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
- Water and marine resource conservation
- 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?
Disagree
2b. Please share the reason for your answer in the space provided
These are good and valid principles but there is a critical one missing, in my opinion. That is a linkage to the Paris Agreement targets. ie. the entire point of a climate taxonomy should be to help direct Canada's actions to those which align with decarbonization and which help direct global funds to Canadian projects which credibly contribute to our progress on decarbonization. Furthermore, decarbonization needs to be defined as near zero. not net zero. and not 2050. but Near Zero by 2040 or earlier.
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
- Not that 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
the DNSH and MSS are as essential as climate mitigation. There is little point in mitigating climate change while harming other environmental or social values or legal right. This sounds like game play to me. It sounds like a ploy to gain check marks at the lowest possible cost rather than doing the right thing. We already know how to solve the climate crisis. It is time to put profit motives and business objectives as secondary and people, nature, and planet as primary. The risk of not doing so is our own extinction. It is time to proceed apace with the full and best approach for all life.
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
the first of the objectives listed is climate adaptation, with no mention of climate mitigation. In my view, this is the time to double down on solutions and mitigation, even as a priority over adaptation. Both are important but the science tell us that the sooner we implement solutions and reduce GHG emissions the more impact that will have. A focus on adaptation risks less focus and resources on mitigation which will then only become more expensive and more dire with time.
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?
Select
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
I think that the standards should apply to all projects of all sizes. This will promote fairness and will develop talent in assessment and reporting to one and only one set of standards which will reduce costs, reduce time, and promote transparency.
9. Are there any gaps in the proposed DNSH/MSS framework that could result in unintended environmental or social harms?
I am no expert in this but I don't see the restitution piece. Where are the requirements for harmed parties (whether human, or non-human) to receive action to bring back the original state and/or other restitution if and when there are unintended environmental or social harms. The cost, including reputational harm, should be high enough to encourage deep risk assessment and preventative actions. Also, I don't see the requirement for on-going assessment once a project is complete and even at end of life – the environmental impact often outlives the project.
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 taxonomy should follow the principles as outlined in UNDRIP, including free, prior, and informed consent of all Indigenous Nations who will be impacted by a project. It is not sufficient to gain consent from one IN and move ahead without consent of other affected INs.
11. Is there any other feedback you would like to provide on the proposed MSS/DNSH framework?
Transparency is key. I do not agree with the partial approach. But, if the government does allow this approach, then I want to see full detail on which objectives are not fully met, with detailed measures, and information on specific actions being taken to increase the degree to which that objective is met. More importantly, I would like annual progress reviews, which will focus on the areas that do not meet the full objective and if progress is not made in line with what was promised, then there are material consequences for the project owners.
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
I am pleased to see that the green category will be limited to zero or near-zero emission activities. Net zero is a false goal.
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
There are very few sectors which are truly hard to decarbonize and I would ask the government to consider carefully which sectors should fall into this category. Global best practices should dictate the degree and timelines for these hard-to-decarbonize sectors. Secondly, 2050 is simply too late. The general economy should be targeting earlier than 2040 and hard-to-decarbonize sectors shortly thereafter.
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
I am very uncomfortable with the notion of transition-type activities being allowed to maintain or even increase output on a presumed pathway to zero. I do not like the emissions lock-in nor the lack of a requirement to decrease production in these high emitting sectors (even if they will eventually decline). I feel like this challenges the credibility of the science-based criteria.
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
We have known for years that our oil and gas production must end. Our energy workers contributed to Canada and to Alberta for many years. Now, we have better information on the negative impacts on the environment and global climate change. We owe it to our energy workers to quickly bring this industry to a close. Their skills can be put to better use in renewable energy. There is no need to maintain, and certainly not to increase, oil and gas production in this country as it will increase GHG emissions and only prolong the clear and needed transition. All investments should be aligned with the Paris Agreement and focus on total GHG emission reduction.
Renewable energy is available today. It is cheaper. It is faster to build. It is reliable. It is not tied to world markets or events, increasing our energy security and resilience. It is not about to become a stranded asset. It does not leak toxic gases. It does not require long transportation which also leaks toxic gases. It is clean – it does not harm our childrens' health or destroy their future.
It is time. Transition to renewable energy should begin today.
Abatement is a dangerous path, designed to allow fossil fuel companies (which are foreign-owned) to squeeze the last bit of profitability out of the extraction of an obsolete fuel resource. Using enhanced oil recovery to produce less GHG per barrel of oil is not a good outcome – it is gaming.
Indeed, it is beyond my comprehension why we are even contemplating this false solution rather than prioritizing the health of Canadians and our country.
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 would like to see a guardrail that has tight timelines for meaningful total GHG emissions reduction including regular and verified reporting and financial consequences for lack of progress (which could go to an environmental remediation fund).
17. Is there any other feedback you would like to provide on the proposed activity classification framework?
I do not agree with the abatement category at all. If the government disagrees, I ask that the guardrails be comprehensive, and focused on the overarching goal – of total emissions reduction as quickly as possible.
The significant reduction requirement should set a very high bar.
The requirement for existing assets should EXCLUDE any expansion, as noted in my comments above.
All of the proposed guardrails should apply to all of the measures.
The rest of the world, countries and companies, are moving quickly toward a renewable energy powered future. We should be running to catch up, not using an abatement category to keep us chained to the past.
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 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 believe every effort should be made to measure, track, and address Scope 2 and 3 emissions. Just because something is hard does not mean that it should not be done. The oil and gas industry has enormous Scope 1 and Scope 3 emissions. We cannot ignore the impact of our industry on global GHG emissions. It is our duty and responsibility to measure and reduce quickly the impact of our emission on the global GHG inventory.
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?
I am pleased that the government is finally getting to this important initiative. Our future and our competitiveness are at stake. I am disappointed by the inclusion of the abatement category and urge the government to consider it's opportunity to create real and sustainable change with this initiative.
Again, we must prioritize renewable, clean energy NOW.
Thank you.