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

Showing posts with label Canada. Show all posts
Showing posts with label Canada. Show all posts

Wednesday, January 22, 2014

Canada Light Bulb Heat and CO2 Emissions


More on Canada light bulb heat issue:
As per the recent previous post Government's own research shows savings are negligible when room heating is welcome.
The point of course is not "to heat your room with light bulbs", simply the benefit when light is wanted and the heat is useful, as at most times when it is dark in Canada.

Several more Canadian and other country studies at http://ceolas.net/#li6x.
These also include the CO2 emission issue:
That "clean" bulb electricity lowering the need for "dirty" room heating source can save CO2 emissions rather than increase them, as usually supposed
(A further reason that CO2 or other emissions are not increased is that coal plants, the main emission source, effectively burn the same coal anyway at the evening-night times when incandescent bulbs are mostly used.
This is from operational factors, their minimum night cycle level, as they are slow and expensive to power down and up including wear and tear, compared to simply keep burning coal at reduced levels that still cover what bulbs people may or may not want to use.
No - there isn't any politician or energy savings agency that takes such practical factors into account, just another reason for the pointlessness behind banning bulbs, as per the end link below).


A recent January 16 article on Canadian Energy Issues website by Steve Aplin again points out the emission saving fallacy when a non-CO2 emitting electricity source replaces an emitting source of ordinary room heating.



Extracts:


Incandescent ban illuminates urgent need for public carbon education


If I can get heat from a low- or zero-carbon source, I am more than happy to choose it over stuff like gasoline or wood. And because I know something about the carbon content of each watt of heat from the different things that make heat, and because I live in Ontario, I would choose Ontario grid electricity over every other source that is available to me.

This is why I shake my head when governments buy into the pseudo-green groupthink that produced the ban on incandescent lightbulbs in Canada. Incandescent lightbulbs convert most of the electricity running through them into heat; only a small percentage—as little as five percent, according to this Popular Mechanics article—goes into producing light. My take on that is: who cares.

In Toronto, Ontario’s capital and Canada’s biggest city, artificial heat is used pretty much from September 15 to June 1. (A city bylaw requires landlords to provide artificial heat to rented homes so that their indoor temperature is maintained at at least 21 °C.) That means that from Sept. 15 to June 1—i.e., in 259 days out of the year—the heat produced by an indandescent lightbulb is actually useful in Toronto residences. Who cares if an incandescent lightbulb turns most of the electricity running through it into heat.

Now, what is the environmental upshot of that electric heat?
You can measure this very easily. Table 1 in the left-hand sidebar provides the hourly carbon content of Ontario electricity. [see the original article, which also provides the calculations to arrive at the data below] This is given in the bottom row of the Table, and is called the CO2 intensity per kilowatt-hour (CIPK) of grid electricity. At eight a.m. today (January 16 2014), Ontario’s CIPK of grid electricity was 54.3 grams. The CIPK varies from hour to hour, depending on the generators that feed the grid in each hour. With the current mix of generation sources, Ontario’s CIPK averaged over a year is around 82 grams....



Using the Ontario average annual CIPK of 82 grams, that 0.95 kWh of electrically generated heat comes with 77.9 grams of CO2.....
Using a natural gas-fired heater to provide the 0.95 kWh of heat, assuming perfect efficiency (which in the case of a combustible heat source is thermodynamically impossible), you would produce 167 grams of CO2



So here is a question for David Suzuki and all those applauding the ban on incandescent lights:
Is it better to put 77.9 grams or 167 grams of CO2 into the air?

It is pretty clear that for 259 days of the year in Toronto Ontario (and more than 259 days in points further north), the heat from an indandescent light is actually beneficial. And with Ontario grid electricity being as clean as it is today, that heat from the incandescent light is demonstrably and provably cleaner than that from the next-cleanest dedicated heat source.

The author is Vice President of Energy and Environment at the HDP Group Inc., an Ottawa-based management consultancy





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.

 
 

Monday, January 13, 2014

Canada Government Research on Light Bulb Heat Effect


Canada heat from bulbs official study
This fits in with other Canadian, Finnish etc research
See http://ceolas.net/#li6x

The reduction in the lighting energy use was almost offset by the increase in the space-heating energy use

The Canadian Centre for Housing Technology (CCHT) "Benchmarking Home Energy Savings from Energy-Efficient Lighting" research from 2008 and seemingly oddly ignored since by the Natural Resources Department behind the Canadian light bulb ban, as covered earlier, in their switchover savings assumptions.
[The National Research Council (NRC) and Natural Resources Government Ministry (NRCan) jointly operate the Canadian Centre for Housing Technology (CCHT]


Excerpt
With conventional lighting, between 89 to 96 per cent of lighting energy use is converted to heat and contributes to space heating as internal gains.
The few losses associated with lighting energy occurred mainly where lights were located close to windows....
The reduction in the lighting energy use was almost offset by the increase in the space-heating energy use

While cooling season (and any air conditioning cooling) as mentioned negate or work against savings at such times, the obvious point then is that incandescent use is voluntary and may be preferred for light quality reasons.
Of course in Canada and similar countries, when it's dark, it's often cold, even in spring and fall (autumn), whereby the heat benefit effect is greater overall anyway.

Finally,
notice that this study only takes the heat factor into account.
There are many more reasons that savings don't hold up - whether as energy savings for society, or money savings for consumers.
See the lighting section of http://ceolas.net for a full account, or the relevant summary points from here onwards, in "How Regulations are Wrongly Justified" on this blog, as also linked below from its start.



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.
 

More USA and Canada reaction against the Light Bulb Ban


South Carolina Congressman Rep. Jeff Duncan has launched a bill seeking to repeal the federal light bulb ban.
As seen on http;//ceolas.net/#bills (updated last year, possibly more since) several bills both federally and in around a dozen individual states have been launched in the past - possibly a few more since the last of those mentioned bills. It should be said that many seem speculative to please a local constituency base, but for all that of course a welcome marker of opinion.
To my knowledge only Texas have actually legalized them under Gov Perry, although Arizona and South Carolina have been close under likewise Republican Parliaments and Governorships (Governors Brewer and Haley). The practical value of state versus federal law is always in question, and depends on sympathetic local Attorney-Generals, as with Arizona gun laws, California (and Colorado) marijuana laws etc, and the willingness and capability of federal oversight.
South Carolina has, or had, independent small incandescent manufacturing, whether or not that played a part in this case.

Rep Jeff Duncan's bill can be seen here, on a Govtrack page

Excerpt, main points
House of Representatives US Congress
January 8, 2014
Mr. Duncan of South Carolina introduced the following bill
H. R. 3818
This Act may be cited as the "Thomas Edison BULB Act".
Lighting energy efficiency
Subtitle B of title III of the Energy Independence and Security Act of 2007 (Public Law 110–140) is repealed.



Also some further reaction in Canada...
which, as covered before, is adopting USA law for North American trade reasons.
Apart from the usual "people are stocking up" kind of articles also seen in the USA, some more petitions have been launched against the ban, for example on thepetitionsite.com and on change.org, also as seen Canadians signing here, on moveon.org.
As seen, they seem as much directed against fluorescents as in saving incandescents as such, and understandably has not had as much publicity and reaction as other efforts, notably Ontario Federal MP Cheryl Gallant's campaign as per previous post.



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.
 

Thursday, January 2, 2014

USA and Canada Light Bulb Ban:
Now and in the Future

Updates Jan 3

Given the entry into force January 1 of the US ban on most remaining incandescent light bulbs for general service use, a review of the law as it stands and future implications.
Note that the same will apply to Canada, adopting the same regulations as USA in a tighter timeframe: Official link, Canada regulations.


"Beyond 2014, while also allowing LEDs, the new rule for general household lighting of 45 lumens per Watt happens to be exactly that of fluorescent 'energy saving' bulbs..."



