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

Tuesday, December 10, 2013

Canada to adopt more US Laws beginning with Light Bulbs:
Losing Industry, Jobs and Choice, with Hardly any Savings

Last updated December 23
Update info: Campaign against the ban by Federal MP (Government Conservative party) Cheryl Gallant of Ontario, blog post about it (December 23).
Also Section 1 of the Document revised, consequent (P7 version) updates also done to Doc and PDF links below.

The below constitutes a reply to the Canadian Natural Resources Government Ministry, Office of Energy Efficiency, concerning the Canada Gazette Vol. 147, No. 40 — October 5, 2013 published proposal on Light Bulb Regulations to be effective as from Jan 1 2014,
and the invitation to comment

Email: equipment@nrcan.gc.ca Telephone: 613-996-4359
John Cockburn, Director Equipment Division Office of Energy Efficiency Natural Resources Canada CEF, Building 3, Observatory Crescent, 1st Floor
Ottawa, Ontario Fax: 613-947-5286
But best to also contact local media etc. Media very quiet on this.

What Canadians are not being told about January 1 2014 Light Bulb Regulations

Enforcing US Law:
Losing Independence, Industry, Jobs and Choice,
with Hardly any Savings and Hardly any Halogens.

In a seemingly hastily written October proposal, just in time to invite standard 75 day comment by December 19
(leaving little time for any subsequent serious analysis, should perchance the Cabinet be interested in doing so),
Canadians are told that by aligning to USA standards Halogen bulbs, similar to regular incandescent bulbs, will not be banned.

They will.
And that's just the start.

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.

Full version:  As Doc    As PDF
Parts 1-3 reproduced below

1. Why Alignment to USA will also ban Halogens

USA Energy Independence and Security Act of 2007/Title III/Subtitle B/Section 321

"The Secretary of Energy shall report to Congress on the time frame for commercialization of lighting to replace incandescent and halogen incandescent lamp technology"

A backstop final rule relates to a cycle of rulemaking that will start in 2014.

" BACKSTOP REQUIREMENT— if the final rule [not later than January 1, 2017] does not produce savings that are greater than or equal to the savings from a minimum efficacy standard of 45 lumens per watt, effective beginning January 1, 2020, the Secretary shall prohibit the sale of any general service lamp that does not meet a minimum efficacy standard of 45 lumens per watt"

As the Energy Information Administration at the Department of Energy puts it, the second tier of energy efficiency improvements “at the latest becomes effective by 2020, essentially requiring general service bulbs to be as efficient as today's CFLs"

The stated main purpose of the current light bulb proposal is to align with US legislation.
Comparatively, the original MEPS legislation can be seen at SOR/94-651 part 1 Items 136-139 with luminous flux based definitions (unfortunately not shown or linked in the proposal). The US wattage based regulations were previously deliberately avoided, citing several disadvantages with the US system including less bright bulbs being allowed in place of brighter ones, usage of higher wattage class defeating the purpose etc. This is not mentioned now in changing standards.

The proposed adoption of USA law is justified as facilitating company product development and distribution to a bigger market, now and in the future, and is to be followed by similar adoption of US law for other products for the same reasons.
With light bulbs a further highlighted beneficial effect is said to be that American standards will allow incandescents in the form of Halogens, albeit still with differences to simple incandescents and a lot more expensive.
However, not only would some higher energy efficiency halogen types not have been banned anyway under the originally proposed legislation, but as seen current USA legislation bans all incandescent technology including touted halogen replacements for general service lighting, EISA tier 2 2014-2017 45 lumen per Watt final rule which equates to fluorescent bulb standard. Replacement Halogens at 18 lumen per Watt, 20-22 at best, are way below that.
The notion that manufacturers would improve halogens falls on commercial consideration (as they at length explained in the November 25 EU meeting and documentation), and for example Philips already quietly dropped promised EcoVantage development once the 2009 EU ban had been achieved.

Aligning with US legislation of course means that guarantees about what will or won't be allowed can no longer be given.

