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.
- Climate change adaptation / resilience
- Pollution prevention and control
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?
Agree
2b. Please share the reason for your answer in the space provided
The six principles are the right foundation. Their value isn't established by how ambitious they sound — it's established by whether independent implementers can apply them to the same asset and reach the same answer. My attached submission focuses on where that consistency isn't yet guaranteed, particularly around Credible, Usable, and Interoperable.
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
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?
Neutral
4b. Please explain your answer in the space below
No specific comment — this falls outside my area of expertise (ESG data governance and index operations). I defer to submissions from parties with direct expertise in DNSH, MSS, and Indigenous rights frameworks.
5a. Do you agree or disagree with the proposed scope of objectives to be covered under the DNSH and MSS frameworks?
Neutral
5b. Please explain your answer in the space below
No specific comment — this falls outside my area of expertise (ESG data governance and index operations). I defer to submissions from parties with direct expertise in DNSH, MSS, and Indigenous rights frameworks.
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
No specific comment — this falls outside my area of expertise (ESG data governance and index operations). I defer to submissions from parties with direct expertise in DNSH, MSS, and Indigenous rights frameworks.
7. In which areas, if any, is it necessary to go beyond existing laws and standards for the DNSH/MSS framework?
No specific comment — this falls outside my area of expertise (ESG data governance and index operations). I defer to submissions from parties with direct expertise in DNSH, MSS, and Indigenous rights frameworks.
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
No specific comment — this falls outside my area of expertise (ESG data governance and index operations). I defer to submissions from parties with direct expertise in DNSH, MSS, and Indigenous rights frameworks.
9. Are there any gaps in the proposed DNSH/MSS framework that could result in unintended environmental or social harms?
No comment
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?
No comment
11. Is there any other feedback you would like to provide on the proposed MSS/DNSH framework?
No comment
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?
Agree
12b. Please explain your answer in the space below
Agree with the definition as framed. My comments focus on the transition and abatement categories, where the operational question of how "zero to near-zero" is measured and evidenced matters more than at the green tier.
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?
Agree
13b. Please explain your answer in the space below
Agree with this approach. The same evidentiary-specification concern I raise for the abatement category in my attached submission applies here: "potential to decarbonize sufficiently" and "lack of technically feasible low-carbon substitutes" are both conditions that will need a specified evidentiary bar — not just a definition — to be applied consistently across implement
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?
Agree
14b. Please explain your answer in the space below
Agree in principle, with conditions. The guardrails are conceptually sound but not yet sufficient as specified. As with the abatement category's capacity baseline, guardrail concepts (whole-of-activity vs. measures pathway) need a single reference methodology — unit of measurement, asset vs. portfolio level — published alongside the category definition. Without this, implementers will interpret the same guardrail differently for economically similar activities, undermining the credibility the guardrail is meant to protect.
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?
Neutral
15b. Please explain your answer in the space below
As stated in my attached submission's conflict-of-interest declaration, I hold no financial or commercial stake in whether this category is adopted, expanded, or narrowed — my interest is limited to whether, once adopted, its criteria can be implemented consistently across the market. My substantive feedback addresses the category's central guardrail (the "no increase in production capacity" baseline) and the evidentiary standards needed for its technical screening criteria, both detailed in the attached document, rather than the merits of including the category itself.
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?
A precisely specified baseline methodology for "no increase in production capacity" (gross vs. net of decline rates; asset vs. portfolio level), a named minimum evidentiary standard for "credible transition plan" (disclosure-only vs. third-party assurance), and disaggregated reporting for metrics with dual environmental/operational meaning (e.g., flaring and fugitive-emissions reduction). Full detail in my attached submission.
17. Is there any other feedback you would like to provide on the proposed activity classification framework?
See attached submission for detailed recommendations on evidentiary standards, baseline methodology, and a proposed technical working consultation with data providers and verifiers ahead of sector-specific criteria finalisation.
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?
Agree
18b. Please explain your answer in the space below
Agree with the proposed approach in principle. As detailed in my attached submission, its practical success depends on specifying, for each criterion, a minimum evidentiary standard and whether independent assurance is required — without this, the same underlying disclosure could satisfy the criterion for one implementer and fail it for another.
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
- Important
- Include sunset and/or sunrise dates where relevant
- Important
- Revise as necessary during regular review periods
- 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
- Important
- Informed by a range of robust methods
- Important
20. When thinking about the taxonomy’s credibility and usability, how technologically specific or prescriptive should the technical screening criteria be?
Criteria should be technology-neutral at the definitional level — avoiding picking specific technologies as eligible or ineligible — but precisely specified at the evidentiary level: what counts as acceptable evidence, what baseline methodology applies, and what assurance is required. Prescriptiveness belongs in how a claim is verified, not in which technology is favoured. This mirrors the evidentiary-tiering recommendation in my attached submission.
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?
Agree with the proposed approach. My concern is not with the Scope 1/2/3 boundary itself but with the phrase "where feasible and/or material" — as currently worded, this leaves the threshold for materiality unspecified, meaning implementers will each construct their own interpretation of when Scope 2/3 reporting becomes required. I recommend the Council specify what "material" means in this context (e.g., a percentage-of-total-emissions threshold or a named methodology for determining it), consistent with the evidentiary-specification approach I've recommended for other criteria in my attached submission.
Final questions
22. Overall, how satisfied are you with the proposed sustainable finance taxonomy framework?
Satisfied