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

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

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

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

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

Campaign site: stopthelightbulbban.ca
Petition signing.


Campaign site message:

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

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

Letter circulated around 14th December

Dear friends,

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

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

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

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

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

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

Sincerely,

Cheryl

How Regulations are Wrongly Justified
14 points, referenced:
Includes why the overall society savings aren't there, and even if they were, why alternative policies are better, including alternative policies that target light bulbs.
 

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.
 

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

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


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


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

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



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

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

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


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

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

Full version:  As Doc    As PDF


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




9.  Alternative Policies targeting Light Bulbs    


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

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

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




Information Policies  


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

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

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

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

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

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

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

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




Taxation-Subsidies  


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

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

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

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

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

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

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

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

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


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

There is a still better alternative...




Stimulation of Free Market Competition  


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

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

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

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

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

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


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

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

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


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

How many citizens should be allowed to choose?
Everyone.



How Regulations are Wrongly Justified
14 points, referenced:
Includes why the overall society savings aren't there, and even if they were, why alternative policies are better, including alternative policies that target light bulbs.