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.

• Other (please specify)

1b. Specify priority

Possible by Design (PbD) does not rank subsequent objectives. Consistent with our full submission (Section 2.1), we propose the taxonomy adopt a ‘do no harm, and where possible do some good’ posture across all Planetary Boundaries throughout its climate mitigation work, rather than treating them as a sequenced pipeline of separate objectives. The Do No Significant Harm framework should be robust from day one across all Planetary Boundaries the mitigation work touches – biodiversity, freshwater use, land-system change, biogeochemical flows, ocean acidification, and pollution. On sequencing of formal objectives beyond climate mitigation, PbD defers to practitioners in each domain. See supporting document Section 2.1 for full response.

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

PbD agrees with the six proposed principles, with two clarifications for the credible and interoperable principles. On credible: the taxonomy is credible when grounded in the full Planetary Boundaries science, which means the CO₂ mitigation work is designed to do no harm to the other boundaries under stress. On both credible and interoperable: both principles require the taxonomy to specify what ‘net zero’ means at the molecular level. Geological Net Zero (GNZ), first articulated in the UK’s Skidmore Mission Zero review (2023) and reinforced by subsequent scientific and policy work, is the specification the international engineering conversation is converging on. It is already operationalized in Canadian federal procurement (PSPC 24062-250403), in the EU CRCF, and in the national climate frameworks of Switzerland, Denmark, and Sweden. Anchoring the Canadian taxonomy to GNZ from the outset positions Canada as aligned with the climate science and a first mover rather than a follower. See supporting document Section 2.2.

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

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

PbD supports the proposed partial alignment approach (disclosure-based rather than binary exclusion) and the two-pronged structure combining generic and sector-specific criteria. The Do No Significant Harm framework is where the taxonomy operationalizes what PbD considers the foundational principle: solving for CO₂ without loading pressure onto the other Planetary Boundaries.

Two observations on implementation:
First, the DNSH framework should be robust from day one across every objective in scope, not developed unevenly based on the availability of international precedent. Where Canadian science on a particular boundary is more advanced than international frameworks (as with some biodiversity, freshwater, and ocean acidification work), the Canadian taxonomy should lead rather than follow. Where international standards are more stringent than Canadian statutes, the taxonomy should reference the higher standard.
Second, the DNSH framework should be alert to pathways that positively serve multiple boundaries at once. Direct air capture powered by clean electricity, for example, avoids the land-system change, biosphere integrity, freshwater, and biogeochemical flows pressures that biological sequestration pathways at scale can create through land conversion, fertilizer inputs, and agricultural runoff. The taxonomy should recognize and encourage engineering choices that deliver co-benefits across boundaries, not just those that avoid harm.

On MSS: Free, Prior, and Informed Consent should be operationalized consistent with UNDRIP and Section 35 of the Constitution Act. PbD defers to Indigenous-led organizations on the specifics of implementation. See supporting document Section 2.5 for full response.

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

See response to 4b. The proposed DNSH scope maps closely onto the Planetary Boundaries most likely to be affected by mitigation pathways. See supporting document Section 2.5.

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

See response to 4b, particularly the observation that where Canadian science on a particular boundary is more advanced than international frameworks, the taxonomy should lead rather than follow, and where international standards are more stringent than Canadian statutes, the taxonomy should reference the higher standard. See supporting document Section 2.5.

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

See response to 4b. PbD defers to sector and Indigenous-rights specialists on specific areas. See supporting document Section 2.5.

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

Reporting requirements may reasonably be proportionate to organizational size and administrative capacity. Substantive environmental and social standards should not vary by size – environmental impacts are determined by activity, not by the size of the entity undertaking them.

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

See response to 4b. See also supporting document Section 2.5.

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?

PbD defers to Indigenous-led organizations on operationalization specifics. See supporting document Section 2.5.

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

Agree

12b. Please explain your answer in the space below

PbD supports the green category as proposed, with one specification: ‘near-zero’ should be defined as residual CO₂ balanced by permanent removals meeting geological-scale permanence, consistent with Geological Net Zero. This captures the same activities the current draft anticipates (renewable electricity, EVs, batteries) and makes the ‘near-zero’ threshold precise rather than nominal. Under net-basis emissions evaluation, activities in the green category can use the full toolkit – including all science-aligned emission reduction solutions as well as permanent CDR to close residuals where genuinely necessary – without changing the character of the category. See supporting document Section 3.2.

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

Agree

13b. Please explain your answer in the space below

PbD supports the transition category and both pathways (whole-of-activity and transition measures). Sector-specific criteria must place activities on a clear ramp to Geological Net Zero and allow the full climate-science-aligned toolkit – emission reduction and permanent removal – to close the gap, with permanent CDR available as the finisher for any residual emissions at-source abatement cannot eliminate within the ramp’s timeframe. Cement, steel, chemicals, aluminum, and similar hard-to-abate industrial sectors face residual process emissions that at-source abatement cannot fully eliminate; these sectors need the full toolkit as part of their standard options, not a truncated version that excludes permanent CDR because it is confined to a separate category. See supporting document Section 3.3 for full argument.

