A JOLT with Sensible Energy Policy...

Interesting article regarding the overall point of banning light bulbs rather than dealing with power plants themselves for energy or emission policy
(light bulbs which don't themselves burn any fossil fuel or release any supposed global warming emissions, though the bulbs do provide a bit of heat!)

"How many Virginians Does it Take to Screw-up a Light Bulb Phase-Out?"
April 11, 2014 by Kit Mathers, Associate Copy Editor, JOLT (The Richmond Journal of Law and Technology)

How many Virginians Does it Take to Screw-up a Light Bulb Phase-Out?
In January, Congress, through overwhelming bipartisan cooperation, approved, and President Obama signed into law, a $1.1 trillion omnibus spending bill; a provision of which precludes the U.S. Department of Energy (“DOE”) from spending allocated funds to enforce twilight measures of a “light bulb phase-out” mandated by the 2007 Energy Independence and Security Act (“EISA”).[1]

The phase-out, which effectively began in January 2012, requires that light bulbs produce a certain level of brightness at specified energy levels.[2]

Of particular significance to the average consumer, traditional incandescent light bulbs are incapable of fulfilling the new energy efficiency standards and as of January 1, 2014 60- and 40-watt incandescent light bulbs (which represent half of the consumer light bulb market) are no longer allowed to be manufactured or imported into the U.S.[3]

Overall, the standards set forth by the EISA are predicted to result in annual electric bill savings of nearly $13-billion, power savings equivalent to the output of 30 large power plants, and will reduce carbon dioxide emissions by about 100 million tons per year.[4]

The spending bill’s ban is not particularly formidable from the perspective of many environmentalists and “pro phase-out” light bulb manufacturers who have characterized it as a nuisance that can’t possibly derail the “market shift” toward more energy-efficient light bulbs.[5]

But should we be more supportive of the spending bill’s ban despite the EISA’s potential environmental benefits?
In support of the ban, House Republicans have stated that EISA phase-out requirements are characteristic of government overreach, and enforcement measures should not be tolerated.[6]

Is there any merit to the House Republicans’ argument?
Is federal product regulation really the proper avenue for catalyzing change in consumer power consumption?
The tension at the heart of the light bulb phase-out is representative of a fundamental issue that must be addressed in any discussion of “where” energy regulations should be focused. I tend to agree with House Republicans who are wary of the government’s reach into consumer purchasing power, but perhaps end-user regulation (“downstream”) is the most parsimonious way of realizing change in energy use and accompanying (upstream) emissions.
Upstream regulation is inescapably difficult. State and federal regulation of power plants and their emissions is tedious work, often drawn out interminably by litigation. But then again, why not increasingly regulate power plants themselves if we are operating under the guise that the end goal is to limit carbon emissions and power plant out-put? It’s not as though the light bulbs are the source of poor energy management decisions or egregious carbon emissions. Understanding why the EISA, in large part, came to be makes the decision to regulate downstream consumer choice even less palatable.

While the EISA does not outrightly proscribe the manufacture or importation of all incandescent light bulbs, it has the net effect of increasing market prevalence and selection of more expensive, compact fluorescent light bulbs (“CFLs”) and light emitting diodes (“LEDs”) which is extremely beneficial to major light bulb manufacturers.
As Timothy Carey of the Washington Examiner details, the 2007 Energy Independence and Security Act “wasn’t a case of an industry getting on board with an inevitable regulation in order to tweak it. The lighting industry was the main reason the legislation was moving.”[7] The light bulb industry is, by its nature, a competitive market with no significant impediments to entry. Characteristic of such competitive markets, under the neoclassical economic model, is product pricing at marginal cost – the cost of producing one additional unit of output- which results in low profit margins.[8] GE, Philips and Sylvania, which dominate the U.S. incandescent light bulb market, want to “convert their dominance into price hikes,” but because market entry is not significantly encumbered by manufacturing or regulatory costs, consumers will gladly purchase new alternative brands that offer bulbs at, or close to, marginal cost.[9] Market giants, with significant capital available for research and development programs, sought to extinguish the threat of competition (which keeps profit margins low) by expending significant money to improve the incandescent light bulb, primarily through advancing halogen, LED and fluorescent technologies.[10] These “energy efficient bulbs” sell at a much higher price point compared to incandescent light bulbs, and because of this, consumer choice has remained somewhat stagnant and heavily biased toward incandescents. Light bulb manufacturers, aware that consumers won’t willingly skirt cost benefit considerations in light bulb selection, have thus collaborated with groups like the NRDC in lobbying for the phase out of incandescents; their agenda being the “push” of profitable products rather than environmental conservancy.[11] Undoubtedly, there are great advantages to newer bulb technologies, as well as associated costs.[12] However, it’s extremely hard to justify the handcuffing of consumer freedom of choice when it is being instituted by government elites and unelected bureaucrats.[13]

All in all, it is extremely important to ask, where (or at what phase) should regulatory efforts be focused (and why)? The upstream power plants, downstream consumers, or both?
Perhaps the fact that light bulb manufacturers are sustaining windfall profits from federal regulation is an inevitable consequence; in any regulatory effort there will always be a party that benefits, perhaps grossly, from regulation. It will be interesting to see what happens to the spending bill’s ban in the coming months, and whether or not downstream regulation will accomplish its goals.

