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

Monday, December 30, 2013

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

Update, additions Jan 1 2014

There are particular reasons to have focused on the Canada light bulb ban in the past several posts.
Firstly, because unlike USA or EU there is some sort of chance of avoiding or at least overturning it later, given a simpler lawmaking procedure in a smaller jurisdiction.
Secondly, because it is particularly odd to ban them in such a country.

Strange to ban a popular safe product:

It's not like banning lead paint, and some of the suggested replacements are arguably less safe to use.
CFLs have known light quality and safety issues, while expensive and subsidised LED clones for many rarely used bulbs in a 36 bulb Canada household hardly saves money and is hardly progress, LEDs use up many rare earth minerals and with several health and environmental issues themselves (eg ANSES France, UC Davis California investigations).

Incandescents have many specific advantages for Canadians:

Canadians live in relatively large homes where much time is spent with varied lighting conditions, and where incandescent light quality, reaction time, brightness, sensor/dimming and other versatility is welcome, along with bulb heat on most dark nights.
Incandescent advantages for Canadians are covered at length in section 3 of the analysis as listed below.
Also see "Why ban in Canada particularly wrong" (http://ceolas.net/#li11x)

Major manufacturers Philips, Osram and GE have oddly welcomed being told what they can or can't make:

They have lobbied in different countries including Canada for a ban on patent expired simple generic cheap and relatively unprofitable products - and the proposal makes repeated mention of justifying a ban on their behalf.
The invitation to sympathy for not having competition banned can be compared with real sympathy if what they were preparing to make had been banned!
There is nothing wrong in manufacturer lobbying for profits on behalf of shareholders - it is arguably wrong of them not to. However, that does not require Government acquiescence on behalf of the public.
Besides, the manufacturers could of course just stop making the bulbs themselves in the name of the "progress" that they like to talk about in all their PR handouts regurgitated by politicians and media. After all, the very same manufacturers stopped making much else in the name of "progress". This had a natural market flow, in that the public could see the advantages of the new products, with little demand for the old ones, although always with niche uses (vinyl records, audio tubes, etc).
Therefore the irony and the idiocy that apples here:
If incandescents were not so popular, there would be no "need" for Government to ban them.

Local Canadian industry and jobs:

Adoption of US law as planned for more products and services carries implications of Canadian industry satisfying any specific local demand.
Not least in terms of ordinary incandescent light bulbs. The loss of jobs in USA and Europe was admitted by policy makers (EU over 5000 in final stage, adding to the thousands in ban anticipation). Complex CFL/LED manufacture is largely outsourced to China.
Local outfits with small overheads could easily make the simple generic patent-free products without licensing obligations, giving local Canadian jobs and local sustainability from using few components with little transport and no recycling needed, and no competition from the USA and little from elsewhere.
Compare with being blown over by Chinese imports and major American distributors who - in addition - have already known about their own American standard for 7 years and implemented it for 2, while, if anything, smaller Canadian counterparts have been preparing for the wrong original MEPS 2008 Canadian standard.

The ban is justified as lowering electricity consumption:

As it is a proposed ban for electricity consumption reasons, not because of unsafe bulbs, logically one would first look at the overall question of electricity consumption, looking at if and when a lowering is needed, and in turn the effects of various measures in relation to the penalty caused in terms of product choice or otherwise.
Renewables wind wave hydro and nuclear (Canadian uranium) hardly have Canadian shortage issues albeit that new plants or extensions could be avoided - hardly an issue with light bulbs for reasons soon explained.
The main issue is usually fossil fuel, especially coal, and its greater emissions (not just CO2) than other sources.

Light bulbs don't burn coal or release CO2 gas.
Power plants might - and might not.
If there's a problem - deal with the problem.
In Canada, hardly a problem, given Canada 86% emission-free electricity, and of course coal itself can be treated in various ways.

The usual "10% of domestic electricity is used for lighting" type statements,
ignore that around half of domestic lighting is not incandescent anyway, especially the mainly used kitchen lighting, also that replacements use electricity, also the heat replacement of incandescents and power factor (PF) issues of CFLs and LEDs (effectively energy use not recorded by the meters), also that domestic electricity is a small part of overall grid demand (industrial, commercial, municipal, transport - with hardly any incandescent use in any of those sectors).
On a general level, also the life cycle energy use of more complex replacement lighting, including transport in all stages from mineral mining to recycling (when not dumped, leeching mercury etc) and bunker oil powered shipping from China by major manufacturers, compared to easier local Canada manufacture by small/new manufacturers of patent-free simple incandescent bulbs.
Incandescent electricity use is just fractional amounts of mostly off-peak evening-night surplus electricity, as per usage and grid data references, effectively smaller still given the bulb heat supplied as per Ontario/BC institutional studies, and with the Canadian Center for Housing Technology also confirming that 83% to 100% of lighting energy contributes to heat demand reduction.

The total reduction [in energy use] would be 0.54 x 0.8 x 0.76% = 0.33%,
This figure is almost certainly an overestimate,
particularly as the inefficiency of conventional bulbs generates heat which supplements other forms of heating in winter.

