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

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

It's very much aligned with international best practice – especially Australia and New Zealand. For Canada, you might also want to consider including a principle reflecting the importance of Indigenous People the same way New Zealand did.

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

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

In many jurisdictions, the DNSH component is an impediment to full taxonomy alignment because it is: (1) data-intensive (2) difficult to fully interpret (3) not interoperable if linked to national legislation. We agree with the streamlined approach in order to allow for a better usability of the taxonomy as well as its uptake by the market.

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

It aligns with international best practices.

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

We recommend keeping national laws and regulation at a minimum and focusing on international standards and best practices. The more national legislation is integrated in the taxonomy, the less interoperable it becomes. By contrast, considering international best practices (or proxies thereof) would allow for more interoperability. Also, national laws and legislation can be obscure and hard to interpret by international investors – who are more acquainted with international standards. It is interesting that the proposal focuses on two tiers of DHSN criteria – one of the being sector-specific criteria whilst most taxonomies would look at activity-specific criteria. Is it a way to further streamline the DNSH component of the Taxonomy?

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

For MSS, you might want to look at existing federal legislation for slavery and child labour as it can be weaker than international best practices in many countries. Also, for DNSH, anything that has legislation at the province level but not at the federal level should be looked at in order to establish a minimum set of requirements for the taxonomy – that was our experience working with Australia where different states had a varying degree of legislation but no federal law existed and so the taxonomy had to come up with a national set of best practices that, in a lot of cases, were more stringent that local legislation. That's also something that happened in the EU with member states best practices applied at the EU level – that is the Taxonomy adopted the best member state practices. For Canada, this could mean water standards, circular economy standards and human rights due diligence requirements for supply chains.

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

It can be a way to better streamline to uptake of the taxonomy even for SMEs, which typically do not have the time, resources and data to comply with DNSH requirements. For MSS, we think it should be applied across the board.

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

We recommend specifying a minimum floor of non-negotiable criteria (Indigenous FPIC and core human rights seem like the obvious candidates given Section 2.5/Box 3) even within a partial-alignment model — this is closer to what MSS frameworks elsewhere actually do in practice (MSS is typically closer to binary even where DNSH is partial).

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?

The way it's formulated now, it's too thin for FPIC specifically, because FPIC is a process right, not a standard to comply with — you can't "disclose the extent to which FPIC is met" the way you can disclose a pollution threshold. We recommed splitting it out as a distinct sub-framework with its own trigger logic, modelled on what the report already cites approvingly: Australia's approach of triggering First Nations criteria whenever an activity has "potential or actual impact on First Nations rights or interests," rather than applying it uniformly to all entities regardless of exposure. In other words, in Australia looks at FPIC as a procedural gate within MSS.

11. Is there any other feedback you would like to provide on the proposed MSS/DNSH framework?

Be mindful of the need of consistency across DNSH requirements – some DNSH objectives (climate mitigation) have decent regulatory anchors, others (circular economy, water) have almost none federally. If sectoral working groups develop these independently and some objectives end up thin or vague while others are rigorous, the weakest-defined objective becomes the reputational liability for the entire DNSH framework.

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

Agree

12b. Please explain your answer in the space below

Limiting "green" to (1) genuinely zero/near-zero activities and (2) activities whose direct output is a zero/near-zero climate solution is a higher bar than most peer taxonomies, namely ASEAN, Australia, and Singapore because they all allow activities that currently meet an emissions benchmark but will need to tighten over time to stay in the green category (emissions pathway). Practically speaking, both green and transition will be eligible under the Taxonomy so the methodology for classification of activities between the two is subjective.

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

Agree

13b. Please explain your answer in the space below

Requiring both conditions — materially high emissions today and stable/growing demand due to lack of technically feasible substitutes — is a meaningful improvement over taxonomies that use "transition" as a looser catch-all. It correctly excludes the ambiguous middle case that's caused the most definitional confusion elsewhere – namely activities that could switch to a low-carbon substitute today but haven't, versus activities that genuinely have no substitute yet. Steel, cement, and chemicals are good anchor examples because they're the standard "hard-to-abate" cases with real technology-based justification — there's no commercially deployed near-zero cement process at scale, for instance.

