Public Consultation Submission

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

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?

Strongly agree

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
Very important
Prioritized
Very 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?

Select

5a. Do you agree or disagree with the proposed scope of objectives to be covered under the DNSH and MSS frameworks?

Select

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?

Select

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

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

We support the high-level definitions of Green-eligible and Transition-eligible outlined in the methodology report as a basis for developing the technical screening criteria, subject to appropriate consideration of regional circumstance

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

We support the high-level definitions of Green-eligible and Transition-eligible outlined in the methodology report as a basis for developing the technical screening criteria, subject to appropriate consideration of regional circumstance

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

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.

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.

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

We recognize that the Buildings Technical Screening criteria for Green-eligible and Transition eligible categories will differ across the building life cycle. For example, we support how the Australian Sustainable Finance Taxonomy includes only green technical screening criteria for “new construction” activities, while both green and transition technical screening criteria are provided for “acquisition and ownership” and “renovation and upgrade” activities.
We also recognize that Scope 2 emissions from purchased electricity, heating and cooling are often material for buildings and that their treatment within the Buildings Technical Screening criteria (both Green-eligible and Transition-eligible) will be an important discussion point for the Buildings Working Group. Energy use and peak electrical demand should also be points of discussion. The criteria should consider grid capacity and resiliency, including energy use and peak electrical demand. They should promote credible emissions reductions and allow technology and fuel diversity.

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?

Select

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
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

Final questions

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

Select

Privacy Policy

Effective Date: 29/04/2025

Business Future Pathways (“we”, “our”, or “us”) is committed to protecting your privacy. We collect personal information such as your name, email, organization, and message details when you submit a form on our website.

We use this information solely to respond to your inquiry, manage your participation, or send updates if you subscribe. Your information will not be sold or shared, except as required by law.

You may request access to, correction of, or deletion of your personal information at any time by contacting us at message@businessfuturepathways.ca.

By using this site, you consent to our collection and use of your information as described.

For any questions, please contact:

Business Future Pathways