Energy Efficiency Regulations Lambasted: Consumers are not Irrational, and Environmental Benefits are "Negligible"

 

Returning to American criticism, after the "world tour" of the last couple of posts.
I received this Working Paper, the authors may therefore make adjustments.

Overriding Consumer Preferences with Energy Regulations by Ted Gayer and W. Kip Viscusi, Mercatus Center, George Mason University, Arlington, Virginia, August 2012

The study is here (pdf document). An alternative link.
A summary (also a pdf document, and similar to the website page embedded below).


The study authors

Ted Gayer
tgayer@brookings.edu
Ted Gayer (more) is the co-director of the Economic Studies program and the Joseph A. Pechman Senior Fellow at the Brookings Institution.
He conducts research on a variety of economic issues, focusing particularly on public finance, environmental and energy economics, housing, and regulatory policy. He received his Ph.D. from Duke University.

W. Kip Viscusi
kip.viscusi@vanderbilt.edu
W. Kip Viscusi (more) is Vanderbilt’s first University Distinguished Professor, with primary appointments in the Department of Economics and the Owen Graduate School of Management as well as in the Law School.
He is the award-winning author of more than 20 books and 300 articles, most of which deal with different aspects of health and safety risks.
He received his Ph.D. from Harvard University.

Abstract

This paper examines the economic justification for recent U.S. energy regulations proposed or enacted by the U.S. Department of Energy, the U.S. Department of Transportation, and the U.S. Environmental Protection Agency.
The case studies include mileage requirements for motor vehicles and energy-efficiency standards for clothes dryers, room air conditioners, and light bulbs.

The main findings are that the standards have a negligible effect on greenhouse gases and the preponderance of the estimated benefits stems from private benefits to consumers, based on the regulators' presumption of consumer irrationality

Mercatus.org currently have a website summarizing the study: embedded below.




Society benefits are therefore seen as negligible, in what after all should be done for Society's good:
Consumers may make some enforced personal savings, from a ban on what they otherwise would have bought.

However, as the authors also point out, the assumed consumer irrationality is a mistake:
Consumers may have good reason to buy cheaper products for shorter or temporary usage, and the energy using products may have compensating features that consumers like - obvious enough, or they would not prefer them.
So what is called "benefits from correcting consumer irrationality" comes from additional purchases not otherwise made.
In simple English, having to buy what they otherwise would not buy.
[For more on the common regulator supposition of "market failure" and that people "only buy energy using products because they are cheap" and that "regulation is the only answer to this", see commenting below]

The authors also note the irony that new extensive information labelling requirements should provide the information that the EPA (Environmental Protection Agency), NHTSA (National Highway Traffic Safety Administration) and other responsible instances say that consumers lack when they need to make informed purchasing decisions.

Amongst case histories is a particular section on light bulbs.
The authors say
"DOE presents relatively little documentation on how it calculated the costs and benefits of the standard."
"No consideration was made for consumer preferences for different types of light bulbs or for such things as the rebound effect. Thus, the quality of light, whether the bulb is dimmable, and other aspects of light bulbs are irrelevant to the DOE assessment"


Edited extracts from the actual study [my added emphases again]:

Introduction

The efficiency rationale for any government regulation rests on the existence of some type of market failure.
The ways markets may fail are quite diverse, ranging from characteristics of the market structure to various kinds of externalities; that is, adverse effects on parties other than the buyer and seller of a product.

In the absence of some type of market failure there is no legitimate basis for regulation from the standpoint of enhancing economic efficiency.
The regulations are based on an assumption that government choices better reflect the preferences of consumers and firms than the choices consumers and firms would make themselves. They assume consumers and, in some cases, firms are incapable of making rational decisions and that regulatory policy should be governed by the myopic objective of energy efficiency to the exclusion of other product attributes.

Energy efficiency standards provide a valuable case study of how agencies can be blinded by parochial interests to assume not only that their mandate trumps all other concerns but also that economic actors outside of the agency are completely incapable of making sound decisions. The assumption that the world outside the agency is irrational is a direct consequence of the agencies’ view that energy efficiency is always the paramount product attribute and that choices made on any other basis must be fundamentally flawed.

They then examine the rationale for regulations,
comparing consumer need and society outcome...

The Energy-Efficiency Gap

The clearest regulatory example questioning consumer rationality is with respect to energy-efficient consumer goods, for which consumers frequently face a tradeoff of a higher upfront capital cost versus lower future operating costs over the life of the product.
A rational consumer will [supposedly] consider things such as the expected future cost of energy, the expected lifetime of the product, the frequency of use of the product, and the discount rate to convert future savings to present value compared to the up-front capital cost.

A long-standing empirical finding, known as the energy-efficiency gap, shows that consumer choices for energy-efficiency purchases imply a discount rate much higher than market discount rates, suggesting that consumers underweight the future cost savings stemming from an energy-efficient product compared to the weight they put on the future in other market settings...

[But] empirical evidence suggests that consumers’ valuation of the long-term differences in fuel efficiency for different models of cars may be quite reasonable.
In an econometric study of prices of used cars, Dreyfus and Viscusi estimated the rate of interest implicit in a consumer’s valuation of the discounted value of vehicle operating costs... [were] consistent with market rates.”
Unlike some engineering studies that purport to show that consumers neglect energy efficiency, this study considered a wide range of car attributes other than energy efficiency that are valued by consumers...
[Also] if you are planning to move or have a current liquidity problem, buying the more energy efficient but more expensive appliance may not make sense from an economic standpoint.....

[Similarly] Anderson and Newell find that manufacturing plants reject about half of the energy-efficiency projects recommended by engineering analyses because of unaccounted physical costs, risks, opportunity costs, lack of staff for analysis or implementation, risk of inconvenience to personnel, or suspected risk of problems with equipment.

