RE: Quebec Wood Charter The ongoing and unreserved promotion of mid-rise wood construction that is taking root

in Quebec and British Columbia, as well as in many municipalities across Canada, is a disservice to the fight against climate change, the green building movement, and the broader institutions whose very mandate it is to ensure the safety and integrity of our building stock. All the more so as it is taking place at a time when there is a growing realization in many corners of Canadian society that building climate-resilient communities and infrastructure is fast becoming an imperative. That forests are a treasured, highly prized natural resource in Quebec, British Columbia and indeed throughout Canada is without question. But the Wood Charter announced by the Government of Quebec last week, and the Wood First program already implemented in B.C. are being instituted on the misguided and increasingly criticized notion that wood is more environmentally friendly than other construction materials. This perception has been aggressively marketed by the wood industry, in the face of a large and growing body of academic, peer-reviewed Life Cycle Assessment research that clearly contradicts this view. Specifically, wood proponents would have us believe that the energy required to construct a building, including the embodied energy of the building materials, is the most important environmental impact of that building. Yet, Life Cycle Assessments of the climate change impacts of buildings consistently and clearly demonstrate that the energy required in a buildings construction is utterly eclipsed by the energy consumed from heating, cooling and lighting that building. This is where other materials, like concrete, shine. Concretes thermal mass can be leveraged by smart energy systems to reduce the cradle-to-cradle carbon emissions by up to 70%. Even if we ignore technologies that activate the thermal efficiency advantages of concrete, a conventional mid-rise building made of concrete can outperform its peers on energy efficiency by upwards of 13%. On other environmental metrics including land, water and biodiversity impacts concrete is also best in class. While it mandates that wood systematically be the preferred material, the Charter rightly calls for life cycle assessments of the GHG performance of wood and other building materials to be conducted for all partially or fully publicly-funded building projects. Lets think for a moment of the serious conundrum that will arise when these LCA results clearly demonstrate that wood is not the lowest environmental impact option over the projects service life. Beyond this, the wood first policies reflect the wood industrys intensive and largely publicly-funded lobbying to convince politicians to bypass building code processes. In so doing, these efforts discount the professional judgement and experience of many architects and engineers and disregard the serious reservations of many fire safety professionals along the way. These experts play a critical role, using rigorous science, testing and experience (not politics) to keep the public safe. Most importantly though, wood first policies force a one-size-fits-all mandate that flies in the face of everything we know about sustainability, innovation and technology development arbitrarily preselecting an individual solution (i.e. picking winners) suppresses all three. In a market-based economy, it is not the role of governments to subjectively decide what industries will profit. While the wood industry and its advocates may brush off the concrete industrys opposition to Wood First as somehow driven by a fear of change, very little attention has been paid to questioning why the wood industry feels

political interference in the market is necessary to secure and grow their market share. At a time when the Boreal Forest Agreement is facing serious criticism from some of its ENGO signatories and the wood industrys commitment to sustainable forest management is called into question, the concrete industry is simply asking for a level playing field. Governments should absolutely promote sustainable construction there is a tremendous gap between what can be achieved today versus what is required in terms of sustainable and climate-resilient infrastructure. But governments should not restrict available options as to how the market can close this gap. Governments should set standards high standards (and not just for mid-rise, but all building segments and not just for climate and energy, but for full cradle-to-cradle sustainability) and then leave it to the qualified and licensed architects, engineers, fire fighters and building professionals to determine the best, safest and most economic way to meet or exceed those standards on a project-by-project basis. We respectfully urge the Minister of Natural Resources, the Honorable Martine Ouellet, to take these considerations into account as she and her department operationalize the Charter. Sincerely, Michael McSweeney President and CEO Cement Association of Canada