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
- 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
3. Please rate each of the principles below on a scale from “very important” to “not at all important.”
- Credible
- Important
- Usable
- Very important
- Interoperable
- 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?
Strongly disagree
4b. Please explain your answer in the space below
I am concerned that partial alignment allows for political misuse. I am concerned with greenwashing and that projects could be funded and given a label that misleads the public as to the degree of alignment with a more climate-preserving taxonomy category.
5a. Do you agree or disagree with the proposed scope of objectives to be covered under the DNSH and MSS frameworks?
Agree
5b. Please explain your answer in the space below
I am fundamentally concerned that we are proposing "Do No Significant Harm", as opposed to "Do No Harm". And, also – how will these harms be identified and quantified? Harm to one's own preferred industrial sector is not equal to harm to the environment. Economic change can be an impact of a climate solution but the "harm" can be reduced if there are ways to appropriately train and redeploy resources. A macro view is important. Too often we have viewed "harm" to an economic sector as more important and have not considered viable alternatives that would allow people to continue to work (albeit in new ways) and reached our objectives.
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
I do not think our existing laws are sufficient to protect our nature environment nor our managed food systems.
7. In which areas, if any, is it necessary to go beyond existing laws and standards for the DNSH/MSS framework?
We have recently repealed laws in Ontario to protect the environment in favor of development. We have also repealed laws around pesticides use on farms at a national level. These changes have a negative impact on natural habitat and biodiversity. I believe we need to be more mindful not less stringient.
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 disagree
9. Are there any gaps in the proposed DNSH/MSS framework that could result in unintended environmental or social harms?
I am sure that there are. The wording is loose and open to interpretation. Note my earlier comments on the definition of "harms" and how we weight them.
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 am not a member of an Indigenous population. Fundamentally I do not believe that the general public should be asked to address this question. This must be a negotiation with the Indigenous nations based on the treaties under which we are bound. I do not believe that the general public understands the harms already caused.
11. Is there any other feedback you would like to provide on the proposed MSS/DNSH framework?
Many of our most polluting activities have happened adjacent to Indigenous communities and have resulted in the pollution of the air, land and water and poisoning the people that live there. As a nation we should be deeply ashamed and put resources into remediation. I have yet to see that done sufficiently (e.g. Grassy Narrows). We live in a country with a track record of doing harm to the most vulnerable. Our MSS/DNSH taxonomy should be as clear as is required to make sure ALL potential harms evident so that any project can be assessed from the perspective of being better and doing what is right.
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?
Agree
12b. Please explain your answer in the space below
If the activities enable zero or near zero climate solutions, how we get there is important as well. The supply chain of the activities need to be evaluated to identify and work towards reducing the climate impact of any process that creates the near-zero emissions climate solutions. We cannot only look at the end result but how we got there as well.
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
"Potential to decarbonize" – this phrase depends on a lot of things. How will we ensure that the positive impact out weight the negative, Here is an area where we could most definitely inadvertently cause harm.
In many causes, new technologies only improve through growing demand due to the "make good enough but then iterate on improvements to be better" philosophy of most technology development. The only way to ensure enough demand to go through this iterative improvement cycle will be through regulations that require its use and money to fund. I am not convinced that these two requirements will be met.
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
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
Abatement encourages continuation of the activity that causes pollution. Many of the abatement technologies are not yet mature and cannot perform the large scale reductions required and thus will require significant investments. This investment will divert money away from cleaner (green category) options. It is likely that this category would prolong our heavy reliance on fossil fuels due to the sunk-cost in these sectors, the lack of vision on how to redeploy our workforce out of these industries, and the political challenges of asking our western provinces to imagine a future without fossil fuels supporting their economy.
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 comment
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
18b. Please explain your answer in the space below
The partial alignment is a problem for me. It is an opportunity for abuse of the system.
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
- 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 that 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?
NO
Final questions
22. Overall, how satisfied are you with the proposed sustainable finance taxonomy framework?
Unsatisfied