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
  • 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

2b. Please share the reason for your answer in the space provide

Generally agree but not informed enough to be more positive

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
Very important
Dynamic
Important
Regionally Specific
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

Partial may allow loopholes

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

Neutral

5b. Please explain your answer in the space below

Not swayed one way or another

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

Only if proven necessary

7. In which areas, if any, is it necessary to go beyond existing laws and standards for the DNSH/MSS framework?

Not sure

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?

Strongly agree

8b. Please explain your answer in the space below

It makes sense to spend more time with projects that will have a greater effect

9. Are there any gaps in the proposed DNSH/MSS framework that could result in unintended environmental or social harms?

None that is immediately evident

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?

Indigenous Peoples in areas affected must be consulted under requirements of UNDRIP

11. Is there any other feedback you would like to provide on the proposed MSS/DNSH framework?

No

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

It’s the only way that our commitment to the Paris Agreement along with other environmental protections can be reached

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?

Disagree

13b. Please explain your answer in the space below

Not enough specifics to be part of this legislation

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?

Disagree

14b. Please explain your answer in the space below

You many future unknowns

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

If oil/gas were part of a special category investment capital would be suspicious that it doesnt align with climate related progress necessary in Canada’s taxonomy: If oil and gas activities could qualify under a special category, investors would no longer see the taxonomy as a credible standard for identifying genuinely climate-aligned investments, reducing its effectiveness in attracting capital.
It .
Too much confusion re definitions and exemptions makes it
difficult to implement fairly.
No other country includes an ‘abatement’ category.
Reducing emissions still doesn’t reduce the infrastructure of fossil fuels that we need to transition away from in the next two decades
Investments in emissions reductions at oil and gas facilities will extend the life of fossil fuel infrastructure and lower success in reaching net zero by 2050

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?

No. There should be no abatement clause as noted in previous question.

17. Is there any other feedback you would like to provide on the proposed activity classification framework?

Again no abatement clause!

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?

Very 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?

Future abatement related possibilities is a big unknown and couldn’t be covered in the methodology of the report

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