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.
 

USA: Congress blocks Light Bulb Ban Funding

As of a few minutes ago as this is written, the House of Representatives has easily passed the Omnibus spending package 359 to 67, partly thwarting the light Bulb ban (blocking oversight funding).

January 14 article in USA Today by Wendy Koch

Excerpts:

Congress to bar enforcement of light-bulb phaseoutThe $1.1 trillion spending bill, which covers all federal agencies
and is expected to pass the House and Senate this week, bars the
Department of Energy from spending money to enforce federal rules that
set tougher efficiency standards for light bulbs. Such a measure has
been attached to prior budget deals as well....

This phaseout -- begun in January 2012 with the 100-watt, followed by
the 75-watt last year and the 60-watt and 40-watt this month -- has
angered many Americans who dislike newer bulbs partly because of their
higher up-front costs. House Republicans have tried but failed to stop
the phaseout so they've focused instead on de-funding its enforcement.

In announcing the new budget deal, Rep. Harold Rogers, R-Ky., chairman
of the House Appropriations Committee, called the
light-bulb-efficiency standard "onerous" and welcomed the enforcement
ban.

The issue is also covered Jan 14 on ARS Technica by John Timmer, and more widely repeated:
Unfortunately (!) he gets it wrong that the standards are repealed, rather than just the funding.
"As part of the new budget deal announced today, Congress has voted to eliminate standards for light bulb efficiency"
Perhaps that is why his story was widely reported on the internet.
It follows similar misunderstanding from previous budget blocks.

Nevertheless with slight editing, his remarks were true:

Recent Congresses have tried many times to repeal the standards, but these have all been blocked.
However, US budgets are often used as a vehicle to get policies enacted that couldn't pass otherwise, since having an actual budget is considered too valuable to hold up over relatively minor disputes. The repeal of the [funding of] these standards got attached to the budget and will be passed into law with it.

Following up on this, Washington Post today, Jan 15 in an article, asks...

My emphases and [] added comment:

....So what did Congress just do?

Tucked inside the $1.012 trillion spending bill that Congress is considering, there's a provision that would bar funding for enforcement of the new lightbulb standards. (It's the same bill that Burgess was pushing last summer and which he added to a 2011 budget bill.) That means the Energy Department can't spend any money to prohibit the manufacture or import of old bulbs.


Will this enforcement provision make any difference?

In some ways, no. All of the big manufacturers — General Electric, Philips, Sylvania — have been working for years to comply with the new standards, churning out new CFLs and halogens and LEDs. They're not expected to change course now.

But some stores could, in theory, try to sell the older incandescents if they can get their hands on them. Opponents of the enforcement provision have worried that foreign companies will do exactly that. "Given that American manufacturers have committed to following the law regardless of whether or not it is enforced," said Rep. Marcy Kaptur (D-Ohio) last year, "the only benefit of this ill-informed rider is to allow foreign manufacturers who may not feel a similar obligation—to import noncompliant light bulbs that will not only harm the investments made by U.S. companies, but place at risk the U.S. manufacturing jobs associated with making compliant bulbs."
[presumably more likely re distributors rather than manufacturers]

Whether that happens or not remains to be seen. It's still illegal to make or import old lightbulbs. The rider just makes it a little easier to get away with it in practice.

Again, today:
Fox News 15 January 2014 unsigned article

My emphases added again:

Congress offers glimmer of hope for incandescent light bulb
The House is expected to vote on a $1.1 trillion spending bill that dictates the budgets for all federal agencies House Wednesday afternoon -- and it may be a desperately needed lifeline for the light bulb.

The bill includes a prohibition on funding for “the Administration’s onerous ‘light bulb’ standard,” as Appropriations Committee chairman Hal Rogers (R., Ky) described it, which had sought to dramatically improve the energy efficiency of ordinary incandescent light bulbs but ultimately spelled the end of the road for the century-old technology.

A portion of that 2007 law, which finally took effect on Jan. 1, mandated that manufacturers improve their light bulbs: 40W bulbs must draw just 10.5W, and 60W bulbs must draw no more than 11W. The result is the effectively a ban: Incandescents simply can’t keep up with those twisty compact fluorescent (CFL) and newer LED bulbs.

But there's hope for those glass globes yet, however: Citing “a continued public desire for these products,” the Energy and Water Appropriations section of the bill would prohibit funds to implement or enforce the higher efficiency light bulb standards.

“None of the funds made available in this Act may be used … to implement or enforce the standards established by the tables contained in section 325(i)(1)(B) of the Energy Policy and Conservation Act,” reads section 322 of the bill.

Critics call the funding ban a nuisance, but said it likely won’t stop the shift toward more energy-efficient bulbs, according to USA Today.

