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

None. There should be no Canadian sustainable finance taxonomy in this phase or any subsequent phase. Expanding the framework to additional objectives only compounds a conceptually flawed hierarchical system for steering private capital. Please see the attached full comment letter for the detailed free-market critique and recommendation that the draft Methodology Report and any resulting taxonomy be withdrawn.

2a. Do you agree or disagree with these proposed principles as the foundation for the taxonomy?

Strongly disagree

2b. Please share the reason for your answer in the space provided

These principles assume the legitimacy of an official hierarchical classification system for private capital. From a free-market perspective, the entire concept is flawed: it substitutes the judgments of committees and politically influenced experts for the dispersed knowledge, risk assessments, and voluntary choices of capital owners. Hierarchical technical criteria cannot correctly define or update “sustainable” activities across dynamic markets and technologies (Hayek’s knowledge problem). Please see the attached full comment letter for the complete rationale.

3. Please rate each of the principles below on a scale from “very important” to “not at all important.”

Credible

Not at all important

Usable

Not at all important

Interoperable

Not at all important

Dynamic

Not at all important

Regionally Specific

Not at all important

Prioritized

Not at all 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

Whether applied partially or fully, DNSH criteria function as a practical veto on new oil and gas development and accelerate the phase-out of existing operations by raising the cost of capital and constraining reinvestment. This converts a purported guidance tool into a capital-allocation filter. See the attached letter for the detailed analysis.

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 proposed scope is overly broad. Existing Canadian constitutional, legal, and treaty protections already address genuine environmental and social harms. Embedding additional hierarchical criteria for biodiversity, circular economy, and other open-ended objectives creates new layers of administrative discretion and compliance risk without strengthening enforceable legal protections. This is mission creep. See the attached letter for the detailed analysis.

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

Existing Canadian legislation, constitutional protections, and treaty rights already provide the appropriate framework. Going beyond those laws through a taxonomy expands bureaucratic conditions on private capital allocation and introduces unnecessary administrative discretion. Remedies for real harm belong in legislation and the courts, not in finance labels. See the attached letter for the detailed analysis.

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

None.

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

Differentiating standards by size still embeds a hierarchical taxonomy that should not exist. Even streamlined requirements for smaller entities create ongoing compliance costs and uncertainty. Standards should rest on existing law and demonstrable harm, not on bureaucratic tiers that expand technocratic oversight of private capital. See the attached letter for the detailed analysis.

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

Yes. The proposed DNSH/MSS framework prioritizes hierarchical environmental criteria while largely ignoring harms to human flourishing like higher energy costs, reduced reliability, lost investment and jobs, and heavier burdens on smaller firms. It creates administrative discretion that can block beneficial projects and lacks any robust mechanism to measure or correct these unintended economic and social costs. These are not minor gaps; they are inherent to using a hierarchical taxonomy to steer private capital. That is why there should be no such taxonomy. Free markets already process environmental and other risks through prices, insurance, and voluntary decisions by capital owners. Please see the attached full comment letter.

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?

The taxonomy should not operationalize UNDRIP or FPIC. Existing Canadian constitutional protections, treaty rights, and legislation already provide the proper legal channels. Embedding additional hierarchical criteria inside a sustainable finance taxonomy creates new layers of administrative discretion and compliance risk without strengthening enforceable legal protections. Indigenous rights should continue to be addressed through established legal and treaty processes, not through a capital-classification system. See the attached full letter.

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

Please see the attached full comment letter.

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

Strongly disagree

12b. Please explain your answer in the space below

Hierarchical categories such as green, transition, abatement or any future ones are arbitrary, non-neutral, and distortive. They create artificial winners and losers by bureaucratic fiat, politicize capital allocation, and, through DNSH, effectively veto new hydrocarbon development while constraining reinvestment in existing operations. The tightly ring-fenced abatement category does not solve these problems. It offers a limited, short-term pathway for certain emissions-reduction measures on existing assets, which may reduce immediate resistance from resource companies, but it remains a transitional concession within a framework whose longer-term logic is to steer capital away from the oil and gas sector. In other words, the abatement category softens the immediate political and industry impact without changing the direction of travel. Official classifications do not create economic value; they redirect existing capital according to political rankings. That is precisely what makes the taxonomy antithetical to a free-market system. Private capital does not exist to be conscripted into official pathways. Redirecting it by bureaucratic fiat substitutes political priorities for voluntary choice and undermines the free-enterprise principle that investment decisions belong to the owners of the capital. Please refer to the attached full comment letter.

