Public Consultation Submission

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.

  • Other (please specify)

1b. Specify priority

Only real pollutants should be a focus for policy, and since we already have laws for these, and pollution has fallen dramatically, no further policy is needed at this time.

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 disagree

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

I disagree, not because I object to a framework being “credible” or “usable” in the abstract, but because these six principles are not the true foundation of the taxonomy, and two of them are defined in ways that pre-load an anti-human conclusion.

The actual foundation is the assumption, stated in the preceding section, that “net zero by 2050” and “Paris alignment” are an unquestioned “ambition.” The six principles are merely design qualities for executing that predetermined goal, so endorsing them means endorsing the goal by the back door.

More telling is what the principles omit: any measure of whether an energy investment serves human flourishing: the affordability, reliability, and security of energy for Canadians. “Usable” refers to usability for financial institutions, not usefulness of the energy to human beings. The report states plainly (Section 1.2) that criteria will be “based on criteria aligned with science-based climate objectives, not economic projections, national priorities beyond climate, or short-term market cycles.” That is an explicit decision to exclude the economic and human benefits of an activity from its evaluation. A framework that scrutinizes emissions while refusing to weigh benefits is not credible; it is one-sided by construction.

Two of the six are not neutral design goals but vehicles for the underlying premise. “Credible,” as defined, means conformity to net-zero pathways plus “guardrails to minimize carbon lock-in”, so “credible” does not mean true or valuable, it means orthodox. “Interoperable” means harmonizing with the EU and other taxonomies, which is precisely how a “voluntary” tool becomes a de facto mandatory trade barrier, since the report itself notes EU-style taxonomies are used for regulatory compliance and market access.

A sound foundation would rest on a single principle the list conspicuously lacks: technology neutrality in the service of human flourishing. Evaluate every energy investment by its full effect on human life: cost, reliability, security, and genuine, demonstrable, reasonably preventable harm; not by its proximity to a political emissions target.

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

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?

Agree

4b. Please explain your answer in the space below

Why this pick: "Disagree" here reads as "I'd prefer the binary EU model," which is worse. So agree — but for a narrow reason, spelled out in the text.

Paste text (4b):

I support a disclosure-based "partial alignment" approach only in the narrow sense that it is less destructive than the binary EU model, which lets a single unmet criterion — a biodiversity box, a "circular economy" checkbox — disqualify an entire viable project. A binary regime hands anti-development activists a one-criterion kill switch over projects that are otherwise sound. Disclosure is the lesser evil.

But I want to be clear that this is a choice between two versions of a framework I consider fundamentally misguided. The relevant question about any activity is not how many taxonomy criteria it "aligns" with, but whether it causes demonstrable, significant, and reasonably preventable harm to human health or property. That is a question for objective law, not for a capital-allocation label. Please do not read my preference for disclosure over a binary veto as support for the taxonomy itself.

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

I disagree. The proposed environmental scope — "protection of biodiversity and healthy ecosystems," "water conservation," "circular economy," alongside pollution — mixes a few legitimate concerns with open-ended, undefinable ones. Terms like "biodiversity," "healthy ecosystems," and "circular economy" have no objective threshold; the report itself concedes these objectives lack "the same clear benchmark" as the climate target. In practice, criteria without objective thresholds become limitless discretion — a standing tool to delay or disqualify power plants, mines, transmission lines, dams, and pipelines because some plant, animal, or "ecosystem value" is affected.

The only legitimate environmental objective is preventing demonstrable, significant, and reasonably preventable harm to human health and property from real pollution — a standard already handled by Canadian environmental and property law. Everything beyond that substitutes an anti-impact standard (minimize humanity's footprint on nature) for a pro-human one (protect people from genuine harm). On the social side, protecting people from fraud, coercion, and violations of actual legal rights is legitimate; using vague "governance" and "social value" language to gatekeep investment is not.

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

I disagree with the proposal to go beyond existing laws and standards. This is the single most important objection in this section. The report states plainly that "the taxonomy itself, as a voluntary market tool, is not the appropriate mechanism to require or enforce higher standards on the private sector beyond those that are already required in existing laws or international standards." I agree with that sentence, and then the very next proposals contemplate doing exactly what it warns against.

If a requirement is genuinely necessary to protect Canadians, it should be enacted as objective law by accountable, elected legislators, where it can be debated, voted on, and repealed. An arm's-length council, funded by the federal government but answerable to no electorate, inventing standards that go beyond democratically enacted law and then using access to capital as the enforcement lever, is technocratic overreach. It is the ESG playbook: impose through finance what could not be passed through legislatures. Ground the framework in existing law and go no further.

