Several environmental and consumer policy advocacy groups have collaborated to petition for new Vermont legislation that would effectively ban the sale of all mercury-containing fluorescent lighting products in the state.
In a joint press announcement, the Vermont Public Interest Research Group (VPIRG), the Mercury Policy Project, the Clean Lighting Coalition (CLiC), and the Appliance Standards Awareness project (ASAP) outlined their reasons for petitioning Vermont state legislators via the Vermont Department of Environmental Conservation (DEC) to alter current policy.
“Under existing Vermont law, fluorescent lamps can only be sold until a mercury-free alternative is available that provides the same performance at an equal or lower cost,” the advocacy groups explained in the announcement. The groups reported that in October, a letter from VPIRG to DEC argued the wide availability of LED-based lamps that meet state criteria as alternatives to mercury-containing fluorescent technology.
State seeks industry input
In turn, DEC representatives sought industry feedback on the comparability of LED lamps and fluorescent lamps in terms of price and performance from the National Electrical Manufacturers Association (NEMA). The association, which represents US electrical and medical imaging equipment manufacturers, sent a response letter to DEC Waste Management & Prevention division director Matt Chapman, dated Nov. 16, 2021, which NEMA vice president of Government Relations Philip A. Squair identified as a “collective response by the [NEMA] Light Source Product Section to correspondence received on November 1st concerning compliance with 10 VSA §7152 of the 2012 legislation for the Collection and Disposal of Mercury-containing Lamps.”
In the NEMA response letter, Squair laid out the point raised by the special interest groups in their initial missive to DEC: “That correspondence cited Subsection 7152(a)(6) of the statute, which addresses the question of whether an ‘alternative, non-mercury energy efficient lamp is available that provides the same or better overall performance at a cost equal to or better than the classes of lamps that the manufacturer proposes to sell.’”
NEMA parties concluded that “the only general purpose, mercury-added lighting product for which an ‘alternative, non-mercury energy efficient lamp is available that provides the same or better overall performance at a cost equal to or better’ than the mercury-added product is screw-based compact fluorescent lamps [CFLs]. Non-mercury alternatives for all other general purpose (as well as specialty) mercury-added lamps are either unavailable, cost substantially more per unit, or present performance challenges.”
Ultimately, NEMA’s response agreed that although CFLs can be suitably replaced with LED lamps, other LED retrofit lamp offerings do not meet the qualifications that would prompt NEMA to identify them as “acceptable replacements” — one extensive lamp category being linear fluorescent lamp (LFL) alternatives.
Debate over LFL alternatives
The advocacy groups disputed NEMA’s feedback to DEC, summarizing their arguments in the full release, which is posted in the Company Newsfeed section of our website. In particular, advocates took issue with the interpretations of cost and price as they appear to be defined by NEMA’s criteria, in addition to the accessibility of LED alternatives to LFLs.
“Price is not the same as cost from a consumer or small business perspective,” said Ana-Maria Carreño of CLiC. “The cost of a light bulb includes both the cost of buying the bulb and the cost of running it in our homes and offices. If the State uses this commonsense definition of cost, fluorescent lighting has already lost across the board.”
Moreover, according to Brian Fadie of ASAP, “[Users] who have instant start fluorescent ballasts can buy a four foot LED retrofit bulb for only 72 cents more than a fluorescent bulb” via a Home Depot retailer in Vermont. “Since the LED bulb cuts electricity costs in half, those 72 cents are saved on the utility bill in just one month, and the LED bulb then goes on to last for 9 years,” asserted Fadie in the announcement.
While such cost breakdowns appear to be solid, the discussion reveals an apples-to-oranges comparison. In NEMA’s letter, the association cited product and pricing data from professional electrical supply distributor Grainger — not a big-box retailer, which tends to be the realm of the do-it-yourself homeowner rather than commercial, industrial, and institutional organizations that are the most dominant consumers of LFLs or tube lamps.
In response to a request for comment on the advocates’ points, LEDs Magazine received the following statement from NEMA’s Phil Squair:
“While non-mercury, linear LED lamps ARE available as replacements for many linear fluorescent lamps (LFLs), only certain types are ‘plug-and-play’ and thus allow a direct cost comparison, with LED lamps selling at significantly higher prices per unit, broadly speaking. Most LFL lighting systems — and virtually all HID [high-intensity discharge] lighting systems — will require a rewiring or replacement by an electrician to convert to LED, which must be factored into the cost comparison. Furthermore, because the installed base of lighting fixtures is so diverse, there will always be limitations for ‘plug-and-play’ or ‘drop-in’ retrofit LED lamps, which are not universally compatible with every fluorescent fixture. Incorrect installation can create excess heat that can damage the fixture or ballast and lead to lamp failure upon initial start-up.
“Each situation must be assessed individually by those who manage — and pay for — lighting systems in private and public facilities. The lighting industry has been installing fluorescent lighting systems for more than 80 years, and manufacturers support and benefit from the ongoing conversion to non-mercury-based light sources. It is a TRANSITION, however, that relies on mercury-added products remaining available as commercial, industrial, and institutional enterprises gradually upgrade their lighting systems,” concluded Squair’s statement.
VPIRG and its partners report that a preliminary decision on this petition is anticipated to be released by DEC in early 2022.
More resources
Read the full letter from NEMA to Vermont DEC
Learn more about VPIRG, CLiC, ASAP, and the Mercury Policy Project
Visit NEMA website for more details on its mission
Read a recent commentary on eliminating mercury-containing lighting
CARRIE MEADOWS is associate editor of LEDs Magazine, with 20 years’ experience in business-to-business publishing across technology markets including solid-state technology manufacturing, fiberoptic communications, machine vision, lasers and photonics, and LEDs and lighting.
Editor’s comment
Other lighting industry researchers and stakeholders have admitted that contemporary plug-and-play LED tubes, or TLEDs, are far from an ideal solution to the ubiquitous LFL — but they have improved over earlier incarnations. Earlier this year, California Lighting Technology Center (CLTC) director Michael Siminovitch noted that a quality specification for LED linear lamps is a must, after evaluating many options for the latest iteration of California’s Million LED Challenge program. Still, said Siminovitch in May, “There are places for TLEDs, a good-quality TLED… Say, if you’ve got a pendant fixture, an expensive indirect fixture.”
It hardly appears that the largest lighting stakeholders are opposed to a phase-out of inefficient general-illumination products that happen to contain mercury. After all, in August contributor Mark Halper reported Signify CEO Eric Rondolat’s comments in backing a European climate initiative called Fit for 55. “Replacing the EU’s 2.3 billion conventional light points with energy-efficient LED would save €40 billion per year and eliminate 50.9 million tons of CO2 emissions per year,” said Rondolat.
Some specialty applications such as germicidal ultraviolet (GUV) systems may take longer to come around to massive LED uptake, but semiconductor industry consultant Mike Krames predicts that these products will see widespread adoption as UV-C LED architectures evolve to deliver more UV-C energy than mercury lamp alternatives.
At any rate, it’s unlikely that policymakers will overlook the cost/benefit scenarios for LEDs as a natural evolution away from less-efficient light sources as burdens on power grids become heavier. Now the question remains as to what happens to all the defunct mercury-containing lamps. But that’s a different thread for another day. — CAM
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