To reply that
"Canada will just adopt the first (USA Tier 1) levels and won't ban Halogens even if the USA does",
is not in keeping with proposal's purpose and argumentation of aligning with USA standards in the first place, including the specifically stated supposed advantages of suppliers not having to deal with two standards for products.

Notice also that 45 lumen per watt is a minimum standard and is set to be followed by others (USA background documentation talks of Tier 3 in 2020).
Notice also that these are and would be technology-neutral standards.
So the splitting up of different products for distribution becomes more difficult anyway, and of course all the more so should further USA rules not be to Canadian taste.

45 lumen per watt is as said based on fluorescent lamps that are going out of political favour, and the hitherto mercury-exception of fluorescent lamps may come to be abolished, if they don't disappear from markets beforehand given recent decreases of allowable mercury levels in some jurisdictions like the EU, which make them less commercially viable to sell.
Of course those who criticise bans on incandescent bulbs might be pleased, should the CFL (fluorescent, "energy saving") bulbs disappear. But that would be on top of banning incandescents, and would hardly happen until other replacements have found political (if not popular) replacement favor.

The big noise in the world of lighting regulation is "Ledification", Japan aiming for a total switch by 2020 and the European Commission in current talks with manufacturer representatives in dealing with the timing of banning halogens and pushing a LED switchover.
[LEDs certainly have energy efficiency advantages, but are also very difficult to make as bright omnidirectional incandescent bulb replacements at low prices, along with having a number of health and environmental concerns of their own as covered later. The simple fact is that all lighting types have advantages and disadvantages, and bans of any should surely be approached with caution. The main distinctive technology advantages are of incandescents as bulbs, fluorescents as long tubes and LEDs as sheets - which is also how the latter 2 were first developed]

Notice how all this is applicable to any aligning to allow Washington to dictate what Canadians can or can't buy, and which may or may not be to Canadian taste, not just with light bulbs, and not just with energy efficiency regulations, given the stated ambition to expand such regulatory alignment and favour multinationals in their North American product development and future distribution of products (see section 2 on industry policy below).

Alternatively, the Canada Government knows about and plans a future ban on halogens.
It is after all true to say that "halogens will still be allowed" - for now.
They would also be doing exactly what USA, EU, and Australia ruling officials did before them:
Wave funny bulbs around to visibly show they were "doing something" about global warming, while "assuring" everybody that "lookalike halogens" to traditional bulbs would still be allowed

It would also seem strange if Canadian lawmakers did not know US law before shifting to it.

The proposal finishes, perhaps with admirable openness:
"...over time, it is anticipated that the proposed standards would help to increase the level of acceptability for MEPS [Minimum Energy Performance Standards] for many Canadians, thus facilitating the adoption of further MEPS for these and other products in the future."

Put the frog into boiling water - it jumps out.
Put the frog into cold water and keep heating it - the frog is cooked
"How to Cook our Canadians"

So, Canadian Cabinet...how about the Canadian public not being duped about "what is allowed"?

In this regard, one should also be aware of how regulations are coordinated and arranged to achieve a desired purpose (read, ban completion).
Jurisdictions like Canada, EU, USA and Australia are in close contact as seen from background documentation to legislation and international meetings between energy agency officials and major manufacturer representatives.

Regulations are therefore divided into Tier 1 and Tier 2 processes.
The original 2012 Canada plans also had a Tier 2 2015 phase-out intention.
Staggered implementation is of course understandable in cushioning the effect both for manufacturers and consumers as new technology is introduced.
However that also allows - or should allow - unbiased monitoring of the effects on consumers of lighting availability and quality, and that supposed energy saving actually takes place.
But follow-ups are no fun for politicians - promises are. The typically and suitably long-term savings projections also apply for Canada (2025, see the proposal annex) allowing catchy quotable big savings figures, and then to say "Well, buddy, we'll check on that in 2025"! Brilliant - the decision makers long since having retired.
Suggested evaluation based on just measuring assumed savings from how products have been adopted (handy for the backing companies, who don't have to pay for that research themselves!) is hardly the same - and misses the overall consumer impact.
In BureaucratSpeak, "stakeholders" aren't any guys and gals strolling around Queen Street in Toronto.

