Public Consultation Submission

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

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

They seem to be reasonable principles that can lead to an actionable taxonomy.

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
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?

Agree

4b. Please explain your answer in the space below

Canada is vast with regional differences. In order to move forward there needs to be some flexibility. That said, the entities should be audited to validate their disclosure, and recent Federal and Provincial legislative changes to designate Economic Zones and bypass existing legislation designed to protect the environment etc. is problematic.

5a. Do you agree or disagree with the proposed scope of objectives to be covered under the DNSH and MSS frameworks?

Select

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?

Neutral

6b. Please explain your answer in the space below

Difficult given Bill C5 and Ontario's MZO in the push to create economic zones

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 agree

8b. Please explain your answer in the space below

A community based solar Co-op does not need as much scrutiny as high speed rail. Consider the potential risk and impact.

9. Are there any gaps in the proposed DNSH/MSS framework that could result in unintended environmental or social harms?

See my comments about C5 and Ontario's MZOs

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?

Validate claims about consultation with the Indigenous Communities in question

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

This is the fastest way to get to net zero

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 agree

13b. Please explain your answer in the space below

We need core industries like steel & cement to build net zero infrastructure and should make every effort to help them transition their operations to reach net zero

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 agree

14b. Please explain your answer in the space below

It's imperative that we don't enable the status quo for industries needed to transition the rest of the economy off fossil fuels e.g. steel production needed to build high speed rail should be as clean as possible

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

The fossil fuel sector must reduce its methane emissions – it's wasteful and toxic. Could there be money to help all those poor landowners with abandoned oil wells on their properties? The ability to scale Carbon Capture and Storage to the degree required seems unrealistic. I'm appalled that the MOU with Alberta allows CCS to be reinjected into wells to squeeze out every last bit of oil.

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.

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

The screening criteria is vital to properly evaluate the merits of a project.

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
Important
Include sunset and/or sunrise dates where relevant
Very important
Revise as necessary during regular review periods
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
Important

20. When thinking about the taxonomy’s credibility and usability, how technologically specific or prescriptive should the technical screening criteria be?

It's helpful to have specific requirements but the credibility of the technical screening will only be as good as the individuals doing the evaluation. Perhaps there is a role for AI here if is it appropriately trained and can be it can be audited.

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 provided Scope 2 and 3 emissions are considered regardless of where they happen i.e. don't only consider what happens in Canada. For example Oil exports to other countries will generate emissions there and we need to be accountable for that.

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?

Please move faster and stop listening to the mostly foreign owned Fossil Fuel lobby – they get far too much consideration in our country

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