Vol. 145, No. 23 — November 9, 2011

Registration

SOR/2011-228 October 21, 2011

ENERGY EFFICIENCY ACT

Regulations Amending the Energy Efficiency Regulations

P.C. 2011-1233 October 20, 2011

Whereas, pursuant to section 26 of the Energy Efficiency Act (see footnote a), a copy of the proposed Regulations Amending the Energy Efficiency Regulations, substantially in the annexed form, was published in the Canada Gazette, Part Ⅰ, on April 16, 2011;

Therefore, His Excellency the Governor General in Council, on the recommendation of the Minister of Natural Resources, pursuant to sections 20 (see footnote b) and 25 of the Energy Efficiency Act (see footnote c), hereby makes the annexed Regulations Amending the Energy Efficiency Regulations.

REGULATIONS AMENDING THE ENERGY EFFICIENCY REGULATIONS

AMENDMENTS

1. Subparagraphs 3(21)(c)(i) and (ii) of the Energy Efficiency Regulations (see footnote 1) are replaced by the following:

1. (i) it has a rated luminous flux of at least 1050 lm but not greater than 2600 lm and its manufacturing process is completed on or after January 1, 2014, or
   (ii) it has a rated luminous flux of at least 250 lm but not greater than 1049 lm and its manufacturing process is completed on or after December 31, 2014.

2. The portion of items 136 to 139 of Part 1 of Schedule I to the Regulations in column IV is replaced by the following:

Item	Column IV Completion Period
136.	on or after January 1, 2014
137.	on or after December 31, 2014
138.	on or after January 1, 2014
139.	on or after December 31, 2014

COMING INTO FORCE

3. These Regulations come into force on December 31, 2011.

REGULATORY IMPACT ANALYSIS STATEMENT

(This statement is not part of the Regulations.)

Executive summary

Issue

Canadians have expressed concerns about certain aspects of the minimum energy performance standard for light bulbs scheduled to affect 100 and 75 W bulbs on January 1, 2012, and 60 and 40 W bulbs on December 31, 2012. This amendment delays the effective dates for these wattages by two years in each case in order to enable Canadians to better understand the benefits of the standards and the alternatives that will be available to them and to allay their concerns.

Background

The existing energy efficiency standard for general service lighting (light bulbs) was introduced by the Minister of Natural Resources and the Minister of the Environment in 2007. The consequential Regulations came into force in December 2008 and applied to 100 and 75 W bulbs manufactured on or after January 1, 2012, and to 60 and 40 W bulbs manufactured on or after December 31, 2012. The Regulations prohibit the importation and interprovincial shipment of non-compliant products. The Regulations provide for a number of alternatives to inefficient bulbs. Where no alternatives exist, exemptions are made.

Since March of 2010, NRCan has received over 100 communications from consumers, principally concerning one of the available alternative technologies: compact fluorescent lamps (CFLs). These concerns are focused mainly on perceived health issues, performance and mercury content. These questions were addressed during consultations on the standard; however, it is clear that evidence to allay these concerns has not been fully communicated to or understood by the consumer.

Canada is part of a broadly coordinated international effort to implement standards to improve the efficiency of general service lighting by phasing out the use of inefficient light bulbs. All developed markets have made commitments to establish standards for this application, including the United States, European Union member countries and Australia. The standard has also been implemented in California and British Columbia and has been proposed in Ontario.

Objectives

Reducing greenhouse gas emissions and air pollution remains a high priority for the Government and minimum energy performance standards (MEPS) are one of the most cost-effective means of achieving this priority. In the case of the minimum energy performance standards for general service lighting, it is clear that there are public misperceptions (concerns) as to what the standards entail and the choices that will be available to Canadians once they are in place.

There has been widespread public discussion concerning one of the common alternatives to inefficient lighting: the CFLs. Concerns have been expressed about perceived health effects associated with the use of CFLs and also, given that they necessarily contain mercury, about disposal issues that may arise from their increased use.

Efforts have been underway for some time to respond to the health concerns. For example, Health Canada and health authorities of other governments have conducted research that indicates that, with respect to ultraviolet radiation and electromagnetic emissions, CFLs do not constitute a health risk.

On February 26, 2011, Environment Canada published in the Canada Gazette, Part Ⅰ, regulations limiting mercury content and announced that requirements for producer responsibility will be made known in the near future.

