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
2b. Please share the reason for your answer in the space provided
In recent years, we have begun to face the consequences of climate warming and pollution, so there is no time to waste when it comes to action. However, to begin, we need to build a common understanding of what various investments are. A taxonomy is an excellent first step.
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
- Not that 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 agree
4b. Please explain your answer in the space below
Disclosing the extent to which the criteria are met will allow the onlooker to evaluate the proposed partial alignment approach.
5a. Do you agree or disagree with the proposed scope of objectives to be covered under the DNSH and MSS frameworks?
Neutral
5b. Please explain your answer in the space below
Still considering the scope of the 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?
Agree
6b. Please explain your answer in the space below
Grounding the frameworks in legislation will ensure that changes will be made publicly. Going beyond existing laws and standards will enable more immediate action vs. amending current laws or standards.
7. In which areas, if any, is it necessary to go beyond existing laws and standards for the DNSH/MSS framework?
While it is necessary to do our part to reduce carbon emissions, the problem is global and requires a global solution. I think the best we can do currently is focus on mitigating the impacts of climate change. Since it must be done immediately, if we are to use the framework generally, we must be careful to err on the side of effective action.
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?
Agree
8b. Please explain your answer in the space below
Once again, we must act immediately. Smaller projects may be deterred from action if encumbered with more comprehensive disclosures. Perhaps the rule should be to disclose as much as is apparent… and then act.
9. Are there any gaps in the proposed DNSH/MSS framework that could result in unintended environmental or social harms?
I am certain that there are gaps, but none that I can see at this time.
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?
UNDRIP principles are extremely important and must be followed to the best of our ability.
11. Is there any other feedback you would like to provide on the proposed MSS/DNSH framework?
None.
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 must be strong when designating activities as "green". Activities that may not qualify are always allowed to "upgrade" their rating. In addition, why should we accept anything less?
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 am extremely suspicious of activities that supposedly have the potential to decarbonize. I'm not convinced there should be a transition category. Let the proposed technology be demonstrated as effective, then re-categorize specific projects that implement green activities. A transition category will enable investments that generate high profits while not genuinely intending to contribute to a 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?
Disagree
14b. Please explain your answer in the space below
I am extremely suspicious of guardrails unless they are demonstrated to be effective.
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
In short, capital must be directed toward Paris-aligned investments. I don't understand how fossil fuel production can be considered sustainable, especially when renewable energy alternatives exist. How can we tolerate a rise in total emissions other than to preserve profits and the jobs that generate them? Let's just declare the fossil fuel era to be over. Making the transition to renewables will take time and enable a just transition for workers.
Get on with implementing renewables and redirect the resources for the proposed new pipeline to the BC coast.
In the meantime, decarbonization should be pursued through regulations that mandate reduced carbon intensity.
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?
If an Abatement category is included in the Taxonomy:
1. All guardrails in the Report should apply to all permitted measures.
2. The "significant reduction" requirement should set a very high bar.
3. The guardrail for existing assets should exclude expansion.
4. CCS should not include enhanced oil recovery since extracting more oil cannot be considered sustainable.
17. Is there any other feedback you would like to provide on the proposed activity classification framework?
That is sufficient for now. Thanks for the opportunity.
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
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?
None