May 2, 2026
To: Environment and Climate Change Canada via email: SDO-BDD@ec.gc.ca
Re: RAIC Response to the Draft 2026–2029 Federal Sustainable Development Strategy
The Royal Architectural Institute of Canada (RAIC) is pleased to provide input on the Draft 2026–2029 Federal Sustainable Development Strategy (FSDS). This submission reflects consolidated feedback from the RAIC’s Committee of Regenerative Environments (CORE), representing advanced expertise in architecture, sustainability, and the built environment from across Canada.
The RAIC supports the Government of Canada’s commitment to advancing climate action, resilience, and sustainable development through a whole-of-government approach. The built environment plays a central role in achieving these objectives. Buildings and infrastructure are not only significant contributors to emissions and resource use, but also critical platforms for strengthening Canada’s resilience to the impacts of climate change while concurrently delivering on affordability and enhancing health and social outcomes. Across RAIC member feedback, several consistent themes emerged.
First, the built environment provides a key cross-cutting delivery pathway to help achieve the FSDS goals. While the draft strategy references buildings in the context of emissions and housing, it does not yet reflect the significant extent to which the built environment can contribute to the FSDS goals of building an inclusive and resilient society, driving clean growth, and protecting our environment and well-being.
Second, members emphasized the importance of whole-life-cycle performance in reaching climate and biodiversity goals. This includes integrating operational and embodied carbon, life-cycle costing into federal policy and procurement frameworks. Additionally, greater emphasis on circular economy policy and strategies to reduce resource consumption and reliance on external markets. This includes prioritizing the adaptability of existing buildings, design for disassembly and adaptation, together with durability and material reuse. These capacities are largely determined at the design stage and should be reflected in federal guidance and procurement criteria.
Third, life-cycle costing and social cost accounting were identified as important tools for evaluating affordability. As climate change increasingly impacts health, land, infrastructure, and the economy, social cost accounting will be vital in evaluating the unseen costs and benefits of policy choices. Life-cycle costing is a design-assist tool that supports affordability over the asset’s life for current and future generations. Policy and early-stage project decisions significantly influence outcomes, requiring better alignment between goals, policy and practice.
Fourth, there is a need to strengthen climate resilience in new and existing buildings and infrastructure. Feedback highlighted the importance of climate-responsive building
standards and national capacity building to address the increasing risks of climate change such as extreme heat, wildfire smoke, cascading impacts of extreme weather events, etc. Policy signals to rapidly scale climate risk assessment, resilience standards and planning, and implementation are critical at the building, community and regional levels. Importantly, the inclusion of diverse perspectives in resilience policy development and planning will be necessary to ensure effective resilience outcomes for all Canadians.
Finally, members identified the importance of leveraging federal leadership to accelerate market transformation. Federal buildings and infrastructure projects present a critical opportunity to serve as demonstration platforms for low-carbon, resilient, and regenerative design, with transparent reporting and knowledge sharing to support sector-wide learning. Additionally, members identified the importance of Indigenous knowledge and leadership in shaping the development and implementation of the FSDS and encouraged a greater emphasis on and inclusion of Indigenous knowledges.
The attached summary table provides detailed, structured feedback aligned to specific FSDS goals and sections, including recommended changes, rationale, and supporting evidence.
The RAIC welcomes the opportunity to continue engaging with the Government of Canada to support implementation of the FSDS, including through knowledge mobilization, professional education, and collaboration on policy and practice.
The RAIC is committed to helping accelerate the transition to a regenerative, equitable and low-carbon future. We invite you to learn more through our Climate Action Plan: A Framework for Engagement and Enablement.
Thank you for the opportunity to contribute to this important national strategy.
Sincerely,
Mike Brennan, Hon. MRAIC, Hon. RAIA, Allied Member, AIA
Chief Executive Officer
Royal Architectural Institute of Canada (RAIC)
Cc
Joanne Perdue and Mona Lemoine
Co-Chairs, RAIC Committee on Regenerative Environments