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.
- Water and marine resource conservation
- Pollution prevention and control
- 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?
Agree
2b. Please share the reason for your answer in the space provided
Investent should only be directed towards getting credible results. CCUS is not credible and does not match any of the other 5 principles
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
- Not that important
- Dynamic
- Not that 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
By allowing some minimal standards you weaken the approach, No Significant harm is the only option.
5a. Do you agree or disagree with the proposed scope of objectives to be covered under the DNSH and MSS frameworks?
Agree
5b. Please explain your answer in the space below
Finding consensus at an international level is very difficult so whatever is agreed upon likely represents minimal standards. However, the need to not adversely impact Indigenous rights, human rights, as well as environmental and social values should not be compromised.
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
There are still many holes in environmental law that need to be closed. There also many jurisdictional barriers. Both of these may require changes that go beyond existing laws and standards to protect Indigenous rights, human rights, as well as environmental and social values.
7. In which areas, if any, is it necessary to go beyond existing laws and standards for the DNSH/MSS framework?
We must allow for changes in knowledge. Many regulators fall under provincial or federal jurisdiction, preventing one from interfering with the other, particularly in regard to protecting Indigenous rights, human rights, as well as environmental and social values. Transportation of dangerous goods, interprovincial and international water ways, water rights, right to extract resources that result in global harm – especially when exported, protection of long lived contaminants from the environment could be 'some' areas where laws need to be changed.
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?
Disagree
8b. Please explain your answer in the space below
Where do you draw the line on large and small projects. Many industries are actually a chain of industries where cumulative impacts of small entities could far exceed those of a single industry. Some industries may want to expand in the future and be grandfathered into their existing rules, rather than open up to new scrutiny. Extraction industries may decide to process at another location and avoid environmental restrictions that way. The life of an extraction industry may be extended, thereby eventually becoming a larger entity. When assessing an industry, both upstream and downstream impacts must be taken into account as to harm.
9. Are there any gaps in the proposed DNSH/MSS framework that could result in unintended environmental or social harms?
If you are referring to figure 3 of the taxonomy methodology report, the flow chart is subjective as to which way things go – no grey areas – just yes and no. who makes the decisions, does it rely on data?
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?
If a project/process can be written in clear, plain language that is easy understood by all and has full disclosure of potential harms and mitigations and the potentially impacted people fully understand these and consent to the risks and are involved in a democratic decision making process (consensus) to proceed and into the future, including monitoring and health effects and future mitigations, then informed consent has been reached. If they are not part of the decisioin making process, I would say no.
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
Not creating futher damage to our climate means eliminating emmissions. Failure to do so at this point will have extremely serious impacts to life on this planet. Our goal must be first to stabilize climate warming to 1.5 degrees C. Should we reach stability, other options might be considered, but not before then. Allowing exceptions threatens all the work that needs to be done. As the climate warms there may also be new information come to light or tipping points may have been crossed that may require even more stringent measures such as zero or negative emissions only.
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
Just because we may have no technically feasible low-carbon substitute doe not justify continuation if it is causing significant planetary harm. AT this point, there is to much risk. Other materials, products, or procedures may have to be developed. This may be damaging to the economy in the short term, but it will adapt. Further damage to the environment may make the economy irrelevant in a world full of chaos.
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
No science-based or robust guardrails were sugested – to be futher researched. This would have ot be locked in really hard. Allowing further emissions to go on simplify because they exist now and there is no present solution is not a solution. Relying on supply chain and customers is not an efficient option. They will adapt to changes.
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
Allowing exceptions weakens the whole taxonomy and invites misuse that only serve to delay transitionand prolong fossil fuel investments under a guise of greenwashing. It also delays implementation and investment in renewables. It would also be hard to prove and monitor progress, if any. Present research seems to be done by Canmet which is federal money which represents a conflict in interest and therefore decision making.
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?
Do not allow oil and gas into the taxonomy.. Investors have been aware of climate change and have had decades to transition. I don't believe it is an industry willing to curb or reduce emissions unless it is forced to. it will prolong the life of its inestments as long as it can, despite the harm it is causing.
17. Is there any other feedback you would like to provide on the proposed activity classification framework?
Only allow green. Allow transition only if technolgies can achieve results within 10 years. No abatement category
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
No Screening Criteria havew been created, as yet, Obviously , it should be as robust as possible. A search of existing solutions and modelling is practical. solutions may not come from what is known, but rather may emerge from some more imaginative research. Noting has been mentioned about science research or the direction it may take
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?
WE may find ourselves in a position where we want to reduce our lifestyle expectation to preserve the climate. Frivolous investments that use energy shoud be frowned upon. Concentrate first on those which are deemed necessary with emphasis on transitioning with 10 years.
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 agree that our focus should be on Phase 1 emissions. However, how we use our power – efficiciency and technology, supply chains and consumers must do their part as well, Use of AI data centers needs tobe limited to what is practical to attain system efficiencies and discouraged where it is being used for public manipulation. Business travel is not a necessity and needs to be addressed through technology such as internet applications.
Final questions
22. Overall, how satisfied are you with the proposed sustainable finance taxonomy framework?
Neutral
23. Is there any other feedback you would like to provide on the methodology report as a whole that has not already been covered?
I think that how investors work may need to considered. My banker tells me that for me to transition any investments I have in O&G , I need to cash in, declare captial gains and then reinvest. This hardly encopurages investoprs to make the transition. new rules need to be in place to encourage green investing. On the other hand, when someone divests this leaves room for someone else to move into those investments – too make money, not for climate concerns. I believe this needs to be addressed as well.