If energy needs to be saved, there are good ways to do it.
                                                               Government product regulation is not one of them

Wednesday, November 27, 2013

EU Commission Light Bulb Ban Review 5:
GWL: 12 Good Reasons to Keep Halogens

Update 27 November. Original post 26 November

For a preliminary report of the November 25 Consultation Forum meeting regarding the commencing review of EU light bulb regulations and involving the EU (European) Commission, national energy efficiency representatives and lighting "stakeholders", see the post published earlier.

Here is another alternative view of the light bulb ban, and of the current issue of allowing halogens or not:
Greenwashing Lamps, like Rik Gheysens in the last post, once again usefully complements what was said in the comments to the first Commission proposal post in the series, this time with a very visual perspective.

The Greenwashing Lamps blog post itself summarizes the proposal. Then it links to the pdf document as also reproduced below (alternative copy).

12 Good Reasons for keeping Tungsten Halogen

A text-only extract of the last sections of the above, themselves well illustrated in the original:

9. Lifespan

• CFLs may, under optimal cicumstances, last from 5 000 to 15 000 hours depending on model.
• LEDs are often claimed to last 20 000 hours or more. A clear advantage when long life is desired.
• Halogen lamp life is typically 2 000 hours for standard models. However, it is quite possible to make halogen lamps that last 10 000 hours. Such lamps already exist on the market.
• Standard incandescent bulbs typically last 1 000 hours, but can also easily be made to last up to 20 000 hours by simple improvements to sensitive parts. Such lamps already exist (in the U.S.).

10. Lower Environmental Impact

New research in January 2013 by scientists in California and South Korea found that:
“The CFLs and LEDs have higher resource depletion and toxicity potentials than the incandescent bulb due primarily to their high aluminum, copper, gold, lead, silver, and zinc.
Comparing the bulbs on an equivalent quantity basis with respect to the expected lifetimes of the bulbs, the CFLs and LEDs have 3–26 and 2–3 times higher potential impacts than the incandescent bulb, respectively.”

Halogen Eco lamp (simple to make and recycle)
• Quartz glass & soda-lime glass
• Tungsten (wire filament)
• Molybdenum, copper, iron or nickel (metal/wires)
• Bromine or iodine (halogen gas)

CFL-i (complex to make and recycle)
• Soda-lime glass
• PBT or PET (brominated polymer) plastic housing
• Nickel-plated brass base
• Aluminum, copper, nickel, tin and/or zinc base or wires
• Lead oxide, aluminium oxide
• Barium/aluminum oxide compounds, manganese (phosphor mix)
• Lanthanum, yttrium oxide or phosphate (rare earths)
• Mercury (vapour or amalgam)
• Lead (solder)
• Krypton-85 (gas)

LED lamp (complex to make and recycle)
Anode, cathode, semiconductor crystal, ballast, socket transformer, capacitor, controller, heat sink, LED module, bulb and base may contain:
• Soda-lime glass
• PMMA, PBT or PET (fire retarded/brominated plastic)
• Aluminium (heat sinks and housings)
• Nickel-plated brass (lamp bases)
• Bauxite (glass and adapters)
• Copper (adapters and wiring)
• Lead (glass and adapters)
• Nickel, zink (adapters)
• Tin (adapters; glass coatings)
• Lanthanum, yttrium oxide, manganese, barite (phosphor mix)
• Semiconductors (depending on colour): Arsenic, boron, gallium,
indium, phosphate rock, selenium, zinc

Low-lumen LEDs (= majority of LEDs available for the home market) use as much precious resources as high-lumen lamps but for very little light. LEDs are most effective when over 800 lumens and used for many hours per day. They are not suitable as low-lumen lamps as the light quality is too low.

11. Different Lighting Technologies

All lighting technologies have their advantages in different situations.
• Incandescent & halogen lamps, where light quality is most important, e.g. at home, in fashion stores, galleries, restaurants, hotels etc.
• CFLs, LEDs, fluorescent tubes, HID lamps where light quantity is of higher priority than quality, e.g in offices, corridors, garages, or as outdoor lighting; when lighting is turned on all day or all night.

Incandescent and luminescent light sources are not interchangable.
They have very different technical properties and light qualities. No matter how much luminescent (phosphor-based) light is improved, it can never be the same as fire-based light, anymore than brass can ever be gold, or rayon silk. It’s a different product; superficially similar and useful in other ways, but still not the same.

A CFL can often be replaced by an LED or metal halide HID lamp of the same colour temperature and socket. They are all phosphor-based and have similar CRI and light quality.

A frosted incandescent lamp cannot be replaced by a CFL or frosted LED without changing and lowering the light quality, or by or clear halogen without changing functionality.
A frosted incandescent lamp can only be replaced by a frosted halogen lamp for the same glare-free top quality light.

A clear halogen lamp cannot be replaced by a CFL or LED without lowering the light quality and changing functionality.
Clear halogen A-bulbs, R7 tubes, G4 and G9 mini bulbs have no replacements.

12. Health & Wellness

Light is an essential bio-nutrient, just like water, food and air.
Physiologically, light regulates hormones. Visually, it helps us see well when there is no daylight.
Psychologically, it is one of the most potent mood enhancers at the disposal of an interior designer, home maker or professional lighting designer.

A clear, top quality, naturally dimmable light that is not too cold or dull, is of essence in order to be able to see well and relax in our own homes at night.
Banning halogen lamps is like banning silk or cotton and forcing everyone (including those who are allergic to them) to use only synthetic fibre because the latter fabrics are considered more durable.
We all want to save the environment, but there are many other ways to easily save the little that could theoretically be gained by banning halogen lamps.

  [there are plenty of reference links to the below points in the pdf document, not coded in here]
All currently available lamps are needed, except CFLs and high pressure mercury lamps which can and should be replaced due to mercury risk, and ‘cool white’ (light blue) LEDs which may harm vision and disrupt sleep hormones.

• Standard halogen Eco bulbs must remain available for those:
- who need bright light of good quality in order to see well (= most people over 60)
- who prefer or need the highest light quality (= many women, artists, photographers etc)
- who have light-sensitive eye- or skin conditions (= c. 25% of the population?)
- for whom CFLs may be hazardous due to mercury spill risk (children & pregnant women)
- for whom LEDs may be hazardous due to blue light risk (= children & people with ARMD)

• As there are no top quality frosted replacements, frosted halogen A-bulbs should be permitted again for those who are sensitive to glare (= e.g. many seniors, migraine patients etc).

• And as there are no good quality replacements for the R7 tubes and, G4 or G9 halogen mini bulbs, these must remain available for those who have invested in costly halogen downlight, floodlight, spotlight, or dimming systems because they wanted the best light on the market.

So please let EU citizens be free to choose from an open market what type of light quality they want to use in their own homes.

Thank You!

How Regulations are Wrongly Justified
14 points, referenced:
Includes why the overall society savings aren't there, and even if they were, why alternative policies are better, including alternative policies that target light bulbs.

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