It is widely known Canada is facing both an affordable housing crisis and a climate crisis, and the worst possible outcome is solving one to punish the other.
The conversation around low-carbon construction is focused on embodied carbon – the emissions associated with manufacturing building materials and constructing homes. Embodied carbon matters, but we are increasingly debating the carbon footprint of materials in the national building code while overlooking the emission savings from materials impacting the buildings performance over time.
The Canadian Board for Harmonized Construction Codes (CBHCC) published a Climate Change Policy Position on Embodied Greenhouse Gas (GHG) Emissions for inclusion in the 2030 Model National Building Code. The policy position was published in July 2025. The CBHCC stated approach is modelled after the tiered approach used for operational carbon emissions which was introduced in the 2020 Model National Building Code.
The focus on the impact of materials on operational carbon is completely omitted and aimed directly at what draws power – think mechanicals, water heaters, lighting, etc. There are materials in buildings that save operational energy and therefore, carbon such as insulation.
This finding is at the centre of a recent lifecycle analysis (study, 2026) conducted by Building Knowledge Canada commissioned by NAIMA Canada, which examined how insulation impacts carbon emissions over the lifespan of a building.
The analysis found in many cases, the carbon savings achieved through reduced operational energy use far exceeded the combined embodied carbon associated with the building over a 100-year lifespan.
This matters because the direction of the 2030 National Building Code increasingly emphasizes reducing upfront embodied carbon. While reducing embodied emissions at construction needs to be part of the solution, analyzing materials without considering how they actually perform over decades, paints an incomplete and potentially misleading picture. We are missing a huge chunk without that operational carbon slice of the pie on energy saving materials.
The study evaluated the “carbon payback period,” defined as the time required for operational carbon savings to offset the additional embodied carbon emissions associated with the upgraded insulation strategy. Across all archetypes, the “carbon payback period” ranged from approximately 3.1 to 5.1 years over the life of the building (75 to 100 years) – an enviable ROI.
Too often, housing affordability is framed around the price tag. Design savings leading to substandard energy performance may seem ideal at first glance, but a less expensive home that permanently costs more to heat and cool is not necessarily affordable.
Lower-performance homes, which are often built at the expense of operational carbon, can force Canadians into higher utility bills and greater exposure to energy price volatility. Cheaper to build can become more expensive to live in. Materials that save operational carbon and utility costs should be accounted for and supported.
Canada needs more housing, but we also need housing that will still perform decades from now, that we can afford to live in.
If we focus too narrowly on upfront embodied carbon without considering full lifecycle building material performance in code, we risk locking in generations of unnecessary emissions, future maintenance and alteration retrofit costs, infrastructure strain and climate vulnerability.
Whether homes are heated with natural gas, heating oil, propane or electricity generated from fossil fuels, energy use creates emissions. And while electrification is an important part of Canada’s climate future, we currently have limited zero-carbon electricity available across much of the country.
The fastest and most cost-effective way to reduce emissions is to reduce the amount of energy buildings need in the first place.
The cleanest energy is the energy we never need to use.
Jay Nordenstrom is the executive director of NAIMA Canada, representing mineral fibre insulation manufacturers. Send Industry Perspectives Op-Ed comments and column ideas to [email protected].
