14 minute read
Ultra Processed Sunlight
By Scott Zimmerman
The 90% of the solar spectrum the DOE eliminated was never theirs to get rid of.
— Scott Zimmerman
Like processed food, ultra-processed sunlight removes critical components that negatively impact our quality of life. The DOE’s mandates in both LED lighting and low E glass windows have the effect of virtually eliminating all UV and near/shortwave infrared within our homes, offices, schools, and hospitals, thereby degrading the body’s immune, metabolic, and neurological health day in and day out for decades.
In all installations where the test subjects (astronauts, submariners, sailors on stealth vessels, and many night workers) are exposed exclusively to LED lighting (with and without circadian controls), mitochondrial damage or other negative biomarkers have been observed within 60 to 365 days. Both the DOE and FDA have failed to not only provide evidence that ultra-processed sunlight can be used safely, but also have via recent rule changes mandated an artificial environment that discriminates against children, pregnant women, the black population, and the elderly.
By not requiring comparisons to the complete solar spectrum, the DOE has put its thumb on the scale. Despite numerous warnings, the DOE has chosen to ignore increasing levels of metabolic diseases in the population along with growing evidence that ultra-processed sunlight is a causal factor in a wide range of modern societal maladies.
REMOVING ROADBLOCKS TO A HEALTHY ENVIRONMENT
Many groups have proposed that Congress eliminate DOE’s Office of Energy Efficiency and Renewable Energy (EERE) based on non-health related issues. We have proposed that DOE EERE programs like Solid State Lighting (SSL), while well intended, now stand in the way of the next generation technologies which will use the visible and non-visible portions of sunlight to enhance the body’s immune, hormonal, metabolic, reproductive, and neurological health.
HISTORY
At the February 28, 2019 public hearing for the 45 L/W rule change for General Service Lamps (GSL), the DOE was informed of negative health consequences associated with eliminating over 90% of the solar spectrum from our indoor lighting. The meeting transcript can be found here.
MR. GRANDA: Thank you. Chris Granda. Two things briefly, first in response to Mr. Zimmerman's concern, I don't think there's anything in any of the existing or future standards that would prohibit any specific technology from being used to meet that standard. So as a technology agnostic standard, the product that you described, as long as the package was within, you know, that 45 lumens per watt threshold, should be just fine. At least that's my reading of it.
Five years later, the DOE has now issued the 120 L/W rule change starting in 2028, despite multiple warnings and comments to the public record (Pickard, Moore-Ede, and others) regarding the biological risk to the public. Recently, the FDA also refused to address the problem based again on eye response only data claiming lack of jurisdiction.
On February 16, 2023, President Joseph R. Biden Jr. issued Executive Order 14091—Further Advancing Racial Equity and Support for Underserved Communities through the Federal Government. This Order was issued during the comment period for the Notice of Proposed Rulemaking.
This order requires that all rules consider their impact on underserved communities. To our knowledge, neither the DOE or FDA actions have complied with this Executive Order.
WHAT THE DOE 120 L/W RULE REALLY DOES
As the only General Service Lamp manufacturer in the US (to our knowledge), the 120 L/W rule change mathematically prohibits not only my company but all lighting companies from restoring the complete biological spectrum back into the billions of Edison screw sockets in the areas that have the greatest need. High melanin individuals not only require more exposure to UV for vitamin D but also require over three times the amount of near/shortwave infrared compared to low melanin individuals. By restoring the near/shortwave infrared in General Service Lamps, it is believed that some level of UV can then be safely restored to our indoor spaces.
In addition, LED lighting also poses a significant risk to a wide range of insects, animals, and plants. Best characterized as sunlight starvation and nightlight pollution, this is contributing to increases in metabolic diseases and behavioral changes within all lifeforms. By limiting all their studies to just the visible portion of sunlight (400nm to 700nm) and not comparing to the complete solar spectrum, the DOE and FDA misrepresented what occurs in nature.
DOE RULE CHANGE BANS SUNLIGHT
To provide perspective, even if the industry could design and build an emitter that mimicked sunlight’s spectrum (250nm to 3000nm) with 100% efficiency, it would limit the industry to approximately 95 L/W and would still be banned by the DOE.
DOE BANS A WALK IN THE FOREST
The body is designed to survive direct sunlight but thrive in the shade. Over the last million years, plants and even dirt preferentially absorbed visible photons and reflected near/shortwave infrared into the body as shown by Fosbury (previous page). This shifts the optimum energy distribution even further into the near infrared, further reducing the maximum theoretical L/W level possible to less than 45 L/W.
