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?
Strongly agree
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?
Select
5a. Do you agree or disagree with the proposed scope of objectives to be covered under the DNSH and MSS frameworks?
Select
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?
Select
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?
Select
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?
Strongly disagree
12b. Please explain your answer in the space below
The proposed criteria for green category activities excludes activities with negative emissions. We strongly recommend that the criteria be edited to say activities with “zero, near-zero, or negative emissions”. As noted in footnote 15 on page 26, carbon removal is required for Canada to achieve net-zero. The Climate Change 2022 report by the IPCC (AR6 WGIII) states “The deployment of carbon dioxide removal (CDR) to counterbalance hard-to-abate residual emissions is unavoidable if net-zero CO2 or GHG emissions are to be achieved.” All modelled scenarios that limit warming to 2 degrees or lower by 2100 require deployment of carbon dioxide removal. Given the goal of the taxonomy is to help accelerate investment into climate solutions and achieve the ambition set out in the Paris Agreement, there’s no reason why this subset of solutions is treated differently than other mitigation measures. Both zero and negative emissions activities can credibly mitigate climate change, as long as the same DNSH and MSS criteria are met.
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?
Select
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?
Select
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?
Neutral
23. Is there any other feedback you would like to provide on the methodology report as a whole that has not already been covered?
The sector prioritization process, as outlined, makes sense, but risks leaving out potentially high impact activities. As acknowledged in footnote 15 on page 26, across the range of carbon dioxide removal activities, some do not fit neatly within existing economic sectors identified as emission sources. Solutions like river alkalinity enhancement and direct air capture do not fit within any sector, and so may be left out of potential consideration for taxonomy inclusion. By contrast, other carbon dioxide removal activities like enhanced rock weathering and surficial mineralization can be slotted within existing sectors (agriculture and mining, respectively).
We recommend allowing flexibility within each sector to allow inclusion for activities that represent opportunities to integrate carbon removal in novel ways within the standard sector activities. To clarify, this would be to draw down total emissions through direct physical assets, not offsets. For example, direct air capture could be built alongside a range of facilities spanning electricity, manufacturing, and buildings, as a way to turn byproducts like waste heat or sodium hydroxide into atmospheric CO2 capture. Biogenic carbon capture and storage can be integrated into pulp and paper, electricity, and manufacturing facilities. There are many other emerging opportunities to physically integrate carbon removal processes within existing industrial activities. Flexibly recognizing potential integrations that meet green activity definitions and DNSH/MSS would satisfy the forward-looking criteria set out in this taxonomy and ensure future relevance without the need for updates.
Alternatively, carbon removal technologies could be grouped into their own subcategory given their overlapping nature. We recognize that not every standalone technology warrants its own category, but given the international consensus that carbon removal is integral to achieving net-zero, we believe it merits closer consideration. A dedicated subcategory would keep these technologies from being scattered across other categories and would future-proof the framework, so that as new technologies and deployment models emerge, the terminology still holds.