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.
- Other (please specify)
1b. Specify priority
Fossil phase-out. Critical Path Method (CP/M) reveals phase-out at Kennedy et al. (2023)'s industry depreciation rate (~0.2% of today's level per week, down to zero extracts in a decade) takes less than a third as long while fully ensuring like-for-like substitution at lower costs and higher GDP, with 70% less transition cost, and ten times the benefits due to moving path times forward.
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
2b. Please share the reason for your answer in the space provide
To be credible, design and implementation should be based on known models, such as model year in the auto sector, version control in IT, and motivational examples like Caesar burning his ships at Alexandria to prevent retreat.
CP/M is the industry standard for useful design. Interoperability is a core Industrial Ecology (IE) perogative, and the tools of IE and CP/M give precedence to all six principles.
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
- Important
- Regionally Specific
- 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 disagree
4b. Please explain your answer in the space below
Fossil extracts present the greatest risk to environmental, economic, and social systems. DNSH and MSS should therefore be designed to reduce unintended harms only after taking steps to avoid creating procedural barriers that delay actions delivering fossil phase-out. The framework should seek proportionality so safeguards strengthen rather than impede timely implementation. Solve extracts in a decade, let others sort out harms after.
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 framework should remain tightly focused on its primary purpose: identifying steps that materially accelerate climate mitigation. Additional objectives however important should not become so extensive that they reduce clarity, increase administrative burden, or delay deployment of fossil phase-out.
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 disagree
6b. Please explain your answer in the space below
Scope creep is the death of projects. Creep into intangibles is poisonous to project management. Where existing legislation provides robust environmental and social protections, added taxonomy should demonstrate clear added value. New requirements should be introduced only where they materially improve environmental outcomes or investor confidence without creating added complexity. Cutting subsidies is more pressing.
7. In which areas, if any, is it necessary to go beyond existing laws and standards for the DNSH/MSS framework?
The right of all to a stable, balanced climate, recognizing that without Holocene Climate Stability there would be no intergenerational sedentary farms, fisheries, forestry, settlements or succession.
That is what is at risk. Without that, all other rights build on that. As such, every legislative drafter should work from a BEX template, like the ones used for PIA, to ensure all legislation complies with BEX and Phase-out.
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
The only harms climate projects need to consider are climate harms.
Get the project done in a decade, and let subsequent projects address consequentials.
9. Are there any gaps in the proposed DNSH/MSS framework that could result in unintended environmental or social harms?
Wasting time on DNSH/MSS is itself a gap; we do not have the luxury of time to delay, in a world already 99% likely to have exceeded 20-year running 1.5 C degree warming. We've been beyond the Paris target since 2023. The crop losses, extreme wildfire weather, severe heat domes, thousands of deaths in Canada resulting outweigh DNSH/MSS heavily. The remedy for DNSH/MSS is to complete fossil phase-out, and then sort out the consequences.
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?
This process. This form. This questionnaire. Have you reached out to Canada's First Peoples to invite all 600+ nations to participate in this? Yes? No?
If yes, that suffices.
If no, what are you waiting for?
11. Is there any other feedback you would like to provide on the proposed MSS/DNSH framework?
I have been alarmed by the vulnerabilities exploited through MSS/DNSH frameworks since Kyoto by the fossil sector and malicious actors. You must recognize and secure against dilution of this project through this gaping and illogical wound in the side of your project planning process. Solve your mission target. Follow current protections in law. Let the next mission in ten years take on the consequentials.
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 disagree
12b. Please explain your answer in the space below
Zero and near-zero emissions are no longer ambitious enough or sufficient. Balancing Embodied eXternalities (BEX) process mandates require net drawdown in product and task Stock Flow Service (SfS). Perhaps code BEX as green, and 'zero or near-zero' as amber? e.g. replace sand with biochar in concrete aggregate, steel with basalt rebar, OPC with kaolin pozzolan, conventional smelting with Elysis(TM)-style aluminum, fossil with BESS+CAES+renewables, etc.
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
Phase-out fossil at 0.2% of today's level per week, down to zero extracts in a decade. The Market, and prudent government policy acting on the same principles as wartime measures did in the last generation, will mobilize technically feasible BEX substitutes in time. No grid has taken more than 5 years to go from fossil to BEX, of dozens of examples worldwide including BC; at rate of depreciation the listed examples can complete transition in a decade.
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
The guardrail should be phase-out at rate of depreciation. O&M costs for substitutes are lower than for incumbent fossil processes, and more nimble. That is a natural self-enforcing guardrail that optimizes transition on cost and timing, saving 70% in both, and generating ten times the benefits of delaying along the net-zero by 2050 precept.
Local authorities and specific Ministries will have to cope with consequentials.
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 don't have until 2027. The Revelle Report came out in 1965. AI enables high-quality dynamic solutions under a reliable 0.2%/week depreciation-based phase-out that every activity can unilaterally respond to locally with greater efficiency than any large coordinated bureacracy that removes decision power from those who know their local level operational needs. To succeed, your project must remain as small as possible and leave others to lift some.
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?
Enforcement: border measures to prevent leakage and smuggling; LIDAR and other monitoring to seek bootleg emissions and 'behind the meter' cheats; the measures we have experience of from the Montreal Protocol on Ozone Depleting Substances.
17. Is there any other feedback you would like to provide on the proposed activity classification framework?
Take a step back and consider the structure of your approach and how it corresponds to the solution space.
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?
Disagree
18b. Please explain your answer in the space below
Scope 1 is useful, but can misclassify high-impact solutions and fossil-adjacent dead ends. SfS/LCA/MFA should not be “progressively added later”; they should be foundational for materials, fuels, infrastructure, agriculture, forestry, and fossil phase-out. Placing fossil extraction phase-out first motivates all levels of business, institutions, and government to immediately prioritize their own technical screening locally and more rapidly with higher quality outcomes.
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
- Not at all 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?
Screening criteria should be the critical entry point of a cascade, the stub from which all later actions and actors take their lead: phase-out fossil extracts 0.2% of today's level/week down to zero in a decade; avoid high-impact emissions (CH4, N2O, H2, etc.) by BEX; Negative CO2 production by BEX; Diversify biomes toward conservation and agricultural BEX; Improve information toward BEX; Eliminate fossil finance and trade; Shift influence from fossil toward BEX.
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?
Disagree. This tends to shift focus to the less than 5% of emissions domestic end-users are responsible for, and leads to ignoring the 95% from business, institutions, government including exports and behind-the-meter processes.
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?
It would have been great, fifty, or even 30 years ago. Please pay attention to project management through modern PMBoK, Critical Path Method (CP/M), and create a template for legislative drafters in all ministries federally and provincially to ensure new regulations and laws conform to BEX, eg, "Does this legislation/regulation impact fossil extracts and recognize their phase-out by 2037?"; "Does this amendment address high-impact GHGs to reduce their emission?"; "Does this amendment address Balancing Embodied eXternalities?", etc.