RE: Toronto and Region…

RE: Toronto and Region Conservation Authority Comments on ERO# 019-8268 Advanced Wood Construction Action Plan, MNR (also submitted on September 30, 2024 to masstimber@ontario.ca)

Thank you for the opportunity to comment on the Draft of “Ontario’s Advanced Wood Construction Action Plan” posted on the Environmental Registry. Wood construction is of particular interest to Toronto and Region Conservation Authority (TRCA) as we near completion of a new, four-storey, 86,000 square foot, cedar clad, mass timber administrative office building near York University in North York. This “wood-first” building is on track to achieve targeted sustainability certifications, including LEED v4 Platinum certification and WELL Building Standard v2 Silver. This is in addition to having already been awarded the Zero Carbon Building Design Certificate and the inaugural Ontario Embodied Carbon Award for New Construction. Further details can be found on TRCA’s project webpage.
Government Proposal
We understand that the Ministry of Natural Resources (MNR) is developing and implementing an Advanced Wood Construction Action Plan to increase the use of wood in construction as part of Sustainable Growth: Ontario’s Forest Sector Strategy (Forest Sector Strategy). The goals of this Action Plan are to, 1) increase the use of Ontario’s wood and grow wood’s market share in construction, 2) establish Ontario as a leader in advanced wood construction manufacturing and expertise, and 3) encourage the use of sustainable materials in infrastructure. The objectives of the Action Plan are to support promotion, education and training initiatives, spur research and the advancement of codes, standards and regulations, stimulate innovation and advanced manufacturing, and demonstrate and display advanced wood construction.
General comments
TRCA supports MNR’s efforts and finds that the strategies in the Draft Advanced Wood Construction Action Plan to be well thought through. In addition to TRCA’s new wood administrative office building, TRCA staff develop and deliver programs and projects in partnership with the private sector and academia focusing on corporate sustainability, building energy efficiency, renewable energy technologies, carbon management, as well as general environmental best practices. With this expertise and experience in mind, we offer the following comments and recommendations on the Draft Action Plan for the MNR’s consideration:
• Incorporate a research component to identify, qualify and articulate the social, environmental and economic impacts of advanced wood construction into Objective 1 Promotion, Education and Training.
• Add an objective that addresses the opportunity to harness nature-based atmospheric carbon removal, with long term sequestration of carbon in building products and future products, as part of a circular economy as the buildings eventually reach their end of life. Working towards this objective in partnership with all levels of government, the forestry sector, universities and non-government organizations would help to build confidence in the path the Forest Sector Strategy has put forward. Addressing the climate lens in this way, would put Ontario on the leading edge of nature based atmospheric carbon removal and sequestration as a climate solution. Natural Resources Canada is in the process of updating their calculations of carbon emission and sequestration from the forestry sector and would be a logical partner.
Thank you