Both the EU and the USA have 2014 review processes:
These should therefore have meant a neutral assessment of Tier 1.But as the continued bans are already written into legislation, the reviews are mainly about alternative lamps and possible change in the timing of Tier 2 implementation. Talk about a 1-way street.

As for the USA, it's not just that halogens are legislated to disappear sometime before 2020. The Obama administration in cooperation with the Democrat controlled Senate Energy Committee already tried to tighten lamp and other energy efficiency regulations in 2011. But as with many bills, it did not make it through Congress. Lowering the standards requires Congress passage, and the President's signature. Hardly anytime soon.

A further possible reason why the officials writing the laws want Tier 2 bans already legislated in place, is the difficulty and nuisance of having to revisit the issue in public or parliamentary debate.
US law is of course already difficult to alter as just noted, and this applies also in the 28 nation and multi-institutional EU.

Canada is different, and could be different, in openly considering what is right or wrong, and not just for multinational corporations.

The proposal here does commendably invite public comment....
but why is it kept away from Canadian Parliament for debate, all the more so since proposal comment finishes Dec 19, with MPs already being off looking for turkeys and tourtières on the 13th and not back until Jan 27?
The government cabinet rubberstamping American legislation into place over the holiday period surely sets a bad precedent if it hasn't done so already, given the mentioned ramifications.

The bigger picture about the light bulb regulations is not any guarantee about halogens.
The bigger picture is about why light bulb ban regulation is necessary in the first place - and particularly in Canada.

Canada has no obligation to ban either halogens or simple incandescents.
This was shown in already delaying ban implementation.
Canada is - still - an independent country.
If it is not in the interest of Canada, Canadian business, Canadian jobs, or Canadian consumers to ban lighting products on other than safety grounds, then it should not be done.

And it isn't...

2. What is good for Canadian Industry, Jobs and Consumers?

"This proposed amendment would support the Government’s regulatory policy of aligning with American standards, where feasible"
"it is anticipated that the proposed standards would help to increase the level of acceptability for MEPS for many Canadians, thus facilitating the adoption of further MEPS for these and other products in the future."
"compliance risks are much less than they would be if Canada had unique standards. Canada would benefit from the compliance regime that is in place to support U.S. standards."

Adoption of US standards for many more products - not just concerning energy efficiency - is set to continue.
The US dominance on the North American market hardly means Washington adopting Ottawa standards.

This does not just sideline Canadian autonomy for its own sake.
It means no longer making products to specific Canadian demands, should they conflict with American desire.

So, should the border just be shut, to only have "Canadian products for Canadians"?
No, the point is not the protectionism angle.
The point is that allowing American standard products in Canada, does not mean having to ban products made to specific Canadian demand and desire.
Manufacturers can still make American standard products both for internal market or export, as they wish.

Presumably if the American standard is so attractive for the major multinationals for market reasons, then they'll make to that standard, and leave the smaller specific Canada demand to Canadian suppliers.
They don't "have to suffer regulatory burden by making products to 2 standards", as the proposal basically puts it.

This is therefore about a lot more than light bulbs, it is about any product that because of climate, geography, culture, or other reason might be of value to Canadian consumers.

Legally, in a case of regulatory conflict between the Canada and USA standards,
if a Canadian requirement is deemed less stringent, that is obviously not a problem - the point here.
If a Canadian requirement is more stringent, perhaps on environmental or safety grounds, that is still justified on Canadian rights as a sovereign country.

The Government proposal at hand is overly focused on helping major manufacturers sell in both countries, repeatedly stating so.
Maybe some more widespread consideration is justified.

Yet even on such narrowly defined market-minded economic justification for bowing to Washington, the question is if it's a good policy.

To keep adopting US standards will likely cost Canadian supply and distribution jobs,
especially of already existing standards as supply and distribution to those standards is already well established on the bigger US market, but also of simultaneously applied standards, as larger US based suppliers simply extend the reach for their products.