"The market has marched forward despite this rider," Franz Matzner, associate director of government affairs at the Natural Resources Defense Council, told the paper. "The manufacturers have all been saying -- we're going to comply anyway."

The demise of the incandescent bulb might come as a surprise to most Americans. A recent study by Lutron pointed out that fewer than 1 in 3 adults (just 28 percent) were aware of the planned phase out. A similar Socket Survey by Sylvania showed slightly more awareness -- 4 in 10 were aware of the phase out, it revealed.

A quick check of Home Depot’s website indicates no shortage of incandescent bulbs; the company sells a six-pack for just under $10 -- and for the born hoarder, a pack of 288 for $118.

In late December, Home Depot told FoxNews.com it had a six-month stockpile before the supplies ran out.

Comment

The amendment to the yearly Water and Energy bill was made in July 2013 by Texan Congressman Michael Burgess
and follows the same manoeuvre in 2012 and 2011.


In practice the result is less clear, as local manufacturers are wary to base production on temporary if to date yearly
Unsurprisingly Texas Congressmen have been behind this, since Gov Rick Perry legalized regular incandescents in Texas which would otherwise be subject to federal opposition, like Arizona gun laws etc


Interesting comment made in the USA Today article above by NRDC (Natural Resources Defense Council), normally very much in favor of the ban as per their website.

With my emphasis

"The market has marched forward despite this rider," says Franz Matzner, associate director of government affairs at the Natural Resources Defense Council, an environmental group. "The manufacturers have all been saying -- we're going to comply anyway."

Yet Matzner says the ban should be eliminated, because it can create a loophole for illegal imports of the old incandescents and doesn't allow DOE to help U.S. companies meet the new standards. The phaseout doesn't stop stores from selling remaining stock of the old bulbs but bars them from making or importing them.

Note, his remark
"the manufacturers have all been saying -- we're going to comply anyway" is presumably in regard to the recent legal block.
Otherwise, as amply covered - and referenced - elsewhere here, major manufacturers jumped in with green activists to seek the ban to stop any small or new local outfits from making the easily made simple generic patent-expired popular cheap bulbs, profitable to the local manufactures on small overheads, but admittedly less profitable than patented complex expensive new CFL/LED alternatives for the majors - and they also wanted "political payback" for any such encouraged investments.
This of course also follows the exact same tactic by the exact same manufacturers to stop small companies from making incandescent bulbs lasting longer than 1000 hours, under the Phoebus cartel, also covered previously here.
Even as the pro-ban lobby themselves typically say, albeit with a different rationale in justifying government legislation:
"The manufacturers had decades to stop making them - but didn't".

As always, the main point is not of manufacturers naturally seeking to make profit and to lobby for them, but rather that legislating politicians wrongfully hand them over...



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.
 

The Odd Green Crony Capitalist Coalition Behind Banning Bulbs

January 7 article by Shawn Regan, from Reason.Com
Good on the industrial policy behind the ban

Lights Out For America’s Favorite Light Bulb
Happy New Year, America! Your favorite light bulb is now illegal.

Well, sort of. As of January 1, U.S. businesses can no longer manufacture or import “general service” incandescent bulbs—the most popular light bulbs in America. Consumers can still buy and use them while supplies last, but the remaining inventory won’t be around for long. Home Depot says it will be out of the bulbs within six months. Some consumers have started to stockpile.

It’s all part of the energy efficiency standards mandated by the Energy Independence and Security Act of 2007. The law already killed off the 100-watt incandescent bulb in 2012, followed by the 75-watt bulb in 2013. Now, in the final step of the phaseout, the minimum efficiency standards have effectively banned the ubiquitous 40- and 60- watt light bulbs.

When industry and environmental groups claim that a regulation will solve all problems, consumers beware. It’s probably green cronyism in disguise.

The ban is crony capitalism in its most seductive form — when it’s disguised as green.

Major light bulb manufacturers supported the ban from the outset.
The profit margin on old-style bulbs was pitifully low, and consumers just weren’t buying the higher-margin efficiency bulbs. New standards were needed, a lobbyist for the National Electrical Manufacturing Association told Congress in 2007, “in order to further educate consumers on the benefits of energy-efficient products.”

So Philips Electronics and other manufacturers joined with environmental groups to push for tighter lighting standards.
As the New York Times Magazine explained in 2011, “Philips told its environmental allies it was well positioned to capitalize on the transition to new technologies and wanted to get ahead of an efficiency movement that was gaining momentum abroad and in states like California.” After much negotiation, a classic “bootleggers-and-Baptists” coalition was born. Industry and environmental groups agreed to endorse legislation to increase lighting efficiency by 25 to 30 percent.

