nitpicky comment,

I even put an asterisk! Oh wait, not the usual "unlimited tape finite universe"

I was unclear. It is intentionally not Turing Complete, by way of avoiding self-references, as self-references would make it a higher-order grammar, and Turing-complete because it then it can innately loop, making it impossible to flatten to a lower, Labeled Push down automaton.

Although they are mutually exclusive, I implied causality.

Its the implicit loop and requirement of a heap/stack of variables self-referencing requires that is Turing-Complete itself.