Conversely, while still allowing such free trade movement of goods,
the freedom of manufacture to local needs gives local jobs and locally satisfied consumers.
Also if Americans are not making or distributing such products then clearly all the better for Canadian jobs.

Turning now specifically to energy efficiency regulations, such as on light bulbs,
the relevance of what has been said is even greater, on several counts.

Firstly, by adopting US legislation, USA based control becomes even more likely - after all, their manufacturers and distributors have had regulatory knowledge and established implementation for several years on any such regulatory shift. With the light bulbs, that's 7 years knowledge and 2 years implementation for the US rivals.
After all, the proposal makes much of how manufacturers prepare for standards in advance (and, conversely, if anything, Canadian suppliers prepared for the wrong MEPS standard).

Secondly, how big is current and assumed future Canadian light bulb production anyway?
While I have been unable to find figures (and, again, the proposal could have supplied them!) it presumably mirrors the USA and EU in dominant Chinese CFL/LED imports and dwindling local incandescent/halogen manufacture.
Maybe it's great to help the Chinese (as also outsourced by Philips. GE or Osram-Sylvania) but surely not of utmost importance, and on the distribution side that again comes down to likely American control on a unified market for reasons given.

Thirdly, with energy efficiency regulations it need not be USA versus Canada standards.
Not having energy efficiency regulations in the first place opens up to true manufacturer freedom without the "regulatory burden" that the proposal worries so much about.
That obviously need defending of itself, and will be done for light bulbs, but one should also be well aware of what it would mean for industrial policy and jobs, given the industry focus in the proposal.

The tone of the proposal is of abandoning regulations with threatened chaos.
But it is just to continue without implementation, and with manufacturer and consumer freedom.
A freedom that allows the start up of making popular bulbs, that hasn't hitherto happened given threatened regulation.

The popularity of bulbs to be banned (phased out, regulated..) is hardly in doubt.
If they were not popular, there would be no "need" to ban them and celebrate the supposed savings.
There are in fact many reasons why it is both easy and attractive to set up local small/new Canadian manufacture and sale with associated jobs of traditional light bulbs.
Firstly in being popular, as mentioned.
Secondly in being simple and easy to make.
Thirdly in being generic patent-free bulbs without licensing requirement from major manufacturers (now guess why GE/Philips/Osram-Sylvania want those bulbs banned).
Finally, in being without competition from America, and with likely little competition from anywhere else - while always allowing alternative "energy saving" bulb manufacture and sale as desired on the market.
Canada could have a considerable domestic light bulb industry of incandescent lighting.
Can the same be said about CFLs or LEDs?

Responding to the idea that regulations might actually not be imposed, the proposal suggests:

"Canada could become susceptible to product dumping from manufacturers from other countries seeking to sell traditional incandescent light bulbs no longer permitted in their own country."

This repeats what they said 2008 in defending the first MEPS regulations.
But bans have now already been legislated in many other jurisdictions (rationale later) and the proposal itself emphasizes how manufacturers prepare for them.
So the notion that those guys have been stockpiling incandescents on-the-side, just to dump on Canada in case Canada does not implement a ban, hardly holds.
Besides, Canadians would get more choice, and would have to want to buy them in the first place - "terrible" if they can buy what they want?
Finally, any dumping problem can always be met by import controls - it does not necessitate, nor does it justify, banning what people want to buy.

Two further justifications are given for not abandoning regulations:
"Suppliers to the Canadian light bulb market have already made considerable investments in research, development and retooling to meet the MEPS as written in 2008.
Canadian retailers have begun selling, promoting, and educating consumers about more efficient bulbs."

As for Canadian retailers,
I am sure they would be delighted to sell whatever Canadians want to buy.
Educating about "efficient bulbs" - that presumably means bulbs efficient in producing bright light using few components?
No? Well, that just shows how politically correct language is defined - handily substituting "efficient" for "energy efficient"
(as with calling fluorescent bulbs "energy saving" bulbs:
Hello Mr Retailer, can I have one of those Energy Wasting bulbs please? Ah, gosh, thanks very much!)

As for suppliers to the market,
the odd notion is this invitation to cry for them when they now instead have full freedom to make and supply what they want - including the bulbs they prepared for.
Compare with if they had been busy preparing to sell a bulb that was then made illegal!

The manufacturers were perfectly free themselves to stop selling incandescents if "they are so bad for the planet", as their press releases keep saying, and the media keeps swallowing. After all - the same GE/Philips and other companies stopped making record players, cassettes, 8-tracks and much else in the name of "progress".
But "unfortunately", others would make the popular bulbs if they stopped!
No manufacturer/distributor should rely on bans on competition to shift product they presumably have some sort of confidence and ability to sell.
Besides, the big American market would still have the limited competition they want.

Moreover, if the suppliers were preparing for the Canadian standard, "MEPS as written in 2008" and it "is a burden to make and distribute to both American and Canadian standard", well, then the suppliers have been preparing for the wrong standard, with Canada Gov now pulling the rug from under their feet!
Also, the fact that simple traditional light bulbs are easy to make means those guys can easily "retool" and make them too, and have the limited competition from USA on that score as already described.
Don't cry for me, Argentina.

For deeper discussion of industrial policy and manufacturers, see section 8

Meanwhile, do these bulbs really have any value for Canadians?.....

3. How Incandescents have particular advantages for Canadians

First, a summary of general advantages of Incandescents, then particular advantages to Canadians, and afterwards, a look at simple incandescent advantages vis-à-vis Halogens.

General incandescent advantages

A high quality 100% CRI (color rendering index) light with a warm characteristic: Incandescent lights have a smooth broad light spectrum, which in ordinary light bulbs rises more towards the red end, giving the characteristic warm glow, increased on dimming (fluorescent and LED lights give out different types of light...LEDs also in car headlamps, bicycle lights, flashlights/torches, sees an often bluey omnidirectionally weaker but point source glare type of lighting taking over in society).

The light bulbs have for many a pleasing simple appearance, and the transparency sparkle effect makes their use in some lamps, lanterns, and chandeliers attractive.
They are versatile with dimmers and sensors, advantageous where vibration or rough use is expected, and in very hot or cold conditions when they are also quick to come on. Moreover, the heat of the light bulbs (of itself often useful) finds direct applications in space heating applications, greenhouses, hatcheries, pet keeping etc.
Converse arguments note the situational disadvantages in particular of CFLs, for example in recessed and enclosed fixtures or humid (bathroom) situations

The brightness issue

Small and standard size incandescent lights are particularly useful, since CFL or LED equivalents usually can't be made as bright, and when they can they are even more expensive than usual.

The early ban on small/standard 100 Watt bulbs is therefore particularly ironic, added to by any future absence of halogens.
Such bulbs have especially good and cheap brightness as well as heat benefit, with 100W bulbs being at the same low price as other bulbs (and yes, that is also a reason they "must" be banned quickly based on what people might otherwise want to buy, such that big "savings" can be announced instead).

Fluorescent and LED lights, often dim to start with, also dim more with age, shortening lab quoted lifespans.
Fluorescent encapsulation (with pear shaped outer envelope, recommended for close use) further reduces brightness, similarly the phosphorescent covering of LEDs to spread the point-source lighting reduces brightness in any direction.
Cheap Chinese imports, directly or for assembly and rebranding, also mean that brightness retention, lifespan and other issues remain with these lights.
Any older reader might like (or not like) to note that not only do older eyes need brighter light, but ageing also means yellowing eye lenses so that they absorb the greater blue light component of fluorescents and LEDs, making them appear still dimmer.
Je vous souhaite la retraite agréable.

