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?
Agree
3. Please rate each of the principles below on a scale from “very important” to “not at all important.”
- Credible
- Very important
- Usable
- Important
- Interoperable
- Important
- Dynamic
- 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?
Agree
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?
Agree
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?
Strongly agree
12b. Please explain your answer in the space below
"Green" investments should only go towards activities that have a beneficial impact on the climate, thus this framing is important for the effectiveness of this taxonomy.
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?
Neutral
13b. Please explain your answer in the space below
This approach is reasonable, but caution needs to be taken when defining this category, I believe that investments in the transition category should only go to organizations that have shown a willingness to decarbonize through their action and material reductions in their emmisions, not just a commitment. It would also ideally be best for the taxonomy to focus on investing in and scaling up businesses in these sectors that are already low carbon (e.g. green steal and green cement), but I recognize the importance of bringing other players in these sectors along for the transition.
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?
Neutral
14b. Please explain your answer in the space below
For the whole of activity pathway gaurdrails, I think that "technically feasible" should be further elaborated on as I believe that could be interpreted in ways that do not protect the science based credibility of the category. I also am unsure if the avoid locking in carbon gaurdrail is effectively worded to reach the desired effects as I am unsure how it will be applied (i.e. will an investment that reduces emmisions by 10 percent but locks in the other 90% of emmisions for a decade be allowed under this category).
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
This category is designed for investments in the oil and gas sector. By allowing this sector to have investments that would be part of a sustainable investment taxonomy, the taxonomy will allow the sector to effectively greenwash their activities and as such lock in further production of fossil fuels. Investments in fossil fuels cannot be considered sustainable as the burning of fossil fuels is what is causing the climate crisis. Any category that allows further production and expansion would destroy the science based credibility of this taxonomy and the credibility with meeting the 1.5 degree target set out in the Paris agreement. If we are to meet that target we needed to stop burning fossil fuels yesterday, locking in production well into the future is unsustainable.
The concerns I have listed above are in general for allowing more investments in fossil fuels and my concerns that the government will water down the gaurdrails. However I should note that this category could very much be effective if all of the gaurdrails are implemented and their is a strong specification for how quickly emmisions need to be reduced, and activities need to be sunsetted. With that said, based on past behaviour I don't believe there would be any investments in the oil and gas sector that could pass these gaurdrails, and thus the category may be ineffective.
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?
I think the gaurdrails need to have specific guidlenines about how significant the emmisions reductions need to be, how quickly assets needs to be decommisioned, and how much asset owners need to invest.
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
I think hte intent of the criteria is good, however I am concerned that as political wills change the reviews could be used to water down, rather than strengthen the taxonomy.
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
- 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?
I disagree, if we are to tackle the climate crisis we need to think about all emmisions related to an activity including those upstream and downstream.
Final questions
22. Overall, how satisfied are you with the proposed sustainable finance taxonomy framework?
Neutral