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

None. If a harm is real, significant, and reasonably preventable, the remedy is objective legislation, applied equally to everyone and enforced by courts, not a voluntary finance label that pressures capital toward politically favored activities. "Going beyond existing law" is simply another way of describing the imposition of requirements that Canada's legislators and voters have not chosen to enact. That the taxonomy's authors feel entitled to set a bar "higher than existing Canadian statutes" is precisely the problem, not a feature to be refined.

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

The proper standard for any project is whether it causes demonstrable, significant, preventable harm, never its size. Scaling disclosure burdens by size does two harmful things. First, it loads the heaviest compliance costs onto exactly the large-scale projects a growing, secure economy depends on: major electricity generation, transmission, mining, and resource infrastructure. Penalizing bigness penalizes the reliable-energy and critical-minerals buildout Canada urgently needs. Second, it adds another layer of arbitrary complexity and discretion to a framework already too heavy with both. If a large project and a small project pose the same genuine risk to a neighbor's health or property, the law should treat that risk identically; if neither poses such a risk, neither should be gated at all.

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

Yes, and the most serious gap is that the framework has no safeguard whatsoever against the harm it is most likely to cause: harm to human beings through the deprivation of reliable, affordable energy and the starvation of capital to the industries that produce it.

The entire apparatus scrutinizes side-effects on nature while ignoring the benefits side of the ledger entirely. Fossil fuels supply roughly 80% of the world's energy and underpin the fertilizer, machinery, and resilient infrastructure that feed and protect billions. Cost-effective energy is why climate-related disaster deaths have fallen about 98% over the last century. A framework that treats CO₂ as the master "harm," relegates oil and gas to a declining "abatement" category, and then adds biodiversity, "circular economy," impact-assessment, and consent vetoes on top, is engineered to make capital flee reliable energy, raising energy costs, weakening Canadian competitiveness and security, and hitting lower-income Canadians hardest. Those are real, foreseeable, human harms, and the framework contains no "do no significant harm" test for them. The DNSH/MSS chokepoints will also predictably be used to block low-emissions projects the authors claim to want (nuclear, hydro, transmission, and the mining of critical minerals) because every one of those "significantly impacts nature." That is not a hypothetical; it is the documented history of Canada's Impact Assessment Act.

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 right principle is the full protection of actual individual and property rights. Where Indigenous individuals or communities hold legally recognized title or treaty rights in land or resources, those rights deserve exactly the same rigorous protection as anyone else's property rights, which means development on those lands requires genuine consent, secured through voluntary agreement and fair compensation. That is legitimate and important.

What the taxonomy should not do is operationalize FPIC as an open-ended collective veto, a standard triggered by any "potential or actual impact on rights or interests," as the Australian precedent cited in the report does. Interpreted that way, "consent" becomes an unbounded power to block projects on Crown land or on others' property, exercisable indefinitely and often driven by outside activist organizations rather than the affected community. Two consequences follow. First, it makes major projects un-financeable through years of uncertainty, the pattern that has already cost Canada pipelines and tens of billions in investment. Second, and less noticed, an activist-driven veto regime can override the actual consent of Indigenous communities that want development, the many nations that are owners, partners, and beneficiaries of resource and energy projects and want the jobs and revenue. Respecting Indigenous rights means respecting their right to say yes as much as their right to say no. Operationalize FPIC as protection of concrete title and treaty rights through consent and contract, not as a generalized veto over public land or third-party projects.

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

My core feedback is directed at the foundation, not the details. The taxonomy takes "net zero by 2050" as its unquestioned "North Star" and defines every activity's worth by proximity to that target. That is the wrong standard. A pro-human financial framework would be technology-neutral and would value energy by its contribution to human flourishing ( affordability, reliability, versatility, scalability) which means treating oil, natural gas, nuclear, and hydro as the assets they are, not liabilities to be phased down. Consigning oil and gas to an "abatement-only," "carbon lock-in," "declining demand" category is economic self-sabotage for a country holding one of the largest oil endowments on Earth and roughly 30% of whose emissions the authors treat as a problem to be managed rather than a source of prosperity to be developed.

Two further points. First, "voluntary" is not reassuring. Taxonomies become de facto mandatory through the back door: disclosure rules, green-bond frameworks (which this document already anticipates the government aligning to the taxonomy), and regulatory and lender pressure. Second, investors are already free to weigh climate and transition risk however they judge best; they do not need a government-funded council to tell them what counts as "green." The honest and pro-human course is to let capital flow to whatever delivers the most human value, hold every project to objective laws against genuine, preventable harm, and abandon the project of politically ranking economic activity. I'd encourage the Council to withdraw the framework rather than refine it.

