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.

  • 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

We need to stop funding pipelines and fossil fuels to curb our greenhouse gas production. This is not regional; this is Canadian and worldwide. We need to finance renewables as our prime source of energy.

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
Not that important
Regionally Specific
Not at all 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

Yes, we want to DNSH and have MSS. As a doctor, prevention is better than cure that often doesn't exist. This is part of the precautionary principle.

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

Agree

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

Yes, we want to DNSH and have MSS. As a doctor, prevention is better than cure that often doesn't exist. This is part of the precautionary principle.

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

Our environment needs to be restored now, not by 2050.

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

DNSH/MSS standards need to be in place across the board.

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?

Yes, these principles need to be respected, and enforced.

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

We have seen green washing occur and need to have the green category mean something.

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

Cement is having new ways to mitigate its green house gas production.
The manufacture of steel is going electric such as Algoma Steel in Ontario.

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?

Agree

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?

Agree (i.e., agree in principle, with conditions)

15b. Please explain your answer in the space below

Oil and gas and LNG can do a lot to mitigate methane gas release now.
Yes, we need to not be expanding production and should do no further exploration.

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?

Yes, the bottom line is to curtail greenhouse gas production by curtailing fossil fuels and LNG.

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

We need to stop funding fossil fuels through our government taxes. Let the huge profits of the Oil and Gas industry fund their projects.

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
Important
Revise as necessary during regular review periods
Important
Primarily use quantitative metrics
Important
Primarily focus on Scope 1 emissions but address Scope 2 and 3 emissions where feasible and/or material
Important
Informed by a range of robust methods
Important

20. When thinking about the taxonomy’s credibility and usability, how technologically specific or prescriptive should the technical screening criteria be?

Should be specific with timelines

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?

We need to stop funding oil and gas and LNG projects and fund renewables instead.,

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