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

Tuesday, December 17, 2013

Why Ban the Bulbs?
Alternative Information, Taxation and Market Policies to Product Prohibition

the game is on for ever more restrictive usage standards of allowable products in society, be that the energy use of buildings or cars, the water use of toilets or showers, or the electricity use of a host of other products.
Already questionable in terms of actual savings and in the compromised performance and usability of what is left for people to buy, the policy is even more questionable on electrical products.
This is not only because there is a whole range of energy alternatives to counter any shortage, but also because electrical product use is not coupled to energy use. Banning certain cars or toilets may at least theoretically reduce their oil and water consumption. Electrical products are not coupled to say coal use, coal and power plant policies can be directly implemented, and the necessary saving of long-lasting/renewables carries its own question mark - in particular as we look at incandescent bulb bans, since they largely use off-peak evening -night surplus capacity electricity and thereby could never save on the building or extension of any power plants even on accepted saving assumptions.

if a politician has something in his or her head that can be likened to a brain, he/she could of course first consider alternatives to banning what people want to buy (no "need" for a ban if they don't want to buy it).
Unfortunately, in today's world, first politicians find it necessary to continually subsidise corporate "green" products, and if this is "not enough", then the competition has to be banned too, with new standards that "happen" to allow the patented goodies of corporate buddies to pass through the needle's eye, with the backing of well-meaning but naive green people, all crying together in ecstasy over saving the planet and echoed by a pathetic media that regurgitates everything thrown at it. Yes folks, it's called progress.

But there is another way.
Actually, several ways, that at least should be considered and arguably implemented to see if effects are judged as sufficient, before arriving at the nuclear option of a ban.

To make clear: I don't consider the product targeting is necessary in the first place.
But the point here is that even going along with the supposed saving effect and justification of targeting products, jumping to bans is still wrong.
Information, building on past efforts, and taxation, with or without parallell subsidy policy, are two alternatives.
However, market competitive stimulation as finally considered is in my view best in any product targeting.

While the following is all applicable to the USA, the EU and anywhere else,
it is also part of 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 by December 19th.

See the introductory post in the series, also covering policy aspects of the Canada Government proposal to switch to USA standards (sections 1 and 2 below).
A main claim is that Halogens "similar to traditional bulbs" will still be allowed, but they will be banned under US law as referenced, and the Government proposal itself speaks of further standard restrictions being facilitated.
Also, Canadian media has missed that the light bulb rules are said to be just a beginning of a switch to USA laws, with implications not just for Canadian sovereignty, but also of local Canadian manufacture and service to specific Canadian needs.

A second post highlighted the particular advantages to Canadian citizens of incandescent bulbs, being a lot more than just incandescent heat, as reflected in time spent at home, home size, number of bulbs and the varied lighting conditions where incandescents are a more desirable choice (section 3 below).

This time, therefore, the highlighting that the knee-jerk banning of products as requested by greens and corporates in odd unison is not the only relevant policy to assure lower energy consumption (section 9 below).
Information, taxation/subsidy and market policies are ignored as alternatives. Why?

1. Why Alignment to USA will also ban Halogens
2. What is good for Canadian Industry, Jobs and Consumers?
3. How Incandescents have particular Advantages for Canadians
4. Simple Incandescent Advantages versus Halogens
5. On Energy saving for the Nation
6. On Emission saving for the Planet
7. On Money saving for the People
8. Worldwide Policy and Major Manufacturers
9. Alternative Policies targeting Light Bulbs
10.Incandescents - the Real Green Bulbs?

Full version:  As Doc    As PDF

As with all section extracts, the below may refer to other parts of the full document.
Certain revisions and update improvements have been added compared to the document version (until that in turn is updated).
This also expands on relevant parts of the 14 point "How Regulations are Wrongly Justified" general international summary.

9.  Alternative Policies targeting Light Bulbs    

Worldwide, remarkably little consideration is given to alternative policies, not just - as already seen - with respect to saving energy, but also with respect of saving energy when targeting light bulbs themselves.
Much the same goes for all other energy efficiency regulation.
Obviously the last section on lobbying and undue influence might - and should - raise questions as to why that may be so.

There are (at least) 3 alternative policy divisions.
In a sense "there is something for everyone", as it includes both traditional left-wing and right-wing policies.
Again, this makes the avoiding of any such policies all the more puzzling.

The consideration here will therefore be on information, taxation/subsidy and market stimulation policies.

