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.
- Protection of biodiversity and healthy ecosystems
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
- Important
- Interoperable
- Important
- Dynamic
- Very 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?
Disagree
4b. Please explain your answer in the space below
I disagree with the proposed partial alignment approach. Allowing companies to simply disclose that they did not meet DNSH or Minimum Social Safeguards (MSS) criteria while still receiving a sustainable label creates a significant risk of greenwashing. A project should not be considered sustainable if it destroys a local ecosystem or violates human rights, regardless of how low its carbon emissions are. Projects should address these issues before qualifying for taxonomy-aligned financing, not merely disclose them.
5a. Do you agree or disagree with the proposed scope of objectives to be covered under the DNSH and MSS frameworks?
Neutral
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
I strongly agree that the taxonomy should go beyond current legislation where necessary. Canadian laws and regulations do not always fully reflect evolving scientific evidence—such as findings from IPBES—or Canada's international commitments, including the Kunming-Montreal Global Biodiversity Framework, Canada’s Nature Strategy, and Quebec’s Nature Plan.
A taxonomy that relies solely on existing legislation risks quickly becoming outdated and would primarily reflect the current regulatory baseline rather than a science-based pathway toward sustainability. The DNSH/MSS frameworks should therefore remain forward-looking and establish criteria that support continuous improvement beyond minimum legal compliance.
7. In which areas, if any, is it necessary to go beyond existing laws and standards for the DNSH/MSS framework?
Several areas require going beyond existing laws and standards. First, the framework should better address cumulative impacts, as environmental assessment processes often remain focused on individual projects and can struggle to capture impacts across multiple developments and over longer time scales.
Second, DNSH criteria should place greater emphasis on ecosystem connectivity and habitat fragmentation, including impacts from infrastructure such as roads and transmission lines, which are not always fully captured through site-specific assessments.
Finally, the framework should align with internationally recognized approaches, such as the TNFD, by incorporating a more comprehensive understanding of nature-related dependencies, impacts, and risks.
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
I support a phased approach for smaller entities, but only to simplify reporting requirements—not to lower environmental standards. Small projects can still create significant cumulative impacts on local ecosystems. Any simplified reporting requirements should be temporary and accompanied by a clear timeline toward full compliance. Smaller entities should be provided with simpler reporting tools, not exemptions from environmental responsibility.
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?
Operationalizing UNDRIP and Free, Prior, and Informed Consent (FPIC) should not rely solely on a single survey question in a broader public consultation. It requires a dedicated consultation process led directly by First Nations, Inuit, and Métis communities, as well as Indigenous financial leaders. Indigenous rights and governance cannot be adequately addressed through a standard technical feedback form.
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?
Disagree
12b. Please explain your answer in the space below
Calling an activity "Green" based solely on its carbon emissions is misleading. If a project is evaluated only on its greenhouse gas reductions, it should instead be classified as "Net Zero" or "Climate Solution." I recommend that the "Green" label be reserved for activities that are also nature-positive by actively protecting or restoring biodiversity, water, and soil while reducing emissions.
Nature-based Solutions, such as restoring wetlands, peatlands, and forests, should be explicitly recognized as core activities within this category. However, robust ecological safeguards are essential to prevent commercial monoculture plantations or other low-integrity projects from qualifying as "Green" or "nature-positive."
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
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
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
No. Creating an "abatement measures" category for oil and gas is fundamentally inconsistent with climate science. Multiple IPCC mitigation pathways and the IEA Net Zero by 2050 scenario indicate that global oil and gas production and use must decline substantially to achieve the goals of the Paris Agreement. An abatement category does not contribute to the necessary phase-out of fossil fuel production.
The Methodology Report itself notes that, in the Canada Energy Regulator's 2023 net-zero scenario, most emissions reductions in the natural gas sector result from declining demand rather than upstream abatement measures. While the report also references scenarios suggesting that global demand for oil and gas may not decline rapidly before 2050, sustainable finance taxonomies should be grounded in climate science and long-term transition pathways—not projected market demand.
Beyond climate impacts, oil and gas activities can also have significant impacts on biodiversity through habitat loss and fragmentation, water contamination, and ecosystem degradation. A sustainable finance taxonomy should not create incentives for activities that remain fundamentally incompatible with both climate and nature objectives.
Including fossil fuel abatement within a sustainable finance taxonomy would undermine its scientific credibility and weaken market confidence.
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?
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
- Very important
- Revise as necessary during regular review periods
- Very important
- Primarily use quantitative metrics
- Important
- Primarily focus on Scope 1 emissions but address Scope 2 and 3 emissions where feasible and/or material
- Not that important
- Informed by a range of robust methods
- Very important
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?
No. Focusing primarily on Scope 1 (direct) emissions creates significant blind spots. In many sectors—including electric vehicle manufacturing, buildings, and data centres—the majority of emissions arise from electricity consumption (Scope 2) or upstream supply chains and raw materials such as steel and batteries (Scope 3). Where Scope 2 or Scope 3 emissions represent the majority of a project's climate impact, full life-cycle greenhouse gas accounting should be required to demonstrate taxonomy alignment.
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?
Prioritizing forestry, agriculture, and mining for 2026–2027 is appropriate, but carbon-based criteria alone are not enough. A forestry or agricultural project that stores carbon while degrading soils or destroying habitat should not be considered green. Likewise, critical mineral extraction needed for the energy transition cannot come at the expense of rivers, wetlands, or wildlife corridors.
Climate and biodiversity should not be treated as separate objectives. Healthy ecosystems support climate mitigation, climate adaptation, and long-term economic resilience. Integrating biodiversity into the taxonomy from the outset will help direct investment toward projects that benefit both climate and nature.
Biodiversity and ecosystem health indicators should therefore be built into the technical screening criteria for land-use and extractive sectors from the beginning, rather than added in later phases. This would better align the taxonomy with the Kunming-Montreal Global Biodiversity Framework, particularly Target 15, and strengthen its scientific credibility.