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
• Water and marine resource conservation
• Pollution prevention and control

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

Neutral

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

I think the proposed principles are reasonable, but I believe they could be strengthened from a physical climate risk and catastrophe modelling perspective. First, the framework has not clearly required quantitative assessment of physical hazards such as flooding, wildfire, extreme heat, drought and water stress. A mitigation-aligned asset may still face substantial physical climate risk. Second, the principles of being dynamic and regionally specific should more explicitly incorporate changing and spatially heterogeneous catastrophe risk under alternative climate scenarios. Forward-looking hazard, vulnerability and loss modelling could help operationalize these principles. Third, the framework should more clearly distinguish climate alignment from climate resilience. Taxonomy alignment indicates whether an activity supports climate objectives, whereas catastrophe modelling evaluates whether the underlying asset can withstand future climate hazards and remain operational and financially viable. I therefore support the general direction of the principles, but believe stronger integration of quantitative physical climate risk and resilience assessment is needed.

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

Important

Dynamic

Important

Regionally Specific

Important

Prioritized

Very 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

4b. Please explain your answer in the space below

I agree with the proposed partial alignment approach, particularly from a physical climate risk perspective. Climate and catastrophe risks are not binary. Flood, wildfire, extreme heat, drought and other hazards occur along a continuum of severity and can vary substantially by location, time horizon and climate scenario. A partial alignment approach allows these differences to be transparently disclosed rather than reducing complex risk assessments to a simple pass/fail outcome. It can also support the use of quantitative catastrophe modelling, including hazard, exposure, vulnerability, expected loss and residual risk metrics. Disclosure of unmet criteria can help identify where adaptation or resilience measures are required and allow improvements in risk to be tracked over time. However, for highly material physical climate risks, I believe minimum risk-management or resilience requirements should still be considered so that partial alignment does not become a substitute for addressing significant risks.

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

Agree

5b. Please explain your answer in the space below

I agree with the proposed scope because it appropriately recognizes that sustainable activities should be assessed not only for climate mitigation, but also for their broader environmental and social impacts. Climate adaptation is becoming essential, as mitigation-aligned assets may still face significant physical risks from flooding, wildfire, extreme heat, drought, and water stress. The inclusion of water, biodiversity, and pollution objectives is also appropriate because these risks are interconnected with catastrophe risk and can materially affect asset resilience and long-term performance. I also support the inclusion of social safeguards, particularly Indigenous rights, because many infrastructure and resource projects are highly location-specific and can directly affect nearby communities. Going forward, I would encourage the framework to support more quantitative, location-specific assessment of physical climate risk, including hazard, vulnerability, expected loss, and residual risk after adaptation measures.

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?

Neutral

6b. Please explain your answer in the space below

I select Neutral because grounding the DNSH/MSS frameworks in Canadian legislation provides a practical and credible baseline, but existing laws and standards may not always be sufficient for forward-looking climate risk assessment. Physical climate risks such as flooding, wildfire, extreme heat, drought, and water stress are changing over time and can exceed conditions reflected in historical regulations or design standards. Going beyond existing requirements may therefore be appropriate where robust climate science and catastrophe modelling indicate material future risks. However, any higher standard should be transparent, evidence-based, quantitatively justified where possible, and applied consistently to avoid creating unnecessary uncertainty or implementation burden.

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

I believe it may be necessary to go beyond existing laws and standards particularly for physical climate risk and resilience. Many existing building codes, infrastructure standards, and risk-management requirements are based largely on historical climate conditions and may not adequately reflect changing risks from flooding, wildfire, extreme heat, drought, and water stress. For long-lived assets, the DNSH framework should encourage forward-looking, location-specific assessment using climate scenarios and catastrophe modelling to evaluate changes in hazard, vulnerability, expected loss, and disruption over the asset's lifetime. Where credible scientific evidence indicates material future risk beyond existing regulatory requirements, additional resilience measures should be considered. Such requirements should remain transparent, proportionate, and evidence-based.

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

I agree that requirements should be proportionate to the size and complexity of projects and entities, as overly burdensome requirements could discourage taxonomy adoption, particularly for smaller organizations. However, project size should not be the only determinant. Physical climate risk is highly location- and hazard-specific; a relatively small project located in a high-risk flood or wildfire area may warrant more detailed assessment than a much larger project in a low-risk location. I therefore suggest a risk- and materiality-based approach, where disclosure and assessment requirements reflect project size, asset life, geographic exposure, potential financial loss, and the severity of relevant climate hazards. Larger or materially exposed projects could require quantitative catastrophe and scenario analysis, while lower-risk projects could use more streamlined assessments. This would balance usability with credible risk management.