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

See response to 13b. The current guardrails against dead-end pathways and against emissions-intensive infrastructure where cost-effective substitutes exist should be retained. Two additions are needed: sector-specific criteria must (1) place activities on a clear ramp to Geological Net Zero, with the required permanence of removals specified for any residual emissions, and (2) allow emissions evaluation on a net basis, with the full climate-science-aligned toolkit available including permanent CDR as a finisher. See supporting document Section 3.3.

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

PbD supports the abatement measures category as a genuinely differentiated Canadian contribution to the global taxonomy landscape, where peer jurisdictions have largely stopped at Green or Green-plus-Transition. Two substantive conditions apply:
First, criteria for the abatement measures category must be developed in parallel with green and transition in 2026-2027, not deferred to 2027+. Deferring the sectors with Canada’s largest emissions exposure means Canada spends the 2026-2027 window publishing green and transition guidance that largely restates what other jurisdictions have already produced, while the piece that would actually add global value – and that Canadian industry most needs – sits unwritten.
Second, permanent CDR eligibility should not be confined to the abatement measures category alone. The full climate-science-aligned toolkit (both ‘do our best’ emission reduction and ‘remove the rest’ permanent removal) should be recognized across all three categories, with sector-appropriate guardrails. See supporting document Preamble Recommendations One, Two, and Three, and Section 3.4.

16. Should any additional guardrails be considered?

Additional guardrails should be applied to the use of the full toolkit across all three categories, not just abatement measures: for permanent CDR specifically, geological-scale permanence for residuals (1,000+ years, aligned with PSPC 24062-250403); no substitution of removal for at-source reduction where at-source is cheaper (permanent CDR is a finisher, not a workhorse); and ring-fencing verification to prevent cross-subsidy of capacity expansion. These are toolkit guardrails, not category guardrails. See supporting document Section 3.4.

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

See supporting document Sections 3.1 through 3.4. PbD’s central recommendations are that (i) every activity’s criteria must place it on a clear ramp to Geological Net Zero; (ii) emissions must be evaluated on a net basis, with standards recognition for all climate-science-aligned pathways across all three categories; and (iii) criteria for the abatement measures category must be developed in parallel with green and transition in 2026-2027, not deferred to 2027+.

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

PbD agrees with the proposed methodological approach – energy system modelling, literature reviews, jurisdictional analysis, policy analysis, and engagement. Sector-specific screening criteria should specify: the ramp trajectory to Geological Net Zero (including interim milestones); the required permanence of removals for residual emissions; the carbon lock-in guardrails; the recognized standards for the full climate-science-aligned toolkit available to the sector; and the sector-specific Do No Significant Harm criteria that operationalize the Planetary Boundaries frame. See supporting document Section 4.6.

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

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?

Criteria should be technology-inclusive rather than technology-prescriptive, specifying outcomes (ramp trajectory to Geological Net Zero, permanence standards for residuals, carbon lock-in avoidance) rather than mandating specific pathways. This preserves innovation space and prevents the taxonomy from freezing today’s technology mix into tomorrow’s compliance framework.

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

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

Neutral

23. Is there any other feedback you would like to provide on the methodology report as a whole that has not already been covered?

PbD’s overall assessment is that the proposed framework is well-intentioned, professionally executed, and structurally sound in its choice to add a differentiated third category – but incomplete in two specific engineering respects: the sequencing that defers the sectors with Canada’s largest emissions to 2027+, and the fragmented standards recognition for climate-science-aligned pathways across categories. Both are fixable within the current framework. See supporting document Section 5.2.

PbD’s cross-cutting recommendation, outside the taxonomy’s core scope but complementary to it: Climate Footprint Labels are the demand-side complement to the taxonomy. Approximately 61% of global emissions originate in consumption categories where the point of decision is a household purchase rather than a capital allocation. Mandatory climate footprint (CO₂e) disclosure on products and services makes embedded emissions visible at the point of purchase, triggers supply-chain cleanup by producers competing on the visible metric, and generates market pull for the taxonomy-aligned activities that supply-side capital is being directed toward. Eighty percent of Canadians say they are either very concerned, concerned, or moderately concerned about climate change. A taxonomy directing capital to activities on credible ramps to Geological Net Zero, paired with mandatory disclosure making those activities visible on the demand side, is a substantially more powerful engineering system than either alone. Federal e-petition e-7510 (closing October 9, 2026) calls for mandatory labels in Canada. See supporting document Cross-Cutting Recommendation.