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

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

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 agree

4b. Please explain your answer in the space below

Very important element, and aligns to other taxonomy approaches

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

Strongly agree

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

7. In which areas, if any, is it necessary to go beyond existing laws and standards for the DNSH/MSS framework?

Areas where existing laws and standards are incompatible with best practices

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

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

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?

Agree

13b. Please explain your answer in the space below

For whole of activity and transition measures, they should avoid being overly prescriptive with timebound constraints and sunset clauses as technological pathways, cost curves and public policy are highly uncertain the farther you go out

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?

Neutral

14b. Please explain your answer in the space below

For guardrails for transition category, focus should be on reductions in Scope 1 + 2 emissions, not getting hung up on debating whether a project phases out in 2045 or 2050 etc

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

Should be able to capture these as they can reduce emissions where possible given the continued use of gas plants. Reflects Canadian market realties.

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?

Strongly agree

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
Not that 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?

• When developing technical screening for data centers, they should include metrics on water use, including overall water footprint from power, not just direct energy use

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?

Agree

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?

Support ‘strongly encourage’ rather than ‘require’ users to meet entity level requirements

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