Safety issues

Normally products are banned for being unsafe to use.
The irony here is that old and thereby well known bulbs in their safety are forcibly, albeit gradually, replaced by CFL and LED bulbs with several health, safety, and environmental concerns.
There is little point in going through the concerns here which can easily be found in online discussion and documentation -
especially regarding fluorescent lighting mercury and radiation concerns, which after all also influenced the 2 year regulatory delay in Canada. Those issues have of course not simply gone away, including accidental breakage of CFLs and their recycling as alternative to being dumped (and with some calls for LED recycling too, see below).
A point of irony is the light bulb heat issue.
Irony, because politicians and journalists and indeed the info sheets from the OEE (Canada Gov office of energy efficiency) love to say how incandescents "waste 90-95% of their energy as heat", never a word that CFLs also waste 70-80% and current LEDs 50-70% of their energy this way.
Irony, because while much incandescent heat is radiated externally to potential use, CFL and LED is internalized, with unpredictable fire risk, especially of CFLs (incandescent heat being more noticeable in burning lampshades and the like, to warn users).

Not only do incandescents often usefully release around 95% of their energy as heat:
Proponents conveniently "forget" to add that CFLs and LEDs really waste energy as heat, CFLs 80% and LEDs 70%.
That is because the CFL/LED heat is internalized, to give a greater, unseen, unpredictable fire risk, particularly with CFLs (incandescent heat being more noticeable, to warn users).

A brief further word on LEDs, as the touted catch-all replacement product.
Just to mention 2 aspects and 2 institutional references.
The official French health agency ANSES in a 2010 multi-disciplinary study highlighted point source glare and blue light radiation issues and various side-effects, echoed by several other studies, and unusually in a repeat call 2013 complained to the Commission that nothing was being done.
Similarly the Department of Chemical Engineering and Materials Science, University of California, USA has been involved in several multi-disciplinary and multi-institutional and international (Korea) studies concerning the toxicity and environmental effects of LEDs, including depletetion of rare earth minerals, and calling for recycling as with CFLs.

Certainly, new technology should be welcomed for its advantages.
But it does not necessitate banning the old - it seems remarkably hard for politicians to understand that manufacturers themselves can and do move on the new products, without the necessity of bans, and that there are many other ways both of reducing energy consumption in general and of enhancing energy saving product purchase in particular.

Progress is welcomed - not feared.
True progressive politics brings more choice and more advantages, a progress helped - not hindered - by allowing competition against that which already exists.

Politicians love to keep saying how "energy saving products are getting better and cheaper all the time".
Then presumably people might actually buy them - voluntarily - while still allowing niche special use of "old" varieties.
We've witnessed an incandescent to solid state switchover before - and with the same GE, Philips etc companies.
The audio version. Incandescent audio tubes to solid state (LED-like) transistors.
Now then: If that had been today, then worldwide the call would have been to ban the "energy guzzling" audio tubes.
Which in turn would have prevented rock era tube amps and other niche audio processing developments.
Politicians set energy cut-off standards thinking they just ban existing products. But they also ban what might have existed, and never will.

New lighting is better - why ban old lighting, no point
New lighting is not better - why ban old lighting, no point

Incandescent advantages for Canadians

(i) Canadian homes tend to be big in international comparison, with more light bulbs:

Canadian around 35 light points per home, EU average 20-25 (less in Southern Europe), USA 40-45

• Increased variety of conditions where different lights are useful, so a ban on any lighting type is felt more.
• More individual rooms and lamps with lights that are not often used - reducing supposed running cost savings after buying expensive "energy saving" lighting

(ii) Canadians have a higher need and usage of lighting itself:

• Increased time indoors, including at home, because the homes are bigger, better and more comfortable, related both to the cooler climate and to a greater household wealth, compared with most other countries.
• Increased time indoors, including at home or other situations where the lighting can be chosen, because of colder climate and also because the dark winter season is only partially offset by summer brightness for working Canadians outside vacation times, when some rooms will likely still need to be lit up fairly early

(iii) Canadians more often have cold conditions that can affect the lighting used:

• Incandescent lights come on quickly in the cold. While nowadays CFLs have little delay in ordinary conditions, that does not apply in cold conditions.
LEDs also are more sensitive to ambient temperatures (both hot and cold performance deterioration).
• Cool or cold conditions can combine with other usage factors unsuitable to other lighting, like incompatibility with sensor systems and/or frequent on-off switching, as with hallway and passage areas, bathrooms, outdoor porch and garage lights.
On a more curious note, replacing incandescents with other lighting has reportedly seen Canadian traffic lights being obscured by snow in wintertime, whereas beforehand the incandescent heat would keep the lights clear.

