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
• Pollution prevention and control
• Circular economy

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 provide

The key criteria should be:
1. The use of the precautionary principle (not just reacting as the dynamic principle would suggest but actively seeking to avoid harm and support for projects that in many cases are mere greenwashing -wasting time and money while causing further harm)
2. Effective in driving down emissions/ level of ambition/setting expectation for future thresholds
3. Does not harm nor export harm (all forms of pollution)
4. Conservation of materials and energy (over growth in supply)
5. Highest and best use of energy and materials (supporting a hierarchy of what should be supported or not -similar to the Zero Waste Hierarchy https://zerowastecanada.ca/zero-waste-hierarchy)
6. Supporting local circular economies
7. Policy coherence and consistency (there have been examples in the past where projects have received government funding that are in direct opposition to key policies)
8. Avoidance of infrastructure, material and financial lock-in

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

Not that important

Dynamic

Very important

Regionally Specific

Not that important

Prioritized

Very important

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 binary approach is preferred. Why should public money or public support of financing be used to support projects that do not meet the criteria? This will lead to greenwashing and diminish the credibility of the taxonomy. This will also likely be used by others to guide investment so set a high bar.

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

Agree

5b. Please explain your answer in the space below

The DNSH and MSS frameworks are sound. Especially appreciate the inclusion of circular economy.
Organizations may disclose progress toward alignment, but partial compliance should not receive the full sustainable-finance designation. Allowing an activity to claim alignment while identifying safeguards that remain unmet would weaken the meaning of alignment and increase greenwashing risk.
Canadian legislation should establish a minimum baseline, not the maximum level of protection. Technical criteria should go beyond legal minimums where existing laws do not adequately address cumulative impacts, pollution, climate effects, material conservation, Indigenous rights or exported harm.
The substantive environmental and social thresholds should apply to projects of all sizes. Documentation may be proportionate to project size, complexity and risk, but the underlying standard should not be lowered.

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

It depends on the laws. If this means the laws will be amended to ensure strong protections then the use of the laws is sound but given that even current, weak legislation is being weakened further (ability to use pesticides, avoiding need for environmental assessments, fast tracking projects with ability to override protections) then if the system relies mainly on weak laws, then the system is not strong enough. The laws should provide a strong backbone and then extensive use of standards and further criteria will be needed (especially until the laws can be improved to be far stronger).

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

Most of them -for example -climate, nuclear waste, inclusion of biogenic emissions from facilities..

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?

Disagree

8b. Please explain your answer in the space below

All projects should need to meet the basic criteria.

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

Currently the proposal is missing key principles and even then the projects only need to meet some of them. It relies on weak and weakened laws. The focus seems to be on making it easy for projects rather than ensuring the best projects are funded. So yes, there are significant loopholes that will cause harms.

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?

Indigenous Peoples should be included in the work to develop the framework. The step of seeking consent should be part of the process.

11. Is there any other feedback you would like to provide on the proposed MSS/DNSH framework?

There needs to be very clear rules and transparency around their application to avoid greenwashing and interference with which projects are funded.

12a. Do you agree or disagree with this approach?

Agree

12b. Please explain your answer in the space below

There needs to be careful evaluation of what actually will enable zero/near zero emissions to avoid funding activities that turn out to be harmful (such as pursuit of burning biomass, burning waste, etc.). It is vitally important to take a look at the systemic impacts rather than a narrow view of the GHGs in and out. For example, in theory e-bikes could replace vehicle or bus trips but if they replace walking or regular bike trips, they are in fact increasing resource use. Similarly, if electric vehicles become autonomous and the number of trips and cars increase, then the GHG savings will be diminished.

Also there should be a general principle included of seeking cobenefits. For example, reducing food waste going to disposal will reduce GHGs but it can also improve food security and reduce other negative environmental impacts.

Finally projects to reduce scope 2 and 3 emissions should be considered as well for a more holistic approach to what causes emissions. This can results in systems-level change. For example, fostering use of reusables and setting up systems to support repair.

13a. Do you agree or disagree with this approach?