[1] Bill Chappell, Obama Signs Trillion-Dollar Spending Bill, NPR, (January 17, 2014), http://www.npr.org/blogs/thetwo-way/2014/01/17/263511534/obama-signs-trillion-dollar-federal-spending-bill.

[2] Jeremy Kaplan, Last light: Final Phaseout of Incandescent Bulbs Coming Jan. 1, FOX NEWS, (December 13, 2013), http://www.foxnews.com/tech/2013/12/13/final-phase-out-incandescent-light-bulbs-jan-1/.

[3] Patrick J. Kiger, U.S. Phase-out of Incandescent Light Bulbs Continues in 2014 with 40-, 60-Watt Varieties, NATIONAL GEOGRAPHIC, (December 31, 2013), http://energyblog.nationalgeographic.com/2013/12/31/u-s-phase-out-of-incandescent-light-bulbs-continues-in-2014-with-40-60-watt-varieties/.

[4] NRDC Fact Sheet, Shedding New Light on the U.S. Energy Efficiency Standards for Everyday Light Bulbs, NRDC, (January 2013), http://www.nrdc.org/energy/energyefficientlightbulbs/files/shedding-new-light-FS.pdf.

[5] Wendy Koch, Congress to Bar Enforcement of Light-bulb Phaseout, USA TODAY, (January 14, 2014), http://www.usatoday.com/story/news/nation/2014/01/14/coal-projects-light-bulb-rules/4476103/.

[6] Timothy P. Carney, Industry, not Environmentalists, Killed Traditional Light Bulbs, WASHINGTON EXAMINER, (January 1, 2014), http://washingtonexaminer.com/article/2541430.
[Tim Carney has extensively and critically covered the issue, from an industrial political angle, as covered on this blog here before]

[7] Id.

[8] See id.

[9] See id.

[10] See id.

[11] For a comical portrayal of the “story behind the ban” (in both the U.S. and Canada) see this crude cartoon: http://www.youtube.com/watch?v=ta2ozf_uJJ8 (a feature from infra note 15).
["Mr Stinkypants" as also featured before here on freedomlightbulb]

[12] It’s contended that new light bulb technologies are not all that “efficient” when used by the average consumer. I recommend looking at Paul Wheaton’s website for a critique of the science behind the phase-out: http://www.richsoil.com/CFL-fluorescent-light-bulbs.jsp.
[Good article, also linked here previously]

[13] See id.

Comment
"It's not as though the light bulbs are the source of poor energy management decisions or egregious carbon emissions."
Exactly
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.

Little attention is paid to practicality rather than side-by-side bulb energy saving theory.
This includes not just compensatory consumer behavior, like leaving lights on because cheaper (and fluorescent on-off switching decreases life span) or using more LEDs due being directional, or higher than supposed wattages for perceived output weakness etc.

Specifically, it includes the main evening/night off-peak time of use of simple incandescent bulbs when surplus electricity available, and coal plants in particular - the main "culprit" - effectively burn the same coal regardless of bulb used, due their minimum night cycle level covering any such demand and not being lowered due operational cost
(slow downturn and stoking up to daytime level and associated wear and
tear).

As referenced with grid data, coal plant and energy commission references etc, below.
Including that those manufacturers already cooperated in the Phoebus cartel to limit standard incandescent lifespan to 1000 hrs...
There is nothing wrong in manufacturers seeking and lobbying for profitable decisions.
There is every wrong in politicians handing them profits at the stroke of a pen.

As for the "necessity" to regulate given that consumers prefer cheap products that hardly holds up either. Plenty of other products are marketed and sold as being "Expensive to buy but Cheap in the long run".
And, even if bulbs "had to" be targeted, competition stimulation (helping new bulbs to market without continuing subsidy) or taxation/subsidy policy, taxing cheap bulbs which could cover price lowering subsidy on alternatives, would still be more relevant to both supposedly save energy, and keep choice.

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


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.
 

Disc Power

It should be clear by now to readers of this blog how incandescent light bulbs are popular, simple, cheap and yes, efficient, in needing few parts to produce bright light, and without supposed energy saving to society (incandescents as the "real green" bulbs).

Unsurprising, then, that people around the world are using workarounds to be able to keep using them. Dumb governments, who make pointless and unpopular laws to suit lobbying profitmakers rather than their citizens, will always find such reactions.

In Europe as in North America, one such avenue has been the use of still legal "rough service" type of bulbs, as well as currently temporarily allowed halogen types.
There are also alternative voltage and current altering ways (in bulbs or externally) that extend incandescent lifetime albeit with some brightness loss.
The various workarounds were most recently covered in the post "USA and Canada Light Bulb Ban: Now and in the Future" from earlier this year.

