Public Consultation Submission

Taxonomy Foundations

Please feel free to answer only the questions that are of the most interest and relevance to you.

1a. The first phase of taxonomy development will focus on climate mitigation. In subsequent phases of the Canadian taxonomy, which objectives should be prioritized? Please select your top choices.

  • Climate change adaptation / resilience

It is proposed that the design and implementation of the Canadian taxonomy be informed by the following six principles: Credible; usable; interoperable; dynamic; regionally specific; and prioritized.

2a. Do you agree or disagree with these proposed principles as the foundation for the taxonomy?

Agree

3. Please rate each of the principles below on a scale from “very important” to “not at all important.”

Credible
Very important
Usable
Very important
Interoperable
Important
Dynamic
Important
Regionally Specific
Important
Prioritized
Important

Do No Significant Harm and Minimum Social Safeguards

Please feel free to answer only the questions that are of the most interest and relevance to you.

The proposed taxonomy framework for Canada includes a set of Do No Significant Harm (DNSH) criteria and Minimum Social Safeguards (MSS), which will be designed to ensure that climate mitigation objectives do not adversely impact other environmental and social values, or legal rights. It is proposed that issuers must disclose the extent to which they meet specific criteria for both DNSH and MSS in order to claim taxonomy alignment.

4a. Do you agree or disagree with the proposed partial alignment approach, which would require entities to disclose the extent to which DNSH/MSS criteria are or are not met rather than requiring full alignment with all DNSH/MSS criteria?

Agree

5a. Do you agree or disagree with the proposed scope of objectives to be covered under the DNSH and MSS frameworks?

Agree

6a. Do you agree or disagree with the proposed approach to grounding the DNSH/MSS frameworks in Canadian legislation and going beyond existing laws and standards where necessary?

Agree

8a. Do you agree or disagree that different DNSH/MSS standards should apply to projects or entities of different sizes? E.g. more comprehensive disclosures required for larger projects and/or entities, with more streamlined disclosures for smaller projects and/or entities?

Agree

Section 3: Activity Classification Framework

Please feel free to answer only the questions that are of the most interest and relevance to you.

The activity classification framework proposes that the green category should be limited to activities with zero or near-zero emissions that make a substantial contribution to climate change mitigation or to activities that directly enable zero to near-zero emissions climate solutions (e.g., electric vehicle manufacturing facilities)

12a. Do you agree or disagree with this approach?

Agree

12b. Please explain your answer in the space below

The report defines green activities as zero- to near-zero-emission climate solutions, including activities that directly enable such solutions. This definition should encompass fuels and fuel-production pathways capable of achieving very low lifecycle carbon intensity, including advanced biofuels, SAF, renewable synthetic fuels, renewable hydrogen-derived fuels, and related production inputs and infrastructure.

The framework proposes that the transition category should include activities that have materially high emissions today but have the potential to decarbonize sufficiently to align with the green definition (i.e., zero to near-zero emissions) by 2050. These activities are likely to experience stable or growing demand in Paris-aligned representative pathways due to a lack of technically feasible low-carbon substitutes (e.g., major decarbonization investments in steel, cement, and chemicals manufacturing).

13a. Do you agree or disagree with this approach?

Agree

13b. Please explain your answer in the space below

ABFC strongly supports the inclusion of a transition category that recognizes deep emissions reductions in activities with stable or growing demand in Paris-aligned pathways. The draft proposes that transition eligibility apply either to the whole activity or to qualifying transition measures that materially improve performance.
This category should explicitly accommodate investments that displace conventional fossil fuels with low-carbon fuels. Eligible investments should include:
• New and expanded production capacity for advanced biofuels, SAF, renewable synthetic fuels, and other qualifying low-carbon fuels.
• Feedstock aggregation, preprocessing, conditioning, and logistics systems necessary for qualifying fuel pathways.
• Terminal, storage, blending, rail, marine, pipeline, and distribution infrastructure that enables the deployment of qualifying low-carbon fuels.
• Facility modifications and fuel-system investments that enable higher blends or the use of qualifying drop-in low-carbon fuels.
• Carbon-reduction measures at qualifying fuel-production facilities, including renewable process energy, energy-efficiency improvements, low-carbon hydrogen, biogenic carbon capture, and other measures that demonstrably improve lifecycle carbon intensity.

14a. Do you agree or disagree that the proposed guardrails for the transition category (both for the whole-of-activity and measures pathways) are sufficient to protect the science-based credibility of the category and reduce the risk of carbon lock-in, while supporting usability?

Agree

The report proposes that initial research on the abatement measures category should be conducted in 2027 and include select emissions-reduction measures for activities that have high Scope 1 emissions today and are unable to achieve the life cycle emissions reductions necessary to align with Paris-aligned pathways (e.g. major decarbonization investments in the upstream production, refining, and distribution of oil and gas). These are activities that are highly likely to experience declining demand as the world transitions to clean energy and alternative technologies.

The report proposes an illustrative list of guardrails for the abatement measures category that, if formally developed and finalized, would be designed to prevent carbon lock-in and ensure the abatement measures category remains credible within a Paris-aligned framework. When thinking about the taxonomy’s credibility and usability, please provide feedback on this illustrative list of guardrails.

Section 4: Technical Screening Criteria

Please feel free to answer only the questions that are of the most interest and relevance to you.

18a. Do you agree or disagree with the proposed approach for developing technical screening criteria?

Select

Final questions

22. Overall, how satisfied are you with the proposed sustainable finance taxonomy framework?

Satisfied

23. Is there any other feedback you would like to provide on the methodology report as a whole that has not already been covered?

Thank you for this opportunity to provide feedback. Please see included submission.

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