More Fun and Games in the European Union

Updated March 30, first posted March 29

While people like me simply comment on light bulb issues,
we should acknowledge our heoroes on the coal face (pun intended), like Howard Brandston in the USA and Kevan Shaw in bonnie Scotland, who actually have to deal with the intransigient legislators!

As covered previously,
Howard was involved in the hearings preceding the US 2007 legislation, and has
commented about it in a worthy e-book read (co-authored with Michael P Leahy, as reviewed).
He has continued to be a lone voice among invited speakers at Congress hearings, such as the one by the Senate Energy Committee last year, and is currently getting a Facebook campaign together, for the general public as well as those with special interest in the issue.

Meanwhile Kevan has do battle with a never ending stream of EU regulation proposals (who knew there were so many lamp types ;-)), moreover written in incomprehensible English, as some of us have seen.
And, similarly to Howard, he is not just as a lighting designer "stakeholder", but also more broadly defending the needs on the public, including those with light sensitivity issues.


Before getting into this, to those not familiar with the EU:
The basic workings of the EU is covered in the introductory section to the Ceolas.net coverage of how the EU Light Bulb Ban came about, "Fun and Games in the European Union", http://ceolas.net/#euban.

So day-to-day it is run by something called the European Commission,
headed up by an unelected body of political cronies called Commissioners, with immense legislative and executive power - they have sole right to initiate legislation concerning all EU members, and also to see that the legislation is carried out.
[The mis-named "European Parliament" is basically a glorified talking shop, and like the nominally overseeing Council of Ministers, usually rubber stamp Commission decisions, with some comment or other addendum, to justify their existence.
Also, because Council decisions are more and more taken by qualified majority, any objecting party has to win over others, which becomes even less likely in the scenario where ministers jet in at regular intervals to sign off on reams of legislation that their COREPER bureaucrat armies stick under their noses]

It should be said that the Commission system had a certain logic when it was known as the High Authority, overseeing coal and steel production for 6 member states, but hardly nowadays.
A particular problem is that money keeps going missing - literally.
The Commission's own accountants have refused to sign off on the accounts for nearly 2 decades now! 2011 report, BBC report in 2007 here.
Insider critical accounts by those directly involved in EU accounting include Marta Andreasen, "Brussels Laid Bare", Paul van Buitenen, "Blowing the Whistle: Fraud in the European Commission", Bernard Connolly, "The Rotten Heart of Europe".
Needless to say they were bumped off rather than praised, while their corrupt masters either stayed in their jobs or got fat pay-offs for their Great Service.

So why do national governments play ball?
Because they also gain in the way the financing works.
The EU Budget was set up as a Gross rather than Net payment system, meaning that net gain countries like Greece make nominal initial contributions, basically to make them feel equal to others.
So countries pay in gross amounts, which they then do everything they can to claw back in all sorts of ways, in agricultural and local spending.
Needless to say the less clearly the money is sloshed around, the better for all concerned.
It is made worse still in that the EU, to win hearts and minds with minimal financial input, often requires "matching local funds" for local projects that they then stick their flag on and brag about - a funding mishmash that again makes auditing difficult.

So it is a Big Circle Game, and a pointless and enormously wasteful one, because the Budget system could of course be run on a Net Pay system: So for example Country X does not pay in 1 billion and desperately claws back 300 million, but simply pays in 700 million for pure EU cross-border project spending - and is responsible for its own local spending, therefore with less waste.
Put another way, it means that all EU Projects are directly financed and monitored instead.

The Commission has lots of Commissioners to satisfy 27 countries, giving obscure "matchstick-making" type responsibilities (look up ec.europa.eu) so everyone has a hook to hang their hat on (with lots of side-hooks for "directorates", departments, committees, and hangaround friends and cronies).

One eager committee is the Committee concerned with Eco-Design in the EU (suitably Orwellian sounding), setting energy efficiency standards on all kinds of products, including lighting.
It should be said that in a free market economy it is perfectly right and understandable to set standards so that products may be graded and more easily traded and sold, with everyone knowing what they are getting.
However, that of course does not necessitate banning products, that are otherwise safe to use.
The lack of logic in all other respects in which the Eco-design committee operates is seen in the Deception arguments 13-point rundown, as seen below or on separate page.

For some kind of legitimacy, this Committee, like other EU institutional organs, pretends - pretends seems to be the operative word - to take into account the wishes of "stakeholders", those with an interest in the legislation at hand (which, interestingly, is never assumed to be the ordinary consumer - the way that EU institutions deal with EU citizens is also dealt with in the account of how the EU ban on light bulbs came about, on the Ceolas.net site).

As a topical point, now on 1 April 2012 with big fanfare the EU will open its "Citizen's Initiative", a 1 million citizen petition system which was also cited as a means for those against the light bulb ban to voice their protest. More about this, and the initiative itself on the Ceolas.net site, http://ceolas.net/#citizenInit. The official EU site about it is here.
As seen the rigorous conditions and all the data required (name, address, place and date of birth, passport number etc for signatures) makes it next to impossible - and then the Commission can reject and alter any proposal anyway!

It is called "European Democracy", folks.




Enter Stakeholder Kevan.

From his blog, the following interesting posts,
edited extracts.

From March 27 post:

Bye bye T12 Fluorescent Lamps

While there has been much concern over the majority of the EcoDesign legislation on lighting emanating from Europe, there has been little attention paid to the impacts of the “Tertiary Lamps” rules.

April 1 2012 sees the banning in Europe of the manufacture and sale of T12 fluorescent tubes.
There are many millions of these older lamps and fitting still in daily use so this legislation will impact on many small businesses who are faced with having to change not just lamps but all their fittings. These lamps are also still in widespread use in the transport sector and can still be seen in London Tube trains of the 1960s and railway carriages in many countries dating from similar periods. So should we welcome this necessity to change at this time?

Kevan seems willing to concede an energy saving justification to their ban compared to other lighting, but the same principles clearly apply to them, in that energy saving mandates change product characteristics, that overall energy savings are limited, and that any "low price giving market failure" argument does not hold up and can be dealt with by several other policies if it did, as per the argumentation rundown on this blog.

T12 types are also being banned in the USA from July 14 2012: more.
I will likely follow this up in another post.


