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.

• Protection of biodiversity and healthy ecosystems
• Pollution prevention and control
• Circular economy

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 provide

We agree with the proposed principles, but they need to be more clearly defined and operationalized so they can be applied consistently. The foundation should also include the precautionary principle, policy coherence, material and energy conservation, highest and best use, polluter pays, avoidance of exported harm, and safeguards against infrastructure and material lock-in. Usability should not be achieved by lowering environmental integrity or allowing unclear criteria that create opportunities for inconsistent interpretation or greenwashing.

3. Please rate each of the principles below on a scale from “very important” to “not at all important.”

Credible

Very important

Usable

Important

Interoperable

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?

Strongly disagree

4b. Please explain your answer in the space below

An activity should not be described as taxonomy-aligned unless all applicable DNSH and MSS criteria are met. Partial alignment would weaken the meaning of Do No Significant Harm, create opportunities for greenwashing, and make it difficult for investors and the public to distinguish full alignment from incomplete performance. Entities should be free to disclose progress toward alignment, but partial compliance should be reported separately and should not receive the taxonomy-aligned designation. The environmental and social standard should remain consistent, while documentation requirements may be proportionate to the size and risk of the activity.

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

We agree with the proposed scope, including climate adaptation, biodiversity and healthy ecosystems, water conservation, pollution prevention and control, circular economy, Indigenous rights, human rights, labour standards, corruption and bribery controls, and taxation integrity. These objectives are appropriate, but they must be clearly defined and applied consistently. The framework should also explicitly address cumulative impacts, lifecycle effects, exported harm, material conservation, and Free, Prior and Informed Consent.

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?

Agree

6b. Please explain your answer in the space below

Canadian legislation should provide the minimum baseline for DNSH and MSS criteria, not the maximum level of protection. The Taxonomy should go beyond existing laws and standards where they are incomplete, inconsistent, outdated, or insufficient to address material risks. This is particularly important for cumulative impacts, climate and biogenic emissions, pollution, circular economy outcomes, Indigenous rights, exported harm, and activities that create infrastructure or material lock-in. Going beyond legal minimums should be a clear requirement where necessary to preserve the credibility of taxonomy alignment.

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

The framework should go beyond existing laws where they do not adequately address cumulative and lifecycle impacts, material Scope 2 and 3 emissions, biogenic emissions, pollution and exported harm, material conservation and circular economy outcomes, Indigenous rights and Free, Prior and Informed Consent, supply-chain traceability, and infrastructure or material lock-in. Legal compliance should be the minimum baseline. Taxonomy alignment should require a higher level of performance, clear evidence and independent verification.

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?

Disagree

8b. Please explain your answer in the space below

The same substantive DNSH and MSS requirements should apply to all projects and entities. Smaller projects should not receive a lower environmental or social standard. However, disclosure and verification requirements may be proportionate to the project’s size, complexity and level of risk, provided this does not reduce the underlying threshold or create gaps in accountability. High-risk activities should face stronger evidence and verification requirements regardless of the size of the entity.

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

Yes. Key gaps include the proposed partial-alignment approach, reliance on legal minimums, limited attention to cumulative and lifecycle impacts, and insufficient requirements for Scope 2 and material Scope 3 emissions, biogenic emissions, exported harm, material conservation, supply-chain traceability and infrastructure lock-in. Without clear definitions and full DNSH/MSS alignment, activities could receive taxonomy recognition while shifting pollution, destroying recoverable materials, extending harmful infrastructure or adversely affecting communities and ecosystems.

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?

Indigenous Peoples and Indigenous-led organizations should be directly involved in developing, governing and reviewing the MSS framework. Free, Prior and Informed Consent should be an explicit requirement for activities that may affect Indigenous rights, lands, waters, resources, cultural heritage or traditional knowledge. Consent should be sought early, before key project or financing decisions are made, and should be documented through a transparent process determined with the affected Indigenous Peoples. Consultation alone should not be treated as equivalent to consent.

