winners
and losers of ‘innovation’ is pure ‘Maoism’, and I can’t believe I have to remind a Government
department in the UK that this ideology does not work out well, and have included reference
material titled ‘Remembering the biggest mass murder in the history of the world’ [27]
.
This also leads into the CMA having to remind itself of previous findings in regard to the Governments
incompetent interference into the energy markets via it’s 2015 Energy market investigation Summary
of provisional findings report [28]
, whereby this form of assistance to rent seekers has continued,
driving up energy costs to grossly unaffordable levels, as is being admitted even by the media, as
per the article ‘As energy costs soar, Britain becoming less attractive for investment, manufacturers
warn’ [29]
. The reduction of gas from Russia, that made up ‘less than 4% of the total UK gas supply’
[30]
is not responsible for this.
It is clear that ‘innovation’ in the energy market, is void of any competent Government intervention,
and the previously mentioned ENERGIEWENDE [21]
programme is a path that should not be
emulated, where the starkest example of ideological interference has been seen in the Government
response to the call to end the ban on fracking, wherein the Government stated ‘further analysis
would be needed to confirm whether hydraulic fracturing could be done safely’ [31]
, at the same time
as promoting ‘innovation’ such as wind energy, despite no such similar consideration of ‘safety’ to
wildlife, as per the evidence provided in the reports ‘Green Killing Machines’ [32], and ‘Are Wind
Turbines Killing Whales’ [33]. With a demonstrable failure of scientific evidence of ‘climate’
doomsday, being the obvious ideological reason for hindrance toward cheap fossil fuel, and blatant
support for ‘innovation’ that is both dangerous and void of proof of business, makes the Maoism
comparison entirely justifiable.
There is a reason why Government has no place being the arbiter of ‘innovation’, and hence neither
should the CMA be empowering itself with abilities beyond its capacity.
Deliver tangible, demonstrable benefits (5.13)
My additional responses to this segment will be shorter, and the ‘deliverables’ will be based on the
‘Areas of Focus for 2023 – 2024’.

6.7 ‘Greenwashing’ – This work must include false claims made by Government, up to and
including false claims of ‘climate change’.
6.9 ‘Caring … Healthcare’ – It would be wise for the CMA to consider and investigate instances of
Government signing non-liability contracts with suppliers of medicines, ‘vaccines’ etc., especially in
circumstances of distribution of supplies that do not, and have not, met any standards of safety and
efficacy, as per definitions prior to 2020.
6.11 ‘Cartels’ – I refer once again to the cartels coercing the financial sector into unlawful ESG
activities, but I would also refer the CMA to the ‘Procurement Reform’ programme [34]
, which is a
Government approved ‘pay to play’ cartel. This cartel actively introduces barriers to entry.
6.18 ‘Environmental sustainability’ – I will continue to point out the illegitimate and unlawful nature
of assisting anti-competitive activities through the stated intention to ‘develop or accelerate the
adoption of more environmentally sustainable products and services’, in direct contradiction to the
CMA’s remit.
6.20 a) ‘Peat ban’ – Based on what, and replaced with what?
6.20 b) ‘Distortive subsidies’ – I would point to the various forms of subsidy, as not every route to
funding is called ‘subsidy’. This includes methods such as via the UKRI, EPSRC, SBIR and AHSN
programmes. These are routes that provide funding to large organisations, subsidising their R&D,
and funnelling SME ‘innovation’ into large business, and hence installing barriers to entry and once
again picking winners and losers.
CONCLUSION
Despite any request via Ministers, the CMA holds a defined remit, and it is incumbent on the
management and staff of the CMA to fulfil this role. As a regulator, no other actions or activities are
required, and there is no need for the CMA to produce any ‘Plan’ that is external to these duties.
Above all, despite any coercion from Government Ministers or any other source of influence, the
CMA must abide by its remit within the applicable laws and codes of conduct, and reject any
activities based on ideology and unproven claims.
If any ‘Plan’ were to be performed, I would suggest a greater concentration on competent due
diligence.
[1] CMA guidance on environmental claims on goods and services:
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1
018820/Guidance_for_businesses_on_making_environmental_claims_.pdf
[2] Ethical standards for providers of public services:
36942/CSPL_EthicalStandards_web.pdf
[3] Civil Service Code: https://www.instituteforgovernment.org.uk/explainers/civil-service-code
[4] Human Rights: The UK’s international human rights obligations:
https://www.gov.uk/government/collections/human-rights-the-uks-international-human-rights-
obligations
[5] Universal Declaration of Human Rights: https://www.un.org/en/about-us/universal-declaration-of-
human-rights
[6] Climate Change 2021: The Physical Science Basis (Full Report):
https://report.ipcc.ch/ar6/wg1/IPCC_AR6_WGI_FullReport.pdf