Any emitter with greater than 45 L/W got there by eliminating large portions of the solar spectrum the body was using. The fundamental flaw in the DOE’s energy savings mandates is that they ignore that the body, after millions of years, uses the entire solar spectrum to protect us from disease, make us happier, heal wounds faster, exercise more effectively, suppress cytokines in the womb, stimulate a wide range of sex hormones, make virtually all biological processes work more efficiently, etc.
Throughout our evolution direct sunlight and sunlight reflected off our surroundings represented the single largest energy input (up to 30 MJ/day) into our body. When we are in nature, over 90% of that energy our eyes cannot see.
COSTS THE DOE HAS IGNORED
The data supports that harm is being caused not just by LEDs but by other DOE energy savings initiatives. The failure of the DOE to include the health costs associated with the largest reduction in solar exposure in human history calls into question the DOE’s energy savings models.
DOE’s cost models also do not include the harm to our agriculture associated with LED light pollution to pollinators, animals, and plants. The DOE was made aware of these hidden costs and chose to ignore them. As discussed by Nichols, even a small percentage of the costs of metabolic diseases eclipses any energy savings projected by the DOE.
WHAT NOW?
To comply with the 120 L/W rule change, all the UV and near/ shortwave infrared, as well as both the violets and a large portion of the reds, must be eliminated from the environment. While the rule change does not mandate compliance for nonGSL yet, there are billions of Edison screw base sockets that could be used for the benefit of our underserved communities.
By taking advantage of the eye’s limited spectral range, the DOE has substituted for sunlight an artificial lighting environment that is almost the opposite of what we evolved in over millions of years. The combination of both DOE lighting and window glass mandates is creating modern day caves.
WHY DO WE CARE?
We now know that these other wavelength regions of the solar spectrum are critical to maintain healthy mitochondria. This change over time alters hormone levels, reduces ATP production rates, negatively impacts fertility, impedes cognitive learning, reduces dimorphic ratio, and hinders our innate immune response. Incandescent light generates copious amounts of near/shortwave infrared but lacks UV and blue unless filament lifetime is sacrificed.
LEDs provide exactly the opposite, generating visible only but no UV or near/shortwave infrared, which makes up most of the solar spectrum. Sunlight provides UV, visible, and near/ shortwave infrared. This is why we can live over 100 years exposed to gorgeous blue skies. Unlike blue emission from LEDs, CFLs, and OLEDs, the blue sky we enjoy is mostly near/ shortwave infrared when our surroundings are included in the measurement.
Under the 120 L/W rule change, it is mathematically impossible to mimic sunlight’s complete biological spectrum.
SUNLIGHT STARVATION
In all cases where there is extended exposure to visible only artificial light, mitochondrial damage is observed. The International Space Station (ISS), submariners, naval stealth sailors, and night shift workers are “canaries in the coal mine.” In these cases, sunlight has been substituted by artificial lighting for up to 100% of the test period.
NASA’s Cell paper shows mitochondria damage in an environment exclusively lit by LEDs. Damage done was reversed upon return to earth. Degrading the health and mental acuity of our astronauts and military personnel could represent a national security issue. On Earth, similar metabolic diseases have been observed after protracted exposure to LEDs.
NARROWBAND EMITTERS TARGET MITOCHONDRIA AT THE CELLULAR LEVEL
Nanolive’s phototoxicity living cell tests show that exposure to artificial narrow band emitters in the UV, violet, blue, and cyan impact cell viability by first slowing and eventually stopping mitochondrial motion, fusion, and fission. Conversely, longer wavelengths out into the near infrared have been shown to enhance mitochondrial dynamics, increasing ATP production efficiency.
This is further supported by thousands of peer reviewed papers showing the ability of near infrared to enhance ATP production efficiency, accelerate wound healing, suppress cytokines, accelerate T cell velocity, etc.
HOW THE DOE HAS CREATED PROBLEMS
It is reasonable to assert that circadian disruption and artificial light at night (ALAN) are self-inflicted wounds created by visibleonly LED lighting and displays. Campfires and incandescent light at night were the norm for over a century, providing copious amounts of near and shortwave infrared into the evening.
Now, that has all changed. We can live over 100 years under a blue sky because there is always a proportional excess of near/shortwave infrared that we don’t see. Yet just a few lux of narrowband blue from a cellphone at the wrong time can disrupt our sleep. Like rickets, long term exposure to less than the complete biological spectrum always creates a negative health impact.