By ignoring these relevant characteristics of the product, and the specifics of the customer’s economic circumstances, the engineering studies can arrive at incorrect findings of personal savings from the products that have higher up-front costs but yield lower operating costs.
Since the engineering studies focus only on capital costs and operating costs, they do not allow for any heterogeneity of preferences and use of products across consumers.
Another possible explanation for the findings of apparently high consumer discount rates in engineering studies is that consumers do not expect to receive as high a return in energy savings as the analyst assumes.
The regulatory agencies [therefore] frequently rely on engineering studies that presume consumers can accrue benefits by regulatory standards that restrict consumption choices.

Taken as a whole, the engineering and empirical literature on the energy-efficiency gap does not provide strong, credible evidence of persistent consumer irrationality.

Providing accurate information to consumers would be preferable to regulatory mandates.
Indeed, Executive Order 12866 (signed by President Clinton and re-affirmed by President Obama in his Executive Order 1356316) requires each agency to “identify and assess available alternatives to direct regulation, . . . such as . . . providing information upon which choices can be made by the public.”
Informational efforts can and do provide energy-cost information over the lifetime of the appliance.

They then go on to "analyze documentation used to support energy efficiency regulations promulgated by DOE, EPA, and DOT" for different products.

Case Studies

CAFE Standards for Passenger Cars and Light Trucks
One does not have to be a reader of automobile reviews in Edmunds.com, Car and Driver, or Road and Track to realize that fuel efficiency is but one of many factors people use to assess the quality of an automobile.
Acceleration, handling, braking ability, legroom, riding comfort, safety, reliability, styling, and trunk storage are among the many other dimensions of concern to automobile purchasers.
Despite the NHTSA (National Highway Traffic Safety Administration) admission that it is uncertain whether the lack of market demand for higher fuel economy is due to consumer irrationality or consumer preferences, it proceeds to promulgate a regulation that assumes the former.

[NHTSA and EPA] justifications largely amount to problems of inadequate information, such as the reasoning that fuel-economy benefits are not salient enough to consumers, that consumers have difficulty calculating expected fuel savings, or that consumers might associate higher fuel
economy with inexpensive, less well-designed vehicles.
[This] raises the question of why a rigid mandate is warranted rather than an informational regulation that would provide consumers with the guidance to make sounder choices.
Indeed, in 2011 EPA did just that by issuing its Motor Vehicle Fuel Economy Label Final Rule. The mandated label for all new cars is quite extensive, including an overall mpg rating, a city mpg rating, a highway mpg rating, gallons/100 miles, driving range on a tank of gas, fuel costs in five years versus the average new vehicle, annual fuel costs, fuel economy and greenhouse-gas rating, and smog rating.

What is striking about the EPA analysis of the CAFE standard is [therefore] that the EPA regulatory impact analysis does not even mention the existence of the agency’s own new label rule.
This oversight goes to the heart of the CAFE standard analysis, as most of the benefits needed to justify the regulation relate to consumer choice failures targeted by the new labeling..

The agencies that regulate these standards—the National Highway Traffic Safety Administration and EPA—estimate greenhouse-gas benefits make up less than 10 percent of the total claimed benefits. But when benefits are restricted to only the United States, they drop to just over 1 percent of total claimed benefits.


Clothes Dryers, Air Conditioners, Clothes Washers
DOE estimates the global greenhouse-gas emissions benefits of clothes dryer standards as between $93 million and $1.49 billion which is below the estimated private benefits range of $1.08 billion to $3.01 billion.
DOE estimates the global greenhouse-gas emissions benefits of room air conditioner standards as between $77 million to $1.16 billion as compared with the estimated private benefits range of $570 million to $1.47 billion.

An earlier proposed regulation of clothes washers was purported to have great energy savings for consumers, but a Rasmussen Research poll found tremendous consumer opposition to the standard.By a margin of 6 to 1 the public opposed regulations that would effectively eliminate top-loading washing machines.
Much of the opposition arose because most consumers wash fewer loads per week than the DOE analysis assumed; for this group the present value of the cost savings is far less than the estimated savings.
Engineering studies divorced from consumer usage and preferences can produce policies that produce far fewer benefits than predicted.


Other Appliances
Acting under authority from EPCA, DOE has promulgated energy-efficiency regulations for other appliances as well.
For example, DOE issued standards for residential refrigerators in 2011, and for industrial products, such as high-intensity light fixtures (known as metal halide lamp fixtures) and walk-in coolers and freezers in 2012.
As in the case of the fuel-economy standards, for each of these appliance standards, the preponderance of the estimated benefits consists of [supposed] private benefits to the purchasers of the products:
There must be some form of individual irrationality or behavioral shortcoming of individual choices to give rise to these benefits. DOE provides little, if any, analysis and documentation of this assumed irrationality in its rules.

Not forgetting light bulbs...

General Service Incandescent Lamps

DOE presents relatively little documentation on how it calculated the costs and benefits of the standard.
The DOE analysis calculated cumulative national energy savings as the sum of annual national energy savings, which in turn was estimated as the difference in annual national energy consumption between the base case and the case with the new General Service Incandescent Lamps (GSIL) standards.
DOE estimates 14.14 quads in cumulative national energy savings.
The net present value to consumers is computed as the present value of operating-cost savings minus the present value of increased total installed costs.

DOE computed the operating-cost savings for a given year by multiplying the surviving stock of GSILs of a given vintage in that year by the per-unit operating-cost savings for that vintage (obtained by multiplying the vintage’s expected energy savings by forecasted energy prices), then summing over vintages.
DOE computed increased total installed costs for a given year by researching product catalogs, online distributors, and manufacturing interviews to estimate “the increase in unit prices for products that comply with EISA 2007.”
It then multiplied the surviving stock of GSILs of a given vintage in that year by this annual per-unit total-installed cost increase, then summed over vintages.

No consideration was made for consumer preferences for different types of light bulbs or for such things as the rebound effect.
Thus, the quality of light, whether the bulb is dimmable, and other aspects of light bulbs are irrelevant to the DOE assessment.

DOE’s net present value estimate is for $27.5 billion (7 percent discount rate) or $64.2 billion (3 percent discount rate) in cumulative savings to consumers from 2008 through 2038 stemming from the efficiency standards for light bulbs.
These estimates of private benefits far outweigh DOE’s estimate of between zero and $16.34 billion in benefits from reducing carbon dioxide emissions.
Once again, [supposed] private benefits to consumers drive the economic justification for the analysis.

Conclusion

The economic puzzle raised by all these energy regulations is why consumers are this remiss.
How can it be that consumers are leaving billions of potential economic gains on the table by not buying the most energy-efficient cars, clothes dryers, air conditioners, and light bulbs?
Moreover, how can it also be the case that firms seeking to earn profits are likewise ignoring highly attractive opportunities to save money?
If the savings are this great, why is it that a very basic labeling approach cannot remedy this seemingly stunning example of completely irrational behavior?

It should be quite simple to rectify decisions that are this "flawed".
It should be a red flag that something is amiss with an analysis that assumes such perplexing consumer and firm behavior that runs counter to the most rudimentary economic theory and our general sense that we do not live in a world in which people never make sound choices.

It might be that there is something that is incorrect or perhaps even irrational in the assumptions being made in the regulatory impact analyses.
Indeed, upon closer inspection it is apparent that there is no empirical evidence provided for the types of consumer failures alleged.
Even if some consumers do sometimes fall short on certain dimensions of choice, the magnitude and prevalence of such a shortfall is important and is never addressed in the regulatory assessments. Nor is there adequate consideration of the actual and potential role of informational remedies that have already been adopted.

Perhaps the main failure of rationality is that of the regulators themselves.  [!]
Agency officials who have been given a specific substantive mission have a tendency to focus on these concerns to the exclusion of all others.
Thus, fuel efficiency and energy efficiency matter, but nothing else does.
If other attributes matter, it is assumed they either are irrelevant or will be included at no additional cost in the post-regulation products. In effect, government officials act as if they are guided by a single mission myopia that leads to the exclusion of all concerns other than their agency’s mandate.
Institutional biases of this type are common and are fundamental characteristics of organizational behavior. Indeed, the existence of parochial visions by agencies is a major reason the Executive Office of the President has institutionalized a formal regulatory oversight process beginning with the Ford administration and including a BCA [Benefit Cost Analysis] test since the Reagan administration.
One question raised by these analyses is whether the legislation mandating these standards permits OMB [Office of Management and Budget] to provide credible evidence of the market failures pivotal to justifying the regulations.

Adopting a more accurate economic analysis does not imply that government agencies do not have any policy tools that can be used to foster greater energy efficiency.
Informational policies and more limited forms of policy intervention may be warranted on a benefit-cost basis.
Recent regulatory analyses demonstrate that the current energy-efficiency initiatives do very little to address climate change. Rather than squander societal resources on more ineffective policy efforts, a more productive approach would be to search for policy options that offer greater potential for making a serious dent in greenhouse-gas emissions.

Even the modest environmental benefits are overstated because they are based on projected benefits to the world — not just to citizens of the United States.

Comment

A further note on the supposition that "there is a market failure that requires regulations".
Market failure is the underlying reason for regulations, in other words that consumers are not voluntarily buying the "right" products, and so the markets have "failed".

As the study authors point out,
the concept of market failure is questionable, in that consumers may have rational reasons for buying what they do:
- either in that the overall cost may be too high for short term or temporary use,
- or that the product may have other desirable features attracting a purchase
These issues are also extensively covered here, regarding the exemplified effect of
regulatory standards on product characteristics, product price and usage savings, http://ceolas.net/#cc21x.

A common follow-up by "market failure" advocates is that people only buy the products because they are "cheap", not because of any useful features:
Therefore, people should be "happy" in being pushed or forced to make purchases "expensive to buy but cheap in the long run".
However, people do buy many other products which are virtually identical except that the expensive kind "is cheaper in the long run", as illustrated with the battery and washing up liquid examples in the Deception of Light Bulb Ban Arguments rundown on this site.

Also more generally do people buy expensive product versions, or they would not be on the market.
In fact, that is precisely the situation with energy saving alternatives, as with the CFL and LED and Halogen alternatives relevant in the context of this blog, and as both American (DoE) and EU (EcoDesign) research has shown:
Most have some of these in their households already - but they obviously don't want all their lighting to be of such kind.
How hard can it be to understand this?


Again, even if it is accepted that "something must be done" to correct the supposed market failure, then, as the authors suggest, better information is the first line of action, informational labelling that has just been introduced in new extensive forms in both the USA and EU (as with light bulbs), and that therefore could be given time to act, again echoing what the authors say.

Ignoring that, regulation is still not the answer to save electricity:
As covered in point 13 of the mentioned Deception rundown.
In other words, stimulation of market competition, or taxation-subsidy policies.

Stimulated market competition involves helping new inventions to market, but without continuing subsidies.
With electricity, it also involves the increased competition of service providers in the grids, thereby using their energy resources efficiently under market pressure - without regulation.

Market Competition and Taxation-Subsidy policies as alternative to Regulations, using Light Bulb example: http://ceolas.net/#li23x.

Taxation is not the best option, but is interestingly and oddly shunned also by liberal pro-regulator tax-and-spend politicians: As said it can pay for price reductions on energy saving alternatives, so people are "Not Just Hit By Taxes".


Bankrupt California has seemingly got round to asking the electorate
"How you want to be taxed, as increased taxation is now a necessity".

Well now!
There is hardly a less painful way to achieve government income than to base energy standards on taxation rather than regulation, be it building construction, cars, washing machines, TV sets, light bulbs etc, given the plethora of current bans accompanied by subsidies to utilities and manufacturers.
It allows such subsidies to be covered, or of course other Government spending, while ensuring greater consumer choice.
Environmental targets are still kept as desired, a high tax simulates a ban, while intermediate levels give high government income for compensatory "Green" measures.

No - taxation is not the best option.
But it is yet another way that the supposition "market failure requires regulation" is wrong:
if there actually is a "market failure" when people are allowed to buy what they want!


Perhaps one day the officials pursuing bans or "energy usage based phase outs" of popular useful products will start to think about what they are doing.
The question is, when.
 

A Dutch View: "The Unholy Alliance between Philips and the Greens"

Updated August 1

Having covered South African and Hong Kong criticism of the ban and of the replacement bulbs, it is worth remembering that there have been similar good articles originating in the EU.
Naturally, most English language articles have a UK source, but some others have appeared that don't need translation tools (or manual work!).
This article by Dutch researchers has been mentioned in a previous post, but deserves its own.
Written in 2010, it remains valid today.

From University of Colorado Professor Roger Pielke Sr Climate Science Site:
Both Professor Roger Pielke Sr and Professor Roger Pielke Jr (blog) are something as unusual as institutional, renowned climate scientists that are not afraid to make their own judgements on climate change.
Note how criticism is otherwise something such scientists tend to do once they leave office!
(and - whatever the rights and wrongs - the notion that "most scientists agree with current climate change policies" should be taken with that knowledge, that few would go against established governmental and institutional opinion anyway, for fear of not receiving continued funding etc)

The below article post has this source.


About the authors

Henk Tennekes is an aeronautical engineer. From 1965 to 1977 he was a professor of Aerospace Engineering at Penn State. He is co-author of A First Course in Turbulence (MIT Press, 1972 – still in print) and author of The Simple Science of Flight, recently (2009) released revised and expanded.


Joost van Kasteren [website] is a senior writer on technology and science in Holland, having also been a science journal editor.
He covers energy, housing, water management, agriculture, food technology, innovation, science policy, and related issues.

Typically straight-talking Dutchmen, they don't spare the rhetoric as they conclude the article...

In 2006, Dutch legislators caved in under the combined lobbying pressure by Philips and Greenpeace. A parliamentary majority in The Hague embraced the idea of banning incandescent bulbs and ordered the Dutch Environment Minister, Jacqueline Cramer, to lobby for an extension of the ban to all states in the European Union.

That task proved simple enough.
Top politicians in Europe, Germany’s Angela Merkel up front, deeply impressed by Al Gore’s Inconvenient Truth, were only too eager to project an image of strength and will power concerning imagined threats to the planet. ”Save the Earth, ban the bulb” was an effective campaign strategy.

To make a long story short, it took less than one year to issue a binding European Union Edict ordering the phasing out of incandescent bulbs, starting with a ban on bulbs of 100 watts and more effective March 1, 2009, and leading to a complete ban of all incandescent lighting on September 1, 2012.

The spin doctors at Philips headquarters have got it made.
And if this scam backfires on them in consumer protests all over Europe, they can cover their backsides by claiming that politicians and the green movement are responsible, not they.
Backfire it will. There exist no decent alternatives to incandescent light. None.

The history of the EU ban is extensively covered with documentation and communication copies on the Ceolas site, here: http://ceolas.net/#euban.





 

Howard Brandston's Mondo Article

 
A while back I had a resource news update, looking at the latest from the sites in the resource link list - it seems better just to highlight different ones, when I notice them.

I mentioned that Howard Brandston had an upcoming article in Mondo magazine.
This is now published:

MERCURY? Thermometers NO! Light bulbs YES!
A plea to the lighting design community from Howard Brandston.


On December 16th 2011, just days before a national ban on the incandescent was to take effect, the United States congress postponed the onset of a law that threatens to alter the very contours of our lives. Starting with a phase-out of the 100-watt bulb in 2012, the Energy Independence and Security Act, signed by George W. Bush in 2007, finishes off the 40-watt lamp by 2014. How do the legislators behind the Act intend to replace Thomas Edison’s time-tested invention? With the squiggly compact fluorescent, which has been touted as a panacea for an ailing planet, even as questions about its energy efficiency and environmental viability abound. The outcry in the U.S. against this proposed ban, however, has been vociferous—loud enough, it seems, to have put at least a momentary halt to legislation that is not dissimilar to bans that are in the process of being enacted all over the world.

In the years leading up to the planned implementation of the Act, American lighting manufacturing giants raced to replace the incandescent light bulb with the compact fluorescent to the tune of 400 million lamps sold each year, sacrificing quality and, ironically, the environment in exchange for what was widely heralded as affordability and energy efficiency—CFLs are said to use up to 75 percent less energy than conventional tungsten bulbs (the figures vary). Meanwhile, compact fluorescents have been flooding landfills around the world, frequently breaking along the way, releasing about 5 milligrams of mercury into the soil, water, and air with every shattered bulb.

A naturally occurring heavy metal, mercury is a potent neurotoxin that causes damage to the central nervous system, the endocrine system, the kidneys and other organs. Mercury poisoning can be fatal; exposure to mercury is especially dangerous for fetuses and children. Yet despite the imminent phase out of the incandescent bulb, the lion’s share of municipalities in the United States have failed to implement safe, accessible recycling solutions for the toxic compact fluorescent. Five years after the signing of the Act, cities and towns with curbside recycling services still do not have the facilities to deal with such bulbs, which must be taken to hazardous waste centers, many of which are open to the public a total of one day a month.

And what happens when one of these fragile glass corkscrews breaks within the safety of the home? The U.S. Environmental Protection Agency recommends evacuation of the site for the first 15 minutes after the breakage in order to avoid exposure to harmful mercury vapors. After an elaborate initial cleanup (instructions available on the internet are confounding in their contradictions), the room should be aired out, the EPA advises, with all HVAC systems turned off, for several hours. Theories as to the health risks posed by any remaining traces of mercury vary wildly depending on who is doing the talking. Consumers can, for the moment, breathe a huge sigh of relief. They have not yet lost the freedom to decide for themselves what kind of bulbs they are willing to risk bringing into their homes.

Now, at the 11th hour, Congress has postponed the bill—which was planned to go into effect on January 1—until September 2012, giving those in support of the incandescent nine more months to harness the momentum necessary to make their voices heard. Vigilance is key. This small victory must not be seen as a mere momentary roadblock to the boondoggle that has been looming over the U.S. lighting industry and how it is that we illuminate the commercial workplace, as well as the sanctity of our homes, for the past five years. Constituents around the world need to make their opposition to the ban known, in the face of the considerable lobbying power of lamp manufacturers, who, no doubt, will continue to put pressure on Congress, fervently politicking for their interests to be served.

The devastating paradox of the supposedly green solution to the global energy crisis proffered by the compact fluorescent is that the mercury contained within these bulbs is poised to invade our homes even as we are promised a reduction in mercury-laced carbon emissions—a reduction that is negligible at best. It is an energy saving that can easily be accomplished by legislation on any number of measures, including wind and solar power and alternative fuels, higher building standards, and HVAC and water heating systems, to name a few.

And what about other lighting alternatives? High-performance energy-efficient incandescents that meet proposed energy efficiency guidelines are in the works. Halogen lamps are everywhere. But unfortunately, the high-performance bulbs currently available or in the pipeline are no competition for the conventional tungsten lamp when it comes to cost. Which means that if a ban on the incandescent does go into effect, the only affordable option for the vast majority of homes will be the noxious compact fluorescent.

Action must be taken to ensure that the repeal is not simply a postponement. It is imperative that we succeed in averting the impending environmental crisis we are so very close to legislating into being. For if just one gram of mercury will pollute a 2-acre pond, imagine the havoc millions of compact fluorescents tossed into our garbage dumps threatens to wreak on the world at large, let alone the sanitation workers who come in constant direct contact with high volumes of these troublesome bulbs. Allowing so much mercury to invade our homes and workplaces, not to mention our already endangered forests and plains, our rivers and oceans, would be not just foolhardy but downright destructive.

And mercury is not the only problem when it comes to the compact fluorescent. Myriad questions remain regarding the negative impact of CFLs on our health and well-being. The flicker rate of the bulb has improved over time, but the jury is still out on CFLs as a trigger for migraines and, in some cases, epileptic seizures. The long-term effects of electro-magnetic fields and the gaps in the colour spectrum peculiar to CFLs have not yet been adequately studied. In addition, the ultra-violet radiation emitted by CFLs poses dangers to those with light-sensitive diseases such as lupus.

And the list of downsides continues: many existing light fixtures are incompatible with CFLs and will need to be replaced. The fact that the bulbs require a different kind of dimmer than those installed in most homes poses yet another challenge. CFLs boast a longevity equal to 3 to 25 (or 8 to 15, again, the figures vary) times that of the incandescent; but these claims are substantially undercut by the rapid reduction in lifespan that occurs when the lights are switched on and off with any sort of frequency. And then there is the CFL delay: when a compact fluorescent is switched on, it does not light up immediately, but takes up to three minutes to reach full intensity. Component parts fail frequently, due to compromises in quality in exchange for affordability. CFLs are manufactured in China, where there are little or no environmental controls, and safety in the workplace is all but nonexistent. Energy savings produced by the bulbs themselves are offset by the distance they must be shipped and the energy expended to manufacture their plastic packaging, which of course, is environmentally unsound. And despite the fact that the quality of light given off by CFLs has improved in recent years, it remains spectrally deficient, and vastly diminished in comparison with that of the incandescent. Not to mention the negative impact that the incandescent ban would have on the work of lighting designers and industry professionals in an era that is presently rife with restrictions.

But the implications of the elimination of the affordable incandescent go far beyond the blatant health risks posed by the compact fluorescent and its roll call of hindrances listed above. What’s most ominous about the incandescent ban proposed by the Energy Independence and Security Act of 2007 is not simply its enforced influx of the compact fluorescent into our homes and workplaces, but the fact that if it does indeed take effect, we will have lost our freedom to choose how we light our lives.

Human beings evolved with and in response to light—sunlight, moonlight, the incandescence of fire. Our physical mechanism, the neuroscience that makes us who we are, is exquisitely attuned to light’s qualities and rhythms. The light that envelops us steers our very existence. To impose limitations on how we choose to illuminate our world carries profound biological implications.

How did we get here? How is it that environmental institutions from the EPA to the Energy Federation to Greenpeace continue to advocate the use of the compact fluorescent despite the overwhelming evidence?
“Politics is the art of looking for trouble, finding it whether it exists or not, diagnosing it incorrectly and applying the wrong remedy.”
—Ernest Benn, British publisher, born in 1875

Our recent predicament is a testament to the hefty lobbying power of a handful of manufacturing giants on Capitol Hill and a barrage of mostly meaningless statistical data. For when one takes a closer look at the bee’s nest of information spun in favour of the ban, one discovers that the “more than 330 million metric tons [of greenhouse gas emissions saved] over the next 30 years” posed in defence of the incandescent ban amounts to .013 percent of energy use over the next three decades. This is a figure that could easily be offset by any one of a number of measures. But the industries behind these measures wield a lobbying muscle that is at least as formidable as that of the lamp manufacturers, if not more so. The community of lighting professionals is only a few thousand strong. The incandescent, then, is an easy target—singled out in the scramble to make our lives more energy efficient, even when the statistics don’t support the argument.