 Gary Locke





Edited and somewhat updated sections of the accompanying website,
http://ceolas.net/#li01inx "What is Banned and When"


Lumens old Watts new Watts Min Life min CRI Date Start
1490-2600 100 72 1,000 hrs 80 1/1/2012
1050-1489 75 531,000 hrs801/1/2013
750-104960 43 1,000 hrs 80 1/1/2014
310-749 40 29 1,000 hrs80 1/1/2014


CANADA: Same rules, 100 + 75W start 1 Jan 2014, 60 + 40W bulbs 31 Dec 2014.
January 1 2015 therefore sees Canada "in phase" with US regulations.

From the legislation, starting 2012 for General Service Incandescent Light Bulbs:
A phase-out based on the lumen (brightness) rating of the bulbs, rather than their wattage.
Standard bright 100 Watt equivalent household light bulbs can therefore be at most 72 Watts equivalent from January 2012, and so on with increasing stringency.
There are also lifespan and CRI (color rendering index) provisions. The coloring rendering index measures how accurately colors are shown.


Energy Independence and Security Act (EISA) of 2007/Title III/Subtitle B/Section 321
"The Secretary of Energy shall report to Congress on the time frame for commercialization of lighting to replace incandescent and halogen incandescent lamp technology"

2 tiers, based on 2012-2014 and 2014-2017, backstop rule extending to 2020.
A third tier is planned, provisionally set for 2020: "DOE [the Department of Energy] is also required under the EISA 2007 to initiate a rulemaking in 2020 to determine whether the standards in effect for general service incandescent lamps should be increased" as per the DOE fact sheet linked below. The understanding since then is that this will likely be brought forward.
Aim: to reduce the allowed wattage for incandescent bulbs by 28 percent starting in 2012, becoming a 67 percent reduction by 2020 at the latest, in accordance with the defined annual review procedures.
Should the review procedures not have produced a minimum efficacy standard of 45 lumens per watt by January 1, 2017, that sees a backstop final rule come into force:
Effective January 1, 2020, the Secretary shall prohibit the sale of such general service lamps that do not by then meet a minimum efficacy standard of 45 lumens per watt.

`(i) The term 'general service incandescent lamp' means a standard incandescent or halogen type lamp that—
`(I) is intended for general service applications;
`(II) has a medium screw base;
`(III) has a lumen range of not less than 310 lumens and not more than 2,600 lumens; and
`(IV) is capable of being operated at a voltage range at least partially within 110 and 130 volts.

Prohibited act... for any manufacturer, distributor, retailer, or private labeler to distribute in commerce an adapter that—
`(A) is designed to allow an incandescent lamp that does not have a medium screw base to be installed into a fixture or lampholder with a medium screw base socket; and
`(B) is capable of being operated at a voltage range at least partially within 110 and 130 volts.'
[In short, to stop people from getting what they want, manufacturers and sellers are not allowed to provide adapters that allow other incandescent lamps to use medium screw base 110-130 volt sockets]


List of exceptions: Appliance lamps, Black light lamps, Bug lamps, Colored lamps, Infrared lamps, Left-hand thread lamps, Marine lamps, Marine’s signal service lamps, Mine service lamps, Plant light lamps, Reflector lamps, Rough service lamps, Shatter-resistant lamps (including shatter-proof and shatter-protected), Sign service lamps, Silver bowl lamps, Showcase lamps, 3-way incandescent lamps, Traffic signal lamps, Vibration service lamps, G shape lamps with a diameter of 5” or more, T shape lamps that use no more than 40W or are longer than 10”, and all B, BA, CA, F, G16-1/2, G-25, G-30, M-14, or S lamps of 40W or less.

Sales will be monitored to avoid substitution effects - see below.
These will also be reduced on mentioned planned tier 3 regulation by 2020.


Lighting section 321 of Energy Independence and Security Act of 2007 (pdf)
Application: DOE appliance standards homepage, details (pdf), details with list of exceptions.
Industry info page: This also includes more information on the law for "modified spectrum" lamp types (less energy efficient ordinary bulbs that have tinting to make the light more white in color).
For extensive information 2012-2014 including reflector lamps etc, with illustrations:
0sram-Sylvania document (pdf)

Greenwashing Lamps good post about the US ban
Also the past posts on the specifications here, with a 2012-2014 update here.




Points regarding the Legislation

General
The manufacture and import - but not the sale itself - of general service incandescent lighting is progressively restricted, beginning with ordinary 100 W bulbs.
So the sale of existing stock of the targeted bulbs will still be allowed.
Bulbs equivalent to 25W and below, of 150-200W, and of higher wattages, are also not affected, subject to sales monitoring as with specialist bulbs.


Packaging
Additionally, the January 1 2012 packaging requirement changed the way light bulbs are referred to.
Instead of buying a "72 watt light bulb," one might purchase a "1500 lumens" light bulb.
See the blog post on packaging and labeling in the USA and the EU.


Halogen Replacements
The Halogen etc incandescent general service mains voltage replacements, which the initial ban was geared to allow via the typical "72 Watt" replacements for 100 W bulbs (etc) found in stores,
will therefore also be banned sometime after 2014. They are typically 20-25 lumen per Watt, way below 45 lumen per Watt equating to fluorescent bulbs. LEDs also pass the standard.
If the review process beginning in 2014 does not ban Halogen replacements by 2017, the backstop final rule that kicks in will ensure a ban by 2020.

Of course, legislation can be overturned.
But any legal change has to pass both Houses of Congress and get the President's signature. Hardly anytime soon.
Rather, the Obama administration with Senate Democrat cooperation has sought to tighten rather than relax energy efficiency regulations, including on lighting.

Besides, Halogens are themselves still different and more complex than ordinary simple incandescents, and much more expensive for marginal savings, so not popular either with politicians (no halogen switchover programs!) or with consumers in a free choice.
Halogen or other incandescent development has moreover been ruled out by major manufacturers, as per meeting with the EU (European) Commission November 25 last.


CRI
About the color rendering index (CRI):
This, more precisely is "the ability of a light source to reproduce the colors of various objects faithfully in comparison with an ideal or natural light source".
According to the legislation, CFL, LED, or incandescent light sources "used to satisfy lighting applications traditionally served by general service incandescent lamps" must as seen have a minimum CRI rating of 80.
Incandescents, in performing as "black body radiators" typically have a perfect or near perfect 100 rating (unlike CFLs or LEDs), so the lesser 80 requirement, if followed by manufacturers, degrades current performance. In other words, yet another issue when it comes to targeting this technology.
Light sources with a high CRI are also desirable in color-critical applications such as photography and cinematography, and even when fluorescent lamps or LEDs have high CRI ratings, their spiky emission spectra do not correlate well with color rendering quality in practice, so that the photography and movie-making issues remain.



Ban Anomaly
It's a funny world and a funny US Congress.
Notice the anomaly that 75 W "dim" bulbs are allowed, but a 75 W "bright" bulb is effectively banned!
In other words, as the official sources confirm, incandescent bulbs are being banned on the basis of their "lumen" brightness - not on their energy use, bright bulbs being banned first.
So you can still, for a while, buy a 100W incandescent bulb if it's dim enough, which might, at least at first, seem an attractive alternative even to regular incandescents, since dimmer incandescent bulbs of given wattages tend to have have longer lifespans (the trade off).
That's just the start of it....there are specific legal workarounds to that effect, higher energy use but longer life for a bulb of given brightness.



Ban Workarounds
CFLs and LEDs have brightness issues, especially omnidirectionally to light up rooms - and they get dimmer with age.
That may mean using more of them to light up a room, negating savings, along with all the other reasons that savings don't hold up in practice, as covered via the left hand links here, especially the summary page link as also found at the bottom of this post.
But the focus here is on the incandescent bulbs themselves, and how they might continue to be used.


Rough Service
One is the "rough service" bulb route, for example Newcandescent incandescent manufacturer (who conspicuously don't state bulb brightness!) eg 100W 130V 10,000 hrs $2.88 bulb, or Aero-Tech , 100W 120V 20 000hr bulb, 1000 lumen, for $2 [both manufacturers with minimum order conditions]
That makes the Aero-Tech bulb brightness somewhere between 1000 hour standard incandescent 60W bulbs (900 lumen) and 75W bulbs (1200 lumen), regular 110-120V 100W bulbs being around 1700 lumen.
While such "rough service" classed sturdier bulbs are allowed subject to sales monitoring as a workaround to get incandescents, and it's welcome that manufacturers are supplying them to meet such consumer demand, the bulbs would therefore otherwise be more of a convenience measure for difficult to reach locations - rather than to save energy or money for required brightness.

Raised Voltage
As also with the Newcandescent bulb, many other currently legal bulbs eg "long life halogen" type replacements are marketed on a longer lifespan basis, this time from raising the voltage usually to 130V - but again, on a "dimmer bulb" 1000 lumen or so for 100W rating.
[As an aside, European and other 220V bulbs are noticeably dimmer than American ones, 100W only c.1300 lumen but rated 1000 hrs lifespan versus 750 hrs on US standard requirement]

AC to DC
A third way also marketed as a workaround is via solutions like Powerdisc.com:
Quote: "By converting the electricity power used by the bulb from AC to DC, the Envirolite PowerDisc significantly reduces energy consumption up to 42% and also extends the bulb life up to 100 times therefore reducing bulb replacement costs." The website quotes around 30% lumen reduction along the lines of 130 Volt lamps, but that this brightness will be better maintained through the bulb life.
It is also more flexibly applicable to any incandescent bulb, just by putting a small disc on the bottom of it. While it does not stop the bulbs being banned, it therefore again extends their life. Good American inventive, and combative. spirit!




 Christena Dowsett

Texas Hold 'Em
While some states like California and Nevada and the Canadian British Columbia province have sought to precede federal regulations, others have sought to stop them.
Most notably, Gov Perry signed into law incandescents as being legal in Texas June 2011 (Texas Allows Regular Incandescent Bulbs). The practical implications are less clear, supposedly that is only for local manufacture and sale, and it comes under similar federal-defying local laws like Arizona gun law or California /Colorado marijuana laws.
Still, Gov Perry got help from Republican colleagues Joe Barton and Michael Burgess in Congress, House Energy Committee, in attempts at thwarting federal regulations, including achieving the specific albeit temporary block of funding for federal oversight of regulations in Texas and elsewhere.
South Carolina Gov Nikki Haley may sign similar bill albeit stuck at end of senate stage there, having local small independent manufacturing, apparently awaiting federal and Texas repeal efforts - in fact around a dozen state repeal bills have been launched, most though likely speculative for a local constituency base without hope of success (similar MP campaign effort seen in Canada, as in a recent post here).



Uncle Sam Strikes Back: Sales Monitoring
Joining hands with Uncle Maple Leaf...

Exemption reversal condition: The Act includes a provision whereby, in cooperation with NEMA, sales of certain exempted lamps will be monitored, specifically:
• rough service
• vibration service
• 2601-3300 lumen general service (150-200W)
• 3-way
• shatter-resistant lamps

For each of these lamp types, if sales double above the increase modeled for a given year — signaling that consumers are shifting from standard incandescents to these incandescents and thereby supposedly not saving energy — the lamp type will lose the exemption.

Consequence: A requirement that any such popular lamp type can then only be sold "in a package containing 1 lamp", and with a maximum 40 watt rating in most cases (95-watt for 2601-3300 lumen ie 150-200W lamps, variably reduced for 3-way lamps).

In other words, if sales go up, further restrictions arise, and only 1 lamp packages may be sold:
Buy several packages, or walk out the shop and back in again to buy another one.

Note that tier 3 regulations by 2020 is planned to cut down on allowed exemptions anyway.



EU too
Too much to go into here, the EU is not behind in elaborate checks and monitoring.
See previous posts under the EU tag. It includes Commission proposals to ban fittings for special bulbs which are modified to take regular bulbs, and the German Energy Commissioner seeking to extend the 50 German store inspectors he apparently got to inspect "rough service" sales in ordinary stores in that country, to EU-wide inspections.
An earlier Irish Government proposal has sought to fine the distribution of illegal (imported) incandescent bulbs by individual citizens eg to neighbors with a 5000 euro first offence fine, and a 50 000 euro fine alternatively 6 months prison for repeat offence. Such would of course be on top of any customs etc fines for illegal imports generally.


Pssst...want to buy a light bulb...


 cei.org


The crass idiocy of a bureaucrat ruled world:
Do whatever it takes, to stop people from buying what they want, who in turn obviously do what they can, to satisfy their desires.
Above all, do not make any rational decisions, to actually deal with energy or emission issues, as per other posts here and the ceolas.net site.



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.
 

Monday, December 30, 2013

Canada Light Bulb Ban:
A Summary of How it is Wrong

Update, additions Jan 1 2014






There are particular reasons to have focused on the Canada light bulb ban in the past several posts.
Firstly, because unlike USA or EU there is some sort of chance of avoiding or at least overturning it later, given a simpler lawmaking procedure in a smaller jurisdiction.
Secondly, because it is particularly odd to ban them in such a country.


Strange to ban a popular safe product:

It's not like banning lead paint, and some of the suggested replacements are arguably less safe to use.
CFLs have known light quality and safety issues, while expensive and subsidised LED clones for many rarely used bulbs in a 36 bulb Canada household hardly saves money and is hardly progress, LEDs use up many rare earth minerals and with several health and environmental issues themselves (eg ANSES France, UC Davis California investigations).



Incandescents have many specific advantages for Canadians:

Canadians live in relatively large homes where much time is spent with varied lighting conditions, and where incandescent light quality, reaction time, brightness, sensor/dimming and other versatility is welcome, along with bulb heat on most dark nights.
Incandescent advantages for Canadians are covered at length in section 3 of the analysis as listed below.
Also see "Why ban in Canada particularly wrong" (http://ceolas.net/#li11x)



Major manufacturers Philips, Osram and GE have oddly welcomed being told what they can or can't make:

They have lobbied in different countries including Canada for a ban on patent expired simple generic cheap and relatively unprofitable products - and the proposal makes repeated mention of justifying a ban on their behalf.
The invitation to sympathy for not having competition banned can be compared with real sympathy if what they were preparing to make had been banned!
There is nothing wrong in manufacturer lobbying for profits on behalf of shareholders - it is arguably wrong of them not to. However, that does not require Government acquiescence on behalf of the public.
Besides, the manufacturers could of course just stop making the bulbs themselves in the name of the "progress" that they like to talk about in all their PR handouts regurgitated by politicians and media. After all, the very same manufacturers stopped making much else in the name of "progress". This had a natural market flow, in that the public could see the advantages of the new products, with little demand for the old ones, although always with niche uses (vinyl records, audio tubes, etc).
Therefore the irony and the idiocy that apples here:
If incandescents were not so popular, there would be no "need" for Government to ban them.



Local Canadian industry and jobs:

Adoption of US law as planned for more products and services carries implications of Canadian industry satisfying any specific local demand.
Not least in terms of ordinary incandescent light bulbs. The loss of jobs in USA and Europe was admitted by policy makers (EU over 5000 in final stage, adding to the thousands in ban anticipation). Complex CFL/LED manufacture is largely outsourced to China.
Local outfits with small overheads could easily make the simple generic patent-free products without licensing obligations, giving local Canadian jobs and local sustainability from using few components with little transport and no recycling needed, and no competition from the USA and little from elsewhere.
Compare with being blown over by Chinese imports and major American distributors who - in addition - have already known about their own American standard for 7 years and implemented it for 2, while, if anything, smaller Canadian counterparts have been preparing for the wrong original MEPS 2008 Canadian standard.



The ban is justified as lowering electricity consumption:

As it is a proposed ban for electricity consumption reasons, not because of unsafe bulbs, logically one would first look at the overall question of electricity consumption, looking at if and when a lowering is needed, and in turn the effects of various measures in relation to the penalty caused in terms of product choice or otherwise.
Renewables wind wave hydro and nuclear (Canadian uranium) hardly have Canadian shortage issues albeit that new plants or extensions could be avoided - hardly an issue with light bulbs for reasons soon explained.
The main issue is usually fossil fuel, especially coal, and its greater emissions (not just CO2) than other sources.

Light bulbs don't burn coal or release CO2 gas.
Power plants might - and might not.
If there's a problem - deal with the problem.
In Canada, hardly a problem, given Canada 86% emission-free electricity, and of course coal itself can be treated in various ways.

The usual "10% of domestic electricity is used for lighting" type statements,
ignore that around half of domestic lighting is not incandescent anyway, especially the mainly used kitchen lighting, also that replacements use electricity, also the heat replacement of incandescents and power factor (PF) issues of CFLs and LEDs (effectively energy use not recorded by the meters), also that domestic electricity is a small part of overall grid demand (industrial, commercial, municipal, transport - with hardly any incandescent use in any of those sectors).
On a general level, also the life cycle energy use of more complex replacement lighting, including transport in all stages from mineral mining to recycling (when not dumped, leeching mercury etc) and bunker oil powered shipping from China by major manufacturers, compared to easier local Canada manufacture by small/new manufacturers of patent-free simple incandescent bulbs.
Incandescent electricity use is just fractional amounts of mostly off-peak evening-night surplus electricity, as per usage and grid data references, effectively smaller still given the bulb heat supplied as per Ontario/BC institutional studies, and with the Canadian Center for Housing Technology also confirming that 83% to 100% of lighting energy contributes to heat demand reduction.

The total reduction [in 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 disadvantages.
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."
Using comparable European Commission VITO data to similarly cut down even greater "15% of domestic electricity use" type statements, this came from the Cambridge University Scientific Alliance, UK Government advisers from several institutions normally supportive of energy and emission measures, similarly with other referenced science institution communications from different countries.



Alternative policies:

Again, as it is a proposed ban for electricity consumption reasons, not because of unsafe bulbs,
then electricity consumption reduction policies should be looked at in an overall sense.
That means, if required, say coal tax or emission tax or regulations, or a general electricity tax with payback subsidies for house insulation etc - ideally conceived within an overall electricity distribution policy that increases supplier competition and ease of switching between those suppliers, itself made more easy with eventual smart metering systems. Smart meter systems will also shift people from peak time use to other times of electricity surplus availability, by time-basd pricing.
Compare with the pedantic bureaucratic exercise of telling Canadian folks what light bulbs they can or can't use in their bedrooms, and repeating the process for a plethora of other products.

Of course, if light bulbs really needed policy targeting, it could be done by information, taxation, or market stimulation measures, as also described, rather than clumsy once-off standards that permanently bans also any future invention that might have been made with its own specific advantages.



The "Hey don't worry everybody" message:

Instead, Canadians worried about future choice may soon hear the on-song message from Government spokespeople:
"Hey, don't worry everybody, similar Halogen incandescent light bulbs will still be allowed!".
Except that they won't.
Adoption of USA law is the main stated justification for the proposal, defended as standard harmonisation to facilitate future trade on the North American market, and planned for more products and services.
This of itself should worry those concerned about specific Canadian service for Canadians.
It also means abiding by future decisions in Washington.
As it happens, USA EISA 2007 law tier 2 2014-2017 regulation on light bulbs will ban all incandescents for general service, including Halogens, based on the 45 lumen per Watt final rule requirement that equates to fluorescent bulb standard.
Presumably the Ottawa Government know this:
"it is anticipated that the proposed standards would help to increase the level of acceptability for MEPS [minimum energy perfomance standards] for many Canadians, thus facilitating the adoption of further MEPS for these and other products in the future."
A little more upfront honesty would perhaps not go amiss...

One might in passing note that the Halogen type replacements anyway have some light qualitative differences, also being more complex and expensive with marginal savings and therefore less popular in a free choice either with consumers or politicians (no Halogen switchover programs!).



For details of why the regulations are wrong for Canada, see the introductory post
"Canada to adopt more US Laws beginning with Light Bulbs:
Losing Industry, Jobs and Choice, with Hardly any Savings
"

Full version   As Doc    As PDF

Content List

1. Why Alignment to USA will also ban Halogens
The supposedly allowed Halogens banned on USA EISA tier 2 2014-2017 backstop final rule equating to CFL standard. Following Washington means following any other change they make. Proposal already envisages further restrictions.
2. What is good for Canadian Industry, Jobs and Consumers?
Light bulbs stated as the first of more US laws in manufacture and service to harmonise NAFTA standards. Allowing US based corporate access does not mean having to legislate against local production to local desire.
3. How Incandescents have particular Advantages for Canadians
Beyond heat, also brightness, and situational advantages in large homes where much time spent
4. Simple Incandescent Advantages versus Halogens
Halogens more complex and expensive for little savings advantage, hence unpopular in free choice either with consumers or politicians.
5. On Energy saving for the Nation
Fractional overall and on comparative policies, and a main off-peak time use avails of surplus production capacity anyway.
6. On Emission saving for the Planet
Ditto, with the addition that Canada has 86% emission-free electricity and that emissions may increase on heat replacement effect
7. On Money saving for the People
Ditto, with the addition that free choice is not always about money saving, that many bulbs are not often used, and that subsidies plus utility compensation may mean higher bulb and electricity payments anyway via tax or electricity bills.
8. Worldwide Policy and Major Manufacturers
Cooperation to enforce low lifespan on incandescent bulbs followed by cooperation to altogether ban such now patent-expired generic cheap competition. Plus ça change, plus c'est la même chose.
9. Alternative Policies targeting Light Bulbs
Information, taxation/subsidy and market competitive alternatives could and should be considered before bans.
10. Incandescents - the Real Green Bulbs?
Efficient, earth saving, long lasting and sustainable.
The simplest way to produce bright light from electricity banned for being too popular, by the stupidity that passes for global governance.




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.
 

Monday, December 23, 2013

Canadian MP Cheryl Gallant's Campaign to Stop the Canada Light Bulb Ban


On the theme of the Canada ban covered in the last series of posts,
Canadian MP Cheryl Gallant (website, facebook page) has a campaign going against it.
Interestingly, she is a member of the Government Conservative Party launching the ban.
But rather than her being an odd one out, what is odder is surely that her Conservative Party which otherwise proudly proclaims a "free market" and "free choice" agenda, should back such a state totalitarian measure.
And, yes, it is a "ban", setting standards that don't allow them obviously "bans" them, and supposedly allowed "similar" incandescent (halogen type) alternatives will be banned too on adopting US law, EISA tier 2 2014-2017 final rule requirement of 45 lumens per Watt equating to fluorescent bulbs.

For more details of the Canada Government ban proposal, and a 10 section analysis of it, see the first post of the series.
As mentioned, direct appeal to Government itself is possible, they invite comments via their stated comment line (+1) 613-996-4359 or email equipment@nrcan.gc.ca
While formally finished 19th December that does not mean not being able to still "send a message".

The same applies of course to MP Cheryl's campaign.
Albeit launched just recently, there does not seem to have been any news or updates since then. But it's still ongoing, and an MP of the same party as the Government would presumably have "the ear" of those in charge more than an effort by other people, also in any future attempt at reversing a decision, and signing the petition and supporting the campaign in other ways also gives such a backing of course.






