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.
- Protection of biodiversity and healthy ecosystems
- Water and marine resource conservation
- Pollution prevention and control
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
2b. Please share the reason for your answer in the space provided
The guide must not be rigid but fluid as circumstances change and progress is made. Canada is a diverse country from an energy generation perspective and the guide must be useful across the country
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
- Dynamic
- Very important
- Regionally Specific
- Very important
- Prioritized
- Very 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?
Strongly agree
4b. Please explain your answer in the space below
In order to be accepted and adopted it must work with these parameters
5a. Do you agree or disagree with the proposed scope of objectives to be covered under the DNSH and MSS frameworks?
Strongly agree
5b. Please explain your answer in the space below
The framework cannot work in isolation from other important quality of life contexts
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?
Strongly agree
6b. Please explain your answer in the space below
Application of the rule of law is essential for success. However given the crisis new and innovative law will be required.
7. In which areas, if any, is it necessary to go beyond existing laws and standards for the DNSH/MSS framework?
We will leave this up to those with greater wisdom
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
8b. Please explain your answer in the space below
Although hesitant to create different standards based on the size of the project, it may not be feasible to have the same level of detail and scope for smaller projects. We do not want to dissuade smaller projects from embracing the guidelines because of the administrative overhead
9. Are there any gaps in the proposed DNSH/MSS framework that could result in unintended environmental or social harms?
Yes not so much gaps but possible inclusions. Abate clauses risk legitimizing continued fossil fuel growth rather than aligning with pathways that actually reduce emissions. They could become greenwashing mechanisms that justify fossil fuel growth rather than supporting a a real green taxonomy. Keep it out of the taxonomy and deal with abatement separately through legislation
10. How should the taxonomy operationalize the principles of the UN Declaration on the Rights of Indigenous Peoples and, in particular, the principle of Free, Prior, and Informed Consent, in the MSS framework?
It should align with UNDRIP
11. Is there any other feedback you would like to provide on the proposed MSS/DNSH framework?
This is a great news. Let’s not undermine its impact by allowing loopholes for fossil investments to be granted legitimacy
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 agree
12b. Please explain your answer in the space below
We need to be clear that this about emissions reductions/elimination not greenwashing opportunities
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
We need to assist hard to transition industries and encourage creativity and innovation
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
14b. Please explain your answer in the space below
Need room for yet to be imagined technology that will assist in the transition
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.
15a. Do you agree or disagree that the taxonomy should include a third “abatement” category, as proposed, that covers demand-decline activities?
Strongly disagree (i.e., disagree on fundamentals)
15b. Please explain your answer in the space below
As noted before, this could create loopholes for fossil fuels and I am not sure they can be closed so leave it out and deal with it outside the taxonomy
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.
16. Should any additional guardrails be considered?
The fossil fuel industry is great at poking holes in emission reduction strategies. Better to exclude than provide insufficient 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?
Agree
18b. Please explain your answer in the space below
Agility and future focus will be keys to success
19. Please rate each of the proposed elements for the screening criteria on a scale from “very important” to “not at all important.”
- Forward-looking wherever possible
- Very important
- Include sunset and/or sunrise dates where relevant
- Important
- Revise as necessary during regular review periods
- Very important
- Primarily use quantitative metrics
- Very important
- Primarily focus on Scope 1 emissions but address Scope 2 and 3 emissions where feasible and/or material
- Very important
- Informed by a range of robust methods
- Very important
20. When thinking about the taxonomy’s credibility and usability, how technologically specific or prescriptive should the technical screening criteria be?
Technology will change over time so openness to technological evolution means less specificity
21. Do you agree or disagree with the proposed approach of focusing primarily on Scope 1 emissions, and addressing Scope 2 and 3 emissions where feasible and/or material?
Agree. Let’s get to the root of each project
Final questions
22. Overall, how satisfied are you with the proposed sustainable finance taxonomy framework?
Satisfied