The Regulations will delay the implementation of the standards for general service lighting by two years for all wattages so that implications for lighting choices for Canadians can be more effectively communicated to them. This delay also allows programs dealing with the disposal of CFLs to be more firmly established.

Description

As a result of this amendment, the completion dates for general service lighting currently prescribed in the Energy Efficiency Regulations will change to January 1, 2014, for 100/75 W bulbs and to December 31, 2014, for 60/40 W bulbs. During the timeframe between the approval of these revised dates and the new completion dates, strengthened communication activities will be launched to respond to the concerns expressed to date.

This communication outreach will focus on the messages that (1) the standards do not prescribe a particular technology; (2) there are a number of alternative technologies available now and more will be available in the future; and (3) CFLs are a good choice and do not represent a health risk to Canadians.

These activities, building on the infrastructure established by Natural Resources Canada (NRCan), will be developed and delivered in concert with other stakeholders, industry, governments and utilities who share common energy efficiency and environmental objectives.

In the meantime, Environment Canada (EC) is working on establishing regulations that would require manufacturers and importers of mercury-containing lamps to develop a program which would ensure that Canadians will be able to recycle mercury-containing lamps. The proposed regulations would target both mercury-containing lamps from the residential (CFLs) and commercial sectors. The proposed regulations would contain national recovery targets for recycling lamps and will ensure that the recycling is done in an environmentally sound manner. EC expects to publish the proposed regulations in the Canada Gazette, Part Ⅰ, by the end of 2011 and have the final regulations implemented by the end of 2012. EC has been actively consulting on the proposed regulations with manufacturers, retailers, recyclers, provinces, municipalities, other government departments and interested non-governmental organizations.

Regulatory and non-regulatory options considered

Since the completion dates are contained in the existing Regulations the only option is an amendment to the Regulations.

Benefits and costs

The benefits and costs of increasing the minimum energy performance standards for these products are evaluated in four parts:

• Benefits and costs to society. A quantitative analysis measuring the change in economic attractiveness to society was conducted for the products specified in the amendment.
• Energy/GHG analysis. A description of the analysis of aggregate energy savings and associated reductions in GHG emissions, resulting from the amendment.
• Benefits and cost to business. A qualitative discussion of the impact of the amendment on affected manufacturers and dealers.
• Benefits and cost to Government. A qualitative discussion of the impact of the amendment to Government.

General

The general service lighting regulation came into force with a 2012 implementation date in Amendment 10. (see footnote 2) This amendment only changes the implementation date for general service lighting to 2014. The benefits and costs analysis develops a scenario for a 2014 implementation and compares it with the original 2012 implementation. The difference is the net impact of this amendment.

Benefits and costs to society

The standard benefits and costs methodology used by the Office of Energy Efficiency compares a single product below the standard to a single product at the standard.

Product-specific assumptions are based on product-specific market analysis reports, testing reports, industry data, engineering studies, experience in other regulating jurisdictions, stakeholder consultation, and other data sources. The delay in the implementation date does not change the product-to-product assumptions and results. For these assumptions and analysis please refer to Amendment 10. (see footnote 3)

The only assumptions that change are the implementation dates, as follows:

• Effective date excluding 40 and 60 W lamp replacement: January 1, 2014
• Effective date for 40 and 60 W lamp replacement: December 31, 2014

Summary: Benefits and costs to society

The net benefits to society are a comparison of the benefits and costs from the 2014 implementation, using product shipment trends from 2014 to 2020, versus the previous analysis which was based on the 2012 to 2020 period. The estimated net present value of benefits for a 2014 implementation date from the general service lighting regulation for all Canadians would be approximately $753 million versus $1,057 million with a 2012 implementation date. (see footnote 4) This is a foregone savings of $303 million, due to the delay, over the service life of general service lighting products shipped by 2020 and is presented in Table Ⅰ.

Table Ⅰ: Benefits and costs (millions 2003 $ (see footnoter 5))

Results	Benefits and costs	2012	2015	2020	Total
Results for a 2012 implementation date	Benefits	84	181	130	1,408
	Costs	19	45	32	351
	Net benefits	65	135	98	1,057
Results for a 2014 implementation date	Benefits	-	181	130	1,002
	Costs	-	45	32	248
	Net benefits	-	135	98	753
Net impact due to delay (foregone savings)	Benefits	(84)	-	-	(406)
	Costs	(19)	-	-	(103)
	Net benefits	(65)	-	-	(303)

*Numbers may not add up because of rounding.