Earlier, more obvious hassle with the European Union...
(amazing news: those who run the EU don't like criticism - let alone any open debate)

Tuesday, February 28, 2012
They knoweth not what they do!

I have upset the EU by blogging the impact of the draft legislation on reflector lamps!

I received a call on Friday from Andras Toth, policy officer at the Directorate General for Energy [and overseeing the Eco-Design Committee] in response to articles in the Daily Mail and Daily Express last week.
He believed that my previous blog on this issue had been the source of these, as usual inflammatory, articles.
It was clear from the conversation that there was no intention to ban MR16, AR111 and other lamps and he felt that the provision for continuing IRC and Xenon filled versions, at least to 2016, answered that. Basically this provision does mean that some of these lamps will still be available, albeit at inflated prices, it does not, however, do anything to ensure that the current huge range of light outputs, beam angles and reflector options will still be available after September 2013.

Press statements from ELC and the Commission have tried to smooth out the situation however the lack of understanding is highlighted by the headline picture in the Commission’s article being a mains voltage rather than a low voltage lamp!

The bottom line remains that we do not know what products will be available after the September 2013 cut off. Requests for information that would enable me to actually work out the “Maximum Energy Efficiency Index” (MEEI) to both lamp manufacturers and the ELC remain unanswered at this date. Until we have this information for ALL currently available lamps no one can claim that lamps are not being banned by this legislation!




Monday, February 06, 2012
New Year New Ban!

MR16 and AR111 Low Voltage Tungsten Halogen Lamps to be banned in September 2013 with more efficient Infra-Red coated types not guaranteed beyond 2016.

This is the proposal in the Draft Legislation on reflector lamps that landed on my desk on January 24. Since then I have been trying to make sense of the implications. To be frank the actual proposal has come as quite a shock after being involved in both consultative and technical sessions on this over the past 3 years. During the most recent technical session in September we thought that the message had got across that there is no reasonable replacement for these LVTH lamps in the market now or in the foreseeable future that will meet the requirements for the professional applications . We also thought that the efficiency requirements would be set to deal with the older and less efficient classes of lamps such as the R40 , PAR38, PAR 30 and the like and permit the LVTH lamps to continue in use to replace the more critical applications for these technologies producing energy savings of 50% or more!

The delay in posting of this blog is that I have been trying to work out exactly what lamps are critically affected.
The problem here is that the energy performance criteria have been set around an arbitrary value of Lumens in a 90 degree cone from the centre of the lamp. This value is just not something that is published by lamp manufacturers. It has no sense or use in the consideration of reflector lamps and can only be properly measured using a goniphotometer, a seriously expensive and relatively rare piece of kit! Again this was pointed out to the technical meeting particularly by the individual countries representatives who will need to use these to undertake market surveillance in order to enforce these regulations.

So I am at this point unable to determine what lamps fall foul of this newly invented and complex metric, the “Maximum Energy Efficiency Index” (MEEI) all I can rely on are the statements in the guidance notes:

Stage 1 (2013)
Poor conventional low voltage halogen lamps (D class) are phased out even at low lumen outputs already in Stage 1.

Phases out quality conventional low voltage halogens starting with high lumen outputs (12V 50W MR16 lamp). Leaves only B-class enhanced lamps (infrared coated or xenon filled)

Stage 2 (2014)
Completes the phase-out started in Stage 1, now applying to low lumen output lamps.

The legislation will be reviewed in 2015.
Meanwhile the lamp industry has no guarantee that TH IRC lamps will be permitted beyond 2016 therefore have no guaranteed return on investment to buy the necessary machinery for the IR coating process. At any event the technical meeting was advised that both the machinery and coating materials have become a monopoly supply in Europe so prices are very likely to increase significantly in the short and medium term.

The legislation also limits efficiencies of LED solutions to points that just cannot be achieved by high quality colour rendering devices and really fails to address the problems in achieving colour consistency and clean narrow beam angles. The meeting in September was also told that in particular MR16 LED lamp replacements could not have their lives guaranteed as components in the integral power supplies are running beyond their design limits.

So we are now in a position where we cannot determine the MEEI of currently available lamps so we just do not know how to correctly advise our clients for whom we have specified LVTH solutions over the past 25 years. As and when the lamp manufacturers provide responses to this I will update this information.

Kevan Shaw 6 February 2012

Regarding the ELC manufacturer association comments

As an industry we are confident that in the future there will remain an adequate choice of high quality, low voltage lamps to satisfy different consumer budgets and needs.

Hardly surprising, for more about the ELC see http://ceolas.net/#ELC.

The mentioned EU press release predictably denies there is a problem, re “press rumors” that low voltage halogens are going to be banned.

As usual they give the impression that they are doing everyone a “favour” by enforcing lower energy usage, ignoring that people can choose it themselves if they want, since of course it also changes lamp characteristics as well as lamp cost.


I am clearly biased against both the EU (as currently run) and its regulations.
However, one can also base such criticism on references and official data, and in the case here, on other ways to achieve any energy saving objectives, even if such objectives themselves are questionable.
 

The Brandston Research Team’s Fluorescent Light Bulb Study

 
From Send Your Light Bulbs To Washington, March 27 post, extracts.

Howard Brandston is a well known New York lighting designer, and is the Congress consultant of choice when they holding hearings into light bulb matters.

The following information is from his website commentary.
As mentioned in a previous post, he is shortly launching a campaign against the light bulb regulations on a Facebook page, details which will appear on the above website link.
Given his status, it will hopefully get a good following.

Research into the Effects and Implications of Increased CFL Use

In September 2009, I assembled a first-class team of doctors and researchers to study the implications of the wide-spread use of CFLs. Supported in part with a grant from the IES, the primary intention was to determine if further investigation and research is warranted to re-examine the direction of current and proposed lighting related legislation. Our study included:

• A literature search of the health hazards post by Electro-magnetic Fields
• Measurements of the fields generated by CFLs
• Measurements of EMF's at installations
• Creation of a detailed list of potential problems stemming from installed CFL usage
• An analysis of actual installation system efficiencies – CFL vs. Incandescent
• An illustration of dimmer induced SPD shifts with CFLs. Illustrated with SPDs.

Our findings fully support that further research must be done. The full research report [originally published March 2010] is available here. The document is large — 3MB (.pdf).
http://www.concerninglight.com/2010-03_Final-Report_comprehensive.pdf

RE " further research must be done", it may be noted that Canada has indeed delayed a ban for (at least) 2 years, in part because of CFL concerns, more:
http://freedomlightbulb.blogspot.com/2011/11/canada-delay-to-2014-its-official.html


Introduction and Conclusion excerpts from the Brandston team study:

The main purpose of the study is to determine if more research is required before the ban on ordinary incandescent lamps takes effect. If it is determined that it would be in the best interest of the country to conduct further studies, then the ban and the restrictions placed on the incandescent lamp should be withdrawn and held in abeyance, until a solid basis can be determined as to what the best course of action be taken to meet the spirit of the act.
All funding by the several government entities promoting the use of CFLs should also cease until there is careful evaluation of relevant CFLs characteristics and comparison with incandescent lamps.

We assembled an experienced interdisciplinary team, fully capable of delivering proposed investigation and research.

Report prepared by:
Howard M. Brandston, FIES, Hon. FCIBSE, FIALD, PLDA, SLL, LC
Philip Brickner, MD St. Vincent’s Hospital
Sasa Djokic, PhD Univ. of Edinburgh
Richard Vincent St. Vincent’s Hospital
Scott Bucher St. Vincent’s Hospital
Heather Auto St. Vincent’s Hospital
Kate Sweater Hickcox Lighting Research Center, RPI


CFLs are not the superior replacement for incandescent lamps, neither in conservation or aesthetics.
Nor is the CFL an equivalent light source technology.
As an indicator of lamp efficiency, lumens-per-watt has been extensively used as a comparative metric to promote the energy advantages of light sources. However, this is flawed because no meaningful conclusions can come from measuring and quantifying an individual type of light source on its own. Lumens-per-watt does not capture any qualitative characteristics, nor does it express the actual performance level of any light source used in practical applications. Most importantly, it does not represent the actual illuminating and spectral properties of a given light source. Lumens-per-watt is simply an idealized quantifier obtained in laboratory measurement, which is often used isolated from other light source characteristics and out of context with the lighting applications under which people live and work. What is really needed is an incandescent lamp with today’s lumen output but with longer life.

Generally, there are no bad light sources, only bad applications.
There are some very laudable characteristics of the CFL, yet the selection of any light source remains inseparable from the luminaire that houses it, along with the space in which both are installed and lighting requirements that need to be satisfied. In the pursuit of more useful lumens-per-watt metric, one must match the luminaire to the space being illuminated.
The lamp, the fixture and the room: all three must work in concert and for the true benefits of end-users. If the CFL should be used for lighting a particular space, or an object within that space, the fixture must be designed to work with that lamp, and that fixture with the room. It is a symbiotic relationship.
A CFL cannot be simply installed in an incandescent fixture and then expected to produce a visual appearance that is more than washed out, foggy and dingy. The whole fixture must be replaced -- light source and luminaire -- and this is never an inexpensive proposition.


Conclusion
“It is wrong to assume that banning the incandescent lamp is an energy- and ecologically conscious action. We have not solved all our lighting problems by finding a highly efficient source. There is presently no lighting technology that can replace certain types and uses of incandescent lamps.”
[ref, IALD]

This study challenges current political consensus and decision to phase out incandescent lamps and switch to CFLs on the assumption that significant energy savings will be achieved without seriously compromising any of the relevant functional and illuminating requirements in target applications. Moreover, and more importantly, the study points out that there is a need to carefully investigate and elucidate some of the important safety concerns that may arise from a prolonged exposure and widespread use of CFLs, of which levels of electromagnetic fields measured around these appliances are illustrated in more detail. (N.B. an initial measurement of approximately 50 DB from a 13W CFL)


We propose the following simple test that may actually provide an effective method for determining whether the legislation will actually serve people:

- Initiate a field study aimed at satisfying the proposed power limits in all public buildings, from museums and hospitals to the White House, and the homes of all elected officials.
- As this will include replacing all incandescent lamps with CFLs, it would be easy to directly ascertain the effects of the proposed legislation/ban.
- Assure that all of these measures to comply with specified power limits in residential units are done and paid for solely by the occupants, i.e. that occupants may freely decide on the use of specific equipment and devices
- At the end of sufficiently long period (e.g. 18 months) check whether the incandescent lighting had not been reinstalled, and perform a detailed survey with all users to determine their overall satisfaction with the initial, intermediate and resulting lighting.
- This will help to identify specific target applications for different light sources, as they will be selected by end-users, based on their needs and requirements.
- In parallel with this field study, initiate and perform detailed research related to determining quantitative and qualitative characteristics of CFLs and other alternative light sources (e.g. LED light sources), as well as the comparative analysis of their relevant aspects and most important effects of use.

Based on the data collected from the above field/labs studies, the Energy Independence and Security Act of 2007 and current lighting related energy legislation still in Congress may be amended, if necessary, to conform to the results of the studies. We expect that the current and proposed legislation would be rewritten in favor of a new act, which will be based on the result of a thoughtful process that could yield a set of proven recommendations that will better serve our nation’s needs by maximizing both human health, environmental satisfaction and energy efficiency. In the end, the most energy effective solution for residences may be achieved using incandescent lamps with a combination of occupancy sensors and dimmers.

As the post also makes clear, regarding the obvious retort of
"incandescents are not banned, energy efficient halogen types allowed",
or
"better LEDs are coming",
and other arguments used to justify bans,
see the 13 point referenced rundown of why the arguments don't hold up below this post,
or on the dedicated page
 

More Fun with Philips: The Philips 95 Watt California Bulb

Update 5 Sep 2012:
Actually, while manufacturers may have profited from regulations they helped to bring about, in the case of the 95 Watt bulbs (similarly 71,57,38 Watt ones) they were just following petty regulations applying from 2008, set down by the California government in reducing bulb wattage (and brightness) a little bit.
For more, see new post of September 4 2012.

#     #     #

Quite a lot about Philips recently here...
their L-Prize LED, their en.lighten campaign involvement with the UN and World Bank, their Phoebus cartel participation, and so on.

They launched a "Philips California bulb" (California approved) as on Bulbs.com of 95W which supposedly circumvents California regulations but really doesn't...

"A former 100-watt light bulb manufactured on or after January 1, 2011 and sold in California will have to use 72 watts or less", California Gov light bulb regulation website, with still stricter standards in 2012.

