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
• Protection of biodiversity and healthy ecosystems
• Circular economy

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

Agree

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

Important

Regionally Specific

Very 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?

Agree

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

Agree

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?

Disagree

6b. Please explain your answer in the space below

We caution against extending DNSH/MSS criteria beyond existing laws and standards without careful consideration of Canada’s regulatory context, regional differences, and the fact that standards in this space are still evolving. This is particularly important when considering sector-specific DNSH criteria. Introducing new limits, plans, or requirements that conflict with, duplicate, or go beyond existing regulatory obligations could create confusion, increase administrative burden and discourage participation.

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

It may be necessary to draw on sector-specific practices, guidance, and operational expertise to ensure DNSH criteria appropriately account for climate adaptation considerations, while being consistent with what is legally required in Canada. See Questions 6 response. Guidelines should not be in conflict or go beyond existing regulatory obligations.

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

Streamlined disclosure requirements for smaller projects and entities would help minimize administrative burden, particularly for companies with more limited capacity or technical expertise in sustainable finance. However, the principle of proportionality should apply more broadly: disclosure requirements should be designed to reduce unnecessary administrative burden across all project and entity sizes while still generating meaningful, decision-useful information.

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

Important to include Indigenous business and private sector considerations when developing, to ensure prior barriers to advancing economic reconciliation are considered.

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

DNSH criteria should recognize that in the Canadian forest sector, active management (harvesting, thinning, fuel treatment) is often the risk-reduction intervention, not the harm. Fire is a natural process many species depend on, but today's uncharacteristically severe and frequent fire regime, outside the historical range of variability, is itself an escalating threat to biodiversity, water, communities, and the carbon sink. Criteria should assess net outcomes at the landscape level, with existing forest management laws and certification as the DNSH floor.

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

Agree

12b. Please explain your answer in the space below

We generally agree. The technical screening criteria will be very important, given the scope (supply chain) in determining zero and near-zero emissions.

Footnote 15 correctly notes that net zero will require removals, including within agriculture and forestry. The green category should explicitly recognize activities whose direct output is carbon removal or durable storage: afforestation and restoration where appropriate to the landscape, management that improves the durability of landscape carbon, and conversion of harvest and fire-mitigation residuals into engineered removals such as biochar. One caution: removal must not be equated with maximizing standing stock. On fire-prone landscapes a tonne added is also a tonne of fuel; the credible removal is the tonne expected to remain. Criteria should reward durable, risk-adjusted removals, so the taxonomy mobilizes a Canadian removals industry without financing new fuel load.

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

Agree

13b. Please explain your answer in the space below

The proposed framework relies heavily on the concept of technically feasible zero to near-zero emissions substitutes. While 3.2 notes that the definition of near-zero will be determined through the development of the technical screening criteria, the importance of this definition cannot be overstated. Also, further clarification is needed regarding how substitutes will be evaluated. Greater transparency on the criteria, including scalability and functional equivalency, would improve clarity and consistency.

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?

Agree

14b. Please explain your answer in the space below

Additional clarity will be needed on how these guardrails are going to be implemented. While the thresholds for determining emissions reduction are going to be established through future technical screening criteria, it is less clear how activities will be evaluated against the requirement to avoid carbon lock-in to dead-end pathways.
In the forest sector the relevant 'asset' is often a managed landscape, not a single facility. Transition measures should be read to include landscape-scale practices (fuel management, thinning, salvage and rehabilitation, fire-risk-reduction treatments) applied across a management unit or tenure. These materially reduce the emissions trajectory of the landscape and are exactly where a credible transition label could unlock capital that does not flow today.

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

Agree (i.e., agree in principle, with conditions)

15b. Please explain your answer in the space below

We generally support the inclusion of an abatement measures category when narrowly applied to activities that can deliver credible, measurable near-term emissions reductions in sectors or activities expected to experience demand decline in Paris-aligned pathways. However, the category should be carefully and transparently scoped, and supported by clear guardrails to avoid misclassifying sectors or activities that are expected to play an ongoing or growing role in a low-carbon economy. For the forest products sector, many activities are better understood as climate solutions, enabling activities, or transition-aligned investments, given their role in low-carbon materials, renewable energy, circularity, housing, and long-term carbon storage. The taxonomy should therefore ensure that abatement measures are not applied in a way that unintentionally characterizes forest products or the broader forest bioeconomy as demand-decline activities.

16. Should any additional guardrails be considered?

We generally support the use of clear guardrails for the abatement measures category, particularly given the need to preserve the taxonomy’s credibility while ensuring it remains usable in practice. Guardrails should ensure that eligible abatement measures deliver measurable, time-bound emissions reductions; avoid extending the operating life of assets or activities that are not aligned with credible decarbonization pathways; and do not divert capital away from longer-term climate solutions, enabling activities, or transition-aligned investments.
Additional guardrails should also clarify how demand-decline activities are identified and ensure this categorization is applied narrowly and transparently. For sectors such as forest products, where many activities are expected to support ongoing or growing demand in a low-carbon economy, the framework should avoid applying abatement guardrails in a way that unintentionally characterizes the broader sector or forest bioeconomy as demand-decline. The guardrails should also be practical to demonstrate and proportionate in their disclosure requirements, particularly for smaller entities or projects with limited administrative capacity.

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

Agree

18b. Please explain your answer in the space below

There are nuanced criteria and approaches for managed forest landscapes, it will be very important to have technical and operational expertise within these technical working groups.

Criteria must work where the operator is not the landowner (Canada is different from EU countries in this regard). About ninety per cent of Canada's forest is publicly owned and managed by tenure holders under binding provincial frameworks. Nothing in the taxonomy requires land ownership, but criteria imported from ownership-based jurisdictions (for example, permanence guarantees that assume land control) will fail here without a tenure-based equivalent. Done well, this would be genuinely novel: the first credible channel for private sustainable finance into publicly owned managed landscapes at scale. Finally, one investment can produce reductions, removals, and ecosystem service outcomes together; criteria should recognize these jointly rather than forcing a single classification.

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

Important

Include sunset and/or sunrise dates where relevant

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

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?

Generally focusing on an outcomes-based approached (with appropriate technical considerations) allows flexibility in implementation and encourages innovation in meeting outcomes, rather than applying a prescriptive approach across sectors and project sizes.
The EU's forestry criteria are a caution on usability: uptake has been minimal, largely because they duplicated existing certification and national frameworks, and the EU is now simplifying them. Canada's concentrated, certified operator base avoids part of that problem, but the lesson holds: recognize existing forest management legislation, planning instruments, and certification (SFI, FSC) as the compliance backbone rather than building a parallel reporting layer.

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?

Generally Agree. Regarding assessing feedstocks within supply chains, specifics on how mill bioenergy is handled in the taxonomy should reflect how bioenergy is already handled at the regulatory and country level, not be rewritten or modified for this voluntary system.

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?

The forest products sector, from forest management through product manufacturing and the full value chain, needs coordinated forestry and manufacturing criteria predicated on comprehensive forest-sector representation in the technical working groups tasked with developing them. We recommend forest products sector technical and operational knowledge (and individuals) be considered for various sector specific guidance technical working groups, in particular, Buildings, Manufacturing and Agriculture and Forestry.

There are nuanced and important considerations around biogenic carbon removal and treatment of harvested wood products, that would warrant dedicated consultation.

A significant opportunity for the taxonomy in the forest products sector (forestry and manufacturing) is mobilizing private capital into the transformation of Canada's fire-prone managed landscapes. The investment required exceeds what governments and forest companies can finance alone, and no standardized instrument exists for sustainable finance to reach this work, including on Crown forest tenures where most of the opportunity sits. Well-designed criteria would make three linked outcomes investable:
• Avoided emissions from reduced catastrophic wildfire;
• Removals from directing recovered biomass into durable products and engineered removals, (e.g. , biochar, BECCS and Carbon Dioxide Removals); and
• Long-term stabilization of the managed forest carbon balance.