Energy/GHG analysis

Methodology and assumptions

The energy and GHG savings (foregone savings) associated with this amendment are estimated by comparing the scenarios analysed for the MEPS with the original 2012 implementation date (Amendment 10) with the MEPS with the new 2014 implementation date. Both scenarios are developed using a business-as-usual case (in the absence of a standard) versus the regulations case. Again, the impact of this amendment is the difference between the two scenarios. Both scenarios are positive although the delayed dates result in foregone energy and GHG savings by 2020.

The energy savings associated with general service lighting occur in both the residential sector and the commercial sector.

The reductions in GHG emissions were calculated by applying emissions factors consistent with those published by Environment Canada (see footnote 6) to the marginal fuels used to generate the electricity that would be saved through the amendment.

Expected results

The results are presented for the years 2012, 2015, 2020, 2025 and 2030. Due to the 2014 implementation date, the energy and GHG savings attributable to the standard for general service lighting are lower than those reported for Amendment 10. The net impact of this amendment is the difference between the expected energy and GHG savings from the scenarios for the 2012 implementation dates (Amendment 10) and the 2014 implementation dates. Thus, the expected results of this amendment, which represent foregone savings, are negative.

The estimated energy savings impact of the amendment is presented in Table Ⅰ. Consequently, the general service lighting will have a total foregone energy savings of 8.26 PJ annually in 2012 and 31.85 PJ in 2013, compared to the one in amendment 10. In 2014, when the Regulations with the new implementation dates come into effect, the more efficient equipment steadily replaces the pre-regulation stock and the two regulations eventually produce the same results, such that, in 2022, both implementation dates produce the same energy savings.

Table Ⅱ: Energy savings (petajoules)

Scenario	2012	2015	2020	2025	2030
2012 implementation date	8.26	43.43	48.69	52.03	55.52
2014 implementation date	0.00	32.89	48.63	52.03	55.52
Energy savings (foregone) net impact of this amendment	(-8.26)	(-10.54)	(-0.07)	0.00	0.00

*Numbers may not add up because of rounding.

Similarly, for GHG emissions reductions, there will be foregone savings. The estimated annual reductions in GHG emissions for the 2012 and 2014 start dates and the resulting foregone savings are presented in Table Ⅲ. The foregone savings of GHG emissions are estimated to be approximately 1.18 Mt annually in 2012. The difference between the 2012 and 2014 implementation dates increases to approximately 1.55 Mt annually in 2015, after which the annual difference decreases and almost reaches parity by 2020.

Table Ⅲ: Reduction in greenhouse gas emissions (megatonnes)

Scenario	2012	2015	2020	2025	2030
2012 implementation date	1.18	6.35	7.09	7.57	8.07
2014 implementation date	0.00	4.80	7.08	7.57	8.07
GHG savings (foregone) net impact of this amendment	(-1.18)	(-1.55)	(-0.01)	0.00	0.00

Benefits and cost to business

Costs and benefits to industry

Some utilities will be required to revise program initiatives already supporting the 2012 dates. For example, Manitoba Hydro discontinued its CFL incentive program in 2010 in anticipation of the 2012 efficiency standard for general service lamps.

Some manufacturers have made investments in research and development of new products, realigning their production plans and equipment, training employees, and testing new products in time for the 2012 completion date. This delay will strand and undermine co-ordinated investments. Canadian marketing plans that were developed to be used jointly with the U.S. standard implementation will now require changes and Canadian companies will incur additional costs.

A delay will provide some suppliers with the time needed to ramp up production and offer more alternatives to the consumers.

North American harmonization

The delay in the completion dates places Canada on an implementation schedule that is generally one and two years behind that of the U.S., as follows in Table Ⅳ: 100 W bulbs, which are affected on January 1, 2012, in the U.S., will be affected in Canada on January 1, 2014; 75 W bulbs, which are affected on January 1, 2013, in the United States, will be affected in Canada on January 1, 2014; and 60/40 W bulbs, which are affected January 1, 2014, in the United States will be affected in Canada on December 31, 2014.

Table Ⅳ: Implementation of minimum energy performance standards for light bulbs in the U.S. and Canada

Coming into force date	United States (currently)	Canada (original)	Canada (final)
January 1, 2012	100 W	100 W / 75 W
December 31, 2012		60 W / 40 W
January 1, 2013	75 W
January 1, 2014	60 W / 40 W		100 W / 75 W
December 31, 2014			60 W / 40 W

British Columbia has had standards in effect for 100/75 W bulbs since January 2011. The 60/40 W bulbs follow the existing federal schedule of December 31, 2012.