However, the use of carbon lock in is inconsistent in the document. Section 3.3 says the transition category excludes investments that "lock activities into technological pathways that… will ultimately be unable to drive the scale of reductions necessary… referred to hereafter as dead-end pathways," and frames this as one of two ways an investment "leads to carbon lock-in." But the glossary defines "dead-end pathways" as its own separate term, with no definitional link back to carbon lock-in. So the document simultaneously treats these as (a) the same phenomenon (Section 3.3's framing) and (b) two independent, separately-defined concepts (the glossary's structure). Figure 3's caption reinforces the separation, listing "risk of carbon lock-in" as one factor alongside "alignment with domestic net zero pathways" as if they're distinct axes, not one nested inside the other. We found it quite confusing.

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

Pairing the transition category with the whole-of-activity net-zero-by-2050 pathway requirement (Section 3.3, guardrail 2) is also a higher bar than ASEAN/Singapore/Australia because those don't require transition-labeled whole-activities to already be on a net-zero trajectory.

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

Most peer taxonomies handle hard-to-abate fossil activities by simply excluding them, which sounds more rigorous but actually just pushes that capital outside any standardised framework. Given oil and gas production and refining account for roughly 30% of Canada's emissions per the report's own figures, a taxonomy that has literally nothing to say about decarbonizing investment in that sector is arguably less useful for Canada specifically than one that carves out a narrow, ring-fenced, guardrailed space for it. The methane abatement example is a reasonable illustration: there's a real difference between financing new upstream production capacity and financing a project that measurably cuts fugitive emissions from existing infrastructure, and most binary taxonomies can't distinguish between those two things at all. The design choices also show some genuine restraint: measures-only (not whole-of-activity), explicit exclusion from the transition category, and demand-decline built into the category's own logic rather than pretended away.

16. Should any additional guardrails be considered?

Perhaps, (1) a mandatory sunset date based on scientific consensus and not based on industry needs – that sunset date should be disclosed before the design of the measures (2) explicit confirmation that abatement-measures alignment can never convert into transition or green status — i.e., no back-door upgrade pathway.

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

The proposed approach lumps Scope 2 in with Scope 3 as both being "addressed where feasible," when the actual comparator taxonomies treat Scope 2 as close to a baseline expectation (via combined intensity metrics or explicit proxies) and reserve the more conditional, deferred treatment specifically for downstream Scope 3. We'd recommend the taxonomy separate these two in Section 4.5 language — commit to Scope 1 + Scope 2 as the standard technical screening basis (consistent with EU/Australia/Singapore practice), and treat downstream Scope 3 as the genuinely harder, more deferred category where "where feasible and/or material" phasing is actually warranted. That's a more precise and more defensible ask than treating Scope 2 and 3 as one bucket.

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

The overall architecture of the TSC (forward-looking criteria, sunset/sunrise dates, periodic review, quantitative-primary metrics, multi-method development process) is sound and consistent with international best practice.

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

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?

Quantitative thresholds should be technology neutral but we have also learnt from other taxonomies that whitelists work really well for the purpose of usability. Hence, we would recommend including whitelists in the measure categories (effectively, if the taxonomy were to adopt the 100grams e CO2/khw threshold across the energy sector, it would generate a whitelist for renewable energy, which is great).

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?

As previously mentioned, Section 4.5 framing of "Scope 1 primarily, Scope 2 and 3 where feasible" understates what peer taxonomies actually do — EU, Australia, and Singapore-Asia generally treat Scope 2 as close to standard (via combined intensity metrics or explicit proxies), reserving the more conditional treatment for downstream Scope 3 specifically.

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?

One of the listed potential guardrails for the abatement category is "only allowing investment into the abatement of existing assets", which sensible in principle in order to stop the category being used to justify new fossil fuel investments. But footnote 33 admits the new/existing asset boundary itself still needs to be defined. This matters because of brownfield expansion – is a new well drilled on an existing lease "existing" or "new"? Is replacing end-of-life equipment at a decades-old facility with higher-capacity equipment "abatement of an existing asset" or effectively new capacity in old asset's clothing? Without the inclusion of further provisions to sanctioned capital expenditure date, or a capacity-expansion cap, this guardrail might have a loophole to enable the extension of the lifetime of exiting brownfield fossil fuel assets.