The Philips California Bulb


Perhaps it just shows the general confusion about light bulb standards...
 

US sales of CFLs have fallen since 2007

 
Thank you to Howard Brandston for this information, via his Facebook page (the "wall" page can be read by anybody logged in).
Incidentally, keep a watch on Howard's website commentary - he is shortly launching a campaign on a new Facebook page. Given his status as renowned lighting designer and congressional consultant on lighting matters, it will hopefully get a good following.

Last week NEMA, the electrical equipment association to which light bulb manufacturers belong and which (as not least seen from Howard's e-book) was heavily involved in pushing for and welcoming the "phase out" of simple incandescent bulbs, published a US sales lighting report.
It not only covers the last quarter of 2011, but also all previous years as useful chart data.

Shipments of Incandescent Lamps Illuminate at the Close of 2011

NEMA’s indexes for incandescent and compact fluorescent (CFL) lamp shipments increased by 29.4 and 3.6 percent, respectively, during Q4 2011 compared to Q3 2011. Incandescent lamp shipments posted a year-over-year gain of 41 percent while CFLs declined by 6.6 percent. The calendar year comparison also showed divergent paths. Shipments of CFLs decreased by 6.6 percent compared to 2010. Conversely, incandescent lamp shipments rose 16.4 percent during 2011. A preponderance–62.1 percent–of the increase over last year occurred during Q4.

Incandescent lamps increased its share of the combined incandescent-CFL market registering a reading of 82.8 percent. Meanwhile, the share of CFLs decreased to 17.2 percent –a ratio of slightly less than one in six lamps sold. The increase in the foothold by incandescent lamps is likely to continue while the new efficiency regulations established by EISA 2007 are phased-in over the next few years. CFLs and other substitute lamp types such as halogen A-Line and LED lamps are then expected to carve out increasing shares of the traditional A-Line market.

Comment

Since NEMA is for the ban, this is hardly biased in favor of incandescents
(besides, either big or small incandescent sales speak against a ban,
big sales = why ban what people prefer,
small sales = why ban when people are voluntarily switching anyway, little savings from a ban).

The relative incandescent sales rise during 2011 is indeed probably related to the growing awareness of the light bulb ban, as NEMA say.

However, what is of greater interest is the stagnation and even relative fall of CFL sales since the 2007 boost, a boost from the extensive subsidy and rebate introduced at the time of the 2007 EISA regulations (the extensive USA CFL promotion campaigns are documented on http://ceolas.net/#li12ax onwards).

In other words, despite the continuation and increase of all the CFL promotion campaigns, subsidies, rebates, handouts etc they are still no more popular.
The sales and market shares of both incandescents and CFLs have held remarkably steady, a slight fall in each perhaps being due to LED sales.

A reasonable reply is that CFLs might be liked, at least if subsidised and handed out, but are simply not suitable for all locations:
Hot or cold ambience, vibration, dampness, enclosed spaces, recesses, existing dimming circuits, timers, movement sensor switching, use in chandeliers and small and unusual lamps, aesthetical use if clear bulbs are preferred, rare usage when cheaper bulbs are preferred - and so on - apart from light quality differences,
particularly noticeable when dimming.

Yes, expensive halogen incandescent alternatives may be offered - but they still have differences to simple cheap incandescents (running hotter and whiter for example), and will as seen from the regulations (http://ceolas.net/#li01inx) also come to be banned for ordinary usage
in the second phase of the 2007 EISA regulations following on after 2014, a phase out which as seen also applies to the European Union.
While the above data does not differentiate simple incandescents from halogen type alternatives, previous data has shown the ongoing popularity of the simpler cheaper incandescents, and NEMA imply the same in their commentary here (the sales rise from 2012 regulations on simple incandescents, the expected increased future sales of halogen type replacements).

Another reply is that LEDs offer an alternative choice - certainly, but again,
with light quality differences in their spiky emission spectra, and with even more light output problems than CFLs to achieve bright (over 60W) light equivalent omnidirectional lighting, and at reasonable cost.


The simple truth is that all lighting has advantages for different uses:
and markets, whether you like them or not, always send a message.
In this case the message is clear - people still like to buy simple incandescent light bulbs.
"Great savings" from banning them is therefore to ban what people would have bought if they could, and as referenced on the Deception page, the overall all-things-considered savings whether of energy or emissions or money, are marginal and irrelevant.
Banning chauffeur driven political limousines might bring "great savings", but that again does not mean that those affected would necessarily be happy with such savings!
 

All about the new Philips LED Bulb, and how it won the L-Prize

Post updated through April 19 - May 1 with new information.
Also, more about Philips lobbying finance in the more recent post here with Senate disclosure records etc.
Otherwise, the post from April 23, and posts that follow about the prize committee lab testing, are also copied below to keep the information complete in one place.

Regarding the earlier post here:
http://freedomlightbulb.blogspot.com/2012/02/philips-osram-and-un-how-we-will.html
"Philips, Osram, the UN and the World Bank:
How we will "en.lighten" the World in 2012"
As seen that was about the worldwide en.lighten program, with public subsidies allowing major manufacturers to dump otherwise unsold bulbs on developing countries.

Philips have been in the news again regarding their prize USA bulb
(Competition website: Competition rules)
Some are entirely made and tested in China, while for the American market, at least in terms of information given in relation to the prize, it is assembled in the U.S. from components manufactured in Shenzhen, China with LED chips made in San Jose, California.

A lot seems to have been going on about it behind the scenes, which also illustrates light subsidy issues more generally, albeit more a reflection of the US Dept of Energy than on Philips, who obviously will take whatever money is going :-)



One of the first articles reporting back on the issue came from the Washington Post, Peter Whoriskey, on the 9th of March, extracts:

The U.S. government last year announced a $10 million award, dubbed the “L Prize,” for any manufacturer that could create a “green” but affordable light bulb.

Energy Secretary Steven Chu said the prize would spur industry to offer the costly bulbs, known as LEDs, at prices “affordable for American families.” There was also a “Buy America” component. Portions of the bulb would have to be made in the United States.

Now the winning bulb is on the market.
The price is $50.
Retailers said the bulb, made by Philips, is likely to be too pricey to have broad appeal. Similar LED bulbs are less than half the cost.

How the expensive bulb won a $10 million government prize meant to foster energy-efficient affordability is one of the curiosities that arise as the country undergoes a massive, mandated turnover from traditional incandescent lamps to more energy-efficient ones.

A rebuttal from both the Dept of Energy and Philips, was to note that the price was expected to come down to 20 dollars or so.

First of all,
this of course raises the general issue of "paying upfront for future savings", and the many reasons that hardly holds with energy efficiency regulations,
in particular light bulb legislation: As extensively covered on Ceolas.net website
from http://ceolas.net/#li12x onwards, and summarized in the deception rundown on the blog, as in savings point 8.

The issue about "CFLs and LEDs becoming cheaper in the future",
is also covered in that rundown, and taken up more extensively on the Send Your Light Bulbs to Washington post, "Will CFLs and LEDs become Cheaper?"



Still, the Philips story has a lot of behind the scenes intrigue to it...
soon after the Washington Post story, also on 9th March, the Reason.com article by Katherine Mangu-Ward Feds Pay $10 Million for $50 Light Bulb, extracts and highlights:

In 2007, when Congress passed legislation that would gradually ban old school incandescent light bulbs, they added a carrot to the pile of sticks: A $10 million dollar prize to encourage the development of a cheap, green, domestic light bulb to replace the dearly departed Edison model.

Five years later, that bulb is coming to a hardware store near you. It will cost you 50 bucks. It also fails to meet many of the original prize specifications. The winner, Dutch electronics company Philips, was the one and only entrant, suggesting that the prize failed to stimulate widespread additional private spending on R&D. The portion of the LED bulb made in America is less than initially envisioned. And the guidelines for pricing were utterly ignored: The goal was $22 price tag in the first year, falling rapidly to $8 by year three.

In this case, the prize was a first-past-the-post arrangement. So electronics giant Philips, which also makes a Chinese-manufactured version of the same product for half the cost, quickly fiddled with the specs and figured out a way to make some of the chips in San Jose—all jobs that will go to American citizens, no doubt—and do the assembly in Wisconsin. Two other companies had announced their intention to join the fray, General Electric and Lighting Science Group, when the Department of Energy abruptly declared a winner.

"We are pleased to be the only one who has submitted anything," chief executive of Philips Lighting North America Zia Eftekhar told National Geographic. "Even though I'm unbelievably happy we won, it's still good to challenge the entire industry to move the technology forward."

One part of that statement is undoubtedly true—Philips was likely quite satisfied to be the only company in the running—but the idea that the prize has moved or will move the industry forward is silly. Instead of spending the time and energy on genuine innovation, Philips diverted resources from developing the bulbs they were planning to build overseas and sell in the United States to tweak their product to conform (not even all that well) to semi-arbitrary guidelines written by a bunch of bureaucrats with the goal of dispensing some guilt cash that was tacked onto a bill that made a product preferred by virtually everyone in the country at the time illegal.

The goal for this prize shouldn't have been fastest, it should have been best. By the time the rules of the competition were announced, it was already apparent that the nation's basic light bulb needs were not going to go unmet. But rather than aim high, the Department of Energy set its sights squarely on a successful press conference at which the backs of congressmen, department officials, and energy execs could be patted and/or scratched. Mission accomplished.

The trade publication Energy Efficiency & Technology notes that the bulbs that are coming to market are actually a little different than the model that won the competition: “The commercial lamp has three rather than four optical segments and uses fewer LEDs. The reason, says Philips, is that LED technology has progressed a bit even since the end of the contest.” In other words, the carrot is worse than irrelevant. Philips dropped whatever they had into the feds’ laps in order to grab the prize and will continue to improve the bulb, running as fast as they can ahead of the stick. (Frankly, it’s a little surprising the sticky gears of the energy bureaucracy didn’t require the company to stick with the federally tested and approved model in order to maintain its favored status. Thanks goodness for small favors.)

While a $10 million check to sell a slight variation on a product you were developing anyway seems like a pretty sweet deal, it’s actually chump change compared to the real prize: preferential treatment by federal buyers and others major players who are beholden to the feds, such as the many utility companies offering subsidies to customers who purchase the bulbs. The knowledge of this pot of gold at the end of the rainbow further reduced Philips' incentive to keep prices low.

But wait: Why would a company that sells power want to subsidize products that help people consume less of what they’re selling? Ordinary economics no longer applies once you go through the looking glass into much of the heavily regulated utility sector. In California, for example, profits and consumption have been “decoupled”: Prices are based solely on what the state deems to be a fair rate of return. Which means that more demand for energy—accompanied by the possibility that new power plants must be built—is just an expensive pain in someone’s butt, not an opportunity to make more money.

Add in a nudge from your industry’s primary federal regulator, and voila!: Power companies are dropping boatloads of Hamiltons on their customers. In fact, that $10 million figure is likely to increase as the Department of Energy pressures utilities to take a bigger bite out of the $50 monster they helped create.

That's not all..
among other observations seen since, the Washington Free Beacon article 14th March by Bill McMorris is of particular interest
"Obama's Dim Bulbs", extracts:

The department [of Energy] has gone from judge to partner to help Philips sell the product. It is now trying to coax utility companies to grant discounts and rebates to customers in order to create demand for the light bulb.

“We are actively working with (utilities) to hammer out deals to introduce the product to their region,” said an official familiar with the L-Prize. “DOE’s mission is energy savings and in order to get that there needs to be widespread market adoption.”

Thirty-one utility companies have partnered with the department and Philips to grant rebates to customers who purchase bulbs, the highest being a $25 rebate from Efficiency Vermont.

Philips Lighting USA has splashed references to the L-Prize bulb—a name assigned to the product by the federal government—and is doing its best to market the product to businesses before launching residential sales next month.

“I know everyone is looking at the $50 price tag, but Philips has been actively working to get those rebates,” company spokeswoman Silvie Casanova said. “The price reflects that it’s harder to make this bulb than existing 60 watt LEDs.”

That technology is also constructed at more expensive plants in Wisconsin and San Jose, rather than the Chinese factories that churn out the company’s existing line of energy efficient bulbs.

Other officials familiar with the project told the Washington Free Beacon that there is little the department or Philips can do to lower the price in the short-term except wait for consumers to adapt the new bulb, as traditional incandescents are phased out.

The steep price tag is not the competition’s first brush with controversy.

A House Appropriations Committee report (pdf) issued in June slammed the department for announcing the $10 million prize without prior approval from Congress.

“The Committee strongly opposes the Department announcing funding opportunities when those funds have not yet been made available by Congress,” the report reads. “In the case of the L Prize, the Department risks damaging its credibility.”

The warning was enough to worry higher-ups at Philips, which spent nearly $1.8 million lobbying Congress to fund the program.

The committee granted the award money to spare the department embarrassment, but changed its rules to prohibit “announcements in advance of appropriations.”

Philips received about $5.6 million from the federal stimulus to advance its LED lighting technology.
It spent nearly as much—$4.5 million since 2008—lobbying Congress and the Obama administration for bills friendly to lighting appropriations.

Casanova refused to “talk to the lobbying spending,” but emphasized that the bulb maker did not use any stimulus dollars for researching the bulb.

“We didn’t get any money to develop this bulb,” she said.

Department officials are backing away from the contest’s initial call to draft an affordable bulb that could come to market at $22 and drop to $8 per bulb by its third year.

“The idea of that light bulb contest was to provide for a goal going further down to get a light bulb that eventually, Americans can afford,” Secretary of Energy Steven Chu told Congress on Tuesday.

Energy officials remain optimistic about the expensive competition and its initial results.

Department lab tests found that the bulbs will last up to 25,000 hours, which would save consumers about $160 over the lifetime of the bulb, according to department estimates.

The department plans to continue with the program, announcing a second competition in March.

The Washington Beacon (see above) in a further article in April by Bill McMorris, had more on this and other mentioned issues. Notice that they also point out how the prize testing lab names were rubbed out (more on this below, also see the technical review copy at the end). My highlighting again:

The Department of Energy awarded lighting giant Philips the $10 million L Prize despite the fact that the winning energy-efficient bulb failed to meet several contest criteria requirements, according to documents obtained by the Washington Free Beacon.

Philips raised eyebrows when it debuted the winning bulb with a $50 price tag. That is far beyond the $22 cost recommended by the department, which is now working with utility companies to cut back on the upfront cost through rebates.

Department documents, however, cast doubt on whether the expensive LED bulb was even worthy of the prize.

Contest rules outlined by the 2007 Energy Independence and Security Act required the winning L Prize bulb to shine at 900 lumens. A department report on 200 bulbs tested at two different facilities showed that nearly 70 bulbs failed to meet that standard, including more than 60 percent of the bulbs tested at one of the labs.

“The integrating sphere test from the [lab name redacted] shows that only 5 of 100 samples tested were below 900 lumens, but the [lab name redacted] integrating sphere testing shows 38 samples that were over 900lm and 62 were under,” the report reads.

Despite Philips’ poor showing at the DOE lab tests, the department passed the bulb after receiving reassurance from the Dutch company.

“Philips data shows all tested lamps (2000) were above 900 lumens. Philips test and modeling data indicate…this criterion will be met in the production lamp,” the report continued.

[More such acceptances of Philips own lab results and promise for production lamp compliance can as said be seen directly on the Test Committee Review comments on the right side of their document report (click on it to enlarge)]

A department spokeswoman insisted that the bulbs met the requirements.

“The minimum output measured in this sample of 200 lamps was 873 lumens and the maximum was 967 lumens, a range consistent with normal manufacturing tolerances,” the spokeswoman said. “The average light output of the 200 samples tested was 910 lumens.”

One lighting expert, however, said the average is not a good indicator of LED performance.

“You have to be very careful in choosing LEDs because there is difficulty in uniformity,” the expert said. “Having that many bulbs fail is suspect, especially if you plan on taking these bulbs to the market.”

Philips spokeswoman Silvie Casanova said the L Prize bulb that will hit store shelves later this spring fulfills every L Prize requirement.

“I’m sure that in the test run, there might have been some that had some performance issues, but I’m sure the department is looking at a baseline of the bulbs overall performance,” she said. “It does meet the requirements; we’re going through Energy Star testing right now” that will verify the company data.

Contest rules mandated that an entrant that failed to meet basic standards would be “terminated” and forced to return to square one of the competition.

There is no indication that Philips’ entry was disqualified, however.

Scientists who developed rival bulbs were outraged when they heard that the department allowed Philips to move forward.

“We treated the standards as Gospel: you had to have 900 lumens, you had to have the right color, the right temperature, the right (light distribution),” said one engineer who worked on the Lighting Sciences Group’s L Prize design.

“We went through revision after revision because if you change the (brightness), the color could be wrong and we’d start over. If we had known we could have fudged the (brightness) then everything else becomes easy,” the engineer said.

In 2009, when other lighting companies were still at the design phase of the process, Philips submitted a 2,000-bulb sample to the department. The quick submission intimidated many others vying for the L Prize, according to multiple industry insiders.

“Not once did the DOE ever let anyone know about the testing results; there was no transparency,” another lighting expert said. “If they had made it known in 2010 that Philips didn’t pass the test, then other competitors would have proceeded forward. The inference was that they passed.”

The department closed the competition and awarded Philips the $10 million prize in August 2011.

The brightness test was not the only requirement that Philips may not have reached. Department notes also indicate that reviewers changed the light distribution criteria to Philips’ favor.

“Testing and modeling of prototype production lamps show the luminous intensity distribution falling below 10 percent from the mean near 150 degrees,” the report said. “However, the TSC finds the use of the 0-135 degree zone acceptable … this is different than the 0-150 zone specified.”

“The department cannot just change the rules on how they are going to test, especially if they don’t tell other competitors about the rule change,” said a second lighting insider. “Only Philips benefited from the criteria change.”


The contest has been marred by several controversies since it opened in 2008.

A House Appropriations Committee report issued in June slammed the department for announcing the $10 million prize without prior approval from Congress.

“The Committee strongly opposes the Department announcing funding opportunities when those funds have not yet been made available by Congress,” the report said. “In the case of the L Prize, the Department risks damaging its credibility.”

The warning was enough to worry higher-ups at Philips, which spent nearly $1.8 million lobbying Congress to fund the program.

The bulb’s $50 price tag also produced sticker shock among industry insiders. It is about double the cost of existing LED bulbs and about fifty times higher than the 60-watt incandescent bulb it was designed to replace.

“I’m impressed with the technology, you’d be hard-pressed to find someone who’s not,” the former LSG engineer said. “But we were going for a $22 bulb, forget rebates, and Philips missed it by a mile.”

The L Prize winner is expected to last 25,000 hours and save consumers $160 over the lifetime of the bulb compared to 60-watt incandescent bulbs, which were outlawed by the 2007 Energy Independence and Security Act (EISA).

Secretary of Energy Steven Chu said the competition helped move LED technology forward by providing companies with incentives to make energy efficient bulbs.

“The idea of that light bulb contest was to provide for a goal going further down to get a light bulb that eventually, Americans can afford,” he told Congress in March.

The former LSG executive is not convinced.

“Letting (the bulb) come out that expensive, I think it set the market back … people are looking for a return on investment and this just tells them they can’t afford any LED bulbs,” he said. “I can’t blame the U.S. citizens for saying, ‘my God, the government is wasting our money.’”

In March, DOE opened the second round of the L Prize competition, which will aim to replace the existing halogen floodlight.

And there is more...

Another angle, from a comment originally by Philip Premysler on Triple Pundit, since updated by him.
It includes relevant documentation links (author's own emphasis in capital letters as well as my bold text highlights):

There are greater troubling issues beyond the price.

The problem is that the L-Prize contest which was supposed to foster U.S. green technology competitiveness was RIGGED.

As a foreign based (headquartered) corporation Philips was excluded from eligibility according to the law that established the L-Prize, in particular public law 110-140 section 655(f)(1).
Under U.S. federal law the term “a primary place of business” used in the statute refers to the single headquarters location, which in the case of Philips is Amsterdam, Netherlands.
Philips, of course, would have known that they were ineligible, so they put out PR flak alleging that the bulb was the result of a global effort. The truth, as evidenced in Philips patent on the bulb, is otherwise.
See Philips L-Bulb Patent.
The bulb was developed in the Netherlands: The patent application which was, originally filed in Europe in 2008, but published in the U.S. two months after the Philips executive made his misrepresentations, lists only Dutch inventors, no U.S. inventors and assignes the patent to the Dutch Philips entity, not to a U.S. entity.

When this issue arose after the announcement of Philips as the L-Prize "winner",
the CEO of Philips Lighting North America Zia Eftekhar went on record falsely stating that the L-Prize bulb was "conceived" and had its "origins" in the U.S.
See EE Times article

[Quoting the article:
"But what about the development of the bulb, and where will it be manufactured?
Zia Eftekhar, CEO of Philips Lighting North America, wanted to set the record straight:
He told me the L Prize bulb “..was conceived, designed, and will be manufactured in the United States.... He repeated this for emphasis: “The origins and development of this product, as well as its future manufacturing are all in the United States."]

These were falsehoods.
In fact Philips' L-Prize entry was invented by three dutch inventors and assigned to Philips of the Netherlands. [As from patent document previously mentioned]


Philips also spent $1.79 Million lobbying for appropriation for the L-PRIZE,
(as referenced, including from Senate Office Of Public Records, Lobbying Disclosure Forms).

Moreover, "A House Appropriations Committee report issued in June slammed the department for announcing the $10 million prize without prior approval from Congress." (Washington Beacon article by Bill McMorris)


The L-Prize entry also failed to meet key technical requirements of the contest. The Philips entry does not meet the stated uniformity requirement of the contest. This is admitted in a document [in its review comments] obtained under the Freedom of Information Act, see http://tinyurl.com/43ECMQM
[alt link to the document source here, easier magnifiable document copy here (click on it to enlarge)].
The curt justification asserted in that document based on comparing uniformity to a standard incandescent lamp is factually (quantifiably) false. The putative L-Prize winner is actually less uniform.

The Philips entry also failed to produce the required amount of light.
In one test 62 out of 100 bulbs failed (see the above linked document).
Whether the commercialized version will consistently produce the required amount of light is an open question [ed- unlikely given that the commercial version is not as good see above]. HOWEVER the stated procedure for the contest was that if the entry failed a required test, the entry would fail.

What happened is that Philips wanted prematurely to claim the prize
(as in Reason.com article) and the Department of Energy did not want to follow the rules and fail them, rather they embarked on RIGGING the contest. They kept the failure secret and proceeded with other tests.

[ed- more on the testing debacle below, also see the comments below to this post]


The result is that a bulb developed by Dutch inventors, built with some (possibly most) of its parts made in Shenzhen China (see http://www.dailytech.com/Philips..) has been given a great initial advantage which may allow it to dominate U.S. competitors, even though the contest is RIGGED.

We may wind up with Dutch citizens enjoying social welfare benefits such as vacations for the unemployed, supported by Chinese workers working 12 hours a day and American consumers squeezed by $50 light bulb prices whether they pay that amount at the check out counter or indirectly pay for subsidies through their electric bill [ed- including the currently planned taxpayer subsidies passed on to stores for price reductions at point of sale].

 


Update:
Philip Premysler's comments regarding the dubious testing were perhaps not as clear as they could have been - and the point was understandably made, in a comment below,
that the bulb after all was passed in all respects by the prize testing committee.

But in looking at the Test Review Comments themselves on the right hand side of the document (click on it to enlarge - or see copy below), the discrepancies start to show up.

While the bulb obviously passes the tests (or of course the prize could not be awarded!), it therefore does so with a lot of provisos, such that Philips own prototype testing are accepted when prize testing lab results show otherwise, and Philips promises about "criterions will be met in production lamp" are also accepted.

Notice also that prize testing lab names whose results conflict are rubbed out (at least 2 labs involved, possibly run by the DOE, judging by the article below).
Why not test results of publicly named labs, in a publicly awarded prize with public money?
As seen in other parts of the assessment the testing by a certain PNNL is not rubbed out. (Pacific Northwest National Laboratory (PNNL) is one of the United States Department of Energy National Laboratories).
In one part, additional to the other criticism mentioned: "Testing conducted by PNNL with a wide variety of dimmers showed several issues with the submitted lamps".


The mentioned test review document copy
(obtained under Freedom of Information legislation)

 

 
 


The US Dept of Energy official site (lightingprize.org) - has a lot more about the evaluation procedure - including their video about the bulb testing:






The just released (April 2012) stress test report follows below.
Alternative link to this PDF document.

As seen, the lab involved was the Pacific Northwest National Laboratory, as mentioned above.








Some recent relevant comments on different posts relating to the testing, extra highlighting (capital letters in original) and direct linking added:

To address the points above as to whether the contest was rigged. If the L-Prize bulb clearly FAILED a technical test where there is a clear cut pass or fail outcome that any freshman engineering student can judge, but the technical review committee writes in PASS and explains, in SECRET, without publishing a rules update, that they are lowering the standard so that they can write in PASS, this is clear cut CORRUPTION.

The technical review committee sought to justify secretly altering the uniformity standard stating
“..however, independent data verifies that this distribution is actually much more uniform than a standard incandescent lamp …“

While there can be no justification for secretly lowering the standard to rigg the contest, astoundingly (or not) this statement is false.
Calculating the standard deviation for the L-Prize bulb tested by the DoE and a standard incandescent lamp, using data provided by the Department of Energy shows that L-Prize lamp tested by the DoE was actually less uniform.
See Light Distribution Analysis (alt link)

The production version of the L-Prize (which by the way appears to be a Chinese product) also does not meet the published L-Prize uniformity criteria of +/-10% of average in the zone 0 to 150 degrees.
See data on page 41 of usa.lighting.philips.com document
Also see: Lab plots of light distribution of Philips bulb (alt link)

The stated procedure for the contest was that if the entry failed a required test the entry would fail.
See flowchart on page 15 of L-Prize competition rules.

Southern California Edison (SCE) which was involved in field testing Philips L-Prize entry, decided to lab test 16 of the bulbs.

It turns out 1 of the 16 exhibited a failure mode in which the light turned red by the time it had 1502 hours of run time. This early failure casts doubt on the 20,000 hour (with 95% confidence) lifetime touted by the Department of Energy.
See link on (Emerging Technologies Coordinating Council) web page http://www.etcc-ca.com/component/content/article/48-Commercial/3044-l-prize-lab-evaluation which has link to report

Quoting from the mentioned Emerging Technologies Coordinating Council (ETCC) webpage

This independent lab assessment was initiated in support of both SCE’s L Prize field testing efforts, as well as its energy efficiency incentive/rebate programs.

SCE’s lab testing capabilities present an enormous resource in understanding and developing confidence in the performance of these units. A winning product stands to undergo considerable mileage in terms of usage/acceptance across the United States. As leaders in energy efficiency, it is important that California utilities stay active in monitoring/assessing such technologies.

Regarding the SCE report about the bulb (long pdf document), from the summary:

The technology shows promise in terms of meeting the efficiency and performance criteria set forth in the L Prize.
However, to better assess feasible implementation into incentive
programs, more investigation is recommended in three key areas:

- Lifetime Testing
o The variation of savings realized with these products throughout their lifetime is not well understood at this point.
Long lifetimes are one of the significant advantages of SSL technology, and should be better understood with this product application.

- Dimming capabilities/issues
o It is not currently known how these products perform when used with other dimmers.
o Their observed inability to toggle off with the selected ELV dimmer presents a large barrier, which needs to be overcome for successful implementation.
(When the ON/OFF function was toggled on the dimmer paired with this product, the product was not able to shut off. It encountered visible flickering at a dimly lit state in the OFF position.)
o The issue of green color shift at low dimming is a barrier to investigate/address for successful implementation

- Thermal effects on product performance
o These lamps are specified to use in dry locations, and not within totally enclosed fixtures. The effects of ambient temperatures/humidities on this technology’s performance and lifetime are not well understood at this point.

The conditions these lamps were subjected to in this lab assessment are within a narrow range, when taking into consideration the various climate zones/applications these general-purpose devices may see.


These key areas represent significant barriers,
to acceptance of this technology when compared with baseline CFLs and incandescents.
Further efforts are recommended to fully understand the benefits of SSL technology in this application, and ensure that product utility is not significantly impacted when encouraging customers to purchase products that are more efficient.
It is recommended that the results of the DOE’s evaluation of the first entry to the “60 Watt incandescent” category be closely monitored;
further understanding of this technology may be achieved through more collaboration with DOE testing, as DOE efforts are initiated/completed.

Regarding this bulb,
dimming is also criticized along with other issues in the committee technical review, above.

Regarding LED technology in general,
as this report also takes up, there are indeed several questionable issues relating to lifespan, enduring brightness, ambient temperature effects etc - apart from the light quality itself:
See the Ceolas website referenced rundown.

The "save energy/money in usage" push should not ignore such factors,
or for that matter the life cycle environmental impact, in terms of components in manufacture (more), energy/emissions in production and (overseas) transport, and environmental dumping when not recycled.
 

Incandescents still going strong here!

 
Engineer and farmer Paul Wheaton and his team behind the Permaculture suite of sites and forums is one of the resource links here.
Among much else they investigate light bulb issues, interestingly being against the light bulb ban from environmental as well as other reasons (unlike many of their green colleagues).

Of the podcasts, one from a few days ago covers his ongoing lifespan comparisons and can be listened to here (mp3 download)

Paul Wheaton talks with Jocelyn Campbell about the CFL experiment he is working on. All the incandescents are still going, one CFL out of 3 is still going, and the LED is still going. He talks a bit about LEDs, and some concerns people have about them.

A good recent summary of Paul's position on the light bulb issue, in particular criticising how CFLs are promoted, can be seen here.
An earlier longer article on the topic: CFL Fluorescent Light Bulbs: More Hype Than Value
 

"Change You Can Believe In"

 
Update March 5:
I have further revised the deception arguments and responses section.


#   #   #   #   #


Original March 1 post:


A main part of this blog, the rundown of the deception arguments used to justify light bulb regulations, and why those arguments don't hold up, is undergoing extensive change.

It seems unbelievable that easily countered assertions continue to be repeated by politicians and media.

Somehow,
to be against a ban, also according to "impartial" media analysing sites,
is to be a "misguided anachronistic backward looking Republican"
(or in Europe and elsewhere, simply to be misguided and backward looking ;-))

Oddly,
regulations are disadvantegous also for "liberal lefties", given the sackful of tax dollars
they could gain for environmental projects (including price lowering of alternative bulbs) on the 1 1/2 - 2 billion annual sales of relevant bulbs.

While taxation is unjustified, it just shows the lack of logic behind the bulb regulations,
for any reason:
http://freedomlightbulb.blogspot.com/p/deception-behind-banning-light-bulbs.html
(also copied below latest postings on the blog)