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
- Other (please specify)
1b. Specify priority
Climate mitigation
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 provide
Sound like reasonable criteria
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
- 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?
Neutral
4b. Please explain your answer in the space below
I have trouble with lumping the two together. DNSH I have no arguments with. MSS is more problematic in my view and my reason is this: I believe that the climate crisis has already reached the advanced emergency phase and as such it may be necessary for climate mitigation measures to infringe on certain social values and legal rights in order to have significant positive impact. Highly unfortunate but necessary.
5a. Do you agree or disagree with the proposed scope of objectives to be covered under the DNSH and MSS frameworks?
Neutral
5b. Please explain your answer in the space below
Not sufficiently informed to make comment
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
The climate crisis is an extraordinary and unprecedented circumstance which will call for similar measures.
Science, rather than politics or the economy should be the ultimate deciding factor.
7. In which areas, if any, is it necessary to go beyond existing laws and standards for the DNSH/MSS framework?
Geoengineering is one obvious example.
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?
Agree
8b. Please explain your answer in the space below
Provided the aggregate of all the smaller projects do not exceed the impact of the larger ones
9. Are there any gaps in the proposed DNSH/MSS framework that could result in unintended environmental or social harms?
Yes. The MSS definition appears to me to leave the door wide open to abuses through ill-advised interpretation of the “national interest” for example.
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?
Implement fully
11. Is there any other feedback you would like to provide on the proposed MSS/DNSH framework?
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
Anything short of that is just greenwashing
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
No! This is fraught with unlimited potential for abuse, particularly by the fossil fuel corporate interests. The current promotion of LNG in BC is a prime example. There may have been a time for transitional or “bridge” measures but that time is long past. The math and physics now demand the cold turkey treatment. We ignore that at our peril.
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
Almost certainly not. The reason being that our scientific consensus to date has consistently underestimated the severity of the crisis and will no doubt continue to do so moving forward.
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?
Disagree (i.e., disagree because of how category is designed)
15b. Please explain your answer in the space below
This sounds like more wishful thinking to me. Any framework should take into account Canada’s deplorable record at meeting past and present commitments and not condone more creative accounting that enabled those previous failures. Science, not weasel words!
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?
Yes. Immediately join and implement ALL the policy guidelines of the Fossil Fuel Non-proliferation Treaty.
17. Is there any other feedback you would like to provide on the proposed activity classification framework?
No
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?
Neutral
18b. Please explain your answer in the space below
Insufficiently informed to comment
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
- Important
- Revise as necessary during regular review periods
- 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?
Very
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?
Yes, provided that scientific analysis is the primary arbiter.
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?
Too many potential loopholes that can still be exploited by entrenched fossil fuel interests. Based on long experience.