Minimizing administrative burden

To ensure a level playing field for compliance and enforcement, the Regulations have standard administrative provisions to reduce the risk of non-compliance: energy efficiency reporting prior to import or inter-provincial transport, and import reporting.

Benefits and cost to Government

Treasury Board approved the resources identified under CARA for the Energy Efficiency Standards and Labelling Program. Thirty-two million dollars over four years supported the development of this amendment amending the first of three amendments completed under CARA; two additional amendments contemplated under CARA that are near finalization; the compliance and maintenance of the existing Regulations; and labelling programs for equipment.

Analytical support is provided through the Department’s core human resources and is estimated at one full-time equivalent employee per year.

Rationale

The impact of this amendment on Canadian society is summarized in Table Ⅴ. The table presents aggregated annual totals for 2012 and 2020 and the average from 2012 to 2020. The net impacts are shown to be negative because this amendment represents the loss of two years of benefits in energy and GHG savings when compared to Amendment 10. This adjustment must be made to avoid double counting.

Section B represents the estimated energy savings and reductions in GHG emissions for all Canadians.

Table Ⅴ: Summary of benefits and costs to Canadians

Costs, benefits & distribution		Aggregated Annual Totals		Total Cumulative	Average Annual
		Base Year 2012	2020	by 2020
A. Quantified impacts in $ (millions in 2003 prices) (impact of delayed implementation)
Benefits	Canadians	(82.58)	0	(406.1)	(45.1)
Costs	Canadians	(18.52)	0	(103.1)	(11.5)
Net benefits				(303.0)	(33.67)
B. Quantified impacts in non-$ (impact of delayed implementation)
Foregone impacts on Canadians	Energy savings (petajoules)	-8.26	-0.07	-88	-9.79
	GHG emissions reductions (megatonnes)	-1.18	-0.01	-13	-1.43

*Numbers may not add up because of rounding.

Consultation

The Regulations were pre-published in the Canada Gazette, Part Ⅰ, on April 16, 2011, for a 75-day period ending June 30, 2011. Since the pre-publication occurred during the election period, a notice was not sent out until after the election; however, the pre-publication in the Canada Gazette was picked up by the news wire and stakeholders began seeking clarification immediately. A notice inviting comment was sent by email to over 1 900 industry stakeholders on May 11, 2011.

During the 75-day comment period, NRCan received comments from 33 stakeholders. Comments came from manufacturers and industry associations (6), utilities (3), other governments (4), non-governmental associations (12) and individuals (8).

Comments were received from organizations representing larger constituencies, including Electro-Federation Canada, the American Lighting Association and the Federation of Canadian Municipalities.

Result of pre-publication

General comments

Light bulb and fixture manufacturers have specifically asked that the Government recognize the urgency of making known its final decision since the original date of completion falls within less than a year of publication in the Canada Gazette, Part Ⅰ.

It is important to mention that Electro-Federation Canada, representing light bulb and fixture manufacturers, submitted two viewpoints as industry was split in their position on the proposed delay.

Against the delay

Of all the comments received, 58% are against delaying the effective dates for general service lighting by two years, stating that the justifications in the Regulatory Impact Analysis Statement are not valid, and that the loss of energy savings and cost to consumers and the environment outweigh the potential benefits of the proposed delay.

These stakeholders are of the view that options for alternative lighting products are available to Canadians and that the market is ready for a 2012 phase-out of inefficient incandescent lamps.

They observed that the performance standard does not mandate the use of CFLs, which renders the issue of safety regarding this product a non-issue.

For the delay

One quarter of respondents supported a delay, stating that the market is not ready for the 2012 effective date. It was stated that more options need to be made available to the consumer and that some alternatives to incandescent light bulbs are still too expensive and not all perform adequately.

Of those that support a delay, some proposed that Canada align its timeline with that of the U.S., stating that more than a one-year delay would have a negative impact on the phase-out.

No standard

Some individuals have expressed the view that a light bulb performance standard in Canada is not desirable, stating reasons such as health and safety concerns regarding some alternatives, and disputing the energy/GHG savings identified by the Regulatory Impact Analysis Statement.

