Cement Association Remarks to Canadian House of Commons Standing Committee on Natural Resources Regarding Private Member's Bill C-354

Speaking Notes for Adam Auer, Vice President, Environment and Sustainability, Cement Association of Canada,

Presentation to Canadian House of Commons Standing Committee  on Natural Resources Regarding Bill C-354

March 22, 2018, Ottawa, Ontario



Thank you, Mr. Chair and members of the committee.

My name is Adam Auer and I am the Vice President of Environment and Sustainability at the Cement Association of Canada. I am joined by the CAC’s Executive Vice President, Steve Morrissey.

Thank you for the opportunity to present our views on Bill c-354.

First, let me state that the Canadian Cement industry unequivocally supports the notion that federal procurement of infrastructure, whether direct, or indirect through investment transfers to other levels of government, can and should influence construction markets toward low-carbon and climate-resilient solutions.

We also agree and, in fact, have consistently championed the use of lifecycle tools as the best (though far from perfected) tools for advancing sustainability in the built environment.

Our issue with Bill C-354 is that it calls on the federal government to leverage its enormous purchasing power to, quote “give preference to projects that promote the use of wood.”

The Bill appears to be attempting to serve two objectives: first to support Canada’s forest sector, which is suffering under a number of pressures including softwood lumber tariffs; second, to help reduce the GHGs associated with buildings in Canada.

Let me start with the first objective.

When governments arbitrarily give preference to one product or technology over another – it has a clear distortionary effect on the market, undermining the healthy, fair and open competition that defines successful modern economies.

Canada’s forest industry already benefits from tremendous federal and provincial government support.

  • The 2017 federal budget alone offered some $40 million to support promotion of wood.
  • Wood-related organizations, such as FP Innovations, benefit from substantial support from the Canadian Forest Service and just about every province and territory.
  • Taxpayer dollars have played an instrumental role in code development and demonstration projects related to tall wood buildings.
  • Governments have also taken the unusual step of leveraging political authority to change building codes to allow taller wood structures.
  • And finally, the wood industry has actively promoted preferential treatment of wood through policies such as Wood First in British Columbia.

All things being equal, it would be hard to fault governments for looking after the interests of major domestic industries. In reality however, such measures often simply “rob Peter to pay Paul” – artificially shifting economic activity from one domestic industry to another.

I would remind committee members that concrete and steel are also important to Canada’s economy – my sector alone employs some 150,000 Canadians and contributes some $73 billion in economic activity. And because concrete is an inherently local material, our economic impact directly benefits just about every community in Canada.

Like forestry, we are also under tremendous economic pressures – for example, in BC our sector has lost some 40% market share to Asian and U.S. imports because those imports are able to bypass BC’s carbon tax. Canadian steel is also struggling in the global economy despite producing some of the highest quality and most environmentally responsible steel in the world.

While there are things governments can do to help balance these pressures, never have we, nor will we, suggest preferential treatment of concrete over other materials as among those measures.

History has taught us that “picking winners” is bad policy – it’s bad for the economy, it’s fiscally inefficient and, perhaps most importantly when it comes to transformative challenges like climate change, it disrupts natural innovation cycles that are constantly pushing competing industries to do better. In the case of cement and concrete, this means dampened investment in a raft of transformative low-carbon solutions, including low carbon fuels and the burgeoning trillion-dollar market for carbon capture and utilization technologies.

Let me use that as a segue into the second stated purpose of the Bill – reducing GHGs from buildings.

First, it is important to understand that carbon emissions from buildings are overwhelmingly associated with the operation of those buildings – primarily heating and cooling. While I would not argue that materials are unimportant, they represent as little as 4% of any given building’s “global warming potential.” In fact, in a well-designed energy efficient structure, the most important variable in determining climate impacts is longevity – in a high-efficiency long service life structure, the impact of materials is vanishingly small.

Wood advocates argue that wood buildings yield a net carbon benefit over alternatives. These claims are based on an assumed “zero sum” balance between commercial logging and afforestation. You cut a tree, a new one grows in its place. You cut a forest, an ecologically equivalent forest grows in its place. This is a misleading oversimplification of forest carbon cycles and a misrepresentation of the real-world success of reforestation programs – particularly in Canada where most logging occurs in first growth forests. In fact, recent science suggests that when land use change impacts of deforestation are taken into account (even accounting for regrowth), some 13 tonnes of GHGs are lost to the atmosphere for every tonne sequestered in a wood product.

While LCA is the best tool we have to account for carbon in the built environment, current standards around the treatment of land use impacts are out of sync with this emerging science. All whole building LCAs of wood buildings, including some of the best tools advanced by the likes of Athena Sustainable Materials Institute, are restricted by these standards and their assumptions.

Let me end by supporting a notion forwarded by Mr. Giroux of the Wood Council about hybrid buildings in his appearance before this committee. Many of the most interesting, innovative and sustainable buildings standing today utilize a variety of materials, including concrete, steel and wood – not because government required any particular material to be used, but because of the natural process of market innovation increasingly directed toward sustainability. It is this very concept, the life cycle integration and optimization of materials and design, that must dominate the discussion on low-carbon climate-resilient construction.

All three levels of government purchase directly and indirectly some 60% of building materials consumed in Canada. A balanced approach to reducing GHGs from the production and use of all of those materials is the only sensible policy.

Thank you very much for your attention.

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