Disagree

13b. Please explain your answer in the space below

This could result in a simplistic focus such as reducing the carbon intensity of cement, etc. rather than a systemic look at what we use it for and why. For example, using the adaptation of the WBCSD building embodied carbon hierarchy (as seen on page 7 of https://docs.communityenergy.ca/wp-content/uploads/Embodied-Emissions-Guide_Final.pdf) could result in far fewer emissions through better use of existing buildings and better design rather than a slightly improved carbon profile of cement.

Rather than a transitional category, perhaps there should be sector specific categories (building, transportation, products, agriculture, etc.) looking at how to reduce emissions through system level changes instead of incremental changes for materials. Many of these sectors already have hierarchies that usually start with redesign or reduce.

If this system is to be used, it is very important that waste is seen as a design flaw to be designed out and not a material to be burned (systems that burn waste then lock us into a very wasteful system and ignore the embodied energy it took to make the products and packaging in the first place; they also are very inefficient and often based on fossil fuels).

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

There needs to be systems level calculations of GHGs and these need to include biogenic GHGs at the facility-level. There are issues with only looking at GHGs in a piecemeal fashion that then allows the perception of GHG reduction when in fact it is supporting the status quo. For example, burning fossil gas has very high emissions levels and is not proven to be a transition fuel, rather an addition of more GHGs. Similarly, ignoring biogenic emissions especially when coming from trees (wood, paper, cardboard, furniture, etc.) that would take decades or centuries to replace results in a net increase in GHGs in the near term when burned.
In many cases substitution is not the answer, systems change will be required instead.

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

There should be no funding provided for these activities The industry could fund it itself but fundamentally these are sunset activities for which the phaseout needs to be accelerated, not prolonged. The statement “Investments that significantly reduce emissions from these activities in the short-term can align with achieving Canada’s climate targets” sounds very hard to prove. This kind of thinking is leading pursuit of the highly speculative carbon capture and storage, wasting time and money, instead of working on the proven GHG reduction methods that are needed.
Guardrails need to address upstream and downstream emissions so there needs to be a credible guardrail to protect the taxonomy’s credibility: exclusion of oil and gas.

Funding should be prioritized to green-eligible activities instead.

16. Should any additional guardrails be considered?

There should be requirements for industry to fund abatement but this is a SUSTAINABLE FINANCE taxonomy (not a BAU taxonomy) and thus no funding through this mechanism and with this label should be used for these abatement activities.

17. Is there any other feedback you would like to provide on the proposed activity classification framework?

The key will be who is determining what is considered green. Today there is much greenwashing and very little systemic analysis. Even published scientific papers lack a systemic lens leading to promotion of actions that if pursued widely could actually increase GHGs. For example, some analyses of burning of waste assume waste is inevitable rather than a policy choice instead of waste prevention.

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

Level of ambition will be key and sunset and sunrise dates are important and need to drive change quickly (rather than providing a subsidy longer than necessary). However, there is an international push to more accurately include biogenic emissions in facility-level carbon accounting so developing systems that rely on the premise that biogenic emissions are carbon-neutral in the relevant time frame is short sighted and not ambitious.

The example of biogas generated in waste management processes is problematic. An anaerobic digestion facility processing crop wastes or food waste (potato peelings for example) could have been designed to only manage unavoidable, source-separated organic waste and as it captures all of the gas, it could then be a climate solution. On the other hand, biogas from landfills is not as it encourages continued wasting and will never capture all of the methane released and so fosters ongoing methane production. Similarly, burning municipal waste in incinerators requires ongoing wasting to feed the system and thus engenders ongoing embodied carbon emissions.

Note that while a literature review is needed, the results often lag behind what a forward-looking system needs. Discussions with cutting edge think-tanks well grounded in sustainability may also be needed

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

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?

Prescriptive enough that it is clear what is in and what is out. Examples will be key to making in clear. Use both technical and simple language to be clear. An example of how not to do it is the Clean Technology Investment Tax credit which cannot answer simple questions about what would qualify.

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?

Scope 2 and 3 emissions need to be included or else the practice of claiming carbon wins as the carbon emissions were offshored will continue with no net benefit to the planet.

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?

A seventh sector should be prioritized which is products and packaging. This would use a system-lens and start to address the need to circularize the economy. The sectors of mining, agriculture and forestry and manufacturing all look at how we produce materials but not at the addressing demand for those materials.