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
• Water and marine resource conservation

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

Strongly agree

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

I strongly support these principles. From my experience raising capital for a Canadian cleantech company, a taxonomy will only be useful if it actually helps good projects get financed.
Credibility is essential. Investors need to trust the taxonomy, particularly international investors such as the European Article 9 funds I worked with. But it also needs to be practical. Smaller companies and projects at the commercialization stage do not have large teams dedicated to reporting and compliance.
Interoperability is also very important. Canadian companies compete for international capital, so we should align with international frameworks wherever it makes sense. A Canadian company should not have to prepare two completely different sets of information to satisfy Canadian and European investors.
I would add two practical points. First, the taxonomy needs some stability. I saw first-hand with advanced recycling how inconsistent definitions can delay projects and financing. The taxonomy will need to evolve, but changes should be predictable and companies should have time to adapt.
Second, the taxonomy should become a common reference. The same activity should not be considered sustainable by one government program, excluded by another, and assessed differently again by a lender. Clear and consistent definitions across programs and levels of government would make a real difference for companies trying to finance projects.

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

Important

Regionally Specific

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

4b. Please explain your answer in the space below

I agree with the partial alignment approach. A strict pass-or-fail test would shut out good projects for missing a single criterion, often just because a smaller or commercialization-stage company does not yet have all the data. Letting issuers disclose how far they meet the criteria is more practical and lets investors see the full picture.

That said, disclosure should not make serious problems acceptable. Some things should remain firm limits, such as serious environmental harm, breaches of human or Indigenous rights, or corruption. Smaller companies should also be able to meet these requirements with lighter, simpler reporting, so the process does not itself become a barrier to financing.

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?

Agree

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 agree

8b. Please explain your answer in the space below

The environmental standard itself should be the same for everyone, since a smaller project should not be allowed to do more harm just because it is small. What should differ is the amount of reporting.

Smaller companies and projects at the commercialization stage do not have large teams for disclosure and compliance, and in my experience the reporting burden itself can become the reason a good project cannot get financed. Simpler templates, standard assumptions, and lighter reporting for smaller projects would keep the standard high while making the taxonomy usable for the companies that need financing the most.

I would add that the level of reporting should also reflect the risk and location of a project, not size alone, since a small project in a sensitive area can still have a significant impact.

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

Agree

12b. Please explain your answer in the space below

I agree that the green category should stay strict. Limiting it to zero or near-zero activities protects the credibility of the label, which is what makes it useful to investors.

I have two points. First, the “directly enable” definition should be broad enough to include circular economy and resource-efficiency solutions, such as advanced recycling that replaces virgin fossil-based production. These are as central to a low-carbon economy as clean electricity and should not be treated as second class.

Second, the taxonomy should recognize investments that reduce energy demand, not only those that build new supply. A Quebec study found that saving a kilowatt-hour through energy efficiency costs about 3 cents, compared with about 12 cents for new generation. The cheapest and cleanest option is often to avoid the need for new infrastructure in the first place, so efficiency and resource productivity should count as real contributions to climate mitigation.

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

Agree

13b. Please explain your answer in the space below

I think the transition category is where Canada can make the biggest difference. Industries like steel, cement, and chemicals cannot become zero-emission overnight, but they still need to decarbonize and need a credible way to show investors that they are on that path.

My main point is that the rules should be usable by smaller and first-of-a-kind projects, not just large incumbents. A lot of the capital gap I have seen is exactly here, at the commercialization stage.

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

I support the intent of the guardrails, but it is hard to say they are sufficient when the detailed criteria are still being developed.

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, but only with strong conditions. There is a real case for funding near-term emissions reductions at high-emitting sites, even in activities that are expected to decline, because those reductions still matter.

My concern is that this is the category most open to greenwashing. It should be kept clearly separate from green and transition, have its own label, and apply only to existing assets, with no expansion and a credible plan for the future of the asset. The label should apply only to the specific investment that reduces emissions, never to the underlying oil and gas activity.

With that clear separation, I think the category can be useful without weakening the credibility of the taxonomy.

16. Should any additional guardrails be considered?

The proposed guardrails are a good start, but I think they should be firm requirements for this category because it carries the greatest risk of being seen as financing fossil fuel activities under a sustainability label.
I would require a real and measurable reduction in total emissions rather than just a lower emissions rate, no use of offsets to meet the target, a clear timeline for the future of the asset, and independent verification for larger projects.
With strong rules, this category can help finance useful emissions reductions in the short term

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

Two things. First, the framework should clearly recognize commercialization-stage technologies, because that is where I have seen one of Canada’s biggest financing gaps. We fund a lot of research and create valuable Canadian intellectual property, but companies can hit the valley of death when they reach commercial scale. The projects are often too large or too advanced for traditional innovation funding, but still too small or too risky for conventional infrastructure investors. A clear, financeable category for these projects could help more Canadian technologies reach commercial scale here.

Second, the taxonomy should recognize investments that reduce demand and improve resource efficiency, not only investments that build new supply. Energy efficiency can often deliver the same climate benefit at a much lower cost than adding new infrastructure. The same principle applies to recycling, reuse and more efficient use of materials. These should count as real contributions to climate mitigation.

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 approach. Clear, measurable criteria are already what institutional investors expect, so this is workable.

A few things matter to me. The criteria should focus on results rather than naming specific technologies, so a new solution is not shut out just because it is new. They should also recognize the difference between something being technically possible and commercially deployable, since a lot of transition capital is needed exactly to close that gap.

Wherever possible, the criteria should line up with European criteria, so a Canadian company can prepare one set of information rather than two. I would also keep the reporting lighter for smaller projects, so the criteria do not become a barrier for the companies that most need financing.

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

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

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?

The criteria should focus on results, not on naming specific technologies. In other words, set a clear performance level to hit, such as an emissions threshold, and let any technology that meets it qualify. This keeps the door open to new solutions instead of locking in the ones we happen to know today, and it fits an economy where technology changes quickly.

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 agree, with one caveat. Starting with Scope 1 makes sense because those are the emissions a company controls most directly and can measure most reliably. But for some activities, much of the real climate impact occurs elsewhere in the supply chain. Recycling is a good example, where much of the benefit comes from avoided emissions elsewhere.

Scope 2 and 3 should therefore be included wherever they are material, with a clear definition of what “material” means so that significant emissions or reductions are not left out simply because they are more difficult to measure.

22. Overall, how satisfied are you with the proposed sustainable finance taxonomy framework?

Very 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?

A taxonomy is only useful if it helps good projects actually get financed. Its success should ultimately be judged by whether it helps move more capital toward credible transition projects, not by how detailed it is on paper.

I saw the problem first-hand. When we were raising capital for our recycling technology, strategic investors would often compare the investment with what they could earn by putting the same amount of money into expanding their conventional production. The conventional investment usually had a higher short-term return, so the sustainable project was difficult to justify internally. It was not necessarily a lack of interest in sustainability. The two investments were being compared on financial return alone, without fully recognizing things like future regulation, transition risk, resource efficiency, access to new markets and the company’s own sustainability commitments.

I am not suggesting that companies should make investments that do not make economic sense. But this is exactly where I think a credible taxonomy can help. It can give investors a common way to identify projects that deliver real transition benefits and help direct the right type of capital toward them.