It’s not too late to set the story straight. We have seen that speaking out can make a difference. We have been given a tremendous opportunity, thanks to the postponement of the ban, to spread the word. Now is the time to organise our resources and step up the good fight. We, as a community of lighting professionals, have a voice that can make itself heard: a clear, unified statement issued on behalf of the lighting community will have far-reaching implications. We must do everything we can to invite the general public to get involved, to urge consumers to contact their legislators and make their feelings known regarding this onerous, ill-thought bill—and others like it all over the world. Our freedom to choose the nature and quality of how we illuminate our lives lies in the balance.

Howard Brandston
www.concerninglight.com LightPain@aol.com

Howard Brandston
biography, commentary, business
As seen, a well known lighting designer with numerous projects, also a guest lecturer, visiting professor, and as noted the Congress choice of expert opinion on lighting issues.


Comment

Listen to what the renowned lighting designer says!

The most common political reply, as also happened to him in the Senate Hearings,
is the well-worn "But we are not banning incandescents... energy efficient types like halogens are still allowed".
Howard does point out the cost difference, there are also some light quality and other differences, and significantly they will be "phased out" too on both US and EU legislation specifications (indeed a ban on low-voltage halogens is in the works in the EU too, or should I say "standards that do not allow them to be made" 8-))

The today revised page The Deception behind Banning Light Bulbs,
a copy which follows underneath, complements the above:
I steer away from specific CFL-mercury criticism in that rundown, as that line of argument (however justified) detracts from the purpose there, to highlight how the ban in itself is wrong.

CFLs, like incandescents and other bulbs have their advantages too.
Provided the usage safety conditions are adhered too, there is no need to ban them either(!).

Energy efficiency regulations make no sense for any reason, including to save energy or emissions.
Coal plants were always the main target.
Yet the irony is that - even with supposed energy usage -
the same coal gets burned regardless of whether your light bulb is on or off! (more)

It's a funny world.  

Comparing North America and EU bans

 

As seen from the recent overview of USA regulations, they are comparable to Canada, but not at all as strict as the EU regulations (regulations for different countries with official links http://ceolas.net/#li01inx).

The EU, then, has not only had an earlier ban, but included most varieties of incandescents, also banning all frosted types (Halogen or not) with immediate effect, on the justification that consumers "can buy the CFLs" if they want opaque bulbs.


There are 2 main reasons for the differences between North America and the EU.

Firstly,
the attitude to climate change a.k.a. global warming:
It should be remembered that reducing CO2 emissions was the original worldwide impetus to ban the bulbs, via Greenpeace and other vociferous campaigns around the turn of the century.
The emphasis on saving energy for society or money for consumers later gained ground to make the proposal more concretely attractive, also in view of a growing scepsis or fatigue regarding the climate change message.
That said, the EU Commission and Parliament - and European politicians in general - have remained strong backers of energy efficiency solutions to reduce CO2 emissions.


Secondly,
the comparably greater cooperation with manufacturers.
Even before the ban, imported CFLs were being tariff-reduced in special deals, and the EU Commission Ecodesign Committee (behind the ban proposals) had an extensive involvement with manufacturers, as covered on the website, from http://ceolas.net/#li12ax onwards, including http://ceolas.net/#euban.

In this regard, the fundamentally undemocratic nature of the EU compared to the USA should be remembered, the EU's own auditors have for the past decade refused to sign off on the accounts, and while for example the USA has open Congress hearings on this and other issues, the EU won't even say who is on the legislation proposing EcoDesign Committee, let alone inform about their meeting activities (I have consistently been refused information about the committee composition etc, one reason seemingly being so that the Committee is not "unduly influenced"... which is ironic of course, since they do liaise closely with manufacturers, as has emerged more and more)


A reason for taking this up here, is also because of interesting documentation that I have come across in the past couple of days, relating to EU manufacturer lobbying, more of which can be seen at http://ceolas.net/#postEUban

For example,

The Unholy Alliance between Philips and the Greens
Guest post by Dutch researchers Joost van Kasteren and Professor Henk Tennekes, on American Climate Scientist Roger Pielke's blog


Some extracts. my emphases:

An unholy alliance (discovered by Elsevier journalist Syp Wynia – see footnote) between a large multinational company and a multinational environmental organization succeeded in their lobby to phase out, and ultimately by 2012 forbid, the sale of incandescent bulbs, because of their low watt-to-lumen efficiency – not only in the Netherlands but in the whole of the European Union.

The multinational company wanted to develop a new market for products with a high profit margin, and the environmental multinational wanted to impress the citizens of Europe with the imminent catastrophe caused by anthropogenic climate change. That would also be of benefit to its battered public image.

Philips, the company involved, started in 1891 with the mass production of Edison lamps, at its home base, Eindhoven, Netherlands. There existed no international court of justice at the time, so they could infringe on US patent law with impunity. In the past 120 years it has expanded continuously, to become the multinational electronics giant it is today. Because nostalgia seldom agrees with the aims of private enterprise, Philips started lobbying to phase out the very product on which its original success is based. They started this campaign around the turn of the century, ten years ago.

Their line of thought is clear: banning incandescent bulbs creates an interesting market for new kinds of home lighting, such as “energy savers” (CFL’s, compact fluorescent lamps) and LED’s (light emitting diodes). The mark-up on these new products is substantially higher than that on old-fashioned incandescent bulbs. The rapid expansion of the lighting industry in China makes the profit margin on ordinary bulbs from factories in Europe smaller yet.

The spectre of catastrophic climate change offered a new opportunity for the strategists and marketing specialists at Philips headquarters.
They changed their marketing concept and jumped on the Global Warming band wagon. From that moment on, energy-saving bulbs could be put on the market as icons of responsibility toward climate change. This would give Philips a head start in the CFL end LED business. The competition would be left far behind by aggressive use of European patent law. That strategy fitted like a glove with that of the environmental movement. For them, ordinary light bulbs had become the ultimate symbol of energy waste and excessive CO2 emissions.