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?

Strongly disagree

12b. Please explain your answer in the space below

I disagree on fundamentals. The error is not where the "green" line is drawn; it's the decision to define "green" by emissions at all. This bakes the anti-impact, emissions-only standard into the foundation of Canadian capital markets: an activity's worth is judged by a single side-effect, carbon dioxide, while its benefits (reliability, affordability, the fact that energy powers every other industry) are excluded by design, exactly as Section 1.2 states.

The arbitrariness is visible in the framework's own example. An electric-vehicle manufacturing facility is deemed "green" as an "enabling" activity, while a natural-gas plant that keeps hospitals and homes powered through a Canadian winter, or a fertilizer plant that helps feed billions, is not. That is not a scientific distinction; it is an ideological one. It also means the label "green" attaches to activities that are neither reliable as energy nor low-impact in reality: industrial-scale solar and wind require vast mining, land, and materials. A sound framework would be technology-neutral and would evaluate every activity by its full effect on human life, not by its position on a carbon scale.

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?

Strongly disagree

13b. Please explain your answer in the space below

I disagree on fundamentals. This category makes a pledge to reach "zero to near-zero emissions by 2050" the entry ticket to legitimacy, regardless of whether such a pathway is technically or economically real for a given industry, and regardless of the enormous human value that steel, cement, and chemicals deliver in the meantime. It steers capital by a speculative political timeline rather than present value, and it stigmatizes as "carbon lock-in" the ordinary act of investing in productive capacity that will still be needed for decades.

The deeper problem is the word "transition" itself, which presupposes the conclusion: that the destination is a near-total elimination of emissions by a fixed date. That destination is the very premise the whole framework refuses to examine. A pro-human framework would have no "transition" category, because it would not assume that moving away from the world's most reliable and scalable energy is the goal. It would ask whether an investment produces genuine value and avoids demonstrable, preventable harm, and if so, fund it, with no expiry date attached.

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

I disagree on fundamentals, and I want to be explicit that this is not a complaint that the guardrails are too weak. It is the opposite. The guardrails exist to serve two objectives I reject: protecting "science-based credibility," which in practice means conformity to net-zero orthodoxy rather than truth, and preventing "carbon lock-in," which treats continued investment in reliable energy as a harm in itself. "Carbon lock-in" is not a demonstrable injury to any Canadian; it is an ideological construct. Guardrails engineered to prevent it are chokepoints in service of a flawed goal, and calibrating them more finely cannot rescue a category built on that goal.

The question also concedes the framework's internal contradiction: guardrails that protect "credibility" work directly against "usability." Every additional whole-of-activity and measures-pathway test adds complexity, discretion, and uncertainty for the businesses and investors who must comply. You cannot maximize both, and the attempt produces a tool that is simultaneously ideologically rigid and practically unusable. The resolution is not a better balance; it is to abandon the exercise of politically pre-ranking investment.

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

I strongly disagree on fundamentals. The "abatement" category is the framework's most damaging feature: it takes Canada's single greatest economic asset, an oil and gas sector resting on the largest proven reserves of any free nation, and formally brands it a managed decline, a stigmatized activity to be wound down rather than developed. For a country whose prosperity, fiscal base, and allies' energy security depend on this industry, that is economic self-sabotage codified into financial architecture.

The category's justifying premise is simply false. The report asserts that oil and gas are "highly likely to experience declining demand as the world transitions to clean energy." That is not an observed fact; it is a net-zero modeling assumption presented as destiny. In reality, global oil demand is at an all-time high and still rising : world supply set a record of roughly 109 million barrels per day in September 2025, with the IEA forecasting continued demand growth through 2026, and Canadian oil-sands production hit a record in 2025. Fossil fuels remain about 80% of world energy. Building a capital-allocation label on a prediction that today's data contradicts creates a self-fulfilling prophecy: defund the industry on the theory that it is dying, and you help kill a thriving industry the world is actively demanding. The honest course is to treat oil and gas as the high-value assets they are, not to invent a euphemistic ("abatement") holding pen for their liquidation.

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.

16. Should any additional guardrails be considered?

No. I decline to help design additional chokepoints, because every guardrail in the illustrative list is engineered to serve two illegitimate ends, preventing "carbon lock-in" and preserving "Paris-aligned" credibility, neither of which corresponds to a real, demonstrable harm to any Canadian. Adding guardrails to the abatement category only tightens a mechanism whose entire purpose is to starve a productive industry of capital.