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

Strongly disagree

13b. Please explain your answer in the space below

Hierarchical categories such as green, transition, abatement or any future ones are arbitrary, non-neutral, and distortive. They create artificial winners and losers by bureaucratic fiat, politicize capital allocation, and, through DNSH, effectively veto new hydrocarbon development while constraining reinvestment in existing operations. The tightly ring-fenced abatement category does not solve these problems. It offers a limited, short-term pathway for certain emissions-reduction measures on existing assets, which may reduce immediate resistance from resource companies, but it remains a transitional concession within a framework whose longer-term logic is to steer capital away from the oil and gas sector. In other words, the abatement category softens the immediate political and industry impact without changing the direction of travel. Official classifications do not create economic value; they redirect existing capital according to political rankings. That is precisely what makes the taxonomy antithetical to a free-market system. Private capital does not exist to be conscripted into official pathways. Redirecting it by bureaucratic fiat substitutes political priorities for voluntary choice and undermines the free-enterprise principle that investment decisions belong to the owners of the capital. Please refer to the attached full comment letter.

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

Hierarchical categories such as green, transition, abatement or any future ones are arbitrary, non-neutral, and distortive. They create artificial winners and losers by bureaucratic fiat, politicize capital allocation, and, through DNSH, effectively veto new hydrocarbon development while constraining reinvestment in existing operations. The tightly ring-fenced abatement category does not solve these problems. It offers a limited, short-term pathway for certain emissions-reduction measures on existing assets, which may reduce immediate resistance from resource companies, but it remains a transitional concession within a framework whose longer-term logic is to steer capital away from the oil and gas sector. In other words, the abatement category softens the immediate political and industry impact without changing the direction of travel. Official classifications do not create economic value; they redirect existing capital according to political rankings. That is precisely what makes the taxonomy antithetical to a free-market system. Private capital does not exist to be conscripted into official pathways. Redirecting it by bureaucratic fiat substitutes political priorities for voluntary choice and undermines the free-enterprise principle that investment decisions belong to the owners of the capital. Please refer to the attached full comment letter.

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

The tightly ring-fenced abatement category does not solve these problems. It offers a limited, short-term pathway for certain emissions-reduction measures on existing assets, which may reduce immediate resistance from resource companies, but it remains a transitional concession within a framework whose longer-term logic is to steer capital away from the oil and gas sector. In other words, the abatement category softens the immediate political and industry impact without changing the direction of travel. Official classifications do not create economic value; they redirect existing capital according to political rankings. That is precisely what makes the taxonomy antithetical to a free-market system. Private capital does not exist to be conscripted into official pathways. Redirecting it by bureaucratic fiat substitutes political priorities for voluntary choice and undermines the free-enterprise principle that investment decisions belong to the owners of the capital. Please refer to the attached full comment letter.

16. Should any additional guardrails be considered?

Even strict guardrails cannot salvage the abatement category. The underlying premise, that certain activities must be treated as demand-decline within a Paris-aligned phase-out framework, is rejected. Additional guardrails merely layer complexity, compliance costs, and administrative discretion onto a conceptually flawed hierarchical system. The entire taxonomy, including any abatement category and its guardrails, should be withdrawn.

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

Please refer to the attached full comment letter.

18a. Do you agree or disagree with the proposed approach for developing technical screening criteria?

Strongly disagree

18b. Please explain your answer in the space below

Technical screening criteria embed the knowledge problem: no central body possesses the information or foresight to correctly define and continuously update performance thresholds across dynamic technologies, markets, and preferences. Such criteria will lag innovation, embed outdated assumptions, and become politicized. Please refer to the attached full comment letter.

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

Not at all important

Primarily focus on Scope 1 emissions but address Scope 2 and 3 emissions where feasible and/or material

Not at all 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?

Ideally not at all. Highly specific or prescriptive technical screening criteria embed central planning into capital allocation, favour politically preferred technologies, lag innovation, and raise compliance costs. From a free-market perspective the entire hierarchical screening exercise should be rejected. Please see the attached full comment letter.

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?

From a free-market perspective, detailed emissions accounting, whether limited to Scope 1 or extended to Scope 2 and 3, is a costly and largely unproductive compliance burden. Markets already process environmental and technological information through prices, insurance, and voluntary disclosure. Mandating hierarchical Scope accounting, especially Scope 3 (which attributes end-use emissions to producers and invites double-counting), embeds political priorities into private commercial decisions and diverts resources from productive activity. The premise that official emissions-accounting frameworks of this kind improve capital allocation is rejected. Please refer to the attached full comment letter.

22. Overall, how satisfied are you with the proposed sustainable finance taxonomy framework?

Very 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?

I fundamentally oppose the concept of a government-endorsed or quasi-official green taxonomy. It constitutes central planning of private capital, substitutes committee judgments for market discovery, and will raise compliance costs while distorting capital allocation, particularly harming Canada’s resource and energy sectors which are a significant driver of the Canadian economy. There is no strong quantifiable evidence that similar taxonomies (including the EU’s) have delivered measurable emissions reductions separable from deindustrialization or other concurrent policies. The attached full comment letter sets out the detailed free-market critique, including the effects of DNSH criteria, the absence of accountability mechanisms, Canada’s FDI relationship with the United States, and the recommendation that the draft Methodology Report and any resulting taxonomy be withdrawn or abandoned.