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?
Agree
2b. Please share the reason for your answer in the space provide
The devil is always in the details hence my slight caution!
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
- 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
It is time to think beyond selfish profit – move from the ME generation to the WE generation – that eans being far more honest.
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 “do not adversely impact other environmental and social values, or legal rights” sums it up for me very nicely.
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
Simply makes sense to me, for the good of all. That may mean setting aside old “defaults” that have been allowed to dictate strategies or allow loopholes.
7. In which areas, if any, is it necessary to go beyond existing laws and standards for the DNSH/MSS framework?
Where habit and “accepted norms” have been established mainly for the goal of constantly increased profits.
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
Every project must be treated as equal or companies will find loopholes in the language. A well established tactic. The only concessions could perhaps be “company sized” levels for certain requirements but they must make sense so that everyone feels they are being treated fairly.
9. Are there any gaps in the proposed DNSH/MSS framework that could result in unintended environmental or social harms?
It would be difficult to pen anything that guarantees no harms slip through the net, but as a fairly solid basis I feel but it is a good starting point. Reviews will be key to close unforeseen loopholes as they are identified.
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
As an EV Senior owner, buying an EV was by far the simplest and quickest change to make in lifestyle with the biggest effect on the environment. The facts that TCO is lower and the driving experience is a noticeable improvement are a bonus! The changes to lifestyle are truly minimal – I have experienced charging in a house, public charging and now in a condo situation -all easily managed even as a Senior. I also assisted our son to make the move to an EV so even if people feel they “can’t” make the shift they can at least “pay it forward”!
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
I may be reading this incorrectly but this sounds more like pandering to the oil and gas industries than making decisive changes that are needed now. Prioritize those changes that can be easily made and support them massively, e.g. EVs (yes I am biased but as explained it is part of the easier solutions list – only current encouragement is at best “luke warm”). Those areas that need to move more slowly are definitely recognized and accepted, but the key will be HUGE communications to the public and much more financial encouragement.
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.
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 this taxonomy is to have any credibility at all it must never build in loopholes or loose language as in an abatement category so that the oil and gas companies can take them as they have done repeatedly while knowing what their industries were going to create and what we are now experiencing. This was known decades ago and has been ignored. Like the tobacco and asbestos industries they must now take full responsibility and act in the best interests of the public – their shareholders gains cannot rule when the environment is the cost of providing dividends – no more kicking it down the road for the future generations.
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?
Agree
18b. Please explain your answer in the space below
Once more the devil will be in the details. The criteria should be done with no companies who have created the current situation being involved. Not a time to let lobbyists once more create language loopholes.
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
20. When thinking about the taxonomy’s credibility and usability, how technologically specific or prescriptive should the technical screening criteria be?
Detailed sufficiently to ensure adherence.
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?
As a starter yes but some timeframe of when things would happen would provide more trust by the public IMO
Final questions
22. Overall, how satisfied are you with the proposed sustainable finance taxonomy framework?
Satisfied
23. Is there any other feedback you would like to provide on the methodology report as a whole that has not already been covered?
My main concern is to not include any language that lawyers can misinterpret so as to avoid real actions that support the meat of the taxonomy. I support the direction but please don’t give off ramps for those who put profits above the environment . . . . as others before you have clearly done.