Mr. Chairman, I also want to thank you and the committee for the opportunity to speak with you today.
Let me begin by building on Mr. Atkinson's comments about material selection and specification, and the relation of Bill C-429 to the National Building Code of Canada.
The motto of the National Building Code of Canada serves as the basis for specifying materials, testing, design, and construction. The National Building Code of Canada is an objective-based code.
Unlike a prescriptive-based code, the objective-based code is specifically intended to facilitate the selection and use of any and all materials that satisfy its stated objectives and performance requirements. It's specifically intended not to limit the application and use of any material component or assembly. Whereas the objective-based National Building Code of Canada is inclusive, a “wood first” policy is exclusive by its very nature. Bill C-429 could undermine the effectiveness and credibility of the National Building Code of Canada.
A wood first policy is intended to influence a designer's choice of construction material. Simply, a designer is encouraged to select wood. Wood becomes the prescribed preference. In effect, Bill C-429 positions wood as the performance benchmark against which all other materials and assemblies will be measured, contrasted, compared, and judged for use in selection. Ultimately, this will adversely affect the development of performance requirements in the National Building Code of Canada by virtually substituting the properties of wood as the performance targets.
This is assuredly not desirable, and effectively caps material and assembly performance to equivalency with those of wood, undermines the spirit of competition to achieve higher performances through research and development, and subordinates and marginalizes other preferred properties not characterized by wood.
Canadian building codes have effectively served the needs and expectations of Canadians for over 60 years. The coalition is steadfast in its belief that Canadian building codes already provide the needed flexibility for design professionals to appropriately select construction materials. The very fact that our building codes prescribe certain conditions under which construction materials, including wood, cannot be used is evidence that no material is always the most appropriate choice.
Publicly funded construction should respect our Canadian building codes, their philosophy for development, system for development, content application, and credibility. A policy for preferential choice of a particular building material does not respect these.
This brings us to our fourth point for consideration: a free marketplace. There are significant legal and trade implications that we believe Bill C-429 cannot avoid. In the interest of time today, I think this was well vetted in the earlier presentations. I think this group has a good understanding of the contraventions that this bill could propose for international trade agreements and domestic trade agreements.
As a final discussion today, we're compelled to address some of the claims made about the sustainable attributes of wood. Certainly, it's a positive step for governments to increasingly demand that buildings and infrastructure be constructed and operated in a more sustainable manner. It's our observation and opinion that all industries that manufacture materials and components for construction are rapidly greening their processes and better respecting principles of sustainability.
Some proponents of Bill C-429 argue that wood is a preferred environmental building material because of its carbon sequestration attributes and because wood products require comparatively less fossil fuel to manufacture. While these material attributes are positive, alone they provide a very limited picture of whole building sustainability. Only a life-cycle assessment of the environmental impact of a whole building over its full service life can identify all attributes that potentially offset greenhouse gases and underscore the real carbon cost.
The honourable members have copies of the presentations. Again, in the interest of time I'll summarize.
Life-cycle analysis provides a complete picture. It requires careful and detailed work by the building sustainability and scientific communities. This type of research has led to the emergence, development, and indeed application and practice of advanced and comprehensive design specifications, and guidelines found in such programs as LEED and other green building programs. A wood first policy undermines their development and use.
In conclusion, we can all agree we want our economy to get moving again and we want all Canadian building products to be more widely used. However, all members of the Coalition for Fair Construction Practices believe that no construction material or assembly should be awarded a legislated priority over others. Let professional judgment, practical application, fair competition, and respect for our building code system determine the best materials for the application and service.
All of the members of the Coalition for Fair Construction Practices express strong disapproval with Bill C-429. Honourable government and opposition members of this committee, we respectfully request that Bill C-429, or any such similar legislation, be not recommended for consideration by the House of Commons.