Comments on draft Philippine Sustainable Finance Taxonomy Guidelines
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Key Findings
IEEFA supports the specified design criteria but emphasizes the importance of credibility, which can be challenging to ensure in a principles-based taxonomy.
To best achieve climate mitigation objectives, IEEFA recommends including or strengthening language that specifies that all fossil fuel-related exploration, production, transportation, and power generation projects be designated as “red.”
Natural gas should not be considered sustainable or transitional, as it risks locking the Philippines into a high-emitting future.
IEEFA recommends removing carbon capture, utilization, and storage (CCUS) as an “enabling sector” from the current iteration of the taxonomy guidelines. While CCUS activities may contribute to climate mitigation objectives in high-emitting sectors, qualification as “sustainable” will require scientific thresholds that are not currently suitable for a principles-based taxonomy.
05 October 2023
To: The Secretariat, Bangko Sentral ng Pilipinas
Re: Philippines Sustainable Finance Taxonomy Guidelines - Consultation Document
IEEFA supports establishing Sustainable Finance Taxonomy Guidelines for the Philippines market that are globally interoperable, credible and high-quality under the Philippine Sustainable Finance Roadmap.
We respond to selected consultation questions in the consultation document:
- What design considerations do you consider most important for the Philippines Sustainable Finance Taxonomy Guidelines? (page 25)
- Do you have any suggestions regarding the list of prohibited activities in Appendix 1? (page 33)
- Is a 5-year period to allow for potential harm to be remediated appropriate? What sectors may require more than 5 years to remediate the harm? Should activities that cause any significant harm be automatically excluded? Would a questionnaire be a viable interim solution pending global efforts to simplify DNSH criteria? (page 42)
- Do the proposed three essential criteria provide enough guidance for taxonomy users to make their assessments of compliance? (page 44)
- Which options for defining the Green and Amber categories above would be considered most suitable in an initial phase of the taxonomy and why? (page 49)
- Do you believe that the proposed sustainable finance taxonomy adequately addresses the risks associated with unsustainable investments and activities? If not, how could the taxonomy be improved to better address these risks? (page 64)
We welcome the opportunity to discuss further issues and participate in setting future standards.
Submitted via email.