Campaign site: stopthelightbulbban.ca
Petition signing.


Campaign site message:

Safe and Affordable
The incandescent light bulb is safe and affordable.
Starting next January, 75- and 100-watt incandescent light bulbs will become black market items, and by the end of 2014 the same will happen to 40- and 60-watt versions.
Co-sign Cheryl Gallant’s letter to the Ministers of Natural Resources, Health and Environment, and tell the Government to stop the light bulb ban.
Most Canadians do not know light bulbs will be banned. Tell your friends and family at once. Encourage everyone you know to co-sign Cheryl’s letter before it is too late!

Unsafe Disposal
Unlike incandescent lights, which can be disposed of safely in the regular garbage, CFLs contain mercury, which can have significant impacts on both human health and the environment if not disposed of properly. Consequently, these lights are generally not accepted in the regular garbage stream and need to be disposed of using a hazardous waste program.
Proper Disposal 24% Tossed In Regular Garbage 55%



Letter circulated around 14th December

Dear friends,

The countdown is on. Starting January 1, 2014 our federal government will commence the phasing out of incandescent light bulbs. The overwhelming response to the constituency survey on whether or not a further delay in the ban is needed was that the ban should not go ahead at all.

The ban arose from the Kyoto Protocol as part of the United Nations Framework Convention on Climate Change (UNFCCC), an international treaty that sets binding obligations on industrialized countries to reduce emissions of greenhouse gases. Although Canada did not ratify the agreement, the ban on incandescent light bulbs stayed on our books.

The main alternative to incandescent light bulbs is the compact fluorescent lamp (CFL). CFL bulbs cost roughly 8 times more than incandescent light bulbs. They contain levels of mercury much higher than that of incandescent light bulbs, and are potentially harmful to humans, animals, and our environment.

Mercury is a neurotoxin, and must be specially disposed of, as it can contaminate water supplies and soil if dumped into landfills. According to Environment Canada the mercury contained in a typical thermometer can contaminate five Olympic-size swimming pools to toxic levels. Less than 10 per cent of CFLs are recycled amongst the tens of millions that are sold each year in Canada.

In a recent stroke of irony Canada signed the UN’s Global Mercury Agreement, which imposes a legally binding pledge to cut atmospheric emissions and environmental releases of mercury, in an international effort to reduce global mercury pollution and protect the environment and human health.

We have 17 days to stop the ban. Will you help me?

Sincerely,

Cheryl




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.
 

Wednesday, December 18, 2013

Incandescents: The Real Green Bulbs
Also in Canada


As the Canadian comment process finishes, as an American incandescent ban largely finishes on January 1, and as the EU review process also seems to have concluded in its first phase, some concluding remarks to the last series of posts seems apt.

The ban, not just on light bulbs but on much else in society, is largely driven by 2 aspects, supposed savings and product progress. Both have been well covered, but product progress deserves extra mention in an overall conclusion.

Product progress?
Product progress arises from increased, not decreased, market competition.
Energy saving progress in particular has been continuous throughout history.
Fluorescents and LEDs? On the market, without bans.
Solid state transistors replacing incandescent tubes? On the market, without bans.

Light bulb manufacturers could themselves simply stop making the "terrible incandescents".
That's what the very same companies normally do in the name of progress, they already stopped making cassettes, video cartridges, 8-track systems and much else.
Certainly they got - and get - lots of taxpayer subsidy goodies to make alternative bulbs while still slapping their own patents on them for yet more profit, and certainly politicians feel obliged to further help out their subsidised buddies sell more bulbs (as the Canadian proposal says, in so many words, in justifying bans because of committed investments).

The supposed problem is therefore that idiot citizens choose not to replace all their existing bulbs with the pushed alternatives, disregarding that most citizens - as the ban brigade keep saying - indeed have bought some for the advantages that they of course also have.

Of course, politicians don't want to declare their voting citizens to be idiots in what they choose to buy. Not openly, anyway. So the roundabout talk is that
"Regulations force faster development of better new products":
"Better" always being energy saving in usage with disregard to all else, including overall savings.
Obviously by necessity this brings new alternatives, but it is development that aims to fill the gap of popular incandescents - look at all the LED incandescent bulb clones. Hardly true or exciting progress.
As said, intrinsic advantages are of incandescents as bulbs, fluorescents as tubes, and LEDs as sheets, and was the original development of the latter 2 products, before all the push to compromise them as bulbs (yes, still with advantages of their own technology, but hardly developed as such now in bulb format, eg the flexible color temperatures of RGB LEDs rather than White LED bulbs).

A further issue is that regulation cut off standards don't just ban what exists. It bans all that could have existed, and never will, despite possible advantages beyond consumption of energy in usage. This, as with all else, is the case not just with light bulbs in the worldwide totalitarian definition of progress.


Everyone can have different legitimate views of the necessity of targeting products to save energy.
But what is then surprising is the complete lack of analysis of alternative policies.
Politicans? Media? Total silence.

Alternative information, taxation, market policies as thoroughly covered in the last post.
As the most fervent political, media and lobby grouped ban supporters tend to have a green or left-wing persuasion, the avoidance of all consideration of taxation is particularly puzzling. Even a mid-size 35 million country like Canada has well over 100 million in relevant sales, while in pre-ban USA and EU it runs into 2 billion sales in each case, of a cheap easily taxable product with high turnover, that could help all the " public spend" measures these people want.
In the USA, the California government is bankrupt - yet, like Canadian British Columbia, they ban every product in sight, instead of taxing it, and could of course announce it as subsidising cheaper alternatives re any "we hate tax" issue.
The point is not that tax is good. The point is that it is arguably better than bans for those who favor bans, while the market stimulation alternative is still better on the argumentation given, if light bulb targeting is (dubiously) deemed necessary.



So, to turn it all around.
Green is a color with many hues!

The case for looking at incandescents as the true environmentally friendly bulbs has been made earlier here.

That can be expanded on, and also put into a Canadian context, given the last series of posts here. The following is based on section 10 of the reply to the Canadian proposal for January 1 regulations on light bulbs, but as seen, it is generally applicable everywhere...









M'Lords and Ladies, the case for the humble simple incandescent light bulb:


Efficient?
Certainly efficient, in making bright light using few components


Earth Saving?
Certainly sparing the earth much mining for minerals


Long Lasting?
Certainly they can last long, at least to 20,000 hours at low price, as shown by mentioned small manufacturers, when major manufacturers don't control the markets.


Sustainable?
Certainly sustainable, in being easily locally made generic patent-free bulbs,
without much transport of parts or product, and without needing recycling.


Incandescents don't burn coal and they don't give out CO2 or other emissions.
Power plants might - and might not.
If there is a Problem - deal with the Problem.

Electrical products are only indirectly coupled to any energy source use, and in turn, the main evening-night time use of incandescent bulbs really only consume small amounts of off-peak surplus capacity electricity anyway, as seen.

Power plant emissions are decreasing on present policies, both from alternative source use and in directly being reduced and treated in various ways. Small overall off-peak bulb use and coal power plant night cycle operational factors reduces if not eliminates supposed bulb ban emission savings, and in a country like Canada of 86% emission-free electricity a ban even increases emissions on the heat replacement effect.



Incandescent light bulbs:
A pointless very visual feel-good target for an agenda driven ban seeking to ensure that the world loses the simplest cheapest product it ever had to produce light from electricity,
an aesthetically pleasing versatile invention, whose doom would arise not from being unpopular, but from being popular, through the stupidity that passes for global governance.




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.
 

