UDI Lower Mainland submission to the Canadian Board for Harmonized Construction Codes on embodied GHG draft policy positions for the National Model Codes.

UDI recommends that the embodied GHG standards do not move forward as they will only exacerbate the cost of delivery and affordability crisis we are facing in the providing new homes to Canadians. They would also make it even more difficult for the Federal Government and the provinces to achieve their ambitious housing objectives. Rather than putting resources into these new requirements, UDI recommends the CBHCC make substantive improvements to the current National Building Code (NBC) development process as the Federal Government has made this a priority. It would also be helpful if more resources could be applied to researching and codifying approaches to cost effectively implement the new seismic provisions in the NBC.