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

Wednesday, May 2, 2012

Howard Brandston Senate Testimony and Follow-Up

Updated May 3 with direct link to video clip of his testimony

Well known New York lighting designer Howard Brandston has been covered before in the excellent work he is doing to try to save the availability of regular incandescent light bulbs in the USA and indeed elsewhere.

A lot of his good defensive argumentation has arisen from participating in the Senate hearing
hearing in March 2011, of the B.U.L.B. (Better Use of Light Bulbs!) bill s395 seeking to repeal the federal ban on regular incandescent light bulbs.

Click to go to the Committee Video of the Hearing:

Alternative links to the video, on Committee site or on C-Span

Link clip of Howard's speech,
and the support shown to him by one of the committee members:

The full hearing record can be seen here (pdf document).
Howard's testimony begins on page 53 of the testimony (page 57 in the pdf document).

As seen, it includes both the version as spoken, and the fuller submitted written version
The written version is also handily available on Kevan Shaw's Save the Bulb site, here, posted march 13 2011, copied below, with my highlighting.

Howard Brandston’s testimony to the US Senate

Howard presented the following very eloquent testimony to the US Senate Energy Committee on 10 March 2011, It states the case beautifully:

Chairman Bingaman and ranking member Murkowski, thank you for inviting me to testify today in support of S395, The Better Use of Light Bulbs Act.
My name is Howard Brandston – I am a lighting designer with over 50 years experience and have completed nearly 3000 projects in approximately 60 countries. I am particularly proud of the work I did for my country, the United States of America. A short list that of that work you might recognize includes: The US Pavilion, Expo 70, Japan; Women’s Rights National Historic Park, Seneca Falls, NY; Memorial for Women in Military Service, Arlington National Cemetery, Washington DC and the relighting of the Statue of Liberty, New York City, NY.

I am here today to ask that you revisit a portion of the Energy Independence and Security Act of 2007 that provides for a de facto ban on the traditional incandescent light bulbs. I firmly believe that the restrictions put on incandescent lamps will have a significant negative impact on almost every residence in our country. I believe how one lives in their home is a decision that rests with the occupant and is not the purview of the government. I believe this violates the very principles upon which this nation was founded and I, as a devoted citizen, am most proud of, our freedom of choice in our personal lives.

What disturbs me even more is that the restrictions placed on incandescent lamps will not save enough energy to be worth the expense and the risks that every person in America will be subjected to. Some of the most knowledgeable people I know have begun to stockpile a lifetime supply of incandescent lamps to protect themselves from the need to use Compact Fluorescent Lamps. The public at large does not understand the problems as these professionals do. And further, the misleading claims made about the benefits of the lamp technologies that are touted as beneficial replacements seduce people to purchase these products. We have over 100 years experience using incandescent lamps. By comparison we have very little experience using the new light sources – especially in residences.

You will hear a wide range of statistical data of energy saved in comparative terms that give the illusion of saving energy and the environment- the plain truth is – according to the Energy Information Administration – only 3.6% of total energy is consumed by incandescent lamps. So you will save some portion of that miniscule number. But I ask, when you enter everyone’s home, and subject them and their families to the list of potential consequences I will list, is that worth it? I do not believe it is.

Consider the following:

• Lighting is not a product – it is a system designed for a purpose.
This act separates one component of that system, the light source, and that destroys the success of the final design.

• Although lamp manufacturers are developing new sources to compete with the incandescent lamp, if they are so superior they should be able to compete in the open marketplace where price will be a factor. Alternative lighting to the incandescent lamp will have to be worth price differential.

• The Compact Fluorescent Lamp contains mercury. This 2007 light bulb standard brings a deadly poison into every residence in our nation.

• The plastic lamp jacket warning is totally insufficient to protect the user. It is a cop-out to protect the manufacturer.

• We do not have enough knowledge of the potential consequences of being continuously exposed to the electromagnetic fields Compact Fluorescent Lamps emit. There are millions of people with Lupus, an auto-immune disease. Exposure to low doses of light from these lamps causes a severe rash. There are over one hundred auto immune diseases.

• Currently you come home and your old fashioned incandescent lamps provide a safe, flattering comfortable scene. You can easily dim these old lamps and the light they emit becomes even more inviting.

