Letter
to Minister John Baird
May 10, 2007
The Honourable John Baird
Minister of the Environment
Les Terrasses de la Chaudière
10 Wellington Street, 28th Floor
Gatineau, Quebec
K1A 0H3
Dear Mr. Baird,
Re: Query submitted about process employed to
decide on incandescent bulb ban
Earlier today, I sent you an e-mail, a copy of which is
attached to this cover letter. I am forwarding that communication
to you today via courier to ensure that it is not lost
in the large volume of e-mail submissions you undoubtedly
receive.
As part of our newly launched “Science Audit Centre”
campaign, the Natural Resources Stewardship Project certainly
look forward to hearing back from you concerning the process
that was employed to come to the decision to ban incandescent
light bulbs. As explained in my e-mail, NRSP believes
that a major government intervention into the lives of
Canadians such as that represented by the incandescent
light bulb ban should have a clear and demonstrable environmental
benefit; otherwise it is not worth the financial cost
and inconvenience. That is why we would like to learn
about the full life cycle assessment process that was
employed in this case.
Sincerely,
Tom
Harris, B. Eng., M. Eng. (mechanical)
Executive Director
Natural Resources Stewardship Project
P.O. Box 23013
Ottawa, Ontario K2A 4E2
Phone: 613-234-4487
e-mail: tom.harris@nrsp.com
Web: www.nrsp.com
May 10, 2007
The Honourable John Baird
Minister of the Environment
Les Terrasses de la Chaudière
10 Wellington Street, 28th Floor
Gatineau, Quebec
K1A 0H3
Dear Minister Baird,
Re: Query about process employed to decide on
incandescent light bulb ban
On April 18, the Natural
Resources Stewardship Project (NRSP) launched its
Science Audit Centre and issued a news
release to describe our programme. We sent the release
to your office shortly after it appeared on the CNW wire.
This letter is in respect to an issue the Science Audit
Centre intends to make one of its first studies: your
decision to ban incandescent light bulbs and replace them
with compact flourescent lamps (CFL).
Note 1 at the end of this letter
includes samples of statements made by the Government
in support of this ban. There is a strong focus in these
statements on reducing carbon dioxide (CO2).
This suggests that CO2 reduction was a key
driver in the decision. NRSP and the many climate experts
we work with do not believe that reduction in CO2,
the greenhouse gas of concern in most climate change schemes,
is a worthwhile goal. While sensible energy conservation
and pollution reduction are indeed important objectives,
modern climate science findings shed serious doubt on
the hypothesis that anthropogenic CO2 emissions
are a significant cause of global climate change. We believe
that an undue focus on CO2 reduction diverts
attention from the important task of reducing real pollutants.
In some cases, actions to reduce CO2 emissions
are taken at the cost of increasing the emission of pollutants
such as mercury, particulates, sulfur dioxide, oxides
of nitrogen, etc. and so are clearly a mistake. We are
concerned that there has been little study of the impact
of your decision to ban incandescent light bulbs on what
we consider to be more serious environmental implications
associated with a switch to CFLs. In Note
2 at the end of this letter we list some of the more
obvious disadvantages of CFLs.
Our concerns have prompted NRSP to make the light bulb
decision a focus for the Science Audit Centre, and in
keeping with that, to ask you a series of questions about
your decision:
1 - Were comprehensive comparative life cycle environmental
impact, energy consumption and economic assessments of
the two methods of lighting conducted? If they were, could
you tell us who performed the analyses? Could you also
share with us the processes used and the results attained
in each case, please? What efforts were made to seek independent
verification of the analyses from third party scientists,
engineers and economists?
A full environmental impact life cycle analysis would
include, but not be limited to, the items specified in
Note 3 at the end of this letter.
Energy consumption analyses include many aspects, the
items specified in Note 4 being examples.
Economic life cycle analyses also incoporates many concerns,
including those specified in Note 5.
2 - Was a comparative heath impact analysis of the two
methods of lighting conducted? If it was, we request the
same information about the analysis as listed in #1 above,
except that the appropriate verification would have been
that by third party medical experts.
A full health impact analysis would include, but not
be limited to, the items specified in Note
6.
3 – What input was sought from the public and other affected
parties? What responses did you receive and how was this
input handled? Is it possible for NRSP to review the consultation
process that was conducted before coming to the decision
to ban incandescent light bulbs and promote CFLs?
4 – Some countries are not installing CFLs, deciding
instead to either wait for more efficient incandescents
(which will be available in the near future) or until
LEDs are ready for broad application in the market place,
which also is expected soon. Were these options compared
with plans to mandate a mass move to CFLs? If so, could
you share the results of this study, please?
NRSP believes that a major government intervention into
the lives of Canadians such as that represented by the
incandescent light bulb ban should have a clear and demonstrable
environmental benefit; otherwise it is not worth the financial
cost and inconvenience. To feel confident that the decision
to ban incandescent bulbs will indeed benefit the environment
and consumers, we request that you share with us answers
to the above questions.
We look forward to hearing from you or your representatives
soon.
Sincerely,
Tom
Harris, B. Eng., M. Eng. (mechanical)
Executive Director
Natural Resources Stewardship Project
P.O. Box 23013
Ottawa, Ontario K2A 4E2
Phone: 613-234-4487
e-mail: tom.harris@nrsp.com
Web: www.nrsp.com
Cc: Timothy F. Ball, PhD, Chair, Science Advisory Committee,
NRSP
Notes:
Note 1: A sample of Government
of Canada statements made in support of the ban:
- Minister of Environment John Baird said
on April 25: "Using more energy-efficient light bulbs
is a great example of a concrete action Canadians can
take at home to reduce harmful greenhouse emissions and
save energy.”
- On the same day, Minister of Natural Resources Mr.
Gary Lunn said that the Canada-wide ban will reduce greenhouse
gas emissions by more than six million tonnes a year,
saving homeowners about $60 a year in electricity costs.
- The Government’s recently announced “Action on Climate
Change and Air Pollution” makes
the following statement: “We will also phase out the use
of inefficient incandescent light bulbs by 2012. All this
will give Canadian consumers real opportunity both to
save money on energy and to help clean up our environment.”
- Environment Canada’s EnviroZine
Web site states: “If every household in Canada changed
just one traditional incandescent light bulb to an ENERGY
STAR labelled CFL, the country would save over $73 million
in energy costs every year and reduce greenhouse gas emissions
by 397,000 tonnes of carbon dioxide – which would have
the same impact on climate change as taking 66,000 cars
off the road for one year.”
- March 19, 2007 Environment Canada press release: it
was explained that the Government of Nunavut may use Canada
ecoTrust funding to, among other things, place “a ban
on incandescent light bulbs, which will result in an annual
reduction of 1,300 tonnes of carbon dioxide or equivalent.”
Note 2: Potential disadvantages
of a mandated mass switch to CFLs:
- Their initial purchase price is significantly higher
than incandescent light bulbs.
- The light quality from all but the most expensive CFLs
is considered by many Canadians to be significantly less
pleasant than incandescents and, according to numerous
scientific studies, has a detrimental impact on human
health and performance due to the spectrum of the light
emitted from cool white fluorescents (which is the type
often employed – ‘full spectrum’ CFL’s typically cost
$30 per CFL bulb and use more power than inexpensive CFLs).
Many in the public have expressed a profound dislike for
CFL illumination – here
is a sample of public opinion from the National Post and
here
is a sample of the many calls Ottawa’s CFRA talk radio
shows have received on the topic.
- CFLs are seen by many Canadians to be less convenient
than incandescent light bulbs for a number of reasons
– here are some:
1. They can not be disposed of as normal household garbage
but must be taken to a mercury recycling facility – your
department has expressed
concern about mercury as a toxin.
2. Breaking a CFL is a concern
as they cannot simply be vacuumed up the way a broken
incandescent bulb can. General Electric (GE) recommends
the public wear chemical resistant gloves in the clean
up process.
3. CFLs do not operate properly at temperatures below
freezing. The U.S. Department of Energy lists a number
of situations where CFL use is inappropriate – see page
2 of http://www1.eere.energy.gov/femp/pdfs/29267-5.4.3.pdf.
4. According to GE, CFLs are not for use in track, recessed
or dimmer fixtures.
5. GE recommends against using CFLs in applications involving
vibration such as a ceiling fan or garage door opener
as vibration can cause CFL electronics to fail.
6. According to this
reference: “Compact fluorescent lamps emit electromagnetic
frequency wavelengths, which can interfere with household
signals such as television and radio. For this reason,
manufacturers recommend positioning these lamps at least
eight feet away from such devices.” Here
is GE’s recommendation.
7. There is a short delay before CFLs fully illuminate.
GE explains: “Compact fluorescent light bulbs work best
if they are left on for over 15 minutes each time they
are turned on. These types of lamps can take up to 3 minutes
to warm-up. Warm-up will probably not be noticeable from
a user stand point, but the lamp needs to warm-up in order
to reach the point of most efficient operation.”
8. There have been reports of CFLs catching fire when
operated on the wrong voltage.
Note 3: Some of the factors
to consider in an environmental life cycle analysis of
competing lighting options:
- The environmental impact of the mercury used in CFLs
must be considered. This would include methods of disposal
and resultant leakage into the environment. According
to the Association of Lighting and Mercury Recyclers in
the U.S. (2004), 70.8% of the mercury lamps used by business
and 98% of the lamps used in homes are not being recycled
and simply end up in landfills. Many of these eventually
leak mercury into the surrounding environment.
- The CFL manufacturing process is apparently more complex,
requiring more electronic materials than the manufacture
of incandescent bulbs. This results in a different environmental
impact during the manufacturing process that must be considered.
- The location of manufacturing must be considered as
well since different countries have different environmental
standards that would apply during the manufacture of light
bulbs. Location is also a factor as it relates to the
pollution produced during transportation of the bulbs
for sale.
- Various factors from Note 4, below,
affect environmental impact as well.
Note 4: Some of the factors
to consider in an energy life cycle analysis of competing
lighting options:
- The Environment Canada Web
site states: “Standard incandescent bulbs ... waste
90 per cent of their energy by producing heat, not light.”
This statement is misleading since Canada requires massive
quantities of space heating for most of the year. While
the efficiency of space heating with heat from incandescent
light bulbs is not high in comparison with, for instance,
space heating from natural gas, it does significantly
improve on the overall efficiency of energy use in these
bulbs during cold weather and so must be considered in
the overall energy life cycle analysis.
- As stated above, the CFL manufacturing process is more
complex, requiring more electronic materials and higher
product-inspection and quality-control costs, presumably
also increasing the energy consumed in their manufacture.
- CFLs are considerably heavier and their packaging more
bulky than incandescent bulbs. One reference lists a package
of four CFLs as weighing 710 grams and occupying double
the space of a pack of four incandescents which weigh
170 grams. This results in greater energy requirements
for shipping and storage (and subsequently, greater environmental
impact as well).
- The energy required to recycle the toxic components
of CFL must be considered.
- According to this
reference: ”Since turning an incandescent bulb on and
off doesn't shorten the life of its filament significantly,
you do well to turn it off whenever possible. The same
isn't true of a fluorescent tube--turning it on ages its
filaments significantly (due to sputtering processes)
so you shouldn't turn a fluorescent lamp off if you plan
to restart it in less than about 1 minute.” Following
these directions (which are similar to those of the manufacturers)
would result in CFLs being on for greater durations that
ordinary bulbs. The impact on total energy consumption
(and subsequent pollution produced) must be considered.
- The net energy cost (and subsequent environmental impact)
of transporting used or broken CFLs to a mercury recycling
facility.
- The net energy cost (and subsequent environmental impact)
of replacing functional incandescent bulbs with CFLs.
Note 5: Some of the factors
to consider in an economic life cycle analysis of competing
lighting options:
- As stated above, the CFL manufacturing process is more
complex, requiring more electronic materials and higher
product-inspection and quality-control costs.
- Will the public continue to use low cost CFLs or switch
to more expensive CFLs when the poor light quality of
less expensive CFLs becomes apparent (see health impact
considerations below)?
- The net reduction in CFL life expectancy due to repeated
turning on and off.
- The greater shipping and storage costs of CFLs due
to their greater mass and bulk.
Note 6: Some of the factors
to consider in a health analysis of competing lighting
options:
- As explained in Note 2, many studies
have demonstrated a measurable negative impact on human
health and productivity when subjects change from use
of incandescent lights to cool white fluorescents (the
most commonly used – various lighting spectrums may be
seen here).
- Health impacts may also translate into significant
economic costs if CFLs completely replace incandescents
in offices, factories, schools and homes.
- The impact of mercury emissions from improper disposal
of CFLs.
- It has been suggested
that fluorescent light destroys vitamin D with commensurate
negative health impacts.
- Other concerns as expressed in the audio file from
the radio programme referenced in Note
2 above.
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