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

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 provided

I do not think your principles are aligned with a climate emergency mindset. First, too much of the document and taxonomy is rooted in pollution prevention/precautionary principle framing. The proper framing is wartime economy management, where speed and scale is the goal, not perfection and where delay is death. You need to reframe your principles to match the mantra that it is time to build, meaning that the goal is to remove barriers and delays for projects that are overwhelmingly positive, and reserving more comprehensive analysis where real trade-offs may exist. Second, this is ultimately about finance, so math needs a stronger seat at the table. Quantitative outcomes in the form of climate math (tonnes CO2e mitigated or removed) need to get a stronger weighting relative to qualitative considerations. Third, we recognize and support the common sense addition of the mitigation category of investment. We think this is a really positive step to ensure that emission reduction capital projects in carbon intensive sectors can continue to access capital. We do think that this pragmatic, science and climate math based approach to the global energy baseline (which is dynamic, not static) should be reflected across the entire document. For example, a new LNG facility in Canada does not lead to "lock-in." Rather, a facility supplying lower-carbon intensity LNG to emerging markets with rapid population growth for power generation, as a substitute for an existing coal-fired power plant or a new build coal-fired generation does reduce emissions. With exploding demand for data centres across the world, natural gas usage across the world will continue to increase. Our objective should be to decrease the carbon intensity of Canadian natural gas and ensure that those lower CI molecules displace other higher CI molecules from elsewhere.

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

Very important

Regionally Specific

Not at all important

Prioritized

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

Strongly disagree. By applying a uniform test, you are creating an additional investment barrier, especially for project activities that are overwhelmingly positive. You need to have flexibility in the process where higher levels of scrutiny are only applied where there are real trade-offs, but where "no-brainer" investments should have a streamlined process. We will submit a separate, more detailed piece on this concept.

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

Again, precautionary principle regulatory approaches are not fit for purpose for climate or emission reduction related investments.

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

The guiding principle should be facilitating more finance to flow faster to high impact projects. Reserve scrutiny to projects with real, tangible trade-offs (deux poids, deux mesures).

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

If you want to attract Capital from outside of Canada, it is imperative to not create additional barriers or possible stroke of the pen risk concerns that may impact a project moving forward.

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 agree

8b. Please explain your answer in the space below

Standards and process should be weighted based on trade-offs. Overwhelmingly positive projects should get fast-tracked, streamlined processes.

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

The objective of carbon or climate finance should be to deliver climate outcomes in tonnes of reductions or removals. That is the ultimate metric. For those projects, there should be no or a limited screen. For projects with trade-offs, a pragmatic framework is likely relevant.

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?

It should not. Do not add new process. If a project directly impacts First Nations land, then those issues will be dealt with at the Environmental Impact Assessment and Approval stage.

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

The goal should be to move away from a pollution regulation lens to a process where necessary stance.

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

Strongly disagree

12b. Please explain your answer in the space below

You need to move away from qualitative, poorly defined terms like "green" to quantitative framing and stick to climate math. For example, is an electric car manufactured in China in a coal-fired factory, where critical minerals/metals may be mined by slave labour truly green? The operation of the vehicle may be near zero emissions in a province like Quebec, Manitoba or BC with a low CI grid, but is the production of that vehicle "greener" than a hybrid electric vehicle manufactured in Alliston, Ontario, under Canadian environmental and labour laws? No. You need to use GHG accounting principles as your North star. Let's take 2 projects: 1. A $10 million methane mitigation program in the oil & gas sector in western Canada may deliver 5 million tonnes CO2e of direct, real, high integrity reductions over 10 years, with an even greater impact given the GHG is methane, a high GWP SLCP. 2. A $10million EV charging infrastructure program that may deliver 200,000 tonnes CO2e of indirect emissions reductions. Which project makes a "substantial contribution to climate change mitigation"? Shift to quantitative, not qualitative criteria.

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

Strongly agree

13b. Please explain your answer in the space below

The global economy that Canada competes in is as it is, not as we would like it to be. Many of our most important economic sectors are extractive, and export based, meaning delivering continued, incremental reductions in our higher carbon sectors, will have real, global level impact. For this taxonomy to be effective, it must reflect the pragmatic reality of our economy. It must also recognize that many of our trading partners in the global south or emerging markets will have different pathways to 2050 that are different than our path. For example in transportation, it is very hard to electrify transport if you do not have a reliable grid or sufficient energy to support that grid. This is the reality of many countries in Africa and Southeast Asia. The transition category cannot be limited to our transition pathway, but rather that of our trading partners.

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

It is our position that the proposed guardrails are overbaked and place too much emphasis on the debunked concept of "lock-in". It is important to understand that the entire principle of "lock-in" in this document is . You must be pragmatic

15a. Do you agree or disagree that the taxonomy should include a third “abatement” category, as proposed, that covers demand-decline activities?

Strongly agree (i.e., agree unconditionally)

15b. Please explain your answer in the space below

We strongly agree. The goal is decarbonization, not deindustrialization. The largest opportunities for decarbonization exist in carbon intensive sectors. If we choke off capital to these sectors, we simply create leakage of emissions to other countries with lower regulatory stringency. The goal should be speed and scale. It should make clear that any activity in any energy intensive sector that delivers quantified emission reductions relative to the baseline or common practice or industry average automatically qualifies. For projects that do not meet that criteria, they should need to demonstrate that they can find a path. It must be made clear that the bar they need to meet is the realistic baseline pathway (the world energy demand as it is).

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

You need to back away from the non-science based concept of lock-in. Our company spends a lot of time in the global south. It is important for Canada to understand that the lock-in concept (Unruh, 2000) assumes energy abundance, where avoiding new fossil infrastructure costs little. In economies where energy access is the binding constraint, natural gas is often the least-cost (and lowest emissions) path to development and talk of "lock-in" is increasingly rejected as climate colonialism. The taxonomy's "global demand in Paris-aligned pathways", treats Global South demand growth as a defect to screen out, as opposed to the existential need for energy that it is. It is not neutral science and Canada must move away from that framing for any export related sectors.

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

Any screening criteria must be clear, math and science based (quantitative), and avoid any subjective qualitative critieria where possible. For domestic projects, any criteria must be limited to direct scope 1 and 2 emissions. For projects that export products to international markets, any screening criteria must be focused on baseline conditions in those markets, not Canada (see the world as it is, not like we would like it to be).

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

Not at all important

Include sunset and/or sunrise dates where relevant

Not at all 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

Not at all important

20. When thinking about the taxonomy’s credibility and usability, how technologically specific or prescriptive should the technical screening criteria be?

This is meant to be a financial framework. The taxonomy should avoid picking winners. Let the market and the climate math decide.

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 the focus should be on scope 1. This is a strong approach.

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?

We would like to congratulate the group for material and positive developments relative to the proposed European taxonomy, that makes some pragmatic improvements to reflect the world as it is, and that the mission is to decarbonize emission intensive sectors within the reality that global energy demand is increasing and accelerating, not to deindustrialize (export emissions to other regions of the world). However, for Canada to secure and build important new export and trading relationships with new partners across the world in this era of uncertainty with our largest trading partner, we need to be pragmatic and ensure that our taxonomy will allow us to support Canadian companies as they seek to grow market share across the world. That is how we will build the prosperity to be able to finance our our transition.