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

Monday, December 2, 2013

Learning from History: Audio Incandescent and Solid State

Revision, additions: December 2, November 29     Original Post: November 28

The beginning of the EU review of the 2009 light bulb regulations which sees the November 25 launch of the EU (European) Commission alteration proposals has been covered here earlier with extensive analysis.
Subsequent posts have covered industry views, mainly LightingEurope (Philips, Osram and other manufacturers).

The main recommendation here as part of the first stage 6 review by the Commission, concerning the future of halogen replacements, is to allow frosted halogen bulbs, which were not banned for any energy efficiency reason but rather to push sales of CFLs, an outdated legacy ban given that solid-state LEDs exist in both clear and frosted versions and will "be bought more and more" according to both the Commission and its energy efficiency advisers, on the basis of becoming "ever better and cheaper", which rather takes away the whole point of the ban.


Compare the close historical relationship to incandescent audio tubes/valves...
after all, who are the major light bulb manufacturers?



source  vintage ad browser







     





The tubes (structurally like incandescent bulbs) were not banned in radios and other audio equipment when "ever better and cheaper" solid-state transistors (structurally like LE diodes) came along: manufacturers - not governments - supplied energy-efficient market demand.


Today's EU Commission would have jumped on top of the "energy-guzzling" tubes.


Never mind that they have retained niche uses - and launched a rock and roll guitar amplifier age.
As with light bulbs, the Killjoy Commission would have been at the forefront of ban implementation to make sure that never happened - which just goes to show that setting usage standards does not just ban existing products - they ban what could have existed, and never will.
Relating such argument to light bulbs, see the post "What We Will Never See".




So who do the Commission talk to about all this?
"Stakeholders".
Ordinary people are never seen by the EU as stakeholders. They just have to swallow what's coming to them.
In fairness, "everyone can't be heard", but Consultation Forums that fill the room with Energy Agency Yes-Men hardly make for balanced conversation.

This is also why alternative views to the EU process have been posted here in recent days.




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.
 

About This Blog


This blog accompanies the website New Electric Politics (http://ceolas.net/).


Why is this blog called Freedom Light Bulb?

The obvious assumption is that this is about individual freedom versus society good.
Wrong.
This is about individual freedom and what is good for society.
On overall energy use as well as on environmental factors, energy standard based bans on simple light bulbs make no sense, as will be shown - while at the same time obviously limiting choice.


But this also goes beyond light bulbs.
It is about the relationship between individual and society, and further to that, the relationship between citizen, industry, government and environment.

It is also about regulations on any product in society:
about seeing the advantages that different products have for different uses,
rather than to look for disadvantages as reasons for their destruction
,
including any government mandated "improvement" that unnecessarily affects their advantages, by bureacratic committees setting arbitrary cut-off points for the allowed existence of otherwise safe products - since citizens are otherwise too stupid to buy what committee members and their political promoters think is "right".

Progress is welcomed - not feared.
Progress brings more choice and more advantages, a progress helped - not hindered - by allowing competition against that which already exists.
This gives the best products at the lowest price: including the best energy saving products, since energy saving is a positive marketable advantage.

The Big Picture is about the need to save energy in the first place, and if so, about alternative energy sources, about electricity generation, grid upgrades, smart grid technology.
It is not about "enlightened politicians" engaging with delighted patent profiting corporations to force feed consumers with new unproven shoddy expensive "Green Technology" they would not otherwise buy, so that the idiot citizens can all save money "in the long run".
In the long run they are all dead, and have questionably made savings on what they did not want in the first place. If they had "sufficiently" wanted what is offered instead, the bans would not have been "necessary".


The light bulb ban is a good illustration:

A product ban justified neither on safety grounds or to save energy.
A symbolic feel good gesture to save the planet, that also happens to deliver big profits to lobbying manufacturers by destroying a bright and popular but also cheap and patent expired "generic" product, in the name of government defined progress.

Government control over citizens - or federal control over states - can be questioned at the best of times. And it can clearly be questioned here.

All products have advantages - all have their reason for existence.
Even if light bulbs - or buildings, cars, washing machines, refrigerators, TV sets, computers and much else - "needed" government policies for product and resource saving progress, then government supported consumer information or government taxation would still be better, not just to keep choice, but ironically also to save energy, for reasons described and referenced.


The website light bulb section more thoroughly lays out why the light bulb regulations are a bad idea, whether to save energy, emissions, or money, or for any of the other reasons held to justify the regulations.
This is done mainly with North American, European and Australian references and links, though the principles of course apply everywhere.

Given the research behind the website, I am getting news updates and other information that may better be suited to a blog, so will see how it goes.

A summary of my position on light bulb regulations can be seen here

For a more comprehensive rundown of reasons why light bulb regulations are wrong,
and how consumers hardly save money regardless of energy savings,
see the page "How Regulations are Wrongly Justified"
 

Friday, November 29, 2013

Kevan Shaw Report:
November 25 EU Consultation Forum


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

Reproduced here:

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

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

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


#   #   #


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

Extracts, my highlighting:


The Latest from Europe

Review of Ecodesign regulation 244/2009 stage 6

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

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

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

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

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

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

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


Comment

Excellent if a little depressing!

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


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

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

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

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

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

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


The following shows replies I recently received looking for information.

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


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

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

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

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


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

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











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

Wednesday, November 27, 2013

Lamp Guide Site: Environment


Also given the recent posts commenting on EU light bulb laws:
A good Lamp Guide.
Aside from much well illustrated practical advice, it also covers health and environmental issues.


Below: the environment section should be viewable








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.