Tuesday, December 17, 2013

Why Ban the Bulbs?
Alternative Information, Taxation and Market Policies to Product Prohibition


Worldwide,
the game is on for ever more restrictive usage standards of allowable products in society, be that the energy use of buildings or cars, the water use of toilets or showers, or the electricity use of a host of other products.
Already questionable in terms of actual savings and in the compromised performance and usability of what is left for people to buy, the policy is even more questionable on electrical products.
This is not only because there is a whole range of energy alternatives to counter any shortage, but also because electrical product use is not coupled to energy use. Banning certain cars or toilets may at least theoretically reduce their oil and water consumption. Electrical products are not coupled to say coal use, coal and power plant policies can be directly implemented, and the necessary saving of long-lasting/renewables carries its own question mark - in particular as we look at incandescent bulb bans, since they largely use off-peak evening -night surplus capacity electricity and thereby could never save on the building or extension of any power plants even on accepted saving assumptions.


Fundamentally,
if a politician has something in his or her head that can be likened to a brain, he/she could of course first consider alternatives to banning what people want to buy (no "need" for a ban if they don't want to buy it).
Unfortunately, in today's world, first politicians find it necessary to continually subsidise corporate "green" products, and if this is "not enough", then the competition has to be banned too, with new standards that "happen" to allow the patented goodies of corporate buddies to pass through the needle's eye, with the backing of well-meaning but naive green people, all crying together in ecstasy over saving the planet and echoed by a pathetic media that regurgitates everything thrown at it. Yes folks, it's called progress.


But there is another way.
Actually, several ways, that at least should be considered and arguably implemented to see if effects are judged as sufficient, before arriving at the nuclear option of a ban.

To make clear: I don't consider the product targeting is necessary in the first place.
But the point here is that even going along with the supposed saving effect and justification of targeting products, jumping to bans is still wrong.
Information, building on past efforts, and taxation, with or without parallell subsidy policy, are two alternatives.
However, market competitive stimulation as finally considered is in my view best in any product targeting.



While the following is all applicable to the USA, the EU and anywhere else,
it is also part of a reply to the Canadian Natural Resources Government Ministry, Office of Energy Efficiency, concerning the Canada Gazette Vol. 147, No. 40 — October 5, 2013 published proposal on Light Bulb Regulations to be effective as from Jan 1 2014,
and the invitation to comment by December 19th.

See the introductory post in the series, also covering policy aspects of the Canada Government proposal to switch to USA standards (sections 1 and 2 below).
A main claim is that Halogens "similar to traditional bulbs" will still be allowed, but they will be banned under US law as referenced, and the Government proposal itself speaks of further standard restrictions being facilitated.
Also, Canadian media has missed that the light bulb rules are said to be just a beginning of a switch to USA laws, with implications not just for Canadian sovereignty, but also of local Canadian manufacture and service to specific Canadian needs.

A second post highlighted the particular advantages to Canadian citizens of incandescent bulbs, being a lot more than just incandescent heat, as reflected in time spent at home, home size, number of bulbs and the varied lighting conditions where incandescents are a more desirable choice (section 3 below).


This time, therefore, the highlighting that the knee-jerk banning of products as requested by greens and corporates in odd unison is not the only relevant policy to assure lower energy consumption (section 9 below).
Information, taxation/subsidy and market policies are ignored as alternatives. Why?

1. Why Alignment to USA will also ban Halogens
2. What is good for Canadian Industry, Jobs and Consumers?
3. How Incandescents have particular Advantages for Canadians
4. Simple Incandescent Advantages versus Halogens
5. On Energy saving for the Nation
6. On Emission saving for the Planet
7. On Money saving for the People
8. Worldwide Policy and Major Manufacturers
9. Alternative Policies targeting Light Bulbs
10.Incandescents - the Real Green Bulbs?


Full version:  As Doc    As PDF


As with all section extracts, the below may refer to other parts of the full document.
Certain revisions and update improvements have been added compared to the document version (until that in turn is updated).
This also expands on relevant parts of the 14 point "How Regulations are Wrongly Justified" general international summary.




9.  Alternative Policies targeting Light Bulbs    


Worldwide, remarkably little consideration is given to alternative policies, not just - as already seen - with respect to saving energy, but also with respect of saving energy when targeting light bulbs themselves.
Much the same goes for all other energy efficiency regulation.
Obviously the last section on lobbying and undue influence might - and should - raise questions as to why that may be so.

There are (at least) 3 alternative policy divisions.
In a sense "there is something for everyone", as it includes both traditional left-wing and right-wing policies.
Again, this makes the avoiding of any such policies all the more puzzling.

The consideration here will therefore be on information, taxation/subsidy and market stimulation policies.




Information Policies  


In the world of odd justification of banning light bulbs, we may as well throw in another one.
US and EU politicians keep talking about uninformed consumers making the "wrong choices".
The right choice is of course always what the politicians want.
Be that as it may, the idea of clear labelling of what people buy presumably helps.
So in the USA and EU, first the bulbs are banned on the basis of poor choices by uninformed consumers, then clearer labelling in terms of bulb brightness comparison and energy use is introduced.
Cart before the horse. Brilliant.

The converse of this is of course that politicians - and not without justification - can say that at least they have had a lot of energy saving and switchover campaigns to encourage switching bulbs (they are even called "energy saving" rather than fluorescent or LED bulbs, for heaven's sake) and store displays tend to do likewise.
On top of that, Canada delayed two years with a specific consumer information rationale and to ally fears about fluorescent bulbs.

One might say that if well-informed people still make the wrong choices, they are either incredibly stupid, or, dare one say it, the ban pushing politicians are.

We are back to the reasons why people choose bulbs, which is not just to save energy, but also not just because incandescents are cheap.
The main point - as highlighted in official and institutional studies (OEE, BC Hydro) is that the penetration of energy saving bulbs is actually pretty good, as in the USA and EU the overwhelming majority have at least one and usually more of them.
The purchase pattern simply suggests that they do not want all their bulbs to be the same kind.
To repeat, the campaigns to "switch all your bulbs and save money" is like saying "Eat only bananas and save money".

There is of course also the simple logic applying that any success in achieving switchover, that for example BC Hydro keeps mentioning albeit via subsidised replacements, or out of "energy saving" bulbs getting "ever cheaper and better", also means less and less savings from imposing a ban - which therefore in turn does not just hit "reluctant technology-fiend backwoodsmen" but also any "progressive" household who sees room and environment conditions where incandescent use is still advantageous (particularly rarely used lamps that don't warrant any unsubsidised costly LED clones either).

Again
New lighting is bought - why ban old lighting, no point
New lighting is not bought - why ban old lighting, no point


It remains strange that particularly in Canada, where a ban was delayed on informational grounds, a ban is deemed necessary for what is said to have been successfully informed consumers about their choices (even if taken as being information about "post-ban" choices, it is still consumer information about the alternatives to simple incandescents).
Assuming a nevertheless continued desire to target bulbs, we have the tax/subsidy and market stimulation alternatives.

In comparison with a regulatory ban, taxation (and/or subsidies) have several advantages apart from keeping choice.




Taxation-Subsidies  


Why are simple incandescent light bulbs being banned?
They are not being banned for being unsafe to use, like lead paint.
No, the reason for banning bulbs is simply to reduce the consumption of energy.

After all, as regulation proponents keep saying,
"We are not banning the bulbs, we are setting energy usage limitations on them!".
Similarly with the plethora of energy usage limitations on buildings (climatically sealed), cars (performance issues, and possible safety issues, in limiting heavier types), white goods, TV sets, computers and much else, and resulting in choice limitation on varied usability/performance characteristics as per references.

Taking a "liberal" left-wing stance, how do governments usually reduce consumption?
Of safe products like luxury goods, or even unsafe ones, like tobacco and alcohol?
That's right - taxation.

Note the Government income from taxation to appropriately reduce energy consumption anywhere along the usage chain, say on coal, electricity from coal, any electricity, or on individual products without replacement worries, compared to a pedantic multitude of carefully crafted legislation on what consumers can or can't buy and use - and without any direct government income from it.

