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
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 disagree
2b. Please share the reason for your answer in the space provided
The design and implementation of the Canadian Taxonomy needs to first and foremost be informed by a full comprehension and acknowledgement of the true threat of the climate crisis that is unfolding before our eyes every day on the legitimate news channels. Record-breaking heat domes and fires in Europe and North America and beyond. Also, the onslaught of unprecedented and widespread drought, crop failures, flooding and famine worldwide. These are the true hallmarks of climate chaos. A climate-based solution in line with the Paris Agreement, must be the foundational premise of the taxonomy. Then you can add in the other stuff if and only if it fits into the aforementioned foundational premise. We are in a climate emergency NOW. Let's take our actions and make our taxonomies accordingly!
3. Please rate each of the principles below on a scale from “very important” to “not at all important.”
- Credible
- Important
- Usable
- Important
- Interoperable
- Important
- Dynamic
- Important
- Regionally Specific
- Important
- Prioritized
- 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
Proposed partial alignment will allow fossil fuel emissions to proliferate and drive us further into the climate emergency we are already experiencing. Over 20,000 people were forced to evacuate their homes in British Columbia over this past week alone. Entities must adhere fully to the Do No Significant Harm and Minimum Social Safeguards criteria.
5a. Do you agree or disagree with the proposed scope of objectives to be covered under the DNSH and MSS frameworks?
Strongly disagree
5b. Please explain your answer in the space below
It is not enough to focus on climate adaptation. Adapting to the new challenges of climate chaos is essential but not sufficient. We must take action to swiftly reduce greenhouse gases to slow and then reverse the onslaught of the climate crisis.
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?
Disagree
6b. Please explain your answer in the space below
I am uncomfortable with the word "beyond" in the question. Does it mean all options are then on the table?
That is not acceptable.
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
It should be the same for all projects so as to not invite the slippery slope of inequity.
9. Are there any gaps in the proposed DNSH/MSS framework that could result in unintended environmental or social harms?
Yes, there are gaps. If a project results in unintentional harm or harm through negligence. Does easily attainable restitution and restoration exist for the harm(s) done to the environment and the residents? For example: Grassy Narrows water contamination with mercury has not yet been resolved. And there are many other examples in Canada.
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?
The high standards of UNDRIP should absolutely be followed in Canada. First Nations communities must be consulted and informed and given the opportunity to discuss the implications of any project between all the groups or tribes affected. Then the larger communities can take an informed decision together. They must have the embedded right to say no to the proposed project.
11. Is there any other feedback you would like to provide on the proposed MSS/DNSH framework?
The information provided to people impacted by any proposal has to include the long range effects of any actions to be taken. Indigenous communities consider their actions today as to their effects on seven future generations.
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
Near zero must mean that every action has been taken to eliminate GHG emissions.
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
If we allow the transition to drag on until 2050, it will be too late! The planet will be uninhabitable for humans and many other species. We therefore need much faster 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?
Strongly disagree
14b. Please explain your answer in the space below
We do not have the luxury of time to permit the emissions embedded in these transitions. Don't lock them in.
We need to find alternative solutions that are GHG free or near zero. We must do that now. The planet is already overheating.
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 agree (i.e., agree unconditionally)
15b. Please explain your answer in the space below
We need to invest capital in investments that align with the Paris Accord. This means that existing fossil fuel energy assets must not be permitted to expand as this will inevitably increase GHG emissions. Carbon capture and storage is a false solution. It is an expensive fig leaf over the real problem that is fossil fuel proliferation, expanding greenhouse gas emissions and global climate chaos. We must invest in scaling up renewables such as solar and wind. We need to provide training in renewable build out and maintenance to apprentices and trades people. We need to ramp up battery storage capabilities to provide reliable power in all jurisdictions. This will help our people and the biosphere on which we depend. We must do this now.
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?
We need to tighten up the timeframe for emissions reductions. Much of the planet is on fire as I write this. We don't have time to dither with fossil fuels. Renewable power is the only realistic way forward if we want to survive this climate crisis.
17. Is there any other feedback you would like to provide on the proposed activity classification framework?
Canada can follow Australia's lead and become a leader in renewable power solutions. Fossil fuel and nuclear are yesterday's energy solutions. We have the minerals, we have the knowledge. Let's push forward into a greener, cleaner era.
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.”
- 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
- Not at all 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?
All emissions must be tracked: scope 1, scope 2 and scope 3. The atmosphere is impacted by all of the above. If we want solve the climate crisis we must stop emitting GHG as soon as absolutely possible. Full stop.
Final questions
22. Overall, how satisfied are you with the proposed sustainable finance taxonomy framework?
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?
Why are renewable power solutions not mentioned when they are the key to getting us out of this mess.