If the Council genuinely wants a "do no significant harm" test, the harm it has ignored is the one this category is most likely to cause: the harm to Canadians from higher energy costs, lost investment and jobs, weakened national and allied energy security, and the perpetuation of energy poverty abroad when capital is steered away from the reliable energy the world demands. There is no guardrail in the framework protecting against that. The appropriate action is not to add guardrails but to eliminate the abatement category altogether.

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

My core feedback is that the three-tier structure (green, transition, abatement) is a single ideological ranking of the entire economy by proximity to net-zero-by-2050, and it should be withdrawn rather than refined. It answers the wrong question. The right question about any investment is not "how close is it to zero emissions?" but "does it create genuine value for human beings while avoiding demonstrable, reasonably preventable harm?" Judged that way, oil, natural gas, nuclear, and hydro are assets, not a hierarchy of liabilities.

Two consequences deserve emphasis. First, this framework will defund even the low-emission energy its authors claim to favor. Nuclear, hydro, transmission, and the mining of critical minerals all "significantly impact nature," so the same Do-No-Significant-Harm logic layered onto these categories will be used to delay and block them, as Canada's own Impact Assessment Act history demonstrates. Second, "voluntary" is not a safeguard: taxonomies become mandatory through the back door via disclosure rules, green-bond frameworks, and lender and regulatory pressure, and the framework's stated goal of interoperability with the EU imports the world's most aggressive anti-fossil-fuel model as a de facto condition of market access. The pro-human course is to let capital flow to whatever delivers the most human value, hold every project to objective laws against real harm, and abandon the project of politically ranking economic activity in the first place.

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?

Strongly disagree

18b. Please explain your answer in the space below

I disagree. My objection is not to any single design choice but to what the entire approach takes for granted: that the right way to evaluate an economic activity is to measure its emissions against Paris-aligned pathways. Every element in the proposed approach (forward-looking metrics, quantitative thresholds, "robust methods") is machinery for executing that flawed standard more precisely, and precision does not cure a wrong standard.

The language of this section is designed to make an ideological judgment look like a scientific measurement. "Science-based" and "quantitative" describe how the criteria are calculated, not whether the thing being calculated is the thing that matters. What matters about an energy source is its full effect on human life: its reliability, its affordability, and whether it causes demonstrable, reasonably preventable harm. The report states plainly (Section 1.2) that criteria will exclude "economic projections, national priorities beyond climate, or short-term market cycles" – that is, it excludes the benefits of the activity by design. A methodology that scrutinizes one side-effect while refusing to weigh benefits is one-sided by construction, and building it on "robust methods" only lends it borrowed authority. A sound approach would be technology-neutral and would evaluate activities by their contribution to human flourishing, not their distance from an emissions target.

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 that 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
Not that important

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

As little as possible. To the extent criteria exist at all, they should be strictly technology-neutral: defined by objective, demonstrable outcomes, never by prescribing or favouring particular technologies. The moment a government body specifies which technologies count as legitimate, it is engaged in central planning — a handful of officials dictating which forms of energy may be pursued and how, instead of letting competing producers discover what actually works. That kind of planning reliably lands somewhere between inefficient and destructive, because no committee can foresee which technologies will best serve human needs, and prescription freezes the framework against the innovation it claims to want.

Technological prescriptiveness also entrenches today's politically favored options, industrial solar and wind, while disadvantaging reliable and low-emission sources like nuclear, hydro, and natural gas that a technology-neutral standard would treat on their merits. If the objective were genuinely to serve Canadians, the framework would set outcome-based requirements (does the activity create value, does it avoid demonstrable and preventable harm?) and let the market determine the means. Prescriptive technical criteria are how a "voluntary" tool becomes a government pick-list for the entire economy.

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?

I disagree, and I want to be unmistakable about the direction of my disagreement, because a climate activist would answer "disagree" here too, wanting more Scope 3. I want the opposite. My objection is that emissions-based screening is the wrong standard entirely, and that dragging Scope 3 into it, even under a "where feasible and material" hedge, is the single most damaging accounting choice in the framework.

Here is why it is decisive rather than technical. For oil and gas, the end-use of the product, a customer burning the fuel, is roughly 81% of total Scope 1+2+3 emissions and about 91% of Scope 3. That means Scope 3 accounting doesn't assess oil and gas; it pre-condemns them. No operational improvement an oil or gas producer could ever make would move the number that decides its classification, because the number is dominated by what millions of independent consumers choose to do with the product. Including Scope 3 builds the verdict into the arithmetic.

Scope 3 accounting is also incoherent on its own terms. It double-counts: the same molecule of CO₂ is charged to the producer, to the shipper, and to the consumer. And it rests on a fallacy: that the producer of a product deserves all the blame for its use while the consumer who demanded it deserves none. That makes no sense. The consumer is the one who asked for the product; the producer supplied a demand that exists regardless of any single company's choices. Attributing a customer's tailpipe to the refinery is not measurement, it is moral bookkeeping dressed as science.