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

A key gap is the limited operational detail for forward-looking physical climate risk. The framework should more explicitly consider how flooding, wildfire, heat, drought, and water stress may change over an asset’s lifetime, including potential cascading impacts on communities and ecosystems. Location-specific climate and catastrophe risk assessment could help identify harms that historical standards may miss.

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 MSS framework should require early, documented, and meaningful engagement with affected Indigenous rights holders for projects that may affect their lands, resources, or communities. FPIC should be integrated into project-level due diligence, with transparent evidence of consultation, identified impacts, mitigation measures, and how Indigenous input influenced project decisions.

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

No

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

Neutral

12b. Please explain your answer in the space below

I selected Neutral because limiting the green category to zero or near-zero emissions provides a clear mitigation-focused definition, but it may not fully capture the long-term sustainability of an activity. A low-emission asset can still be highly exposed to flooding, wildfire, extreme heat, drought, or water stress. In future phases, I would encourage the taxonomy to complement emissions-based classification with forward-looking physical climate resilience considerations, so that activities labelled green are not only low-carbon but also capable of remaining viable under changing climate conditions.

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

Neutral

13b. Please explain your answer in the space below

I selected Neutral because the transition category is useful for recognizing credible decarbonization pathways in hard-to-abate sectors, but eligibility should not rely only on emissions trajectories. Long-lived transition assets should also be assessed for future physical climate risks such as flooding, wildfire, heat, drought, and water stress to ensure they remain resilient and financially viable through 2050.

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?

Disagree

14b. Please explain your answer in the space below

I disagree because the proposed guardrails appear focused mainly on emissions reduction and carbon lock-in, but do not sufficiently address whether transition activities remain resilient to future physical climate risks. Long-lived assets in sectors such as steel, cement, chemicals, energy, and infrastructure can face increasing exposure to flooding, wildfire, extreme heat, drought, and water stress. Stronger guardrails should therefore include forward-looking, location-specific climate risk assessment and, where material, quantitative measures of expected loss, operational disruption, and residual risk after adaptation. This would strengthen the science-based credibility of the transition category without undermining usability.

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

I agree in principle, provided the abatement category has strong and transparent guardrails. It can recognize meaningful near-term emissions reductions in activities that are likely to decline over time, but eligibility should be clearly time-limited and demonstrate that investments do not extend asset life or create carbon lock-in. I would also encourage the guardrails to consider forward-looking physical climate risk, since long-lived abatement investments may still be exposed to flooding, wildfire, extreme heat, drought, or water stress. Quantitative assessment of emissions reduction, asset lifetime, and residual climate risk would help maintain the credibility of this category.

16. Should any additional guardrails be considered?

Additional guardrails may include forward-looking physical climate risk and resilience. Abatement investments should be assessed for material exposure to flooding, wildfire, extreme heat, drought, and water stress over their expected lifetime. Where risks are significant, projects should demonstrate appropriate adaptation measures and acceptable residual risk.

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

Not at this time, thanks.

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

I agree with the proposed approach because forward-looking, quantitative, and regularly updated screening criteria can improve credibility and consistency. I would also encourage the criteria to incorporate location-specific physical climate risk and resilience, particularly for long-lived assets exposed to flooding, wildfire, heat, drought, and water stress.

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

Very important

Include sunset and/or sunrise dates where relevant

Very important

Revise as necessary during regular review periods

Very important

Primarily use quantitative metrics

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?

I think the criteria should be more performance-based. They should define measurable outcomes and minimum thresholds while allowing different technologies and modelling approaches to demonstrate compliance. For physical climate risk, this could include location-specific hazard, vulnerability, expected-loss and resilience metrics under forward-looking climate scenarios. This is more robust than prescribing specific technologies, which may become outdated as science and engineering evolve.

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 generally agree with prioritizing Scope 1 while including Scope 2 and 3 where material, but materiality should be assessed carefully at the activity and sector level. For some activities, upstream or downstream emissions may dominate the total climate impact and should not be excluded simply because they are harder to measure. I would also keep emissions accounting distinct from physical climate risk: a low-emission activity can still be highly vulnerable to flood, wildfire, heat, drought or other hazards, so both dimensions should ultimately be considered.

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?

No, thank you.