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
- 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?
Select
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
- 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?
Select
5a. Do you agree or disagree with the proposed scope of objectives to be covered under the DNSH and MSS frameworks?
Select
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?
Select
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?
Select
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
Activities classified as green must have zero or near-zero emissions. Enabling activities for near-zero climate solutions should themselves also have near-zero emissions to be classified as green. We cannot evaluate climate solutions in isolation from the lifecycle of the materials required for these solutions and the consequences of adopting these solutions. Thus, emissions from sourcing materials (manufacturing, mining) and from disposing of materials (whether waste by-products or end-of-life products) need to be accounted for. Other consequences of proposed green climate solutions may include emissions associated with land-use changes or with replacing old equipment with low-emission alternatives. All emissions associated with enabling an activity or consequences of an activity should be accounted for and only activities with minimal associated emissions should be classified as green, regardless of whether the activity is a climate solution or an enabling activity.
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
The requirement that activities in the transition category align with pathways to net zero emissions by 2050 is critical, as is avoiding locking into dead-end pathways.
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
14b. Please explain your answer in the space below
The proposed guardrails appear sufficient, as long as the screening criteria are strong enough. The thresholds for the extent to which a measure must reduce an activity's emission to qualify as a transition measure will need to require a large enough reduction in emissions to realistically achieve zero emissions by 2050.
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
Including an abatement category promotes continued investments in oil and gas. While it is possible that emissions from oil and gas could be decreased, these decreases will never be sufficient to mitigate climate change.
We need to redirect capital toward Paris-aligned investments. Supporting fossil fuel production—the largest source of GHG emissions in Canada—cannot be considered sustainable, especially when renewable energy alternatives exist.
As the Report acknowledges, even with abatement measures, total emissions can rise if production increases. A significant production increase is expected to fill the proposed new pipeline to the BC coast. If fossil fuel production continues in the near term, decarbonization should be addressed through regulations mandating reduced carbon intensity.
If an Abatement category is included in the Taxonomy:
– All guardrails in the Report should apply to all permitted measures.
– The "significant reduction" requirement should set a very high bar.
– The guardrail for existing assets should exclude expansion.
– Carbon capture measures should not include enhanced oil recovery, as using captured carbon to extract more oil cannot be considered sustainable.
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.
17. Is there any other feedback you would like to provide on the proposed activity classification framework?
Classifying activities that truly contribute to decreasing Canada's greenhouse gas emissions to as close to zero as possible is a valuable way to promote investment into these activites. For this approach to be credible and to actually advance Canada's climate goals, in line with the Paris Agreement, fossil fuels must be completely excluded from the Climate Finance Taxonomy.
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.”
- Include sunset and/or sunrise dates where relevant
- Very important
Final questions
22. Overall, how satisfied are you with the proposed sustainable finance taxonomy framework?
Select