One innovative way was as seen recently launched in the USA by two bright entrepreneurs, Lisa Elder and Trishah Woolley, using a disc with any ordinary light bulb.
To expand a little more about the California based Power Disc venture, edited extracts from the website, powerdisc.com...

It consists of a nylon reinforced thermoset plastic disc, a solid-state rectifying diode and a foam washer with an adhesive surface. The PowerDiscTM is attached to the base of a light bulb by means of the 3M adhesive coated foam so that the center contact of the bulb is in contact with one end of the diode. When screwed into a light socket, the other end of the diode contacts the center contact of the light socket.

By converting the electricity power used by the bulb from AC to DC, the PowerDisc™ significantly reduces energy consumption up to 42% and also extends the bulb life up to 100 times therefore reducing bulb replacement costs.

In other words, 120 volts of alternating current (AC) are converted to approximately 85 volts direct current (DC).
The light bulb filaments, that actually create the light we see, will burn at a much lower temperature...The degree to which the filament is heated is directly related to the life of the bulb.

Using the formula from the General Electric Incandescent Lamps Booklet (ref. GE #TP-1100R2 5/84) we calculate the life of the bulb with the reduced voltage.... example...

[On the light output reduction issue, making comparisons:]

As it is well known in the industry, all energy efficient light bulbs will have some reduction in lumens (light output), initially up to 30% over the first couple of months. Take note of the packaging for CFL and LED bulbs, they claim they will operate at 70% efficacy - which means they know their bulbs will lose 30% in lumens. Example, the packaging states 1000 lumens but they "guarantee" that the bulb will operate at 700 lumens.

Also the "long life" incandescent and halogen bulbs which operate at 130 volts, when you use it in a 120 volt socket, there is an immediate 25% lumen loss from what is stated on the packaging. Example, the packaging states 1000 lumens but in a 120V socket it is really 750 lumens.

With the PowerDisc there is also an initial lumen loss, the difference is the bulb will maintain that lumen level for the life of the bulb- it won't get dimmer and dimmer over time until it burns out. If it is necessary to maintain similar lumen levels it is recommended to increase the wattage of the light bulb used. The lumen level of the light bulb is dependent upon the manufacturer, clear or frosted and type of light bulb being used. Also keep in mind the lumen level you have upon insertion will be the lumen level for the rest of the life of your bulb until the day it burns out, which means it does not diminish over time, whereas with CFLs and LEDs you get around a 30% lumen loss in the first couple of months, then it slowly decreases until it is very dim. This makes for safety and security issues in certain areas.

If it is important to maintain the visible light level, a higher wattage bulb should be used...but as bulb wattage increases, efficiency in the transformation of electricity to light also increases.

So to begin with the downside, there is a seeming 25-30% brightness loss which means higher electricity costs for a bulb of given brightness, compared with an ordinary simple incandescent bulb.
But... the point is of course is that as such bulbs gradually get banned (and in the USA as in Europe there is talk of controlling the availability of rough service incandescents for ordinary consumers), it allows the extended use of any such bulb without hoarding.
Also, as they say, fluorescents and LEDs dim as they are used, reducing their effective light output too.
Finally the advantage of not having to change bulbs may be useful in some locations.

Overall, good to see this innovative spirit from others who are against the ban - and doing something about it!


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.
 

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.

 
 

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.
 

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.
 

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.
 

Canada to adopt more US Laws beginning with Light Bulbs: Losing Industry, Jobs and Choice, with Hardly any Savings

Last updated December 23
Update info: Campaign against the ban by Federal MP (Government Conservative party) Cheryl Gallant of Ontario, blog post about it (December 23).
Also Section 1 of the Document revised, consequent (P7 version) updates also done to Doc and PDF links below.


The below constitutes 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

Email: equipment@nrcan.gc.ca Telephone: 613-996-4359
John Cockburn, Director Equipment Division Office of Energy Efficiency Natural Resources Canada CEF, Building 3, Observatory Crescent, 1st Floor
Ottawa, Ontario Fax: 613-947-5286
But best to also contact local media etc. Media very quiet on this.


What Canadians are not being told about January 1 2014 Light Bulb Regulations

Enforcing US Law:
Losing Independence, Industry, Jobs and Choice,
with Hardly any Savings and Hardly any Halogens.


In a seemingly hastily written October proposal, just in time to invite standard 75 day comment by December 19
(leaving little time for any subsequent serious analysis, should perchance the Cabinet be interested in doing so),
Canadians are told that by aligning to USA standards Halogen bulbs, similar to regular incandescent bulbs, will not be banned.

They will.
And that's just the start.


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.

Full version:  As Doc    As PDF
Parts 1-3 reproduced below



1. Why Alignment to USA will also ban Halogens

USA Energy Independence and Security Act 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"

A backstop final rule relates to a cycle of rulemaking that will start in 2014.

" BACKSTOP REQUIREMENT— if the final rule [not later than January 1, 2017] does not produce savings that are greater than or equal to the savings from a minimum efficacy standard of 45 lumens per watt, effective beginning January 1, 2020, the Secretary shall prohibit the sale of any general service lamp that does not meet a minimum efficacy standard of 45 lumens per watt"

As the Energy Information Administration at the Department of Energy puts it, the second tier of energy efficiency improvements “at the latest becomes effective by 2020, essentially requiring general service bulbs to be as efficient as today's CFLs"


The stated main purpose of the current light bulb proposal is to align with US legislation.
Comparatively, the original MEPS legislation can be seen at SOR/94-651 part 1 Items 136-139 with luminous flux based definitions (unfortunately not shown or linked in the proposal). The US wattage based regulations were previously deliberately avoided, citing several disadvantages with the US system including less bright bulbs being allowed in place of brighter ones, usage of higher wattage class defeating the purpose etc. This is not mentioned now in changing standards.

The proposed adoption of USA law is justified as facilitating company product development and distribution to a bigger market, now and in the future, and is to be followed by similar adoption of US law for other products for the same reasons.
With light bulbs a further highlighted beneficial effect is said to be that American standards will allow incandescents in the form of Halogens, albeit still with differences to simple incandescents and a lot more expensive.
However, not only would some higher energy efficiency halogen types not have been banned anyway under the originally proposed legislation, but as seen current USA legislation bans all incandescent technology including touted halogen replacements for general service lighting, EISA tier 2 2014-2017 45 lumen per Watt final rule which equates to fluorescent bulb standard. Replacement Halogens at 18 lumen per Watt, 20-22 at best, are way below that.
The notion that manufacturers would improve halogens falls on commercial consideration (as they at length explained in the November 25 EU meeting and documentation), and for example Philips already quietly dropped promised EcoVantage development once the 2009 EU ban had been achieved.

Aligning with US legislation of course means that guarantees about what will or won't be allowed can no longer be given.

To reply that
"Canada will just adopt the first (USA Tier 1) levels and won't ban Halogens even if the USA does",
is not in keeping with proposal's purpose and argumentation of aligning with USA standards in the first place, including the specifically stated supposed advantages of suppliers not having to deal with two standards for products.

Notice also that 45 lumen per watt is a minimum standard and is set to be followed by others (USA background documentation talks of Tier 3 in 2020).
Notice also that these are and would be technology-neutral standards.
So the splitting up of different products for distribution becomes more difficult anyway, and of course all the more so should further USA rules not be to Canadian taste.

45 lumen per watt is as said based on fluorescent lamps that are going out of political favour, and the hitherto mercury-exception of fluorescent lamps may come to be abolished, if they don't disappear from markets beforehand given recent decreases of allowable mercury levels in some jurisdictions like the EU, which make them less commercially viable to sell.
Of course those who criticise bans on incandescent bulbs might be pleased, should the CFL (fluorescent, "energy saving") bulbs disappear. But that would be on top of banning incandescents, and would hardly happen until other replacements have found political (if not popular) replacement favor.

The big noise in the world of lighting regulation is "Ledification", Japan aiming for a total switch by 2020 and the European Commission in current talks with manufacturer representatives in dealing with the timing of banning halogens and pushing a LED switchover.
[LEDs certainly have energy efficiency advantages, but are also very difficult to make as bright omnidirectional incandescent bulb replacements at low prices, along with having a number of health and environmental concerns of their own as covered later. The simple fact is that all lighting types have advantages and disadvantages, and bans of any should surely be approached with caution. The main distinctive technology advantages are of incandescents as bulbs, fluorescents as long tubes and LEDs as sheets - which is also how the latter 2 were first developed]

Notice how all this is applicable to any aligning to allow Washington to dictate what Canadians can or can't buy, and which may or may not be to Canadian taste, not just with light bulbs, and not just with energy efficiency regulations, given the stated ambition to expand such regulatory alignment and favour multinationals in their North American product development and future distribution of products (see section 2 on industry policy below).

Alternatively, the Canada Government knows about and plans a future ban on halogens.
It is after all true to say that "halogens will still be allowed" - for now.
They would also be doing exactly what USA, EU, and Australia ruling officials did before them:
Wave funny bulbs around to visibly show they were "doing something" about global warming, while "assuring" everybody that "lookalike halogens" to traditional bulbs would still be allowed
It would also seem strange if Canadian lawmakers did not know US law before shifting to it.


The proposal finishes, perhaps with admirable openness:

"...over time, it is anticipated that the proposed standards would help to increase the level of acceptability for MEPS [Minimum Energy Performance Standards] for many Canadians, thus facilitating the adoption of further MEPS for these and other products in the future."

Put the frog into boiling water - it jumps out.
Put the frog into cold water and keep heating it - the frog is cooked
"How to Cook our Canadians"

So, Canadian Cabinet...how about the Canadian public not being duped about "what is allowed"?


In this regard, one should also be aware of how regulations are coordinated and arranged to achieve a desired purpose (read, ban completion).
Jurisdictions like Canada, EU, USA and Australia are in close contact as seen from background documentation to legislation and international meetings between energy agency officials and major manufacturer representatives.

Regulations are therefore divided into Tier 1 and Tier 2 processes.
The original 2012 Canada plans also had a Tier 2 2015 phase-out intention.
Staggered implementation is of course understandable in cushioning the effect both for manufacturers and consumers as new technology is introduced.
However that also allows - or should allow - unbiased monitoring of the effects on consumers of lighting availability and quality, and that supposed energy saving actually takes place.
But follow-ups are no fun for politicians - promises are. The typically and suitably long-term savings projections also apply for Canada (2025, see the proposal annex) allowing catchy quotable big savings figures, and then to say "Well, buddy, we'll check on that in 2025"! Brilliant - the decision makers long since having retired.
Suggested evaluation based on just measuring assumed savings from how products have been adopted (handy for the backing companies, who don't have to pay for that research themselves!) is hardly the same - and misses the overall consumer impact.
In BureaucratSpeak, "stakeholders" aren't any guys and gals strolling around Queen Street in Toronto.

Both the EU and the USA have 2014 review processes:
These should therefore have meant a neutral assessment of Tier 1.But as the continued bans are already written into legislation, the reviews are mainly about alternative lamps and possible change in the timing of Tier 2 implementation. Talk about a 1-way street.

As for the USA, it's not just that halogens are legislated to disappear sometime before 2020. The Obama administration in cooperation with the Democrat controlled Senate Energy Committee already tried to tighten lamp and other energy efficiency regulations in 2011. But as with many bills, it did not make it through Congress. Lowering the standards requires Congress passage, and the President's signature. Hardly anytime soon.

A further possible reason why the officials writing the laws want Tier 2 bans already legislated in place, is the difficulty and nuisance of having to revisit the issue in public or parliamentary debate.
US law is of course already difficult to alter as just noted, and this applies also in the 28 nation and multi-institutional EU.

Canada is different, and could be different, in openly considering what is right or wrong, and not just for multinational corporations.


The proposal here does commendably invite public comment....
but why is it kept away from Canadian Parliament for debate, all the more so since proposal comment finishes Dec 19, with MPs already being off looking for turkeys and tourtières on the 13th and not back until Jan 27?
The government cabinet rubberstamping American legislation into place over the holiday period surely sets a bad precedent if it hasn't done so already, given the mentioned ramifications.


The bigger picture about the light bulb regulations is not any guarantee about halogens.
The bigger picture is about why light bulb ban regulation is necessary in the first place - and particularly in Canada.

Canada has no obligation to ban either halogens or simple incandescents.
This was shown in already delaying ban implementation.
Canada is - still - an independent country.
If it is not in the interest of Canada, Canadian business, Canadian jobs, or Canadian consumers to ban lighting products on other than safety grounds, then it should not be done.

And it isn't...




2. What is good for Canadian Industry, Jobs and Consumers?

"This proposed amendment would support the Government’s regulatory policy of aligning with American standards, where feasible"
"it is anticipated that the proposed standards would help to increase the level of acceptability for MEPS for many Canadians, thus facilitating the adoption of further MEPS for these and other products in the future."
"compliance risks are much less than they would be if Canada had unique standards. Canada would benefit from the compliance regime that is in place to support U.S. standards."

Adoption of US standards for many more products - not just concerning energy efficiency - is set to continue.
The US dominance on the North American market hardly means Washington adopting Ottawa standards.

This does not just sideline Canadian autonomy for its own sake.
It means no longer making products to specific Canadian demands, should they conflict with American desire.

So, should the border just be shut, to only have "Canadian products for Canadians"?
No, the point is not the protectionism angle.
The point is that allowing American standard products in Canada, does not mean having to ban products made to specific Canadian demand and desire.
Manufacturers can still make American standard products both for internal market or export, as they wish.

Presumably if the American standard is so attractive for the major multinationals for market reasons, then they'll make to that standard, and leave the smaller specific Canada demand to Canadian suppliers.
They don't "have to suffer regulatory burden by making products to 2 standards", as the proposal basically puts it.


This is therefore about a lot more than light bulbs, it is about any product that because of climate, geography, culture, or other reason might be of value to Canadian consumers.

Legally, in a case of regulatory conflict between the Canada and USA standards,
if a Canadian requirement is deemed less stringent, that is obviously not a problem - the point here.
If a Canadian requirement is more stringent, perhaps on environmental or safety grounds, that is still justified on Canadian rights as a sovereign country.

The Government proposal at hand is overly focused on helping major manufacturers sell in both countries, repeatedly stating so.
Maybe some more widespread consideration is justified.