Taxation is of course also of popularity concern to politicians, particularly in the USA.
But this can be countered with how the money is spent - at least among poorer voters - such that for example electricity price rises may be countered by home insulation schemes.
Moreover, taxing say coal (or CO2 emissions) makes renewables and other sources more attractive, and with proper grid competition the switching of suppliers is easier.
As for product taxation, taxation can help subsidise the lower price of alternatives.
A quadruple whammy, in reducing consumption, equilibrating the market, keeping choice and maybe leaving some government income for other uses.
So much for "the market has failed - we must ban these products".


That's not all:
Because in facing the inevitable grumble about the "higher price" for a targeted product, politicians can therefore counter that they are lowering the price on other products, or similarly on lowering the price of alternative electricity provision, where subsidising renewables may be helped out of coal tax receipts.

It gets even better, in the sense that with say light bulbs, there'd be knowledge that a ban would have been the alternative - and the government can of course remind people of that too.

For a government so inclined it gets still better with the simple incandescent light bulbs, compared to other products.
They are cheap and can proportionate to price absorb a fair bit of tax, and they have a relatively fast turnover as commonly produced in short (1000 hr) lifespans.
I could not locate Canada relevant annual light bulb sales, but a rough estimate based on 13 million households and average 36 lighting points and somewhat less than half relevantly incandescent and comparable pre-ban Scandinavian turnover rate would be well over 100 million annual incandescent sales.
Whatever, a neat little earner, even if taxing obviously reduces sales (conversely a very pro-ban government can of course equate with a ban by a large tax, but then the ban route becomes more logical except for determined buyers of the bulbs).
Bans as said give no government income (at least not directly - strictly, supposed household money savings from a ban can be used for other taxable consumption, but the money savings argumentation is itself dubious for reasons given, and savings are of course more indirect anyway, also in assuming people will relevantly spend the money in equal or greater taxable ways).

That is not all.
It is much easier to implement and to alter taxation, and easier to flexibly apply it to new products that change the market situation, than clumsy one-set-standard regulations that need to have complex bureaucratic worked-out replacements - as seen from current elaborately defined regulations.
It is also easier to remove taxation when deemed no longer to be needed (eg when sufficient low emission energy is available), without having to restart the abandoned manufacture of products, as with regulation.


Still, I am against taxation as the best alternative choice, as it assumes there is a reason to target the bulbs, and affects local industry and jobs advantages and much else for much the same reasons as bans.

There is a still better alternative...




Stimulation of Free Market Competition  


If light bulbs need to be targeted in the first place (doubtful, for all other reasons given), then market stimulation, or more exactly market competitive stimulation, is in my view the best option also to lower energy consumption all the way along the energy usage chain:

Firstly, because producers of electricity, just like manufacturers, are then more keen to keep down their own energy usage and cost.
Secondly, because manufacturers are also pushed to deliver energy and cost saving products that the public actually want (and have always wanted, and do buy, even when costing more, and can imaginately be marketed for their savings in usage - rather than to lobby regulators for easier profits through bans on cheap competition).

"Expensive to buy but cheap in the long run"?
Clothes, battery, or washing up liquid manufacturers don't look for bans on cheap alternatives.
They properly and imaginatively advertise their wares.

New inventions, new products, energy saving or with other advantages - can always be helped to the market, though not continually supported.
Contrary to common political propaganda, innovation does not necessitate banning what has gone before.
On the contrary, product innovation - whether with buildings, cars, washing machines or light bulbs - is proven as desirable, in direct comparison and direct competition on the market place.
A progress seen throughout history, also of new energy saving alternatives, like the invention of fluorescent and LED lighting - without regulations being present.

The proposal specifically states a reason for delaying the ban was "for further advances in lighting technology to develop".
Presumably waiting longer allows still further development, and still less reason to ban alternatives.

The retort may be that "banning forces speedier development of new products":
Obviously by necessity it brings new alternatives, but it is development that aims to fill the gap of popular incandescents - look at all the LED incandescent bulb clones.
Hardly true or exciting progress, now is it, hand on your hearts, Canadian politicians?
As said, intrinsic advantages are of incandescents as bulbs, fluorescents as tubes, and LEDs as sheets, and was the original development of the latter 2 products, before all the push to compromise them as bulbs (yes, still with advantages of their own technology, but hardly developed as such now in bulb format, eg the flexible color temperatures of RGB LEDs rather than White LED bulbs).


A further issue is that regulation cut off standards don't just ban what exists. It bans all that could have existed, and never will, despite possible advantages beyond consumption of energy in usage.
For example in new bio-luminescence research, if assisted power consumption went beyond a certain level it would never be allowed, given new technology-neutral energy consumption standards.
Of course incandescent technology development itself is doomed for lack of research funding commitment on what would likely anyway be banned.

The point is not that energy saving is not good. Of course it is.
But product bans that are arguably overall and comparatively pointless in saving energy become a form of totalitarian policy to favour some whisper-in-the-ear multinational corporations to force people to buy products they presumably would not otherwise buy (or the bans would not be "necessary"), products which might indeed improve in internal competition of restricted choice but hardly as much as on an open free market against a multitude of products and manufacturers, and without the quality-for-price pressure that the continued existence of cheap alternatives would give.

Canadians like people elsewhere spend much of their lives under artificial lighting.
There is hardly any regulation that has such an effect on so many for so much of the time.


How many politicians should it take to change a light bulb?
None.

How many citizens should be allowed to choose?
Everyone.



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.
 

Thursday, December 12, 2013

Canada and Nordic Countries:
Incandescent Light Bulb Usage Advantages


... it's about a lot more than the heat of incandescent bulbs!

Update info: Campaign against the ban by Ontario MP Cheryl Gallant:
stop the ban page (with petition), facebook page

See the last post.
It focuses on policy aspects of the Canada Government proposal to switch to USA standards.
A main claim is that Halogens "similar to traditional bulbs" will still be allowed, but they will be banned under US law as referenced, and the Government proposal itself speaks of further standard restrictions being facilitated.
While section 3 will remain there, having already linked to it in correspondence etc, it and some other sections have a general informative aspect so may be further highlighted separately.

To recap:
This is part of a reply to the Canadian Natural Resources Government Ministry, Office of Energy Efficiency, concerning the Canada Gazette Vol. 147, No. 40 — October 5, 2013 published proposal on Light Bulb Regulations to be effective as from Jan 1 2014,
and the invitation to comment by December 19th.


Below is seen section 3 of the following:

1. Why Alignment to USA will also ban Halogens
2. What is good for Canadian Industry, Jobs and Consumers?
3. How Incandescents have particular Advantages for Canadians
4. Simple Incandescent Advantages versus Halogens
5. On Energy saving for the Nation
6. On Emission saving for the Planet
7. On Money saving for the People
8. Worldwide Policy and Major Manufacturers
9. Alternative Policies targeting Light Bulbs
10.Incandescents - the Real Green Bulbs?


Full version:  As Doc    As PDF



3. How Incandescents have particular advantages for Canadians

First, a summary of general advantages of Incandescents, then particular advantages to Canadians.


General incandescent advantages

A high quality 100% CRI (color rendering index) light with a warm characteristic: Incandescent lights have a smooth broad light spectrum, which in ordinary light bulbs rises more towards the red end, giving the characteristic warm glow, increased on dimming (fluorescent and LED lights give out different types of light...LEDs also in car headlamps, bicycle lights, flashlights/torches, sees an often bluey omnidirectionally weaker but point source glare type of lighting taking over in society).

The light bulbs have for many a pleasing simple appearance, and the transparency sparkle effect makes their use in some lamps, lanterns, and chandeliers attractive.
They are versatile with dimmers and sensors, advantageous where vibration or rough use is expected, and in very hot or cold conditions when they are also quick to come on. Moreover, the heat of the light bulbs (of itself often useful) finds direct applications in space heating applications, greenhouses, hatcheries, pet keeping etc.
Converse arguments note the situational disadvantages in particular of CFLs, for example in recessed and enclosed fixtures or humid (bathroom) situations



The brightness issue


Small and standard size incandescent lights are particularly useful, since CFL or LED equivalents usually can't be made as bright, and when they can they are even more expensive than usual.