(iv) Canadians particularly benefit from the light bulb heat effect:

• The heat effect, of which more later, gives an overall reduction of energy use to maintain room temperature.
That is not just from being used more than air-conditioning cooling through the year. Even in the summer, when it is dark, it may be cold enough to turn on room heating. Besides incandescents can be changed as desired if conflicting with air conditioning - and may of course be preferred anyway for their other advantages.
• The house insulation factor: Well built Canadian houses that are well insulated, giving a greater light bulb heat benefit compared to more poorly insulated ones elsewhere, as in the UK. The heat from bulbs stays in the room, not escaping through the ceiling.
A point of irony is therefore how governments are increasing home insulation schemes to save on heating, while banning bulbs which, proportionate to small energy use of course, would thereby contribute more to such heating.

(v) Canadians are more likely to enjoy the psychologically warm effect:

Incandescents tend towards the red end of the spectrum, while unmodified fluorescents and LED lighting have more blue light, cooler in effect.
Also, when dimmed, the warm effect of incandescents increases: and people in northern countries like Canada or Nordic Europe are more likely to entertain others in their homes for say dinner parties, possibly also for cultural reasons.
Compare with warmer regions where people go out more to socialize, have no control over such lighting used, and barely use their own home lighting that they can control.

(vi) Canadians are more likely to enjoy bright light:

Having longer darker winters, and generally with less bright conditions than more tropical locations.
100W+ bright equivalent lighting is less easy to make in fluorescent or LED bulb form, is not often available for general household use, and is particularly expensive when it is (and is still not widely possible omnidirectionally with LED bulbs).
The importance is also seen from the existence of SAD, Seasonal Affective Disorder in Northern countries generally, where the lack of light during winter months plays a role as seen from the bright light phototherapy treatment that is involved.

[ Sections 4 to 10 can be seen via doc or pdf download, see top of this page]

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.


Traceii Roberts said...

Incandescent bulb use is essential for me as the UV in floresent lights trigger an immune response in me which triggers my Lupus. Lupus is an auto immune disease that has no present cure. Lupus flares by attacking a person's own tissues and organs, Such as: your joints, skin, kidneys, blood cells, brain, heart and lungs. many people die from lupus. It is essential to have a choice in the products we buy, especially when they strong impact our health and quality of life. How many flares does a person need before it is the final one??
From a very concerned Canadian, Traceii Roberts

manskybook said...

LEDs can be created to filter UV. Even CFLs can be coated to eliminate UV. But no one is saying you can't use incandescents, only that the old Edison bulb is very inefficient. Halogen bulbs create warm incandescent light, and LEDs can be created to span the visual spectrum. It's not clear that you understand the physics of light that affect your condition

manskybook said...

Really? You can get both CFLs and LEDs that don't have UV, and LEDs can be tailored to specific wavelengths. What about auto-immune reaction to the magnetic coil in incandescents? There's not much science in your comment.

Lighthouse said...

Thank you for answering Traceii.
Certainly one can get around the UV issue, albeit with certain disadvantages.
CFLs are usually in an envelope to cut the UV, but that further reduces their brightness, and LEDs have cost issues especially for omnidirectional brightness (and in turn particularly for less frequently used bulbs in relatively large c.36 lighting point Canadian homes).
Incandescents for general use will effectively be banned on adopting US legislation, as further covered in a recent post

That included halogen replacements, on tier 2 2014-2017 regulation, backstop final rule 45 lumen/W, Halogens around half that, sufficient incandescent rise would hardly be possible and was anyway recently ruled out by major manufacturers meeting with EU officials, as also covered here previously.

Lighthouse said...

Manskybook Re "auto-immune reaction to the magnetic coil in incandescents"
I think you might be mixing it up with electromagnetic radiation sensitivity reaction to CFLs...
incandescents a simple wire heating technology