While it is easy to blame the societal shift to an indoor lifestyle, our work suggests that restoring spectrum and enhanced dimming controls can have a significant restorative benefit on our health. Unlike a pill or a 20-minute red light therapy treatment, LED lighting, displays, and UV/NIR blocking glass are impacting us throughout the day and into the night.
DOE IS TURNING OUR CHILDREN INTO CORTISOL ADDICTS
The reality is that lighting, displays, and windows have become a substitute for sunlight for large portions of the population. This radical shift in spectrum favors stress hormones like adrenaline and cortisol. As shown by Mello, cortisol can take hours to return to baseline after a moderate cocaine hit. Visible only LEDs causes a similar cortisol response as reported by Figueiro and Rea, with 35% increase in cortisol levels after 1 hour of exposure at 800 lux in the morning.
Similar studies regarding reduced sex hormones under artificial lighting have been reported. The level of stress and sex hormones in children in our modern society is concerning and needs to be addressed.
DOE RULE DISCRIMINATES AGAINST THE BLACK POPULATION
The DOE mandate mathematically eliminates our ability to restore any significant amount of near infrared and UV back to our most underserved communities. As published in the October 2022 issue with Dr. Jean-Louis, the African American and black populations require significantly higher levels of solar exposure to generate the same level of stimulus compared to low melanin populations.
Building on the redox biology of Mittler, it is easy to see how all lifeforms have cytotoxic (too much sun) and cytostatic (too little sun) operational ranges. Given the added burden of limited access to nature in many black communities, it is reasonable to argue that DOE’s rule change adversely impacts the black community.
Like the oximeter fiasco during COVID, failure to consider all population groups can have devastating consequences. In all lifeforms, redox biology as discussed by Mittler directly impacts almost all cellular functions. Every portion of sunlight alters reactive oxygen species densities based on propagation in the body (up to inches).
TIPPING THE SCALE BACK TO PUBLIC HEALTH
Clearly, the DOE has shown a disregard for the health impacts of its energy saving initiatives despite multiple warnings and clear data supporting that harm is being done. In all cases where test subjects are exposed exclusively to LED lighting even with circadian controls, mitochondrial damage (60 days to a year) is observed.
The long-term impact (decades) is yet to be determined, but there is strong evidence that increasing metabolic, neurological, and physiological diseases in the general population are at least in part due to the DOE’s energy initiatives. As we have shown children, pregnant women, certain ethnic groups, and elderly are disproportionately harmed by DOE initiatives. Given the discriminatory impact of DOE’s “energy savings at-all-cost" approach, it is hard to see how the existing agencies can address this problem. There may be other departments who would be more focused on learning how to provide all individuals with lighting, displays, and buildings that support human health.
PERSONAL OPINION ON NEXT STEPS
In many ways the best course of action for the DOE would be to remove all L/W restrictions and get out of the lighting business. But, the damage has been done and some level of oversight is required.
It is proposed that the DOE reverse course and ban the sale of lighting with greater than 45 L/W, mandate minimum NIR/VIS ratios of greater than 3, and require enhanced dimming range with minimum flicker. Similarly, DOE mandates regarding low E glass should be revisited especially for hospitals, nursing homes, and schools. The 90% of the solar spectrum the DOE eliminated was never theirs to get rid of.
From a discovery and innovation perspective, the 120 L/W rule represents a major impediment to progress. While far from perfect, our GSL’s show that our industry has all the technology to create lighting that is supportive of the human body. Lighting can mimic the entire spectral range we experience under a shade tree but only if we are not constrained by the 120 L/W rule change.
It is reasonable to argue that the true energy savings is via using lighting to enhance the body’s internal energy production efficiency, pathogen protection, and neurological function. As shown by Jeffery, the very wavelengths the 120 L/W rule change eliminates enhance our most basic energy production in our cells and slow aging.
At some point maybe we will be able to make emitters that can safely save some more energy without causing harm. It is more likely we will be able to provide the customer with data that shows them a real benefit to not only changing their lighting and architectural features but also to turning those lights off. These alternate innovation pathways are being severely hampered by the DOE’s “energy savings at-all-cost” perspective.
The DOE has created a host of problems that now require innovation to fix. Only within the last few decades has our ability to measure biological processes and structures advanced to the point that we can get a glimpse of how sunlight impacts our health. These tools reveal how complex and finely tuned biological systems are to sunlight and our surroundings.
Putting roadblocks in the way of that progress is counterproductive. As an example, Buknahov’s work shows how infantile our understanding and limited our measurements are when it comes to biological systems. Cells have for millions of years built optical structures that are the envy of any optical engineer. Altering the environment we live in should only be done with a great deal of respect for how limited our understanding is.