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

The framework should establish clear, consistent and publicly available criteria, evidence requirements and verification procedures. Applicants should bear the burden and cost of demonstrating alignment, including impacts across the complete supply chain. Independent verification, conflict-of-interest safeguards, public disclosure and a process to correct or withdraw unsupported claims are necessary to protect the credibility of the Taxonomy. Partial progress may be disclosed, but activities should not be described as taxonomy-aligned unless all applicable DNSH and MSS requirements are met.

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

Agree

12b. Please explain your answer in the space below

We agree that the green category should be limited to zero or near-zero emissions activities and activities that directly enable credible climate solutions. However, eligibility should be based on lifecycle and systems-level performance, not only direct facility emissions. The criteria should consider Scope 2 and material Scope 3 emissions, embodied impacts, material demand, product longevity, final management outcomes, rebound effects and whether the activity displaces a lower-impact alternative. Enabling activities should also demonstrate that they support the practical infrastructure and networks needed to deliver the claimed outcome. Activities involving destructive use of discarded materials, fuel production, combustion or infrastructure lock-in should not qualify as green.

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

Agree

13b. Please explain your answer in the space below

We agree that a transition category may be appropriate for emissions-intensive activities that are expected to remain necessary in Paris-aligned pathways and can credibly reach zero or near-zero emissions by 2050. However, the lack of technically feasible substitutes and the expectation of stable or growing demand should be demonstrated, not assumed.

Technical criteria should consider lifecycle emissions, Scope 2 and material Scope 3 emissions, absolute emissions, material demand, available alternatives and the potential to reduce the need for new production through preservation, reuse, repair, material efficiency and better design. The category should not reward minor efficiency improvements, increased production, asset-life extension or investments that create infrastructure or material lock-in. Clear interim thresholds, sunset dates and independent verification will be essential.

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

The proposed direction is appropriate, but the guardrails are not yet sufficient. The whole-of-activity pathway relies mainly on Scope 1 alignment by 2050 and a broad requirement to avoid “dead-end pathways,” while transition measures need only materially reduce Scope 1 and/or 2 emissions and avoid future lock-in. Key terms such as “materially reduce,” “technically feasible substitute,” and “dead-end pathway” require clear, measurable definitions.

The criteria should also require interim emissions milestones, material Scope 3 and lifecycle accounting, binding sunset dates, no unnecessary expansion of capacity or extension of asset life, assessment of lower-impact alternatives and material demand, qualified independent verification, and a credible entity-level transition plan. A measure should not qualify simply because full conversion is considered financially undesirable. Fuel switching to discarded plastics, rubber, wood, refuse-derived fuels or other materials used for combustion or in cement kilns should not qualify where it creates material destruction, pollution or long-term infrastructure lock-in.

15a. Do you agree or disagree that the taxonomy should include a third “abatement” category, as proposed, that covers demand-decline activities?

Disagree (i.e., disagree because of how category is designed)

15b. Please explain your answer in the space below

We disagree because the proposed category could give a sustainable-finance designation to investments in activities that are expected to decline and cannot align with Paris-aligned lifecycle emissions pathways. These industries should be required to reduce emissions and pollution, but those obligations do not automatically constitute sustainable investment.

A separate abatement label may also create confusion by implying that the underlying activity is aligned with a net-zero future, while increasing the risk of asset-life extension, carbon lock-in and diversion of capital from proven green and transition activities. If the category is retained, it must remain clearly separate from green and transition classifications and be subject to strict limits, full lifecycle accounting, binding decommissioning dates and independent verification.

16. Should any additional guardrails be considered?

Yes. If an abatement category is retained, it should remain clearly separate from green and transition classifications and must not imply that the underlying activity is sustainable. Eligibility should be limited to existing assets and should prohibit production expansion, increased throughput and asset-life extension.

Applicants should be required to demonstrate full lifecycle emissions, including Scope 1, 2 and material Scope 3 emissions; binding interim targets; a fixed decommissioning date; investment in replacement systems; and a credible entity-level transition plan. Polluters should bear the cost of required pollution controls, and sustainable-finance support should not replace normal regulatory obligations.

