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?
Strongly disagree
2b. Please share the reason for your answer in the space provide
Where is the principle carbon neutral? Canada is on fire while we focus on attracting investment for fossil fuels. We need to wake up to the scientifically based facts: it is time to stop spoon-feeding investors. As for question 3, it is not possible for me to give credible answers as business future pathways has not defined these terms using concrete examples.
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
- Not that important
- Dynamic
- Not that 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 disagree
4b. Please explain your answer in the space below
Why not give 'entities' full rein to do significant harm and have no social safeguards, rather than go through the motions of partial alignment? Would there be consequences for 'entities' with criteria not being met? Would it be an honour system based method of disclosure? How ironic and naive if so.
5a. Do you agree or disagree with the proposed scope of objectives to be covered under the DNSH and MSS frameworks?
Strongly disagree
5b. Please explain your answer in the space below
I get the impression of a serious attempt at green washing. I will repeat: Canada is on fire. This is a consequence of climate change. Climate change is a consequence of the burning of fossil fuels. We have known this for decades.
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 disagree
6b. Please explain your answer in the space below
What is the definition of 'where necessary'? Who gets to decide? The Canadian people? Why bother to say that the frameworks would be grounded in Canadian legislation if that legislation can be so easily disregarded?
7. In which areas, if any, is it necessary to go beyond existing laws and standards for the DNSH/MSS framework?
Let us go beyond the minimum and do everything we can to save our land and waters, so that seven generations from now have clean air, clean water and healthy food.
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?
Neutral
8b. Please explain your answer in the space below
Does larger in size mean larger in potential environmental impact? This is a vague question.
9. Are there any gaps in the proposed DNSH/MSS framework that could result in unintended environmental or social harms?
I haven't seen the framework so cannot comment. The wording of the question implies that the framework was conceived in terms of intentional environmental and social harms. Intentional implies known harms. I cannot agree to enhancing the economic prosperity of the few with the hopes of a trickle down effect for the many at the cost of the destruction of habitat. We cannot live without the land.
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?
I think if you understand those words unambiguously the answer is obvious. There is no shortcut.
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
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?
Strongly disagree
13b. Please explain your answer in the space below
A category is categorical, by definition. Having a potential for anything does not mean that that potential will become reality.
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?
Strongly disagree
14b. Please explain your answer in the space below
See above.
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
Is it possible to have decarbonization investments in fossil fuel industries? Is this not an abuse of the English language? Carbon capture and storage is a green washing mechanism for fossil fuel companies. The only viable decarbonization is transitioning to renewable energy. Why not encourage that kind of investment, when, as mentioned, demand for fossil fuels is decreasing and the global energy market is investing in renewables. It seems that Canada, for reasons unknown, wants to be the dinosaur in the energy market.
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?
Calling them guardrails is not convincing me that they would be respected. The previous suggestion is that Canadian law itself is up for dismissal if the law constrains investment.
17. Is there any other feedback you would like to provide on the proposed activity classification framework?
Consultants should inform themselves on climate change before proceeding with the proposition.
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
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
- Not at all 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?
Absolutely specific.
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?
Scope 1, 2 and 3 need to be better defined.
Final questions
22. Overall, how satisfied are you with the proposed sustainable finance taxonomy framework?
Very unsatisfied