Incandescent light bulbs, we’re told, are vastly inferior to the newfangled alternatives available today.
The compact fluorescents lamps (CFLs), LEDs, and halogen bulbs are an apparent no-brainer: They last longer and convert much more of their energy into light rather than heat, all while cutting back on your energy bill. (So, of course, the government must stop you from ever making the mistake of choosing the traditional bulbs.)

Except many consumers aren’t buying it.
The EPA estimates that, of the four billion light-bulb sockets in United States, more than three billion still hold incandescent bulbs. “By 2014, the traditional incandescent light bulbs… will be virtually obsolete,” claimed a 2007 press release from former Sen. Jeff Bingaman, the ban’s original sponsor. But according to the latest industry data, incandescents still make up nearly 65 percent of all U.S. light-bulb shipments.

Many consumers are turned off by the higher upfront costs of the alternatives.
A single 40-watt LED bulb costs $7.50 or more, while a traditional incandescent bulb goes for around 40 cents. Some are finding that the CFLs don’t last nearly as long as their supporters claim—especially if they are switched on and off frequently, or if they are attached to a dimmer switch.

The list of complaints about the “efficient” bulbs goes on:
They are often slow to respond, sensitive to high temperatures, and can cast a harsh and unattractive tone. CFLs also contain a small amount of mercury, which requires extensive and careful cleanup when a bulb breaks.

And they may not be saving us much energy after all.
The typical U.S. home uses no less energy per capita than it did in the 1970s, despite an onslaught of efficiency standards for everything from refrigerators and televisions to the amount of power consumed when appliances are in “standby mode.” The money saved in the long run by using these appliances is often spent on even more power-sucking gadgets. And if light bulbs cost less to use, why not just leave the lights on longer?

The light-bulb ban is an example of how political coalitions are formed to force regulations on the general public that benefit a few large producers.
A recent survey found that six out of every ten Americans are still in the dark about the latest bulb ban. Meanwhile, the dimwitted light-bulb policy just became the law of the land.
The lesson here is straightforward: When industry and environmental groups claim that a regulation will solve all problems, consumers beware. It’s probably green cronyism in disguise.

Shawn Regan is a research fellow at the Property and Environment Research Center (PERC), a nonprofit research institute in Bozeman, Montana, dedicated to improving environmental quality through property rights and markets.

This complements a January 1 article by Tim Carney at the Washington Examiner.
Tim Carney has for several years covered the industrial policy behind the USA ban.

Industry, not environmentalists, killed traditional bulbs
Say goodbye to the regular light bulb this New Year.

For more than a century, the traditional incandescent bulb was the symbol of American innovation. Starting Jan. 1, the famous bulb is illegal to manufacture in the U.S., and it has become a fitting symbol for the collusion of big business and big government.

The 2007 Energy Bill, a stew of regulations and subsidies, set mandatory efficiency standards for most light bulbs. Any bulbs that couldn't produce a given brightness at the specified energy input would be illegal. That meant the 25-cent bulbs most Americans used in nearly every socket of their home would be outlawed.

People often assume green regulations like this represent the triumph of environmental activists trying to save the planet. That’s rarely the case, and it wasn't here. Light bulb manufacturers whole-heartedly supported the efficiency standards. General Electric, Sylvania and Philips — the three companies that dominated the bulb industry — all backed the 2007 rule, while opposing proposals to explicitly outlaw incandescent technology (thus leaving the door open for high-efficiency incandescents).

This 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. As the New York Times reported in 2011, “Philips formed a coalition with environmental groups including the Natural Resources Defense Council to push for higher standards.”

Industry support for the regulations struck lawmakers and journalists as a ringing endorsement of the regulations. Republican Congressmen Fred Upton, who has since flip-flopped and attacked the regulations, cosponsored the light bulb provision in 2007. His excuse, according to conservatives I spoke to: It couldn't be that bad if the industry supported it.

Liberals used this very argument to ridicule Republicans' 2011 efforts to repeal the law. Democratic congressman Steny Hoyer defended the rule by saying, “The standards are supported by the lightbulb industry.”

Joe Romm at the Center for American Progress pinned repeal efforts on the “extremist Tea Party wing of the party, which opposes all government standards, even ones that the lightbulb industry itself wants.”
That “even” signifies that the industry’s support indicates consensus. Instead, it signifies how consumers lose.

Competitive markets with low costs of entry have a characteristic that consumers love and businesses lament: very low profit margins. GE, Philips and Sylvania dominated the U.S. market in incandescents, but they couldn’t convert that dominance into price hikes. Because of light bulb’s low material and manufacturing costs, any big climb in prices would have invited new competitors to undercut the giants — and that new competitor would probably have won a distribution deal with Wal-Mart.