Yet even on such narrowly defined market-minded economic justification for bowing to Washington, the question is if it's a good policy.

To keep adopting US standards will likely cost Canadian supply and distribution jobs,
especially of already existing standards as supply and distribution to those standards is already well established on the bigger US market, but also of simultaneously applied standards, as larger US based suppliers simply extend the reach for their products.

Conversely, while still allowing such free trade movement of goods,
the freedom of manufacture to local needs gives local jobs and locally satisfied consumers.
Also if Americans are not making or distributing such products then clearly all the better for Canadian jobs.


Turning now specifically to energy efficiency regulations, such as on light bulbs,
the relevance of what has been said is even greater, on several counts.

Firstly, by adopting US legislation, USA based control becomes even more likely - after all, their manufacturers and distributors have had regulatory knowledge and established implementation for several years on any such regulatory shift. With the light bulbs, that's 7 years knowledge and 2 years implementation for the US rivals.
After all, the proposal makes much of how manufacturers prepare for standards in advance (and, conversely, if anything, Canadian suppliers prepared for the wrong MEPS standard).

Secondly, how big is current and assumed future Canadian light bulb production anyway?
While I have been unable to find figures (and, again, the proposal could have supplied them!) it presumably mirrors the USA and EU in dominant Chinese CFL/LED imports and dwindling local incandescent/halogen manufacture.
Maybe it's great to help the Chinese (as also outsourced by Philips. GE or Osram-Sylvania) but surely not of utmost importance, and on the distribution side that again comes down to likely American control on a unified market for reasons given.

Thirdly, with energy efficiency regulations it need not be USA versus Canada standards.
Not having energy efficiency regulations in the first place opens up to true manufacturer freedom without the "regulatory burden" that the proposal worries so much about.
That obviously need defending of itself, and will be done for light bulbs, but one should also be well aware of what it would mean for industrial policy and jobs, given the industry focus in the proposal.

The tone of the proposal is of abandoning regulations with threatened chaos.
But it is just to continue without implementation, and with manufacturer and consumer freedom.
A freedom that allows the start up of making popular bulbs, that hasn't hitherto happened given threatened regulation.


The popularity of bulbs to be banned (phased out, regulated..) is hardly in doubt.
If they were not popular, there would be no "need" to ban them and celebrate the supposed savings.
There are in fact many reasons why it is both easy and attractive to set up local small/new Canadian manufacture and sale with associated jobs of traditional light bulbs.
Firstly in being popular, as mentioned.
Secondly in being simple and easy to make.
Thirdly in being generic patent-free bulbs without licensing requirement from major manufacturers (now guess why GE/Philips/Osram-Sylvania want those bulbs banned).
Finally, in being without competition from America, and with likely little competition from anywhere else - while always allowing alternative "energy saving" bulb manufacture and sale as desired on the market.
Canada could have a considerable domestic light bulb industry of incandescent lighting.
Can the same be said about CFLs or LEDs?



Responding to the idea that regulations might actually not be imposed, the proposal suggests:

"Canada could become susceptible to product dumping from manufacturers from other countries seeking to sell traditional incandescent light bulbs no longer permitted in their own country."

This repeats what they said 2008 in defending the first MEPS regulations.
But bans have now already been legislated in many other jurisdictions (rationale later) and the proposal itself emphasizes how manufacturers prepare for them.
So the notion that those guys have been stockpiling incandescents on-the-side, just to dump on Canada in case Canada does not implement a ban, hardly holds.
Besides, Canadians would get more choice, and would have to want to buy them in the first place - "terrible" if they can buy what they want?
Finally, any dumping problem can always be met by import controls - it does not necessitate, nor does it justify, banning what people want to buy.


Two further justifications are given for not abandoning regulations:

"Suppliers to the Canadian light bulb market have already made considerable investments in research, development and retooling to meet the MEPS as written in 2008.
Canadian retailers have begun selling, promoting, and educating consumers about more efficient bulbs."

As for Canadian retailers,
I am sure they would be delighted to sell whatever Canadians want to buy.
Educating about "efficient bulbs" - that presumably means bulbs efficient in producing bright light using few components?
No? Well, that just shows how politically correct language is defined - handily substituting "efficient" for "energy efficient"
(as with calling fluorescent bulbs "energy saving" bulbs:
Hello Mr Retailer, can I have one of those Energy Wasting bulbs please? Ah, gosh, thanks very much!)

As for suppliers to the market,
the odd notion is this invitation to cry for them when they now instead have full freedom to make and supply what they want - including the bulbs they prepared for.
Compare with if they had been busy preparing to sell a bulb that was then made illegal!

The manufacturers were perfectly free themselves to stop selling incandescents if "they are so bad for the planet", as their press releases keep saying, and the media keeps swallowing. After all - the same GE/Philips and other companies stopped making record players, cassettes, 8-tracks and much else in the name of "progress".
But "unfortunately", others would make the popular bulbs if they stopped!
No manufacturer/distributor should rely on bans on competition to shift product they presumably have some sort of confidence and ability to sell.
Besides, the big American market would still have the limited competition they want.

Moreover, if the suppliers were preparing for the Canadian standard, "MEPS as written in 2008" and it "is a burden to make and distribute to both American and Canadian standard", well, then the suppliers have been preparing for the wrong standard, with Canada Gov now pulling the rug from under their feet!
Also, the fact that simple traditional light bulbs are easy to make means those guys can easily "retool" and make them too, and have the limited competition from USA on that score as already described.
Don't cry for me, Argentina.


For deeper discussion of industrial policy and manufacturers, see section 8

Meanwhile, do these bulbs really have any value for Canadians?.....



3. How Incandescents have particular advantages for Canadians

First, a summary of general advantages of Incandescents, then particular advantages to Canadians, and afterwards, a look at simple incandescent advantages vis-à-vis Halogens.

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.
 

Kevan Shaw Report: November 25 EU Consultation Forum

Regarding the EU Consultation Forum on domestic lighting November 25 meeting in Brussels
A report was posted here November 26.

Reproduced here:

Concerning the EU (European Commission) Light Bulb Review and their proposal to alter the regulations as laid out in detail previously:

Yesterday saw the previously mentioned meeting in Brussels of the Consultation Forum involving the Commission, national energy representatives and a few lighting "stakeholder" delegates.
I will expand on anything arising out of this: Suffice to say that while LightingEurope (representing Philips, Osram, GE and other major manufacturers, pre-meeting official statement of their position) and a few other lighting representatives were for the continuation of halogens without time limit, most of the energy agency type people predictably wanted to keep the 2016 ban, with some national representatives (eg Germany, Austria and Italy) wanting at least a delay, in that sense siding with the Commission 2 year delay proposal.
As this was just a consultation, decisions will take some time yet. Final decision on all aspects of the regulation review will be made by April 2014.

The most surprising aspect of the meeting was the focus on clamping down on "rough service" type industrial bulb sales to ordinary consumers - EU light bulb sales inspectors will likely be authorised to patrol the sale outlets of member nations, as already demanded by Energy Commissioner Oettinger for his native Germany. The idea therefore already has strong backing from the boss - and this time nearly all are for it, including the major manufacturers, as a lot of those bulbs are cheap Chinese imports. Thereby also "useful EU job creation" achieved. General applause.
What, the consumer? When were consumers ever important?!


#   #   #


Award winning (Lux UK Designer of the Year) Kevan Shaw of SavetheBulb.org has published a fuller analysis of the meeting and future prospects... The Latest from Europe

Extracts, my highlighting:

The Latest from Europe

Review of Ecodesign regulation 244/2009 stage 6

The Consultation meeting that took place in Brussels on 25 November revealed clearly that the EcoDesign process, particularly for lighting products is now only a political action.

In the meeting the majority of the national representatives spoke against delay or removal of the ban, not for substantial reasons of energy savings but because it might be seen as a precedent for delays or revisions for other products in the EcoDesign system.
There was also considerable support not to look at this issue in isolation but conflate it with the omnibus review of the regulation next year to save these civil servants from having to attend any more meetings where they are clearly completely out of their depth on fundamentals of the technologies being discussed.

The gloves are also off the conceit that these regulations are “Technology Neutral”.
Clear statements were made that funding would be provided for SSL but not other research.
[this was also seen in the circulated Commission proposal leading up to the meeting]

The UK representative claimed that the statements in lighting industry press clearly showed that SSL was the "only future for lighting". This obvious gullibility to marketing messages is truly scary in the context of pan European regulations that will, in effect kill off the only remaining bulk lamp manufacturing in Europe, which is tungsten halogen.

There is also seemingly no need to prove that the existing regulation has been effective in its core purpose of saving energy. The argument here is that energy use may have gone up despite the regulations but if the regulations had not been in place the increase would have been far worse!.....It was pointed out that the regulation has been very effective in bringing to the public’s attention that "something was being done" about energy use in Europe.

As for any negative impact on consumers, these are brushed under the carpet of savings on energy bills.
The unrealistic life in service expectations of extortionately priced SSL lamps, again largely statistical rather than actual, feed this argument.
Health concerns? Not the concern of this process SCENHIR deals with that.
Product safety? Again not a concern of this process. In the last year there have been 6 recalls of LED replacement lamps that I am aware of. These have been for life safety issues, touchable parts of the lamps becoming live to mains electricity. Throughout my long career in lighting I can only remember one recall of an incandescent lamp and that was because some shattered when they failed at end of a full service life.

There was some indication of the expectations of the omnibus review.
Spearheaded by Sweden and vociferously supported by CLASP the umbrella research organisation funded by the green pressure groups including WWF, Greenpeace etc, the proposal is that only A class lamps should be available in the market by 2020 if not sooner! ....Even SSL will not be able to deliver the warm colour appearance good colour rendering light that we are used to at the levels of “efficiency” demanded.
The near future looks like becoming cold and dead looking place.

