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

Thursday, April 16, 2015

Why Continued Energy Saving Rules Make No Sense: Lighting as a Main Example

Updated 17-22 April, including comments to EU legislation and added conclusion at the end

Why is it wrong to have rules that limit how much energy any product can use?

>> Energy saving is not the only advantage a product can have
>> Enforcing lower energy use on any given product affects performance, usability and/or appearance as well as price, whether on buildings, cars or household products including lighting (http://ceolas.net/#cc21x)
>> Supposed savings are questionable at both overall life cycle and usage specific levels, and replacements may have their own environmental concerns.
>> Even if products needed targeting to save energy, there are better ways of doing it (consumer information, taxation+subsidy policies, marketing policies)
>> Future advantages of a banned product may be unknown

Before running through these points as related to lighting, some comments on the recent EU Halogen ban decision.

Halogens have similarities to regular incandescent bulbs and are the last commonly available examples of allowed incandescent technology for general service lighting.
The EU has just announced a ban also on such forms, similar to current American, Australian and other legislation. The halogen ban is part of the several ongoing EU review processes on lighting, of which more can be seen on the related Facebook group.

While this blog has covered why the original regulations made no sense, the irony is how in perspective of 2018 and beyond a ban not only on halogens but also a maintained ban on simpler incandescent bulbs makes even less sense than the ban in the first place.

This relates to hailed market transformation effects, and, as will be seen, CREE (USA) and other manufacturers seem to be coming round to the idea that bans are not urgently needed - albeit one might note that they happily supported a ban on cheap generic patent-expired and comparatively unprofitable incandescents in the first place.
So an interesting polemic has arisen between manufacturers and energy saving agencies/consultants (eg The Danish agency, CLASP consultancy, and the ECEEE councillors that argued for keeping 2016 versus Lighting Europe manufacturer consortium that argued for 2020)
I will likely further cover EU decision matters in a separate post, but some points should be mentioned here.

1. Whatever about temporarily allowing halogens to 2018, and perhaps beyond that in due course, it's odd to see a maintained ban on frosted (non-transparent halogen type) incandescents that meet required standards.
This was a legal add-on, unique to the EU in worldwide legislation. Original reason for this was that
"Consumers desiring such lamps could buy CFL (fluorescent bulb) alternatives"
However, given the LED switchover drive and that LEDs can be made transparent, such a ban seems unnecessary and unduly petty.
"LED clear incandescent look-alikes are several years ahead of price and performance projections" the European Council for an Energy Efficient Economy (ECEEE) emphatically state.
So on EU logic there should be no difference made between any transparent and frosted bulbs: ban all or allow all that meet currently required standards.

2. I note several stakeholder comments of the variety
"New LEDs are/will be better and cheaper for consumer satisfaction on the lighting market"
Also statements along the lines of
"Habitual consumers will be happy with new technology once they have got used to it".

But what - exactly - is then the point in terms of any meaningful society savings of say a 2018 continued ban on what few people are assumed to still want (but might particularly appreciate)?
A new product is desirable - why ban alternatives (little society saving)
A new product is not desirable - why ban alternatives (obvious enough)
More precisely, what the EU keeps missing - from their own stats - is that even pre 2009 ban, most households did and do have some "energy saving" light bulbs. They simply don't want all their light bulbs to be the same type, whether on light quality or usability or indeed their own logical cost-benefit analysis, where cheap ones make more sense for the many little used bulbs in their houses.

Ban proponents like ECEEE incongruously praise the "much lower prices and much better performance levels" of new LEDs and how great they are for consumers - and then the "massive multi-billion euro" saving from a ban.
But "massive future savings" assumes few would buy the supposedly "great" new LED lamps if they could still buy incandescent alternatives!
Conversely of course, no "big savings" if people voluntarily buy the supposedly "great" LEDs.

In this, they cite how badly CFLs fared....
Clear mains-voltage halogen lamps were allowed to remain on the market as a replacement for clear incandescent lamps and they were expected to constitute a relatively small share of total sales for non-directional lamps. New evidence has become available that has shown the market did not behave in this way, and instead halogen sales have quadrupled while CFL sales have declined.

So, as also from the official EU comment to the 2018 ban, the fact that consumers prefer halogens is seen as why they should be banned:
The consumer preference for halogens against CFLs is also assumed against LEDs, since otherwise there would not be the big savings as repeated in the EU comments to legislation. For good measure, they add that it's "the annual electricity consumption of Portugal" (it used to be "the annual consumption of Roumania" = progress?). As usual, an unsubstantiated media-friendly soundbite. Curiously, the CO2 emissions on equally unsubstantiated multi-year projections are supposedly equal to that "generated by around two million people per year" (new campaign: Stop breathing and save light bulbs?).
The questionable nature of energy/emission savings claims will be returned to below.

Plus ca change, plus c'est la meme chose
Ban proponents previously praised CFLs in exactly the same way that they now praise LEDs. How "great" for consumers they would be, how "great" to ban the incandescent alternatives.

one might take the line of Lighting Europe of waiting for the impact of better future LEDs and a smoother market transformation (their 2020 final ban suggestion).
Clearly LED sales are indeed increasing, but that leads to the opposite scenario:
What is the point of a ban if LEDs are indeed better, desirable, and bought, such that there are little or no society savings?
This also applies to already banned simple incandescents, and as will be seen CREE LED manufacturers are indeed suggesting the upholding a ban is no longer needed in the USA.

The duality was seen before.
VITO research figures ahead of 2009 suggested switchover already occuring from simple incandescents... so little savings from a ban, as highlighted by the Cambridge University Network, Scientific Alliance section:
The total reduction in EU energy use would be 0.54 x 0.8 x 0.76% = 0.33%,
This figure is almost certainly an overestimate,
particularly as the inefficiency of conventional bulbs generates heat
which supplements other forms of heating in winter.
Which begs the question: is it really worth it?
Politicians are forcing a change to a particular technology which is
fine for some applications but not universally liked, and which has
The problem is that legislators are unable to tackle the big issues of
energy use effectively, so go for the soft target of a high profile
domestic use of energy...
...This is gesture politics.

The notion of "little savings" not being appealing to the EU,
an alternative in-house agency report was duly commissioned suggesting that indeed there were many light bulbs to be switched, allowing for great consumer savings after all, since they would presumably not otherwise buy the great new light bulbs (being CFLs at the time).
[Note: The EU was criticised by their own scientific advisor (duly not re-hired!) for commissioning on-message studies for a desired outcome, laying on the gravy for research agencies who naturally want repeat business: EU twisting facts to fit political agenda, chief scientist says Also see the EU Light Bulb Ban Story]

Somewhere basic points are forgotten.
Light bulbs don't burn coal or give out CO2 gas: power plants do.
So the mandates on increasing "clean" production of energy correspondingly decreases lighting effects on the environment.

Notice also that EU analysis is always about projected savings.
The current EU "reviews" of different lighting regulations conspicuously avoids any research to see if any savings have actually accrued from preceding regulations.
As will be seen, there are several reasons to doubt the savings...

3. In overall Ecodesign terms

(i) That energy saving is not the only advantage a product can have

(ii) That, unfortunately, enforcing lower energy use on a given product changes its characteristics eg usability, performance, appearance, as well as price, as per linked product examples http://ceolas.net/#cc21x covering buildings, cars, as well as washing machines and other household products.
The same document also deals with the specific advantages of halogens and of simpler incandescents, and extends other arguments made here.

(iii) That "efficiency" is not "energy efficiency" but also about deliverance capability, such as the great difficulty to produce bright 100W+ omnidirectional lighting with fluorescent/LED bulb alternatives.
That "efficiency" can moreover relate to the few components incandescents need to produce such bright lighting.

(iv) That supposedly old outdated technology is also well known technology in health and environmental perspectives.
LED flicker, point source glare, blue light and other issues have all been highlighted in recent years - including by LED proponents like the authoritative US journal "LEDs Magazine", for example the lighting program manager at the US Department of Energy in the "12 lessons" article

Complex LED lighting is also environmentally resource demanding.
Recent French documentary on TV highlighted the multi-mineral content (as with pushed CFL or LED light substitutes) and consequent enormous resource loss of unrecycled "E-waste", EU sponsored recycling paybacks (as with VAT) leading to illegal dumping, or illicit deals with China etc that alternatively loses such mineral resources for the EU.