[7] CLIMATE FACT CHECK 2022: https://junkscience.com/wp-content/uploads/2022/12/Climate-
Fact-Check-2022_v793.pdf
[8] In our hands: behaviour change for climate and environmental goals:
https://publications.parliament.uk/pa/ld5803/ldselect/ldenvcl/64/64.pdf
[9] Written evidence from InfluenceMap:
https://committees.parliament.uk/writtenevidence/108046/pdf/
[10] Written evidence from British Standards Institute:
https://committees.parliament.uk/writtenevidence/108005/pdf/
[11] The Economics of Biodiversity: The Dasgupta Review:
62785/The_Economics_of_Biodiversity_The_Dasgupta_Review_Full_Report.pdf
[12] Population Matters: https://populationmatters.org/
[13] The Simon Abundance Index: A New Way to Measure Availability of Resources:
https://www.cato.org/policy-analysis/simon-abundance-index-new-way-measure-availability-
resources
[14] Sustainable development – historical roots of the concept:
https://www.tandfonline.com/doi/full/10.1080/15693430600688831
[15] Woke eugenics : https://thecritic.co.uk/issues/march-2020/woke-eugenics/
[16] Thriving Together: https://thrivingtogether.global/
[17] Mission Possible Partnership : https://missionpossiblepartnership.org/
[18] Task Force on Climate-related Financial Disclosures: https://www.fsb-tcfd.org/
[19] UK Sustainable Investment and Finance Association (UKSIF): https://uksif.org/
[20] FCA A strategy for positive change: our ESG priorities:
https://www.fca.org.uk/publications/corporate-documents/strategy-positive-change-our-esg-priorities
[21] GERMANY’S ENERGIEWENDE A disaster in the making, Fritz Vahrenholt:
https://www.thegwpf.org/content/uploads/2017/01/Vahrenholt-Energiewende.pdf
[22] Thomson Reuters – Convergence of AML sanctions regulations & ESG risk:
https://www.thomsonreuters.com/en-us/posts/investigation-fraud-and-risk/aml-sanctions-esg-risk/
[23] Absolute Zero: https://ukfires.org/absolute-zero/
[24] House Republican letter to Climate Action 100+ :
https://www.scribd.com/document/612712009/House-Republican-letter-to-Climate-Action-
100?secret_password=Mwh1dnvVutA58FgVubBG#
[25] ESG: The Banking Industry: https://www.heartland.org/_template-
assets/documents/esg/PolicyTipSheetESG7src.pdf
[26] ESG: Financial Discrimination: https://www.heartland.org/_template-
assets/documents/esg/PolicyTipSheetESG8src.pdf

[27] Remembering the biggest mass murder in the history of the world:
https://www.washingtonpost.com/news/volokh-conspiracy/wp/2016/08/03/giving-historys-greatest-
mass-murderer-his-due/
[28] Energy market investigation Summary of provisional findings report (2015):
https://assets.publishing.service.gov.uk/media/559ad883e5274a155c00001b/EMI_PFs_Summary.p
df
[29] As energy costs soar, Britain becoming less attractive for investment, manufacturers warn:
https://www.reuters.com/world/uk/uk-becoming-less-attractive-investment-manufacturers-warn-
2023-01-09/?mc_cid=68c967d683
[30] Russia-Ukraine and UK energy: factsheet: https://www.gov.uk/government/news/russia-
ukraine-and-uk-energy-factsheet
[31] End the ban on fracking (Government Response):
https://petition.parliament.uk/petitions/608745?reveal_response=yes
[32] Green Killing Machines: https://www.thegwpf.org/content/uploads/2019/07/Green-Killing-
Machines-1.pdf
[33] Are Wind Turbines Killing Whales: https://www.cfact.org/2016/03/04/are-wind-turbines-killing-
whales/
[34] Procurement Reform programme: https://www.procurementreform.co.uk/

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Competition and Markets Authority Annual Plan 2023 to 2024 consultation.pdf