Specific comments

Communication

Many stakeholders were of the view that communications with consumers were already underway or being prepared in anticipation of the 2012 dates. Utilities and other organizations, including the Retail Council of Canada, have been educating consumers to dispel myths and misconceptions about CFLs for some time now. Retailers and some manufacturers have already developed the necessary training material for the 2012 phase-out.

A few stakeholders had opposing viewpoints and agreed that more time is needed to better educate stakeholders on options available to them. It was suggested that a strong communication strategy be developed to better educate the consumer on the benefits of the Regulations.

Cost and benefits to stakeholders

Industry expressed concerns about costs already incurred by their organization in preparation for the 2012 deadline.

Utilities have concerns about changes to their energy efficiency programs that will be required due to this delay. BC Hydro has indicated that the delay will cause the province to be at risk of not meeting its energy conservation targets.

Stakeholders have noted that consumers will be paying higher energy costs using inefficient lighting.

Others favour full harmonization with the U.S. standard and timeline as the least costly option for industry and consumers. It is expected that the cost of the U.S. halogen bulb will be lower than the more advanced halogen infrared bulb that will meet Canada’s standard.

International efforts

Concerns were expressed about how Canada would be perceived by the international community should a delay in the effective date take place, based on Canada’s proposal not to follow through on its original commitments as part of an international effort.

Should Canada delay by two years the effective dates, the U.S. standard would be in force one to two years ahead of Canada, and there is the possibility of inefficient light bulbs that do not meet the U.S. standard being dumped on the Canadian market.

Three stakeholders favour harmonizing dates with the U.S., and two also recommend adopting the same performance standard methodology as the U.S.

British Columbia’s implementation of the standard

The Province of British Columbia implemented part of the performance standard for general service lamps on January 1, 2011, a full year before the federal government’s currently planned date. The Province and other stakeholders argue that this experience has provided the federal government with valuable information on the acceptance of the standard by consumers. It has raised awareness of the light bulb standard and alternatives to inefficient lighting, so the timing is right for national implementation. They also contend that media and public dissatisfaction with the standard has quickly subsided.

Health concerns

Stakeholders against the delay have stated that “health concerns” raised by consumers over the use of CFLs have been put to rest by HC and that CFLs do not pose any risk for Canadians. Some have noted that the proposed delay would increase health problems by postponing the elimination of GHG emissions and air pollution from coal-fired power plants in Canada.

One United Kingdom organization representing people affected by the use of low energy light urged the Canadian government not to ban existing incandescent lighting.

Mercury and recycling

An environmental organization stated that mercury released in the atmosphere from coal-fired power plants will have far greater reach than the small amounts of mercury used in CFLs that make their way to landfills and stay local. Most of today’s CFLs only contain 3 mg of mercury, compared to 10 mg used 10 years ago. EC has published its intentions to limit the content of mercury in lamps and to eliminate any remaining CFLs that may still be using larger quantities of mercury.

Another environmental organization stated that using incandescent lamps releases twice as much mercury in the atmosphere as the amount used in CFLs, even if they are not recycled.

There are several retailers and local governments that do recycle CFLs today and this will only improve through EC’s proposed framework for extended producer responsibility of CFL recycling.

Some have opposing views and believe that more time would allow for a more robust recycling structure to be in place in Canada prior to the Regulations taking effect.

Outcome

The Government has decided to proceed with the delay of the standard for the reasons originally cited. It feels that this is the best way of balancing the achievement of its GHG reduction objectives and assuage the concerns expressed by a significant percentage of the population since the standard was proposed.

Implementation, enforcement and service standards

Since the amendment constitutes a relaxation of the timetable in Amendment 10, no additional enforcement efforts need be considered. Implementation of the delay will be accomplished through effective communication activities before and after publication.

Strategic environmental assessment

In accordance with the Cabinet Directive on the Environmental Assessment of Policy, Plan and Program Proposals, a preliminary Strategic Environmental Assessment (SEA) was conducted for the Regulations. Elements of this amendment have undergone environmental analysis via a previous, detailed SEA in 2008 — An Act to Amend the Energy Efficiency Act. Moreover, the analysis of environmental impacts is ongoing and inherent to the program. Expected outcomes, including greenhouse gas reductions and associated environmental impacts, are detailed in the “Benefits and costs” section of this document.

The Energy Efficiency Regulations are referenced in the October 2010 Federal Sustainable Development Strategy as implementation strategy 2.1.11.