(v) That supposed energy savings do not hold up on life cycle factors, especially with complex multi-component substitutes, not just in the sole assembly energy use that the EU and Osram confine themselves to measuring, but taking account of every life cycle stage all the way from mining and component manufacture through assembly, delivery and final recycling - and the transport of all components in all stages, including that of bunker oil powered ship transports from (and back to) China - compared to easily locally manufactured patent-free simple incandescent bulbs for true sustainability and local jobs - the EU admitting to 5000 job losses in the final years alone relating to the incandescent 2009 ban. As seen from the referenced EU comment they now add thousands more "inevitable" job losses.

(vi) That in relation to incandescent technology, the fact of a Phoebus cartel between major manufacturers giving 1000 hour limited standard incandescent lifespan does not relate to a true potential incandescent lifespan of 20 000 - 25 000 hours as per incandescents principally made for the mining industry at low cost eg Aero-Tech bulbs around 1.50 euro per bulb.
Encouraging open free market competition brings out the best products, rather than banning generic patent expired unprofitable choices.

(vii) The further light bulb specific issues of a heat benefit payback for most industrialised countries as per referenced Finnish, German, UK and Canadian research.
Side by side bulb comparisons also do not take into account power factor (PF) issues of CFLs and LEDs affecting practical energy use, or actual usage situations, such as using several directional LEDs as replacements for omnidirectional incandescents, or indeed in touted money savings for consumers for rarely used bulbs in 30-40 lighting point households, or temporary usage.
Talk of "reducing consumer bills" carries little weight when electricity providers raise consumer charges to compensate for the shortfall and/or are compensated by the taxpayers via governments, as in the UK and several US states.
Unnecessary use is a waste, personal choice is not, for what after all is about electricity use - not about the use of lighting as such.

Turning therefore to electricity use,
"20% lighting use in society", "millions tons CO2 saved" has nothing to do with actual fractional percentage electricity grid savings (as referenced, EU and US Dept of Energy data) from banning defined and domestically dominated lighting:
and even of that, a main usage in off-peak evening and night hours of low electricity demand does not not tax power plant electricity production anyway, specifically with "culprit" coal as also referenced, where commercially a minimal night level is maintained for wear and tear cost reasons and reason of slow stoking up to daytime level, a minimal level therefore not lowered further and that more than covers whatever bulbs people are using, therefore in effect without society energy/emission saving at such times.

4. Even if targeting bulbs was still deemed necessary:
Why does the EU not consider taxation (EU set VAT directives on products), a more conventional way of lowering consumption, where even a relatively low taxation can act to cost cover subsidies for products judged more desirable, and thus equilibrate markets sufficiently to dampen "wrong" demand while still allowing choice for the most needy users.
Of course higher VAT also brings national governments - and the EU -a direct "own resource" income.
Bans give no such income.
Specific carbon taxes are an alternative.
Taxation is more flexible than blunt permanent bans at arbitrary cut-off points, and can cease when market transformation is deemed sufficient.

Alternatively, "Expensive to buy but cheap in the long run" advertising is used by battery and washing up liquid manufacturers - LED manufacturers can do likewise, rather than lobbying for bans on patent expired unprofitable simple bulbs.
Philips slumbering lighting division bounced up to record profits on LED sales before (ironically) suffering from Chinese competition.

The EU in their comments to the ban "helpfully" state for light bulb manufacturers:
Benefits for industry
This means significant extra revenue.
Moreover, these measures protect EU industry from competition from low-quality and inefficient imported products.
Better products for consumers arise from increasing rather than decreasing competition among manufacturers and bulb types.

Susanne Hammarström of Sweden was head of the main Brussels based PR agency Diplomat-PR engaged in the lobbying on behalf of the light bulb manufacturers. Translated from the largest Swedish business paper, Dagens Industri, she says:
The ban would never have happened, without the large and extensive lobby campaign, in all member countries, as well as towards The European Commission and the media

5. Products using energy above a given standard may have unknown future advantages.
Arbitrary legal cut-off points are set based on what alternatives are available. As with incandescent lighting, this effectively bans a given technology for defined purposes.
One often talks of basic and applied research at universities and other institutions. This is often used with regard to doing research for companies or out of a simple desire to make new discoveries without preconception. But if a product is already illegal there is little point in researching alternative use.
For example, bioluminescence (chemically produced light, as with glowworms) could hypothetically be an interesting new lighting development. But if it does not meet energy saving criteria in any required electrically assisted operation, it is illegal from the outset on legal luminaire qualifications for general purpose lighting.

