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.
- 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
This taxonomy must be credible. It must take into account all submissions in a respectful and meaningful way and take all details, comments and suggestions seriously.
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
- Very important
- Regionally Specific
- Very 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
Only full alignment can be acceptable to be meaningful. Parital alignment can allow for a slippery slope of alignment that may lead to actions that do harm and not meet social safeguards.
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
The scope of objectives refer to the word significant. The meaning of the word significant and the determination of what is concluded to be significant can vary when not defined in detail.
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
This needs to be taken seriusly.
7. In which areas, if any, is it necessary to go beyond existing laws and standards for the DNSH/MSS framework?
The framework should ensure that lobbyists are not able to twist the meaning and purpose of the framework to support initiatives or actions of any kind that weaken the framework.
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
8b. Please explain your answer in the space below
comprehensive disclosures must be required for all projects and/or entities of any size because these standards must be held to a very high bar.
9. Are there any gaps in the proposed DNSH/MSS framework that could result in unintended environmental or social harms?
Not if followed and be required to be followed and also measured and monitored with the needed oversight. Failure to monitor appropriately would be a gap.
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?
By making sure there is sufficient oversight by the needed number of people in each province and to ensure the public is well informed. Transparency is very important.
11. Is there any other feedback you would like to provide on the proposed MSS/DNSH framework?
I would like my submission to speak to this question and that is why I am attaching a detailed pdf file that I request be made available to the public for review.
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 disagree
12b. Please explain your answer in the space below
A green category cannot be near-zero. It must be able to expedite the transition away from Fossil Fuels to help meet targets. Near-zero can becomce subjective and stretched beyond the word near.
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?
Strongly disagree
13b. Please explain your answer in the space below
The words "potential to decarbonize sufficiently" is a wide open phrase that is unacceptable. Claims can be made with the the word "potential" and "sufficiently" that can result is greenwashing statements and this must be avoided for credibilty to be established.
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
14b. Please explain your answer in the space below
The guardrails are not strong enough and can be stretched by claiming "potential benefits" that are not proven and "sufficient benefits" that are not sufficient.
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
My answer is a definate no. A third "abatement" category must not be established. For my detailed reason please see my detailed answer in my attached pdf file response and post this for public viewing.
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?
An addional guardrails should be the inclusion of the determination of all Scope 1, Scope 2 and Scope 3 emissions by detailed mathematical calculations by all parties. This means the mathematics of all emissions generated needs to be examined much more than at present. Emissions must not be allowed to be buried by a lack of calculation and attention.
17. Is there any other feedback you would like to provide on the proposed activity classification framework?
Yes – The framework activityt classification must focus attention on and be able to expedite the transition away from fossil fuels. Time matters in our efforts to transition away from fossil fuels as fast a possible. All governmets should be working on this goal 24 hours a day every day. The government of Canada should hire the needed mathematicians and engineers to work 3 shifts a day every day to help expedite the work involved.
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
In my view whatever approach is used the approach should be focused a nd staffed as needed to ensure success.
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
- Very 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
- Very important
- Informed by a range of robust methods
- Very important
20. When thinking about the taxonomy’s credibility and usability, how technologically specific or prescriptive should the technical screening criteria be?
Very specific and very prescriptive. Transparency is very important and transparency needs both.
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. To succeed Scope 2 and 3 must be given as much focus as Scope 1. Anything less will reduce the efforts to ensure a healthy and safe future for all people living today and all future generations. That should be considered unacceptable.
Final questions
22. Overall, how satisfied are you with the proposed sustainable finance taxonomy framework?
Very unsatisfied
23. Is there any other feedback you would like to provide on the methodology report as a whole that has not already been covered?
Considering the importance of the methodology report and the need for it to guide Canada in its efforts to transition away from fossil fuels as fast a possible, I am very disappointed that it is introducing or suggesting a third category as technically defensible. The question is whether adding that category gradually alters the meaning of the entire taxonomy. Please see my detailed pdf submission.