Information Policies  

In the world of odd justification of banning light bulbs, we may as well throw in another one.
US and EU politicians keep talking about uninformed consumers making the "wrong choices".
The right choice is of course always what the politicians want.
Be that as it may, the idea of clear labelling of what people buy presumably helps.
So in the USA and EU, first the bulbs are banned on the basis of poor choices by uninformed consumers, then clearer labelling in terms of bulb brightness comparison and energy use is introduced.
Cart before the horse. Brilliant.

The converse of this is of course that politicians - and not without justification - can say that at least they have had a lot of energy saving and switchover campaigns to encourage switching bulbs (they are even called "energy saving" rather than fluorescent or LED bulbs, for heaven's sake) and store displays tend to do likewise.
On top of that, Canada delayed two years with a specific consumer information rationale and to ally fears about fluorescent bulbs.

One might say that if well-informed people still make the wrong choices, they are either incredibly stupid, or, dare one say it, the ban pushing politicians are.

We are back to the reasons why people choose bulbs, which is not just to save energy, but also not just because incandescents are cheap.
The main point - as highlighted in official and institutional studies (OEE, BC Hydro) is that the penetration of energy saving bulbs is actually pretty good, as in the USA and EU the overwhelming majority have at least one and usually more of them.
The purchase pattern simply suggests that they do not want all their bulbs to be the same kind.
To repeat, the campaigns to "switch all your bulbs and save money" is like saying "Eat only bananas and save money".

There is of course also the simple logic applying that any success in achieving switchover, that for example BC Hydro keeps mentioning albeit via subsidised replacements, or out of "energy saving" bulbs getting "ever cheaper and better", also means less and less savings from imposing a ban - which therefore in turn does not just hit "reluctant technology-fiend backwoodsmen" but also any "progressive" household who sees room and environment conditions where incandescent use is still advantageous (particularly rarely used lamps that don't warrant any unsubsidised costly LED clones either).

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

It remains strange that particularly in Canada, where a ban was delayed on informational grounds, a ban is deemed necessary for what is said to have been successfully informed consumers about their choices (even if taken as being information about "post-ban" choices, it is still consumer information about the alternatives to simple incandescents).
Assuming a nevertheless continued desire to target bulbs, we have the tax/subsidy and market stimulation alternatives.

In comparison with a regulatory ban, taxation (and/or subsidies) have several advantages apart from keeping choice.


Why are simple incandescent light bulbs being banned?
They are not being banned for being unsafe to use, like lead paint.
No, the reason for banning bulbs is simply to reduce the consumption of energy.

After all, as regulation proponents keep saying,
"We are not banning the bulbs, we are setting energy usage limitations on them!".
Similarly with the plethora of energy usage limitations on buildings (climatically sealed), cars (performance issues, and possible safety issues, in limiting heavier types), white goods, TV sets, computers and much else, and resulting in choice limitation on varied usability/performance characteristics as per references.

Taking a "liberal" left-wing stance, how do governments usually reduce consumption?
Of safe products like luxury goods, or even unsafe ones, like tobacco and alcohol?
That's right - taxation.

Note the Government income from taxation to appropriately reduce energy consumption anywhere along the usage chain, say on coal, electricity from coal, any electricity, or on individual products without replacement worries, compared to a pedantic multitude of carefully crafted legislation on what consumers can or can't buy and use - and without any direct government income from it.

Taxation is of course also of popularity concern to politicians, particularly in the USA.
But this can be countered with how the money is spent - at least among poorer voters - such that for example electricity price rises may be countered by home insulation schemes.
Moreover, taxing say coal (or CO2 emissions) makes renewables and other sources more attractive, and with proper grid competition the switching of suppliers is easier.
As for product taxation, taxation can help subsidise the lower price of alternatives.
A quadruple whammy, in reducing consumption, equilibrating the market, keeping choice and maybe leaving some government income for other uses.
So much for "the market has failed - we must ban these products".

That's not all:
Because in facing the inevitable grumble about the "higher price" for a targeted product, politicians can therefore counter that they are lowering the price on other products, or similarly on lowering the price of alternative electricity provision, where subsidising renewables may be helped out of coal tax receipts.

It gets even better, in the sense that with say light bulbs, there'd be knowledge that a ban would have been the alternative - and the government can of course remind people of that too.