Seeing the opportunity, Greenpeace immediately made a forward pass with the ball thrown by Philips’ pitchers. The incandescent bulb would serve as an ideal vehicle for ramming Global Warming down people’s throats.
No abstract discussions about CO2-emissions any more: a ban on bulbs would suffice.
Not unlike the misguided banning of DDT in the name of environmentalism, which leads to the loss of countless lives due to malaria.

In 2006, Dutch legislators caved in under the combined lobbying pressure by Philips and Greenpeace.
A parliamentary majority in The Hague embraced the idea of banning incandescent bulbs and ordered the Dutch Environment Minister, Jacqueline Cramer, to lobby for an extension of the ban to all states in the European Union. That task proved simple enough. Top politicians in Europe, Germany’s Angela Merkel up front, deeply impressed by Al Gore’s Inconvenient Truth, were only too eager to project an image of strength and will power concerning imagined threats to the planet. ”Save the Earth, ban the bulb” was an effective campaign strategy.

To make a long story short, it took less than one year to issue a binding European Union Edict ordering the phasing out of incandescent bulbs, starting with a ban on bulbs of 100 watts and more effective March 1, 2009, and leading to a complete ban of all incandescent lighting on September 1, 2012.

The spin doctors at Philips headquarters have got it made.
And if this scam backfires on them in consumer protests all over Europe, they can cover their backsides by claiming that politicians and the green movement are responsible, not they.
Backfire it will. There exist no decent alternatives to incandescent light. None.

Footnote, again quoting the blog post:

Elsevier, the Dutch weekly, is the local equivalent of TIME magazine. On August 8, 2009 it ran a revealing cover story by Syp Wynia, entitled “How war was declared against the incandescent bulb.” Other sources of information include an article by James Kanter in the New York Times of August 31, 2009 and many others, easily found by googling “incandescent bulbs” and “banned.”

Henk Tennekes is an aeronautical engineer. From 1965 to 1977 he was a professor of Aerospace Engineering at Penn State. He is co-author of A First Course in Turbulence (MIT Press, 1972 – still in print) and author of The Simple Science of Flight, recently (2009) released in a revised and expanded edition.
Joost van Kasteren is a senior writer on technology and science in Holland. He covers energy, housing, water management, agriculture, food technology, innovation, science policy, and related issues.

 

...and Ontario, Canada puts off their Ban

(If this does not work, you may have Flash software issues.. try the YouTube source: http://www.youtube.com/watch?feature=player_embedded&v=N9ehXDdCsjk)
Following the Canada federal decision to delay to 2014 any ban on simple incandescents,
and the likely suspension of British Columbia to continue with such a ban,
now comes the expected decision by Ontario to put off their own planned ban.
This is not surprising for another reason, namely the proximity to the major Ontario population centres of the USA, Quebec and Manitoba, all (in practice) without such bans next year.


As covered by Antonella Artuso, Cnews Canoe December 21:

Ontario is delaying its ban of incandescent light bulbs for two years.
The 75- and 100-watt incandescent light bulbs were set to be outlawed as of Jan. 1.
The 60- and 40-watts bulbs would have been gone as of the end of 2012.
The move coincides with a federal government decision to put off banning the import of regular light bulbs until 2014.

Rob Ferguson in the Toronto Star adds (extracts):

“Did it make sense for us to have a different approach from the federal government on this issue? No,” [Ontario Energy Minister] Bentley said.
“Our thinking is how do we make it easiest for consumers. It would be hard and confusing to do it differently.”
The two-year reprieve for the incandescents ban will give governments time to come up with a “better approach” for disposing of compact fluorescents, he added.

The Star first reported on Saturday that the Ontario promise, made by former energy minister Dwight Duncan in 2007, was in jeopardy because of the federal move.

Some interesting background information from the Freedom Party of Ontario.

Basically, coal-powered Ontario meant environmental reasons were used to justify a ban,
along with the usual supposed lowered energy usage:
But with any surplus of electricity production being sold to the USA anyway,
it would not have reduced the burning of coal in local power plants.
"The oversupply is so bad that Ontario sometimes has to pay American facilities to take our excess electricity"...

In 2003, [Ontario Premier] Dalton McGuinty had campaigned on closing all of Ontario's coal-powered electricity generation plants by 2007 for the purposes of improving air quality. By 2007, he was nowhere close to closing them. He could not do so, because Ontario did not reliably have enough power to meet its needs, and closing the coal plants would have worsened the crisis greatly.
Having failed for almost four years to increase the supply of electricity in the province, the McGuinty government decided to force people to consume less energy: to ration electricity.

Imposing a system of rationing is not a politically popular thing to do, but people generally do not blame politicians who impose rationing if there is a "need" to ration.
Luckily for McGuinty, Al Gore had provided him with the alleged "need" he was looking for. In 2006, Gore's movie, "An Inconvenient Truth", had caused wide-spread panic that human industrial activity was producing enough CO2 to cause catastrophic global warming. McGuinty capitalized on that fear. Rather than telling Ontarians that he was turning to electricity rationing because he had failed to increase the supply of electricity, McGuinty told Ontarians that "...Ontario has to start being a responsible global citizen", and that he was working on an "aggressive plan" to "deal with greenhouse gases".

Far from condemning the 2012 ban on incandescent light bulbs, the Progressive Conservatives wanted the ban to start sooner. Then Progressive Conservative party leader John Tory said the Progressive Conservatives wanted the ban to start "as soon as possible" and that the McGuinty government "should get on with it."

