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
• Other (please specify)

1b. Specify priority

Climate change adaptation/resilience is the ‘no regrets’ path. The scientific basis relied upon for the taxonomy is out-of-date, so updated climate science should be the priority.

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

None of these principles are met by this exercise as the Sustainable Finance Taxonomy group is using the outdated science of IPCC SR1.5 from 2018. As of 2026, the climate catastrophe scenario known as RCP8.5/SSP5-8.5 has been sidelined by the official climate modelling community as ‘implausible’; there is no further rationale or urgency for Net Zero climate action.

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

Not at all important

Dynamic

Not at all important

Regionally Specific

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

Efforts to decarbonization are doing significant harm (Do No Significant Harm (DNSH)) to Canada’s economy and exceeding Minimum Social Safeguards (MMS). For instance, to decarbonize Alberta oil, the province would lose staggering revenues and thousands of jobs. Retired energy economist Robert Lyman writes in his new report: “Here, I would like to focus on the implications of complete decarbonization on oil and gas. It is the largest single contributor to the Alberta economy, accounting for roughly $88 billion of GDP in 2024, equivalent to 25% of the province’s total GDP. It directly accounted for 200,000 jobs, equating to 8% of total employment. Total revenue from oil and gas production to Alberta was $153 billion in 2024, with oil sands ($105 billion) accounting for the lion’s share.” https://blog.friendsofscience.org/2026/08/09/decarbonize-alberta-really/

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

Canada already has stringent environmental regulations in place and has made Indigenous rights a center piece of all related energy developments.

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 last thing Canada needs is more regulation. According to the Business Council of Canada, companies are strangled by red tape and regulations “The Canadian Federation of Independent Business, which issues regular reports tackling red tape, has pegged the number at 170,000 at a minimum.

A recent paper from Statistics Canada is probably the most thorough. It put the total number of regulatory requirements in Canada at 321,000 in 2021.” https://www.thebusinesscouncil.ca/report/stifled-by-red-tape/

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

Layers of overlapping climate regulations (of which there are some 400 – none of which have ever been audited for effectiveness) need to be repealed in order to unleash Canada’s national energy security and economic prowess.

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

These disclosures are make-work projects for consultants that create no useful or saleable products or services. They raise the cost of doing business, especially for small and medium sized enterprises, the life-blood of democracy and job creation, and they limit the productivity of companies by raising the risk of lawfare over nebulous carbon accounting issues.

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

Lack of investment in conventional energy and dispatchable power generation will lead to the failure of manufacturing in Canada, job loss, social disorder, and potential blackouts. Unless we REcarbonize Canada, we will not be seen as a reliable energy provider and partner on the world stage, but rather a country self-sabotaging its own riches and potential at a time of great global demand and need for energy.

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?

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

Canada has substantial regulatory frameworks already in place to address these issues. Companies should not have to comply with this additional layer of compliance and reporting.

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

Strongly disagree

12b. Please explain your answer in the space below

Unfortunately, the so-called ‘green’ category misleads people. Renewable energy generation, batteries and some storage technologies as well as electric vehicles use far more critical minerals that conventional generation – meaning that at the ‘back-end’ of their production, they are far more energy intense in terms of mining and mineral processing. Most of these items are also transported by sea can carriers, thousands of miles across the ocean using marine diesel. To date, solar panels cannot be recycled; old wind turbines are being buried, not recycled, old EV batteries and grid-scale battery farms have a risk of toxic, uncontrollable thermal fires. There is nothing green about this category.

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

Strongly disagree

13b. Please explain your answer in the space below

Counting carbon molecules, when the rationale for Net Zero has evaporated (i.e. the sidelining of the climate catastrophe scenario RCP 8.5) is a meaningless but costly activity.

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

The science-based credibility relied upon in the Sustainable Finance Taxonomy is that of the IPCC SR 1.5 report from 2018, which has been debunked by the fact that RCP 8.5, upon which that report relied, has been officially sidelined as ‘implausible’. There is no scientific credibility in the taxonomy designations.

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

As explained in previous sections, the taxonomy has no scientific credibility and additional measures of any kind are simply burdensome on industry and corporations, inviting lawfare from ENGOs who will seek out the smallest possible error (all emissions are estimated, not measured) to attack our major industries. In a time of a global energy crisis, deemed to last at least 2 years if not more, our major resource and energy industries must not be burdened with useless regulations or further risks of lawfare.

16. Should any additional guardrails be considered?

Again, the taxonomy is not based on any valid scientific or economic basis, it fails to address the new realities of global geopolitics and energy demand/supply. None of the taxonomy plan should be implemented.

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

The 2026 Statistical Review of World Energy reveals that, contrary to the report’s claim of declining use of fossil fuels, there has been and will be ever increasing use.
The 2026 edition of the Statistical Review of World Energy, like virtually all of its predecessors back to the year 2000, documented the continuing (indeed, growing) percentage of the world energy needs that are supplied by hydrocarbons. In 2025 it was 87%. in other words, hydrocarbons remain essential to the world’s energy security, economic wellbeing and food production. There is no evidence that this growth in demand, with the associated greenhouse gas emissions, will decline significantly in the near future. Indeed, 69% of the current global GHG emissions are produced by the non-OECD countries, for which reliance on hydrocarbons is essential to their economic growth and the wellbeing of their growing populations. The trend, in other words, is for economic and population-driven growth in hydrocarbons use and related emissions. The companies that ignore this trend are the ones whose financial prospects are likely to be most at risk, not those who pretend that climate policies in the OECD countries will change energy consumption patterns.
In JP Morgan’s “Heliocentrism” of 2025, energy analyst Michael Cembalist noted that “Reality Bites. Goldman Sachs has been at the forefront of aggressive renewable transition projections in its Carbonomics series. However, they struck a much more cautious tone in their October 2024 piece, particularly as it relates to slow progress on hydrogen, carbon capture and coal decommissioning. Goldman now assumes a “longer life for hydrocarbon assets”, growing demand for natural gas as a transition fuel until 2050, and the need for new oil & gas development beyond 2040. What a difference a year makes.”
The Sustainable Finance Taxonomy does not recognize this reality, which is much amplified with the spring 2026 closure/complications in the Strait of Hormuz and the resulting global deficits of Gulf Coast crude oil, LNG, urea for fertilizer, helium (for hi-tech processes), and materials necessary for processing copper, to name a few critical issues.

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

These are unnecessarily elaborate and convoluted and they do not address the fact that the world needs a reliable supplier of conventional oil, gas and coal, and critical minerals, all of which Canada can provide, but not under blankets of regulations of carbon accounting and climate risk disclosure (invalidated by the removal of RCP 8.5 from climate risk analysis – meaning there is no Net Zero rationale at all).

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

Very 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?

To reiterate: These are unnecessarily elaborate and convoluted and they do not address the fact that the world needs a reliable supplier of conventional oil, gas and coal, and critical minerals, all of which Canada can provide, but not under blankets of regulations of carbon accounting and climate risk disclosure (invalidated by the removal of RCP 8.5 from climate risk analysis – meaning there is no Net Zero rationale at all).

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. We must REcarbonize Canada’s economy, jump start jobs in the energy and resource sector and throw off the burden of climate risk reporting as the removal of the climate catastrophe scenario, RCP 8.5, makes this unnecessary.

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?

The world has changed – national energy security and economic power based on conventional energy must be Canada’s focus. The scientific basis of the alleged climate emergency (and thus the need for Net Zero) has been dissolved by the elimination of the climate catastrophe scenario known as RCP 8.5 (SSP5-8.5).
Please read our report:
Sustainable Finance Taxonomy – Is Based on Out-of-date Science and Greenwashing Unsustainability – A response to the Business Future Pathways Report
https://blog.friendsofscience.org/2026/08/12/sustainable-finance-taxonomy-out-of-date-science-and-unsustainable-greenwashing/