There is a direct historical audio parallel to lighting development.
The invention of solid state transistors (technically similar to solid state lighting, like LEDs) meant that radio valves or vacuum tubes (technically similar to incandescent light bulbs) could in many instances be replaced. So if the ban-happy EU, American and other bureaucrats had been around in the early 1950's, no doubt they would have drooled at the prospect of getting rid of the "energy guzzling valves". Unforeseen was the popularity these would come to have in guitar amps in the rock and roll evolution. Some might have said "thank goodness" for a ban, but along with other specialized uses it shows that the bureaucrats are actually (surprise) not Gods, in their mania to decree "what consumers should want to use".

Another connection might be made with the new craze for vinyl records, in the sense that manufacturers ceasing to make "outdated" technology is not the same as politically banning it.
This means that if people want to make vinyl records, a vintage type car or other "old technology" products, they can. Politically banned products, they can't, even for their own use.

In Summary
Any energy saving directive should take into account
A. The effect of legislation
B. The concomitant value of any saving acquired.

Even within the Ecodesign doctrine, light bulb regulations are uniquely questionable.
A particularly simple technology that is particularly effective in purpose, namely to produce powerful bright light, is banned in favour of particularly complex technologies that with difficulty reach such bright levels.
Moreover, it is a technology with recognized output quality, producing omnidirectional broad spectrum light with a colour rendering index of 100%, and without the health and environmental recycling concerns raised by the pushed alternatives.

On an open market any lighting product would be more reflective of inherent usage advantages:
= Incandescents as bulbs,
= Fluorescents as long tubes,
= LEDs as sheets,
as also originally developed in each case.
Today sees the oddity of heavily promoted expensive complex LED clones striving to approximate what simple incandescents can do.
It's as if all giraffes were destroyed, with the proponents excitedly proclaiming
"But hey everybody, look at the elephants with longer necks that we are breeding!"

The savings relate to the actual amount of switched bulbs pertaining to a ban, product related life cycle and usage effects, and factors related to electricity production

Again, light bulb regulations are particularly questionable, in terms of comparative life cycle energy usavings when all stages are included, as well as in actual usage, and in grid electricity saving perspectives, as has been described.
René Kemna of the Dutch VHK research group has been leading the studies into the regulations, and stated at the last 5 February meeting:
"A 100% primary energy input at the power plant actually results in 1% useful light."
Fractions of 1% in improved energy efficiency at the delivery end would therefore seem to be of negligible consequence in an overall perspective, all the more so taken with all the other mentioned factors.

The time element is also relevant:
If a market switchover transformation has already occurred, little or no extra gain is achieved with a ban, and regressive purchase activity is presumably limited for the reasons given, including new LEDs being so "attractive for consumers".

Indeed, CREE LED manufacturer in the USA has publicly announced that
"Incandescent bulb legislation doesn't matter"
Extracts put together:
Even as consumers continue to evaluate and make lighting choices in favor of energy-efficient LED bulbs, many regulators are still concerned that the unenforced incandescent ban could set the country back in the execution of energy-efficient policies.
This would be true and problematic if the industry and consumers weren't already headed in the direction of energy efficiency. According to Cree's own consumer surveys, the ability to reduce in-home energy costs without compromising the lighting experience is the most important factor for consumers when they're choosing a light bulb. We've also found that most consumers are interested in LED bulbs because they last longer than traditional incandescent bulbs, and are environmentally friendly. Look at the consumer lighting market today and you'll see a wide range of energy-efficient options that didn't exist a few years ago. In the past two years alone, the quality of light from LEDs has risen sharply and the price has significantly dropped.
In the end, consumers are making educated, well thought-out choices in lighting, with or without legislation or its enforcement. The legislation and its enforcement are simply needless.

LEDs are better - why ban incandescents
LEDs are not better - why ban incandescents
More to the point, all lighting types have advantages in specific uses, including mercury containing fluorescent tubes that may soon be targeted, and should not be banned unless health and safety in usage demands it.
As said, stats also show households do buy different bulb types, but don't want all bulbs to be the same type whether on light quality or the little savings from rarely used bulbs.

Some consider the saving of energy for society to be a priority concern - and why not.
But as shown this is minimal in terms of targeting light bulbs, and even if it was not, alternative policies would be better anyway, based on:
>> consumer information including clearer labelling (as is being introduced), or
>> taxation and subsidies as described, or
>> free market competition where "desirable" bulbs can still be helped to market and imaginative advertising applied, as happens with other initially expensive but long term saving products.

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.