However, by that time, industrial and commercial businesses - which then consumed more than 70 percent of Ontario's electricity - were leaving Ontario for places like India and China, where labour costs are exceptionally lower. By 2010, Ontario's industrial sector had been gutted.
The result:
Ontario now has not too little electricity, but too much.
The oversupply is so bad that Ontario sometimes has to pay American facilities to take our excess electricity.

Each kind of bulb has its advantages and disadvantages.
Ontario now has surplus energy.
There is no need to ban incandescent light bulbs.

There is a parallell with this in the ever more connected EU or other international grids:
Any celebrated supposed local lowered energy use by power plants, for whatever reason,
may of course be negated by power plant cross border surplus export!
Politicians won't stop that for industrial political profit reasons.
One message for local environmentalists and consumers,
another message for power-hungry neigbor states waving crisp banknotes under the noses of
local utility owners and legislators.



The local Ontario light bulb ban story has interesting and amusing twists and turns
also for a general audience...

In February of 2006, radical environmentalist Matt Prescott launched a "ban the bulb" campaign to encourage governments to ban the incandescent light bulb and to subsidize fluorescent light bulbs. On April 18, 2007, the McGuinty government announced that it was banning incandescent bulbs starting in 2012. That ban was released as part of a misguided "Flick Off" campaign to discourage electricity use


Aimed at youth, the Flick Off campaign intentionally used a font designed to make the word "Flick" look light a four-letter expletive...


Then Liberal Environment Minister Laurel Broten
introduces Ontario's $500,000.00 contribution to the
"Flick Off" campaign (April 25, 2007). The campaign website's
homepage read: "We need you to FLICK OFF, and tell
everyone you know to FLICK OFF. The more you do it,
the cooler it gets. The planet, that is." The Liberals defended
their half-million dollar expenditure on the campaign:
"It's a suitable website for youth" said Broten.





(If above not work, you may have Flash issues, try original YouTube page, they seem more flexible: http://www.youtube.com/watch?v=1ig65TMTMQY)

"At the same time, the McGuinty government forked out taxpayer dollars for commercials in which TV personality David Suzuki is depicted fictionally snatching incandescent light bulbs from the homes of homeowners, and replacing them with fluorescent ones."

[A parody of this was made by cartoonist Niffiwan]






Finally, returning to the Freedom Party Campaign:

As seen, one campaign mainstay is that there is "no Ontario energy shortage that justifies a ban".
Of course the lighting switchover energy savings themselves are small anyway for society as a whole, which is obviously what should count as a society energy policy.
That is, less than 1% of overall energy use on US, EU and international statistics, or 1-2% of grid energy, as referenced here,
with all the described generation, grid, and other energy efficiency alternatives that will be familiar to regular readers of this blog.


Combining the quoted website source with this earlier policy outline on the issue,
Freedom Party leader Paul McKeever states several reasons why a ban is bad,
as also seen in the summaries and links from this blog.

Certainly, people are not "forced" to use CFLs:
But they are often the only practical alternative,
and regardless of any bans they are of course being pushed on consumers via government sponsored industry CFL programs, with all the handouts and subsidies that involves, in Canada as elsewhere.
CFLs are good in some situations, but not in all lamps in North American households with 40-odd lighting points...

Fluorescent light bulbs have some advantages over incandescent bulbs.
They do not give off as much heat, which is good during hot summer months.
It is claimed that they last longer than incandescent light bulbs.
They also require less electricity.

However, fluorescent light bulbs also have some drawbacks:

• some people have reported the explosion of fluorescent bulbs;
• fluorescent light bulbs contain mercury, which makes them difficult to dispose of in an environmental sound way;
• fluorescent light bulbs are not suitable for exterior use on Canada's freezing cold days of winter, of late fall, and of early spring;
• some people find fluorescent light to be hard on the eyes, especially when reading;
• fluorescent light bulbs do not provide the additional house-warming heat that incandescent light bulbs do for Ontario's cool or freezing days in Autumn, Winter, and Spring; and
• fluorescent light bulbs are much more expensive than incandescent bulbs.

Here are some sobering facts.

Banning 50 cent incandescent bulbs will relieve $4 fluorescent bulb manufacturers of price competition:
the price of flourescent bulbs will most certainly be higher than they would have been but for the ban on incandescents.

Banning incandescents will also relieve bulb manufacturers from competition on light quality: the currently harsh quality of the light provided by non-incandescent bulbs will not improve as quickly as it would have but for the ban on incandescents.

This ban is a bad and harmful idea.
We need more competition and private-sector involvement in power generation and delivery,
not less competition and more government involvement in light-bulbs.

The Ceolas site accompanying this blog has a full account of Why a ban in Canada is particularly wrong (http://ceolas.net/#li11x).
 

Reasoning against the regulations...

The media and online arguments over the coming USA light bulb ban tend to focus either on how much of a "ban" it is, or how terrible or not the main pushed alternatives are, the fluorescent bulbs (CFLs).

Understandable enough, in letting people know what is happening. But there is a lack of wider perspective.

This video interview extract from a couple of days ago by Reason.com editor Nick Gillespie (pictured) with host John Stossel on Fox TV was a welcome change:
Short enough (5 minutes), and with a song interlude, but having time to mention why great products "getting better" should be bought voluntarily irrespective of price, and the big business push behind it.

The John Stossel site (http://www.foxbusiness.com/on-air/stossel/) has more about the show, and other clips from it - it was about the "unintended consequences of big government meddling in our lives".

It also covered the oddness of regulations reducing electricity use and emissions by targeting products people like to use, and how energy efficiency regulations anyway effectively mean cheaper use and greater (wasted) use, negating supposed energy savings.

One could add that the savings involved are very small in overall terms anyway, and all the other reasons against the regulations including the tax alternative for bankrupt governments (California) as summarized in a preceding post on this blog, but it is good to see the issue widened here and there in the media.