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NCBI's Response to Proposed Energy Efficiency and Performance Standard for Light Bulbs used for General Lighting.

1. Introduction

The National Council for the Blind of Ireland (NCBI) is a not-for-profit charitable organisation that provides support and services to more than 13,000 people who are blind and vision impaired throughout the country.

Established in 1931 NCBI currently works with more than 13,000 people of all ages throughout the country who have varying degrees of sight loss. We provide information, advice and support as well as rehabilitation and other training services which are designed to assist people who are living with sight loss to do so independently.

Our vision is for people who are blind and vision impaired to have the same opportunities, rights and choices as others to fully participate in society. Our mission is to enable people who are blind and vision impaired to overcome the barriers that impede their independence and participation in society.

This paper sets out the National Council for the Blind of Ireland’s (NCBI) position in relation to the proposed phasing out of “standard” light bulbs in Ireland and their replacement with more energy-efficient bulbs which and the introduction of new national standards (the proposal).

2. NCBI’s Position

NCBI is aware of, and supports, the need and commitments made to improve Ireland’s energy efficiency and to reduce the amount of carbon and other greenhouse gasses that are emitted nationally. NCBI does, however, have serious concerns regarding the implications of this proposal in that it will have a disproportionate impact on many people who are blind and vision impaired, in particular.

NCBI would, therefore, like to see a derogation of the proposal for people who need fluorescent lighting due to impaired vision.

2.1 Importance of Adequate Lighting

Depending on the condition that a person with impaired vision may have, many people find that they require more light than their fully-sighted peers in order for them to make use of their residual vision and to maximise the level of vision that they have.

For example, people with impaired vision often find that it takes a long time for their eyes to adapt when moving from bright to dark places. Therefore, they attempt to keep lighting levels bright throughout their entire home. As a result, people who are vision impaired will often use more lighting than the average person. Clearly by using more light fittings or higher wattage bulbs they are able to increases the light levels.

Energy efficient light bulbs are slower to “warm up”. As such they take longer to get to their optimum level of brightness than filament light bulbs. For a person with low vision, it takes their eyes longer to adjust between light and dark, so there can be a double jeopardy for a person in the time it will take them to be able to see under the new standards.

2.2 Need for Additional Lighting

Many people with impaired vision find it much easier to see when they are doing close-up tasks like reading, knitting, or writing a letter, if they use better lighting. Therefore, as well as having good general lighting in the room, it is important that they have additional light sources, for example a task light that can shine directly onto what they need to see.

By making simple changes to the lighting in their home, people with impaired vision can make things easier to see and are therefore more comfortable and safer in their homes. Furthermore, people who are vision impaired often need the strongest possible lighting to ensure that their residual vision is maximised and will, therefore, need use bulbs with a higher output (100+ watts). There is concern among NCBI’s service users that energy efficient bulbs are not available in the higher 150 watt category.

2.3 Additional Financial Cost

The additional cost of the new bulbs poses a significant financial problem for people who are blind and vision impaired. While a major benefit of the new bulbs is that they are more cost efficient to run, they are significantly more expensive to purchase. The cost to the average home of replacing their existing lighting will increase significantly as a result. For example using the prices quoted online at a major Irish DIY store, two bayonet cap 100w clear bulbs cost €1.89, while one energy saving bulb ES 20w (100w) costs €7.99. Therefore, the cost of replacing two standard 100 watt bulbs with two 100 watt energy efficient bulbs increases by more than a factor of 8.

According to the National Disability Authority, people with disabilities experience a high rate of poverty, double the national average. People whose labour force status is “sick and unable to work” are up to three times more likely to experience poverty. Of all groups, people with disabilities are second only to lone parents in the proportion at risk of poverty, or experiencing consistent poverty.

The impact of increased costs to something as essential as lighting on a household where a person resides who is legally blind or vision impaired will compounded their financial situation and may be prohibitive. As has been stated above, a person with impaired vision is likely to have a higher proportion of lights in their home to remove some of the obstacles they face as a result of darkness and to ensure that they are both comfortable and safe in their own homes.

Furthermore, the vast majority of people who are blind or vision impaired are in low income categories and will be simply unable to afford the additional and increased capital outlay to purchase the replacement bulbs at this significantly higher cost.

2.4 Introduction of a Grant

In order to encourage people to improve their environmental efficiency, the State provides a range of grants and allowances to assist them in meeting the initial increase in costs of installing energy efficient technologies. These grants include the Greener Homes, the Home Energy Savings Scheme and the Warmer Homes Scheme.

NCBI urges the Department for the Environment, Heritage and Local Government (the Department) to introduce a system of grants to off-set the additional costs that will result from this proposal. NCBI would be happy to work with the Department to propose a mechanism and criteria for this system in relation to people who are blind or vision impaired.

2.5 Timeframe and Scope of the Changes

A number of NCBI’s service users have in recent weeks contacted the organisation to express their concern at the speed of the proposed changes and uncertainty about the scope of the changes.

NCBI recognises that the nature of this proposal is technical in nature and understands that it is specific in terms of what falls within and outside of the scope of the new standards. However, Section 5 of the consultation document is technical in nature and may not be easily interpreted by the lay person. This is likely to lead to a degree of confusion about the scope of the proposal and the timeframe for the introduction of the new standards.

NCBI recommends that the Department ensures that the public understands the situation regarding the time frame for the introduction of the standard, the timeframe of the phasing of the standard and which light bulbs will be affected as a result of the standard at each phase in advance of the changes coming into force.

2.6 Health Concerns

Finally, a number of potential health concerns relating to energy efficient light bulbs have been brought to the NCBI’s attention.
The issue is reported to affect people with some form of light sensivity including

  • The auto-immune disease lupus;
  • The genetic disorder Xeroderma Pigmentosum (XP);
  • Certain forms of eczema and dermatitis;
  • Photosensitivity; and
  • Porphyria.

Furthermore, reports in the UK suggest that people suffering from ME have had bad reactions to fluorescent light and there have been warnings that energy-efficient bulbs cause migraines and increase the risk of seizures in people with epilepsy.

Obviously, safety is a key issue in relation to the proposal.

3. Summary of Recommendations

NCBI is broadly supportive of measures which enhance Ireland’s performance in reducing our emissions and damage to the environment. However, we are concerned that without amendment, the introduction of this new standard will impact negatively on people who are blind and vision impaired.

NCBI recommends the following:

  • A derogation of the proposal for people who need fluorescent lighting due to low vision.
  • That the Department recognises that a person with impaired vision will often have a greater need for additional lighting than their fully sighted peers.
  • That the Government recognises that energy efficient light bulbs take longer to light up to their capacity and that this light may not be as pure as tungsten bulbs.
  • That the Government recognises the additional costs that will apply to people who are blind and vision impaired.
  • That a new grant, or one-off payment, is introduced to off-set the increased costs of switching to the new standard of light bulbs for people who are blind or vision impaired.
  • That the Government clarifies the situation regarding the time frame for the introduction of the new standard, the phasing of the standard; and which light bulbs will be affected as a result of the new standard.
  • That NCBI is invited to meet with the National Climate Change Policy Section of the Department to discuss the proposal and the practicalities of introducing a new grant system.
  • That NCBI is involved in the review of the implementation of the proposed new standard in order to ensure that the interests of blind and vision impaired people are fully considered as part of that process.
  • That an independent assessment of the health and safety of energy efficient bulbs is carried out and published in advance of the proposed changes being adopted.

NCBI would welcome the opportunity to meet with the Department to discuss the impact that this proposal may have on people who are blind or vision impaired.

November 2008