So, simply the threat of competition kept profit margins low on the traditional light bulb — that's the magic of capitalism. GE and Sylvania searched for higher profits by improving the bulb — think of the GE Soft White bulb. These companies, with their giant research budgets, made advances with halogen, LED and fluorescent technologies, and even high-efficiency incandescents. They sold these bulbs at a much higher prices — but they couldn’t get many customers to buy them for those high prices. That's the hard part about capitalism — consumers, not manufacturers, get to demand what something is worth.

Capitalism ruining their party, the bulb-makers turned to government. Philips teamed up with NRDC. GE leaned on its huge lobbying army — the largest in the nation — and soon they were able to ban the low-profit-margin bulbs.

The high-tech, high-cost, high-margin bulbs have advantages: They live longer and use much less electricity. In the long run, this can save people money. But depending on your circumstances, these gains might be mitigated or eradicated.

The current replacement for traditional bulbs are compact fluorescents (those curly bulbs). They give off UV rays, contain mercury gas, take a while to get bright and don’t last any longer than regular bulbs if you flip them on and off a lot.

Newer technologies, like LED bulbs, are better than CFLs, and they supposedly last 20 years. But they cost even more. In your office building, they probably make sense. In your house? Well they won't last two decades in a house full of kids who wrestle with the dog and throw footballs around the living room (maybe Congress should ban domestic wrestling and passing).

There is a middle ground between everyone using traditional bulbs and traditional bulbs being illegal. It's called free choice: Let people choose if they want more efficient and expensive bulbs. Maybe they'll chose LEDs for some purposes and cheap bulbs for others.

But consumer choice is no good either for nanny-staters or companies seeking high profit margins.

Technologies often run the course from breakthrough innovation to obsolete. Think of the 8-track, the Model T or Kodachrome film. But the market didn’t kill the traditional light bulb. Government did it, at the request of big business.

Timothy P. Carney, The Washington Examiner's senior political columnist, can be contacted at tcarney@washingtonexaminer.com His column appears Sunday and Wednesday on washingtonexaminer.com.

Comment

A lot more on the industrial policy behind the banning of light bulbs in the USA, Europe and elsewhere: http://ceolas.net/#li1ax
Specifically in an American context, also the "I Light Bulb" eBook by M.P. Leahy and Howard Brandston.
Howard Brandston, a well known New York lighting designer, was involved from the start in recurrent Senate hearings, and has covered the strange workings of the NEMA sub-committee (Philips, GE, Osram/Sylvania) in seeking the USA 2007 ban and indeed in their seeking to uphold it through 2011 (and no doubt 2014) reviews and bill attempts at tightening legislation further. His specific webpage and campaign against the regulations: http://www.concerninglight.com/commentary.html

The major manufacturers not unnaturally want to sell more profitable patented expensive alternative bulbs, and feel that any obstruction would be reneging on "promises" by politicians to smooth the way for them through initial consultation and legislation as per 2007 US law, 2008 Canada law, or 2009 Australia and EU laws.
Philips, GE, Osram/Sylvania cooperated to ensure incandescents did not have more than 1000 hour lifespan (the Phoebus cartel) and then cooperated to get rid of them altogether. Slam-Dunk.



Paul Wheaton

Note the irony:
Any outsider would of course consider it unusual that manufacturers would voluntarily seek to legally limit what they are allowed to make, and to welcome such laws once they are made.
The manufacturers are therefore repeatedly lauded by perennially clueless journalists for their "great green conscience", and of course happily strengthen such an image in their press releases.

Somewhat more perceptive observers remark that the manufacturers could have voluntarily stopped making the bulbs, just like they stop making much else in the name of progress - but that would therefore have allowed small and new and local manufacturers to happily and profitably make the patent expired generic cheap bulbs, without global distributive overheads or commitments to expensive alternatives.

In turn misunderstanding the process, "progressive green" people claim that legislation was necessary or the manufacturers would "never" have stopped making the old bulbs.
Apart from ignoring that incandescent lighting might have light quality and other advantages beyond crass economic or energy use reasoning (and the supposed savings not being there anyway as per other argumentation), this ignores what "progress" is: and it is hardly expensively imitative replacement clones of incandescent bulbs.
Increased - not reduced - competition drives progress, and it is conveniently forgotten that CFLs and LED bulbs were invented in the presence - not the absence - of incandescent competition, moreover that new inventions can always be helped to market albeit without continuing subsidies, allowing the best alternatives to flourish, with "expensive to buy but cheap in the long run" advantages highlighted by imaginative advertising, as is done for other products.

Overall it is of course odd to ban popular safe products just to reduce electricity consumption.
There are plenty of ways to reduce say coal use or emission or electricity, whether by legislation or taxation, and plenty of informative possibilities to say encourage lighting to be switched off rather than to ban a particular choice of it.

There is nothing but idiocy behind this banning of light bulbs.


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.
 

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.