So the "primarily Scope 1" instinct is the less irrational floor: Scope 1 at least covers emissions an operator actually controls. But the "Scope 2 and 3 where feasible and material" language is a loophole activists will drive straight through to disqualify oil and gas by end-use accounting, and it should be closed, not left ajar. To be clear, I reach this conclusion while rejecting the emissions-screening exercise as a whole: the right question is whether an activity delivers human value and avoids demonstrable, preventable harm, not how many tonnes of its customers' voluntary consumption can be assigned back to it.

Final questions

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?

My overall assessment is that this framework is built on the wrong foundation and should be withdrawn and reconceived, not amended. Nearly every problem I have identified in the detailed sections is a symptom of one root error, and no amount of technical refinement can cure a root error. A more sophisticated version of this taxonomy would do more damage, not less, because its machinery would more efficiently accomplish an anti-human end.

The root error: the wrong standard. The taxonomy evaluates economic activity by a single measure, proximity to a net-zero-by-2050 pathway, and it excludes the benefits of that activity by design. The methodology states plainly (Section 1.2) that criteria will rest on “science-based climate objectives, not economic projections, national priorities beyond climate, or short-term market cycles.” That sentence should alarm any Canadian. It means the affordability, reliability, and productivity of an energy source, the very things that make energy valuable to human beings, are ruled out of consideration before the analysis begins. A framework that scrutinizes one side-effect while refusing to weigh benefits is not “science-based.” It is one-sided by construction. The correct standard is technology-neutral and pro-human: evaluate every activity by its full effect on human life, its cost, reliability, and security, and hold it to objective law against demonstrable, significant, and reasonably preventable harm.

The framework targets Canada’s greatest asset on a false premise. By consigning oil and gas to a stigmatized “abatement” category, the taxonomy formally brands the country’s most valuable industry a managed decline. Its justification, that these activities face “declining demand as the world transitions,” is not an observed fact but a modeling assumption, and current reality contradicts it: global oil demand is at an all-time high and still rising, world supply set a record of roughly 109 million barrels per day in late 2025, and Canadian oil-sands output hit a record the same year, on the largest proven reserves of any free nation. Building a capital-allocation label on a prophecy of decline risks making that decline self-fulfilling: defund an industry on the theory that it is dying, and you help kill an industry the world is actively demanding.

It will defund even the low-emission energy its authors claim to want. Nuclear, hydro, transmission, and the mining of critical minerals all significantly affect nature, so the Do-No-Significant-Harm logic layered onto every category will be used to delay and block them, exactly as Canada’s Impact Assessment Act history demonstrates. A framework that stalls the reliable, low-emission buildout it purports to champion is incoherent on its own terms.

“Voluntary” is not a safeguard. Taxonomies become mandatory through the back door, via disclosure rules, green-bond frameworks the government already intends to align to this taxonomy, and lender and regulatory pressure. The framework’s stated goal of interoperability with the EU imports the world’s most aggressive anti-fossil-fuel model as a de facto condition of market access. Canadians should not be reassured by the word “voluntary.”

It is technocratic overreach. The methodology concedes that a voluntary market tool “is not the appropriate mechanism to require or enforce higher standards on the private sector beyond those already required in existing laws,” and then proposes to go beyond existing law anyway. If a requirement is genuinely necessary to protect Canadians, it should be enacted as objective legislation by accountable, elected representatives, where it can be debated, voted on, and repealed, not invented by a federally funded council answerable to no electorate and enforced through access to capital. That is the imposition through finance of what could not be passed through the legislature.

The alternative. Investors are already free to weigh climate and transition risk however they judge best; they do not need a government-blessed council to rank the economy for them. The pro-human course is to let capital flow to whatever delivers the most value to human beings, hold every project to objective laws against real and preventable harm, and abandon the project of politically pre-ranking economic activity. I respectfully urge the Council to withdraw this framework rather than refine it.

Privacy Policy

Effective Date: 29/04/2025

Business Future Pathways (“we”, “our”, or “us”) is committed to protecting your privacy. We collect personal information such as your name, email, organization, and message details when you submit a form on our website.

We use this information solely to respond to your inquiry, manage your participation, or send updates if you subscribe. Your information will not be sold or shared, except as required by law.

You may request access to, correction of, or deletion of your personal information at any time by contacting us at message@businessfuturepathways.ca.

By using this site, you consent to our collection and use of your information as described.

For any questions, please contact:

Business Future Pathways