Abatement measures should also be excluded where they rely on combustion of discarded plastics, rubber, wood or other materials, fuel substitution in cement kilns, or other activities that create material destruction, pollution or infrastructure lock-in. Claims should be independently verified, publicly disclosed and withdrawn where evidence is incomplete or performance is not achieved.

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

The framework should more clearly recognize material conservation, responsible consumption and production, and the infrastructure and networks required to support reuse, refill, repair, sanitization, redistribution and reverse logistics.

Products and packaging should be addressed through either a dedicated priority sector or a mandatory cross-sector workstream. Clear, outcome-based definitions are also needed for recycling, material recovery, incineration, energy recovery, discard-derived fuels and chemical processing into materials or fuels.

Source separation or preprocessing should not change the classification of the final outcome. Discarded plastics, rubber, wood, textiles, carpet and other materials should not qualify as recycling, circularity, green or transition activities when they are converted into fuel or combusted, including in cement and lime kilns.

Where discarded materials are involved, the applicant should bear the burden and cost of demonstrating source, composition, processing history, chain of custody and final outcome. If the material cannot be verified before it loses its identity through shredding, blending or pelletization, the activity should not 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

We agree with the proposed overall approach, including forward-looking criteria, sunrise and sunset dates, regular review, quantitative thresholds, energy-system modelling, policy and jurisdictional analysis, and stakeholder engagement.

The criteria should also exceed regulatory minimums, identify acceptable evidence, address infrastructure and material lock-in, and require qualified independent verification. They should assess material lifecycle impacts, including Scope 2 and material Scope 3 emissions, rather than focusing primarily on Scope 1 where this could shift or conceal impacts elsewhere in the value chain.

Criteria should also consider material demand, product longevity, final management outcomes, and the infrastructure and networks needed to deliver the claimed benefit. Where discarded materials are involved, applicants should bear the burden and cost of demonstrating source, composition, chain of custody, processing history and final outcome.

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

Not that 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?

The criteria should be technology-neutral where different approaches can deliver the same verified outcome, but highly prescriptive about performance, evidence and unacceptable outcomes. They should establish clear quantitative thresholds, lifecycle boundaries, chain-of-custody requirements, verification methods and exclusions for activities that create pollution, material destruction or infrastructure lock-in.

Greater technological specificity is appropriate where terminology or preprocessing could conceal the actual outcome, including discard-derived fuels, biomass, pyrolysis, gasification, chemical conversion and the use of discarded materials in cement or lime kilns. The Taxonomy should not endorse a technology simply by name; eligibility should depend on independently verified system-level outcomes.

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?

Disagree. Scope 1 emissions are important but are not sufficient to determine whether an activity is climate-aligned. Scope 2 and material Scope 3 emissions should be required whenever they materially affect the outcome, including embodied emissions, upstream extraction and production, transportation, biogenic emissions, product use and final management.

“Where feasible” should not become a loophole that allows significant impacts to be omitted or shifted elsewhere in the supply chain. Proportionate methods may be used, but where material lifecycle emissions cannot be reliably assessed, the activity should not receive taxonomy alignment.

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

Unsatisfied

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

The development of sector-specific technical screening criteria should include further public consultation and meaningful participation from practitioners with direct experience in reuse, repair, redistribution, material processing, supply-chain verification, Indigenous rights and environmental assessment.

The final Taxonomy should include transparent governance, publicly documented rationales for eligibility decisions and revisions, and clear implementation guidance. An accessible digital tool linking each activity to applicable thresholds, evidence requirements, definitions and verification methods would improve consistency and reduce interpretation gaps.

Before broad implementation, the criteria should be tested against representative projects and supply chains to identify unintended loopholes, administrative barriers and greenwashing risks. Future reviews should publish what has changed, the evidence supporting those changes and how public feedback was considered.