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 provided

I strongly agree with the proposed principles of credible, usable, interoperable, dynamic and prioritised. Together, they provide a strong foundation for the taxonomy that can help accelerate investment in climate solutions, reduce the risk of greenwashing and promote consistency with international taxonomies. This is particularly important as Canada seeks to strengthen trade and attract investments beyond the United States.

However, I do not agree with the principle of being regionally specific. While regional circumstances can inform transition pathways, introducing region-specific technical screening criteria would increase complexity, reduce comparability and could unintentionally impact capital flows across provinces. Instead, I recommend maintaining nationally consistent technical screening criteria while allowing flexibility in how regions achieve those outcomes.

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

Not that 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 proposed partial alignment approach as it provides practical way to recognise the extent of alignment and can improve the usability of the taxonomy. It can also give investors useful information that can help unlock transition finance that might otherwise be overlooked. However, partially aligned activities should not be considered taxonomy-aligned as they have not demonstrated compliance with all required DNSH and MSS criteria. Instead, partial alignment is to provide additional information that can support investment assessments as well as for stewardship & engagement activities.

To support effective implementation of the partial alignment approach, I recommend the taxonomy provides guidance on the following areas:
1. Where entities choose to provide further information on why an activity is considered partially aligned, guidance should define a consistent approach for additional information to disclose. This can include which DNSH and MSS criteria are met or not met, rationale for any gaps and actions being taken to address these gaps.
2. Provide clarity on acceptable data sources, documentation requirements and when proxy data or estimates may be used to demonstrate the extent of alignment.
3. Provide guidance on how alignment should be measured and communicated to ensure the nature or materiality of outstanding DNSH or MSS gaps are not obscured
4. Provide guidance on when DNSH assessments need to be updated e.g. on an annual basis or only when there is a material change in the activity or risk profile.

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 of environmental objectives as they address outcomes that are relevant to Canada and broadly align with international taxonomies.
I recommend the below are considered when developing the taxonomy’s approach to these environmental objectives:
1. Align the definitions of the proposed environmental objectives, where practical, with those used in international taxonomies to promote interoperability.
2. The DNSH criteria should explicitly address, where relevant, climate hazards most relevant to the location of the activity, such as wildfires, flooding, permafrost thaw and extreme heat. This would help ensure activities are assessed against the environmental risks most significant to the Canadian context.

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 agree

6b. Please explain your answer in the space below

I agree with the proposed approach of grounding the DNSH and MSS frameworks in Canadian legislation for both generic and sector-specific DNSH criteria. Using Canadian laws and regulations as the starting point is practical and proportionate, as these requirements already represent the baseline expectations for operating in Canada. Adopting this approach should help minimise additional burden for entities as it builds on existing obligations.
Where there is no relevant Canadian legislation for a sector-specific DNSH criteria, the taxonomy should specify acceptable Canadian and/or international standard(s) that should be applied. This will promote consistency, transparency and comparability.

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?

Select

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

Agree

12b. Please explain your answer in the space below

I agree with the proposed approach to classifying activities as green. However, further guidance would be helpful in the following areas to support the consistent identification and assessment of enabling activities:
• Clarify what "direct output" of an enabling activity means and whether this output must itself be a zero- or near-zero-emission activity. It should be noted that a narrow interpretation could exclude investments in activities that play a critical role in enabling low-emission activities.
• Clarify how activities with multiple outputs should be treated where some outputs support zero- or near-zero-emission activities while others support higher-emission activities. Also clarify how the qualifying proportion of outputs should be determined.
• Clarify how entities should demonstrate the direct link between the enabling activity and the zero- or near-zero-emission climate solution it supports.

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

Select

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?

Select

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

While the proposed design provides a good framework for identifying decarbonisation measures in the oil and gas sector, its effectiveness will ultimately depend on the specific measures that are included and how ambitious the criteria are. The final list of eligible activities will be important to ensure the taxonomy is tied to credible and meaningful decarbonisation outcomes, rather than simply providing a pathway for oil and gas activities to qualify

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 to determining the technical screening criteria. However, I recommend the following are considered:
• Where possible, technical screening criteria should lead to a pass/fail outcome and be capable of being evidenced through documentation, testing or independent verification. This will promote consistent interpretation and reduce the risk of greenwashing.
• Ensure data needed to demonstrate adherence with the TSC and DNSH requirements do not create undue reporting burden or costs, particularly where information needs to be obtained from third parties or across the value chain.

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

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

Important

Informed by a range of robust methods

Very important

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 with the approach on only focusing on Scope 1. I recommend the approach focus primarily on Scope 1 and Scope 2 emissions as these reflect the operational emissions for an activity

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?

To maximise the effectiveness of the taxonomy, I recommend the below additional points are considered
• Use consistent definitions and publish practical implementation guidance that includes illustrative examples to support the consistent interpretation and application of taxonomy requirements.
• Avoid over-reliance on technologies that are not yet commercially scalable, as this may limit taxonomy-aligned investment opportunities.
• Where Canada's sectoral transition pathways differ from Paris-aligned pathways, document rationale and assumptions underpinning these differences to help international investors better understand Canada's approach and make more informed assessment of taxonomy-aligned investments