For a government so inclined it gets still better with the simple incandescent light bulbs, compared to other products.
They are cheap and can proportionate to price absorb a fair bit of tax, and they have a relatively fast turnover as commonly produced in short (1000 hr) lifespans.
I could not locate Canada relevant annual light bulb sales, but a rough estimate based on 13 million households and average 36 lighting points and somewhat less than half relevantly incandescent and comparable pre-ban Scandinavian turnover rate would be well over 100 million annual incandescent sales.
Whatever, a neat little earner, even if taxing obviously reduces sales (conversely a very pro-ban government can of course equate with a ban by a large tax, but then the ban route becomes more logical except for determined buyers of the bulbs).
Bans as said give no government income (at least not directly - strictly, supposed household money savings from a ban can be used for other taxable consumption, but the money savings argumentation is itself dubious for reasons given, and savings are of course more indirect anyway, also in assuming people will relevantly spend the money in equal or greater taxable ways).

That is not all.
It is much easier to implement and to alter taxation, and easier to flexibly apply it to new products that change the market situation, than clumsy one-set-standard regulations that need to have complex bureaucratic worked-out replacements - as seen from current elaborately defined regulations.
It is also easier to remove taxation when deemed no longer to be needed (eg when sufficient low emission energy is available), without having to restart the abandoned manufacture of products, as with regulation.

Still, I am against taxation as the best alternative choice, as it assumes there is a reason to target the bulbs, and affects local industry and jobs advantages and much else for much the same reasons as bans.

There is a still better alternative...

Stimulation of Free Market Competition  

If light bulbs need to be targeted in the first place (doubtful, for all other reasons given), then market stimulation, or more exactly market competitive stimulation, is in my view the best option also to lower energy consumption all the way along the energy usage chain:

Firstly, because producers of electricity, just like manufacturers, are then more keen to keep down their own energy usage and cost.
Secondly, because manufacturers are also pushed to deliver energy and cost saving products that the public actually want (and have always wanted, and do buy, even when costing more, and can imaginately be marketed for their savings in usage - rather than to lobby regulators for easier profits through bans on cheap competition).

"Expensive to buy but cheap in the long run"?
Clothes, battery, or washing up liquid manufacturers don't look for bans on cheap alternatives.
They properly and imaginatively advertise their wares.

New inventions, new products, energy saving or with other advantages - can always be helped to the market, though not continually supported.
Contrary to common political propaganda, innovation does not necessitate banning what has gone before.
On the contrary, product innovation - whether with buildings, cars, washing machines or light bulbs - is proven as desirable, in direct comparison and direct competition on the market place.
A progress seen throughout history, also of new energy saving alternatives, like the invention of fluorescent and LED lighting - without regulations being present.

The proposal specifically states a reason for delaying the ban was "for further advances in lighting technology to develop".
Presumably waiting longer allows still further development, and still less reason to ban alternatives.

The retort may be that "banning forces speedier development of new products":
Obviously by necessity it brings new alternatives, but it is development that aims to fill the gap of popular incandescents - look at all the LED incandescent bulb clones.
Hardly true or exciting progress, now is it, hand on your hearts, Canadian politicians?
As said, intrinsic advantages are of incandescents as bulbs, fluorescents as tubes, and LEDs as sheets, and was the original development of the latter 2 products, before all the push to compromise them as bulbs (yes, still with advantages of their own technology, but hardly developed as such now in bulb format, eg the flexible color temperatures of RGB LEDs rather than White LED bulbs).

A further issue is that regulation cut off standards don't just ban what exists. It bans all that could have existed, and never will, despite possible advantages beyond consumption of energy in usage.
For example in new bio-luminescence research, if assisted power consumption went beyond a certain level it would never be allowed, given new technology-neutral energy consumption standards.
Of course incandescent technology development itself is doomed for lack of research funding commitment on what would likely anyway be banned.

The point is not that energy saving is not good. Of course it is.
But product bans that are arguably overall and comparatively pointless in saving energy become a form of totalitarian policy to favour some whisper-in-the-ear multinational corporations to force people to buy products they presumably would not otherwise buy (or the bans would not be "necessary"), products which might indeed improve in internal competition of restricted choice but hardly as much as on an open free market against a multitude of products and manufacturers, and without the quality-for-price pressure that the continued existence of cheap alternatives would give.

Canadians like people elsewhere spend much of their lives under artificial lighting.
There is hardly any regulation that has such an effect on so many for so much of the time.

How many politicians should it take to change a light bulb?

How many citizens should be allowed to choose?

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.

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