Performance measurement and evaluation

As noted, the Regulations would be amending the outcomes in the first of the amendments announced as part of the Energy Efficiency Standards and Labelling component of CARA. Therefore, it will be subject to the performance management strategy for CARA.

Detailed accounts of progress towards this objective will be found in departmental business plans, reports on plans and priorities, and the Report to Parliament under the Energy Efficiency Act.

Performance measurement and evaluation plans have been established for the Energy Efficiency Standards and Labelling program as a whole: key activities and outputs are identified, expectations quantified, ongoing data collection from program files maintained and appropriate targets defined. Feedback on the status of all activities is provided to the program on a continuous basis.

A formal evaluation of the Standards and Labelling program was completed by a third party for NRCan in July 2010 and covered general service lamp consumer labelling. NRCan is committed to evaluating the program by 2018 to include the general service lighting standard.

A performance measurement and evaluation plan (PMEP) as specified under the Cabinet Directive on the Streamlining of Regulations specific to this amendment has been developed and is made available upon request.

To implement and administer the change to Amendment 10 that is implemented by this amendment, the regulatory cost-benefit and environmental impact analyses were revised to reflect the two-year delay based on the standard inputs to regulations used in Amendment 10, as well as an assessment of stakeholder comments on the overall general service lighting standard and communications.

As this amendment stems from concerns expressed by Canadians regarding replacement light bulb options, NRCan will implement a specific communication strategy for Canadians to address these concerns.

The regulated entities are Canadian dealers of general service lighting products. Dealers are already submitting performance and import reports for these products due to existing labelling requirements. Dealers and Canadian importers — but moreso the key stakeholders, especially manufacturers (10) — who are submitting the energy efficiency reports must ensure that their product offerings for Canada will comply with the MEPS when the Regulations come into force.

It is expected that upon publication, dealers/manufacturers would revise their business plans to reflect their business needs before and after the new effective dates for the light bulb standard. Their awareness, understanding and technical capacity to comply with the MEPS were facilitated through the development of national standards and stakeholder consultations well before the introduction of MEPS. Once the Regulations come into force, NRCan facilitates the reporting of new requirements by providing all manufacturers/dealers with standardized energy efficiency report forms and works with the Canada Border Services Agency to clearly communicate to customs brokers and dealers any new electronic reporting requirements related to importing.

As an immediate outcome, it is anticipated that within a short period after the effective date dealers will comply with the MEPS by reporting to NRCan the energy performance of regulated light bulbs. With respect to an intermediate outcome, over time, it is anticipated that the implementation of the light bulb standard will begin to affect the efficiency of light bulbs that are in use in Canada, leading to a growth in products that meet new MEPS. As the annual energy and emissions savings estimated in the analysis of Amendment 10 will be deferred for two years as a result of the delay, the final outcome of this deferral would be the loss of those two years of savings and impact on annual energy savings and GHG emissions.

Contacts

John Cockburn
Director
Equipment Division
Office of Energy Efficiency
Natural Resources Canada
1 Observatory Crescent, 2nd Floor
Ottawa, Ontario
K1A 0E4
Telephone: 613-996-4359
Fax: 613-947-5286
Email: equipment@nrcan.gc.ca

For information on Benefits and costs to society and Energy/GHG analysis, please write to

Dominic Demers
Economist
Demand Policy and Analysis Division
Office of Energy Efficiency
Natural Resources Canada
580 Booth Street, 18th Floor
Ottawa, Ontario
K1A 0E4
Email: equipment@nrcan.gc.ca

Footnote a
S.C. 1992, c. 36

Footnote b
S.C. 2009, c. 8, s. 5

Footnote c
S.C. 1992, c. 36

Footnote 1
SOR/94-651

Footnote 2
www.gazette.gc.ca/rp-pr/p2/2008/2008-12-24/html/sor-dors323-eng.html

Footnote 3
www.gazette.gc.ca/rp-pr/p2/2008/2008-12-24/html/sor-dors323-eng.html

Footnote 4
Values are reported using 2003 as the base year to remain consistent with previously published values for general service lighting in Amendment 10. Re-basing would have introduced an additional set of numbers.

Footnote 5
Values are reported using 2003 as the base year to remain consistent with previously published values for general service lighting in Amendment 10. Re-basing would have introduced an additional set of numbers.

Footnote 6
www.ec.gc.ca/pdb/ghg/ghg_home_e.cfm or www.ec.gc.ca/pdb/ghg/ghg_home_f.cfm