Comment

Excellent if a little depressing!

The declared position of the main lighting manufacturers is as seen against the energy agency type people, but clearly
their worry of losing profit is not the same as when cheap simple incandescents were legal.
It would rather seem to be a marketing exercise for manufacturers to support the more expensive halogens, also presumably having more of an "ear to the ground" of what consumers want - compared to the civil servants and ideological fanatics as per the above. But manufacturers also know full well that they can simply point a finger at the Commission for any unpopular decision made (and in addition can then claim to have "tried on behalf of consumers to save the halogens"). Maybe that's their game all along - they know full well the position of agencies and Commission, and at the end of the day can simply count the profit - and reap all the subsidies - pertaining to LED manufacture and sales.
That leaves naive people like me thinking that manufacturers, for once, might have been concerned about people's choices without wholly regard to profit.
But, to repeat, manufacturers can and arguably should lobby for profitable decisions on behalf of their shareholders.
The problem, as always, is the extent that the Commission only listens to them, or indeed the national agency types or environmental pressure groups - which brings us back to the democratic acceptance of other views, and the various comments by other groups and individuals as highlighted here in recent days.


There is a further aspect to the review democracy, as highlighted by these type of meetings:
Not just who is allowed to attend, and not just that others are not heard (file your opinion in the waste paper bin/trash can), but of knowing who was there in the first place.

Who sits on the "Commission Ecodesign Committee", that pours out legislative initiatives on everything from light bulbs to vacuum cleaners to TV sets, which will apply to the EU?
Nobody knows - Nobody is allowed to know.
By research reports and other roundabout ways (eg who sits on the DG Energy C3 Committee on Energy Efficient Products) one gets to know some likely names on the Commission side - but that's it.
They don't even seem to have a secretariat. At most they have an email address type "tren-ecodesign@ec.europa.eu" but they never reply.
You might as well be dealing with the Cosa Nostra.

Much the same with these Consultation Forums.
Again, by various reports one finds out some likely representatives.
The Commission can rightly say that it's up to National Governments, Trade Organisations and Energy Saving Associations to decide who they want to send to represent them.
But that does not excuse saying afterwards who attended - after all, they have a monitored, named guest list of all who attended.
It's not as if it was the Ku Klux Klan attendance list. Presumably there is no shame/reluctance in name revelation.

The point is this: The Commission has sole rights to initiate legislation in the EU - presumably those selectively invited are invited to give valued input into this, and presumably they would not attend otherwise.
They should therefore stand by what they say - openly.
It's not good enough to say "by contacting the organisations concerned, they may say who was sent".
No real minutes are revealed (see the summary type below), no real information about what was discussed or who said what.

That's not all.
In any voting procedure, only the overall result is given. Not even the names of countries/organisations (as applicable) voting for/against, let alone reprentatives themselves.

Compare with equivalent launching of consultative forums or hearings in say the USA, or in individual European countries at least of the Western democratic tradition.
I have covered US Senate Hearings, similar to the EU Consultation Forum in having invited representative participation - that's even televised (C-Span) or retrievable by video. Video!!!
If any EU Commission hearing even had summary minutes released by someone, he or she would probably be crucified within minutes up on the Berlaymont.


The following shows replies I recently received looking for information.

They suggest looking at vacuum cleaner legislation as an example (this was before the light bulb review).
Vacuum cleaners of course will also soon be limited in energy use, so expect to spend twice as long cleaning up and use the same energy anyway.

Members of the Regulatory Committee are representatives of Member
States of the European Union (EU). A list of the persons who
participated in a particular meeting is not published on the EU’s
‘EUROPA’ web portal.

You may want to contact directly the Permanent Representations of the
Member States to enquire about whether the names of delegates in a
particular meeting are available. You can find the relevant contact
details on the EU’s ‘whoiswho’ portal at the following URL:
http://europa.eu/whoiswho/public/index.cfm?fuseaction=idea.hierarchy&nodeID=3780&lang=en

Furthermore, you might be interested to know that by consulting a
Summary Record of one of the Ecodesign regulatory Committee, you can
find at the end of the document the Ministry/Department/Agency which
represented the Member State in that particular Committee meeting
[Ecodesign Committee has the reference: C07900]. An example is the
meeting of 27/02/2013 on vacuum cleaners:
http://ec.europa.eu/transparency/regcomitology/index.cfm?do=search.documentdetail&F8O7DquaYsFIjeSNfyvxNCwAqN39eC+0fCcDkqDDB/sxdbQ+AI/X9VTTMRqv00VG

We hope you find this information useful. Please contact us again if
you have other questions.

PDF documents below, in case not seen:
Document 1
A typical Ecodesign meeting's summary report and (as here) a brief voting record

Document 2
A list of typical national ministries and agencies represented (anonymously)











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.