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
• Pollution prevention and control

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

Agree

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

I fear that the Regionally specific criteria will end up giving priority to regional economic drivers at the expense of climate mitigation. An example would be fossil fuel extraction and transportation (pipelines) in Alberta and British Columbia.

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

Very important

Dynamic

Very important

Regionally Specific

Not at all 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?

Disagree

4b. Please explain your answer in the space below

The proposed "partial alignment" approach would appear to make the DNSH/MSS criteria optional. Companies can get the benefit of inclusion in the taxonomy even if they are not in alignment with the DNSH/MSS criteria.

As well, it appears that the DNSH/MSS criteria will not exceed standards that are already required under Canadian legislation, which entities are obliged to comply with regardless of the taxonomy.

One wonders why the DNSH/MSS criteria are included in the taxonomy if they are, essentially, optional and add little or nothing to the obligations of entities to whom the taxonomy will be relevant.

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

The objectives seem comprehensive. the comprehensiveness of the proposed scope of objectives to be covered under the DNSH/MSS framework does not address the value of adding DNSH/MSS criteria into the taxonomy, as explained in my answer to questions 4b and 6b.

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

As all companies must comply with Canadian legislation, it seems duplicative (and unnecessary) to also require this compliance as a basis for the DNSH/MSS criteria: it would not appear to add anything to the obligations of companies offering goods/services to which the taxonomy would apply.

As well, we see serious roll backs on environmental standards in legislation at the federal and provincial levels, meaning that these existing laws would set ever lower bars for the DNSH/MSS criteria, and federal/provincial/territorial governments could, by changing legislation, change the "grounding" of the DNSH/MSS criteria. For example, both the federal and Ontario governments can declare special economic zones and activities where limited or no environmental legislation is applicable.

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

It is admittedly difficult to decide what criteria would necessitate going beyond existing laws and standards for the DNSH/MSS framework, but it must be done.

One area could be where there are differing federal/provincial/territorial standards, the strictest should apply.

Again, one questions why have DNSH/MSS criteria at all as parts of the taxonomy if they are optional and do not require anything that is not already required by existing legislation.

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?

Neutral

8b. Please explain your answer in the space below

In all government regulations and policies, there must be some element of proportionality as to administrative and substantive requirements. That said, in the absence of knowing what is meant by "smaller projects and/or entities" or "more streamlined disclosures" it is difficult to answer this question.

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

As the proposed DNSH/MSS framework will be based in existing legislation and standards, the DNSH/MSS criteria will only be as good as the existing legislation and standards. For example, it does not take much imagination to predict the social harms that could result in projects to which the federal or Ontario governments will exclude from any/all applicable regulatory legislation.

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?

In the context of the Canadian constitution.

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

Strongly agree

12b. Please explain your answer in the space below

The Green label will appropriately be reserved for 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).

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

Agree

13b. Please explain your answer in the space below

I agree strongly that the transition category should not include activities that generate any level of emissions reductions relative to the status quo, even if they do not align with Paris-based pathways (e.g., substituting unabated natural gas for coal).

I also strongly agree with excluding from this category investments that support new emissions-intensive infrastructure when a low-carbon substitute can already be cost-effectively deployed and/or lock activities into technological pathways that, are dead-end pathways

To the extent that emissions can be lowered, if not to zero, in hard to abate activities, this should be encouraged, for existing assets.

For new assets, it is not clear how the guardrails for not locking in long term investments in an entity that will fail to meet Paris targets can be developed, and how the investment in transition measures can be separated from investment in the new asset.

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?

Neutral

14b. Please explain your answer in the space below

The guardrails are high level statements of principle. I would reserve judgement on this question until the high level principles of the guardrails are operationalised in a manner that materially reduces emissions ad prevents carbon lock in.

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

We need to redirect capital toward Paris-aligned investments. Supporting fossil fuel production—the largest source of GHG emissions in Canada—cannot be considered sustainable, especially when renewable energy alternatives exist.

I strongly agree that taxonomy-aligned investments cannot go toward the general activity itself (e.g., oil production and/or to activities that will increase Scope 3 emissions) the abatement category.

However, as the Report acknowledges, even with abatement measures, total emissions can rise if production increases. This is particularly relevant because a significant production increase is expected to fill the proposed new pipeline to the BC coast.

If fossil fuel production continues in the near term, decarbonisation should be addressed through regulations mandating a meaningful reduction of carbon intensity.

16. Should any additional guardrails be considered?

If an Abatement category is included in the Taxonomy:

– All guardrails in the Report should apply to all permitted measures.

– The "significant reduction" requirement should set a very high bar.

– The guardrail for applying this category to existing assets should exclude expansion of existing assets.

– Carbon capture measures should not include enhanced oil recovery, as using captured carbon to extract more oil cannot be considered sustainable.

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

It is disappointing that Scope 3 emissions will not be covered. This is particularly the case for fossil fuel extraction, where 80% of the emissions are scope 3 when the fossil fuel is combusted. Any fossil fuel activities (extraction, transportation, processing) should take Scope 3 emissions into account.

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

Very 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?

As prescriptive as possible to make them transparent and able to be verified. Performance based standards are always "open to interpretation" and applications that are not widely accepted.

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. It is disappointing that Scope 3 emissions will not be covered. This is particularly the case for fossil fuel extraction, where 80% of the emissions are scope 3 when the fossil fuel is combusted. Any fossil fuel activities (extraction, transportation, processing) should take Scope 3 emissions into account.

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?

Thank you to the CCI and BFP for undertaking the very important, and challenging, task of developing the taxonomy.

I look forward to seeing whether the high statements of principle in expressed in the DNSH/MSS and guardrails can be developed in a manner that meaning fully directs investments to activities which will result in significant mitigation of GHG emissions, and will have positive social and environmental effects.