Which begs the question: is it really worth it?
Politicians are forcing a change to a particular technology which is fine for some applications but not universally liked, and which has disadvantages.
The problem is that legislators are unable to tackle the big issues of energy use effectively, so go for the soft target of a high profile domestic use of energy...
...This is gesture politics."
Using comparable European Commission VITO data to similarly cut down even greater "15% of domestic electricity use" type statements, this came from the Cambridge University Scientific Alliance, UK Government advisers from several institutions normally supportive of energy and emission measures, similarly with other referenced science institution communications from different countries.

Alternative policies:

Again, as it is a proposed ban for electricity consumption reasons, not because of unsafe bulbs,
then electricity consumption reduction policies should be looked at in an overall sense.
That means, if required, say coal tax or emission tax or regulations, or a general electricity tax with payback subsidies for house insulation etc - ideally conceived within an overall electricity distribution policy that increases supplier competition and ease of switching between those suppliers, itself made more easy with eventual smart metering systems. Smart meter systems will also shift people from peak time use to other times of electricity surplus availability, by time-basd pricing.
Compare with the pedantic bureaucratic exercise of telling Canadian folks what light bulbs they can or can't use in their bedrooms, and repeating the process for a plethora of other products.

Of course, if light bulbs really needed policy targeting, it could be done by information, taxation, or market stimulation measures, as also described, rather than clumsy once-off standards that permanently bans also any future invention that might have been made with its own specific advantages.

The "Hey don't worry everybody" message:

Instead, Canadians worried about future choice may soon hear the on-song message from Government spokespeople:
"Hey, don't worry everybody, similar Halogen incandescent light bulbs will still be allowed!".
Except that they won't.
Adoption of USA law is the main stated justification for the proposal, defended as standard harmonisation to facilitate future trade on the North American market, and planned for more products and services.
This of itself should worry those concerned about specific Canadian service for Canadians.
It also means abiding by future decisions in Washington.
As it happens, USA EISA 2007 law tier 2 2014-2017 regulation on light bulbs will ban all incandescents for general service, including Halogens, based on the 45 lumen per Watt final rule requirement that equates to fluorescent bulb standard.
Presumably the Ottawa Government know this:
"it is anticipated that the proposed standards would help to increase the level of acceptability for MEPS [minimum energy perfomance standards] for many Canadians, thus facilitating the adoption of further MEPS for these and other products in the future."
A little more upfront honesty would perhaps not go amiss...

One might in passing note that the Halogen type replacements anyway have some light qualitative differences, also being more complex and expensive with marginal savings and therefore less popular in a free choice either with consumers or politicians (no Halogen switchover programs!).

For details of why the regulations are wrong for Canada, see the introductory post
"Canada to adopt more US Laws beginning with Light Bulbs:
Losing Industry, Jobs and Choice, with Hardly any Savings

Full version   As Doc    As PDF

Content List

1. Why Alignment to USA will also ban Halogens
The supposedly allowed Halogens banned on USA EISA tier 2 2014-2017 backstop final rule equating to CFL standard. Following Washington means following any other change they make. Proposal already envisages further restrictions.
2. What is good for Canadian Industry, Jobs and Consumers?
Light bulbs stated as the first of more US laws in manufacture and service to harmonise NAFTA standards. Allowing US based corporate access does not mean having to legislate against local production to local desire.
3. How Incandescents have particular Advantages for Canadians
Beyond heat, also brightness, and situational advantages in large homes where much time spent
4. Simple Incandescent Advantages versus Halogens
Halogens more complex and expensive for little savings advantage, hence unpopular in free choice either with consumers or politicians.
5. On Energy saving for the Nation
Fractional overall and on comparative policies, and a main off-peak time use avails of surplus production capacity anyway.
6. On Emission saving for the Planet
Ditto, with the addition that Canada has 86% emission-free electricity and that emissions may increase on heat replacement effect
7. On Money saving for the People
Ditto, with the addition that free choice is not always about money saving, that many bulbs are not often used, and that subsidies plus utility compensation may mean higher bulb and electricity payments anyway via tax or electricity bills.
8. Worldwide Policy and Major Manufacturers
Cooperation to enforce low lifespan on incandescent bulbs followed by cooperation to altogether ban such now patent-expired generic cheap competition. Plus ça change, plus c'est la même chose.
9. Alternative Policies targeting Light Bulbs
Information, taxation/subsidy and market competitive alternatives could and should be considered before bans.
10. Incandescents - the Real Green Bulbs?
Efficient, earth saving, long lasting and sustainable.
The simplest way to produce bright light from electricity banned for being too popular, by the stupidity that passes for global governance.

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

1 comment:

Unknown said...

I agree that this is yet further government encroachment on liberties. Governments of the world conveniently say the populace is in favour of such actions, but appear from the ground to be very unpopular. Hence the rise of parties such as UKIP.
Governments take too much sovereignty from us cattle.
At the same time, I believe people in full possession of the facts would typically chose CFL or LED lighting over incandescent. Not least due to the much lower maintenance, and better economy, and reduced costs due to lower thermal stress on fittings.
I know people who go both ways, but life is all about making your own choices, and living with those choices. You are not a robot.