• The compact fluorescent lamp does not dim well and the color of the light it emits deteriorates as you continue to dim it.

• If you do not install these lamps in appropriate fixtures they might cause a fire. Save energy by incinerating part of your home.

• The cost to retrofit your lighting to use the new light sources may be beyond the financial and technical capacity of most home owners.

• This Standard sends lamp-manufacturing jobs to China.

I have a particular passion for saving energy – I was a member of the committee that wrote the first energy code for the USA in 1975. My contribution was the mathematical formula that set the upper power limit for lighting in that code. It was a performance based equation – not a product restricting simplistic solution. The Energy Information Administration noted that by the year 2000 it cut the energy used for lighting to pre-1970 levels. It cut in less than half the energy used for lighting by 1990.
The Energy Independence and Security Act of 2007 ignores the fundamentals of good lighting practice and intrudes on our ability to choose how we live. Please respect the privacy of our homes, allow people their indispensible right to choose how they live and light their homes and eliminate the restrictions on the incandescent lamp.

Thank You. I look forward to answering any questions you may have

Since then, Howard has followed up with a good lengthier rundown of issues arising from the Hearing - including answering questions put to him by Senators.

Copy below from his website commentary section,
direct link to the document, alt link.


I started going through a lengthy comment - so many good points there - but it is probably easier to see how most of them find echo in the The Deception: The Arguments behind the Light Bulb Ban page (regular readers might notice I renamed it... calling it "The Deception behind Banning Light Bulbs" led to too many assuming it was yet another "Hey this is not really a ban" type of statement!).

Indeed the "this is not a ban, you can still buy replacement incandescents like halogens, for regular use" type of argument predictably resurfaces.

It should be noted that those touted replacements will in fact be banned too
in phase 2 of EISA that kicks in after 2014, that politicians fail or conveniently forget to take account of http://ceolas.net/#li01inx

Besides, the Halogen and other replacement type incandescents have already existed for some time, and are not popular with either consumers or politicians, as they cost much more for marginal energy savings, so politicians have not pushed their use with subsidies etc as with "energy saving" fluorescent bulbs (CFLs).

The replacement incandescents also have differences in light quality, in running hotter, and so on, compared to traditional simple incandescent bulbs, and in the EU are hardly available anyway, CFL usage being pushed also in the in-store display of supermarkets and general stores.

Finally, one has to be aware that the manufacturers supporting the ban would hardly
seek to further improve incandescent technology, given the more profitable alternatives,
as covered in the linked Deception rundown.
In the EU, the promised Philips Halogen Ecosaver improvement was quietly shelved, once the ban was in place.

To take up another point,
Cooper goes on to say, ―Our analysis of the energy efficiency gap identifies a number of market imperfections that cause the market to undersupply energy efficiency… Standards are the ideal way to address these market imperfections

It is odd how the Consumer association representative is so against consumer choice.
His repeated arguments, also in other statements, is of "market failure",
which he then basically clarifies (put more simply) as
"people won't buy expensive bulbs even if they save money by doing so"

Of course, there are other reasons to choose a light bulb than to save money,
and as Howard also goes into, overall savings are much smaller than supposed, for many reasons.

On a more basic market level, people also don't keep buying cheap products that don't satisfy their needs, while expensive alternatives are not avoided either - or no-one would be buying woollen coats, Energizer/Duracell longlasting batteries, certain washing up liquids etc "expensive to buy but cheap in the long run" - and properly marketed as such.

Mr Cooper is even wrong, if he had been right(!):
That is, if it was really necessary to interfere in the market,
then a tax on incandescents could subsidise lower prices on CFLs and LEDs,
equilibrating the market, making money for politicians (for other or additional spending),
and keep choice,
while not "just hitting people with taxes" in that they would have cheaper alternatives than before.

No, I don't expect Mr Cooper understands that either...
and taxation is not justifiable of itself anyway (if a specific light bulb policy really was needed, stimulating competition would be better also to save energy, as in the Deception rundown explanation) - it simply is just another reason the arguments don't hold up...

(I will likely edit and brush up on this post in coming days)

No comments: