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
- Protection of biodiversity and healthy ecosystems
- Circular economy
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?
Neutral
3. Please rate each of the principles below on a scale from “very important” to “not at all important.”
- Credible
- Very important
- Usable
- Important
- Interoperable
- Not that important
- Dynamic
- Important
- Regionally Specific
- Not that 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?
Disagree
4b. Please explain your answer in the space below
Full alignment with the DNSH/ MSS criteria should required, in keeping with the binary approach taken by the European Union (EU) taxonomy. Under this approach, failure to meet any DNSH and MSS criteria precludes an activity from achieving taxonomy-aligned status
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 proposed objectives are not broad enough. They should include, minimally, respect for human rights and the rights of indigenous peoples (UNDRIP).
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?
Neutral
6b. Please explain your answer in the space below
Going beyond existing laws and standards is necessary. The Climate Aligned Finance Act (CAFA), as introduced in its original form (S-243) is the only proper framework to form the basis of legislation.
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?
Disagree
8b. Please explain your answer in the space below
It is better to enact the same disclosure obligations for all but offer relief for very small entities with neglible impacts as provided for by CAFA
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?
Neutral
12b. Please explain your answer in the space below
It must be on a full life cycle basis and exclude all fossil fuels.
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
so long as it clearly excludes all fossil fuels.
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?
Neutral
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
The addition of an abatement category harms the credibility of the taxonomy being developed. The only category in which fossil fuels belong is "phase out". See "The state of energy transition research and the need for fossil phase-out: evidence from Environmental Research Letters"
International sustainable finance groups already recognize that we must reduce fossil fuel investment. The Commission Climat et Finance Durable of the French Autorité des Marchés Financiers concluded that many initiatives have recommend reducing fossil fuel financing.Notably, its reviewix found that the following groups and initiatives urge firms to reduce financing to new fossil fuel projects:
The United Nations’ High-Level Expert Group on the Net Zero Emissions Commitments of Non-State Entities’ report on net-zero commitments
UN Race to Zero
Glasgow Financial Alliance for Net Zero
UN Environment Programme Finance Initiative
SBTi
Transition Pathway Initiative’s Net Zero Banking Assessment Framework
Climate Bonds Initiative
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?
Neutral
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
- Very 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
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?
Lifecycle emissions are the relevant metric.
Final questions
22. Overall, how satisfied are you with the proposed sustainable finance taxonomy framework?
Unsatisfied
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 process for developing the taxonomy should not be dominated by financial institutions. More independent experts should have been included in the process; specifically including scientists with no ties to the governing party.