The early ban on small/standard 100 Watt bulbs is therefore particularly ironic, added to by any future absence of halogens.
Such bulbs have especially good and cheap brightness as well as heat benefit, with 100W bulbs being at the same low price as other bulbs (and yes, that is also a reason they "must" be banned quickly based on what people might otherwise want to buy, such that big "savings" can be announced instead).

Fluorescent and LED lights, often dim to start with, also dim more with age, shortening lab quoted lifespans.
Fluorescent encapsulation (with pear shaped outer envelope, recommended for close use) further reduces brightness, similarly the phosphorescent covering of LEDs to spread the point-source lighting reduces brightness in any direction.
Cheap Chinese imports, directly or for assembly and rebranding, also mean that brightness retention, lifespan and other issues remain with these lights.
Any older reader might like (or not like) to note that not only do older eyes need brighter light, but ageing also means yellowing eye lenses so that they absorb the greater blue light component of fluorescents and LEDs, making them appear still dimmer.
Je vous souhaite la retraite agréable.



Safety issues

Normally products are banned for being unsafe to use.
The irony here is that old and thereby well known bulbs in their safety are forcibly, albeit gradually, replaced by CFL and LED bulbs with several health, safety, and environmental concerns.
There is little point in going through the concerns here which can easily be found in online discussion and documentation -
especially regarding fluorescent lighting mercury and radiation concerns, which after all also influenced the 2 year regulatory delay in Canada. Those issues have of course not simply gone away, including accidental breakage of CFLs and their recycling as alternative to being dumped (and with some calls for LED recycling too, see below).
A point of irony is the light bulb heat issue.
Irony, because politicians and journalists and indeed the info sheets from the OEE (Canada Gov office of energy efficiency) love to say how incandescents "waste 90-95% of their energy as heat", never a word that CFLs also waste 70-80% and current LEDs 50-70% of their energy this way.
Irony, because while much incandescent heat is radiated externally to potential use, CFL and LED is internalized, with unpredictable fire risk, especially of CFLs (incandescent heat being more noticeable in burning lampshades and the like, to warn users).

Not only do incandescents often usefully release around 95% of their energy as heat:
Proponents conveniently "forget" to add that CFLs and LEDs really waste energy as heat, CFLs 80% and LEDs 70%.
That is because the CFL/LED heat is internalized, to give a greater, unseen, unpredictable fire risk, particularly with CFLs (incandescent heat being more noticeable, to warn users).

A brief further word on LEDs, as the touted catch-all replacement product.
Just to mention 2 aspects and 2 institutional references.
The official French health agency ANSES in a 2010 multi-disciplinary study highlighted point source glare and blue light radiation issues and various side-effects, echoed by several other studies, and unusually in a repeat call 2013 complained to the Commission that nothing was being done.
Similarly the Department of Chemical Engineering and Materials Science, University of California, USA has been involved in several multi-disciplinary and multi-institutional and international (Korea) studies concerning the toxicity and environmental effects of LEDs, including depletetion of rare earth minerals, and calling for recycling as with CFLs.



Certainly, new technology should be welcomed for its advantages.
But it does not necessitate banning the old - it seems remarkably hard for politicians to understand that manufacturers themselves can and do move on the new products, without the necessity of bans, and that there are many other ways both of reducing energy consumption in general and of enhancing energy saving product purchase in particular.

Progress is welcomed - not feared.
True progressive politics brings more choice and more advantages, a progress helped - not hindered - by allowing competition against that which already exists.

Politicians love to keep saying how "energy saving products are getting better and cheaper all the time".
Good.
Then presumably people might actually buy them - voluntarily - while still allowing niche special use of "old" varieties.
We've witnessed an incandescent to solid state switchover before - and with the same GE, Philips etc companies.
The audio version. Incandescent audio tubes to solid state (LED-like) transistors.
Now then: If that had been today, then worldwide the call would have been to ban the "energy guzzling" audio tubes.
Which in turn would have prevented rock era tube amps and other niche audio processing developments.
Politicians set energy cut-off standards thinking they just ban existing products. But they also ban what might have existed, and never will.

Ergo:
New lighting is better - why ban old lighting, no point
New lighting is not better - why ban old lighting, no point




Incandescent advantages for Canadians


(i) Canadian homes tend to be big in international comparison, with more light bulbs:

Canadian around 35 light points per home, EU average 20-25 (less in Southern Europe), USA 40-45

Thereby:
• Increased variety of conditions where different lights are useful, so a ban on any lighting type is felt more.
• More individual rooms and lamps with lights that are not often used - reducing supposed running cost savings after buying expensive "energy saving" lighting



(ii) Canadians have a higher need and usage of lighting itself:

• Increased time indoors, including at home, because the homes are bigger, better and more comfortable, related both to the cooler climate and to a greater household wealth, compared with most other countries.
• Increased time indoors, including at home or other situations where the lighting can be chosen, because of colder climate and also because the dark winter season is only partially offset by summer brightness for working Canadians outside vacation times, when some rooms will likely still need to be lit up fairly early



(iii) Canadians more often have cold conditions that can affect the lighting used:

• Incandescent lights come on quickly in the cold. While nowadays CFLs have little delay in ordinary conditions, that does not apply in cold conditions.
LEDs also are more sensitive to ambient temperatures (both hot and cold performance deterioration).
• Cool or cold conditions can combine with other usage factors unsuitable to other lighting, like incompatibility with sensor systems and/or frequent on-off switching, as with hallway and passage areas, bathrooms, outdoor porch and garage lights.
On a more curious note, replacing incandescents with other lighting has reportedly seen Canadian traffic lights being obscured by snow in wintertime, whereas beforehand the incandescent heat would keep the lights clear.



(iv) Canadians particularly benefit from the light bulb heat effect:

• The heat effect, of which more later, gives an overall reduction of energy use to maintain room temperature.
That is not just from being used more than air-conditioning cooling through the year. Even in the summer, when it is dark, it may be cold enough to turn on room heating. Besides incandescents can be changed as desired if conflicting with air conditioning - and may of course be preferred anyway for their other advantages.
• The house insulation factor: Well built Canadian houses that are well insulated, giving a greater light bulb heat benefit compared to more poorly insulated ones elsewhere, as in the UK. The heat from bulbs stays in the room, not escaping through the ceiling.
A point of irony is therefore how governments are increasing home insulation schemes to save on heating, while banning bulbs which, proportionate to small energy use of course, would thereby contribute more to such heating.



(v) Canadians are more likely to enjoy the psychologically warm effect:

Incandescents tend towards the red end of the spectrum, while unmodified fluorescents and LED lighting have more blue light, cooler in effect.
Also, when dimmed, the warm effect of incandescents increases: and people in northern countries like Canada or Nordic Europe are more likely to entertain others in their homes for say dinner parties, possibly also for cultural reasons.
Compare with warmer regions where people go out more to socialize, have no control over such lighting used, and barely use their own home lighting that they can control.



(vi) Canadians are more likely to enjoy bright light:

Having longer darker winters, and generally with less bright conditions than more tropical locations.
100W+ bright equivalent lighting is less easy to make in fluorescent or LED bulb form, is not often available for general household use, and is particularly expensive when it is (and is still not widely possible omnidirectionally with LED bulbs).
The importance is also seen from the existence of SAD, Seasonal Affective Disorder in Northern countries generally, where the lack of light during winter months plays a role as seen from the bright light phototherapy treatment that is involved.

[ Sections 4 to 10 can be seen via doc or pdf download, see top of this page]



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.