The Odd Green Crony Capitalist Coalition Behind Banning Bulbs

January 7 article by Shawn Regan, from Reason.Com
Good on the industrial policy behind the ban

Lights Out For America’s Favorite Light Bulb
Happy New Year, America! Your favorite light bulb is now illegal.

Well, sort of. As of January 1, U.S. businesses can no longer manufacture or import “general service” incandescent bulbs—the most popular light bulbs in America. Consumers can still buy and use them while supplies last, but the remaining inventory won’t be around for long. Home Depot says it will be out of the bulbs within six months. Some consumers have started to stockpile.

It’s all part of the energy efficiency standards mandated by the Energy Independence and Security Act of 2007. The law already killed off the 100-watt incandescent bulb in 2012, followed by the 75-watt bulb in 2013. Now, in the final step of the phaseout, the minimum efficiency standards have effectively banned the ubiquitous 40- and 60- watt light bulbs.

When industry and environmental groups claim that a regulation will solve all problems, consumers beware. It’s probably green cronyism in disguise.

The ban is crony capitalism in its most seductive form — when it’s disguised as green.

Major light bulb manufacturers supported the ban from the outset.
The profit margin on old-style bulbs was pitifully low, and consumers just weren’t buying the higher-margin efficiency bulbs. New standards were needed, a lobbyist for the National Electrical Manufacturing Association told Congress in 2007, “in order to further educate consumers on the benefits of energy-efficient products.”

So Philips Electronics and other manufacturers joined with environmental groups to push for tighter lighting standards.
As the New York Times Magazine explained in 2011, “Philips told its environmental allies it was well positioned to capitalize on the transition to new technologies and wanted to get ahead of an efficiency movement that was gaining momentum abroad and in states like California.” After much negotiation, a classic “bootleggers-and-Baptists” coalition was born. Industry and environmental groups agreed to endorse legislation to increase lighting efficiency by 25 to 30 percent.

Incandescent light bulbs, we’re told, are vastly inferior to the newfangled alternatives available today.
The compact fluorescents lamps (CFLs), LEDs, and halogen bulbs are an apparent no-brainer: They last longer and convert much more of their energy into light rather than heat, all while cutting back on your energy bill. (So, of course, the government must stop you from ever making the mistake of choosing the traditional bulbs.)

Except many consumers aren’t buying it.
The EPA estimates that, of the four billion light-bulb sockets in United States, more than three billion still hold incandescent bulbs. “By 2014, the traditional incandescent light bulbs… will be virtually obsolete,” claimed a 2007 press release from former Sen. Jeff Bingaman, the ban’s original sponsor. But according to the latest industry data, incandescents still make up nearly 65 percent of all U.S. light-bulb shipments.

Many consumers are turned off by the higher upfront costs of the alternatives.
A single 40-watt LED bulb costs $7.50 or more, while a traditional incandescent bulb goes for around 40 cents. Some are finding that the CFLs don’t last nearly as long as their supporters claim—especially if they are switched on and off frequently, or if they are attached to a dimmer switch.

The list of complaints about the “efficient” bulbs goes on:
They are often slow to respond, sensitive to high temperatures, and can cast a harsh and unattractive tone. CFLs also contain a small amount of mercury, which requires extensive and careful cleanup when a bulb breaks.

And they may not be saving us much energy after all.
The typical U.S. home uses no less energy per capita than it did in the 1970s, despite an onslaught of efficiency standards for everything from refrigerators and televisions to the amount of power consumed when appliances are in “standby mode.” The money saved in the long run by using these appliances is often spent on even more power-sucking gadgets. And if light bulbs cost less to use, why not just leave the lights on longer?

The light-bulb ban is an example of how political coalitions are formed to force regulations on the general public that benefit a few large producers.
A recent survey found that six out of every ten Americans are still in the dark about the latest bulb ban. Meanwhile, the dimwitted light-bulb policy just became the law of the land.
The lesson here is straightforward: When industry and environmental groups claim that a regulation will solve all problems, consumers beware. It’s probably green cronyism in disguise.

Shawn Regan is a research fellow at the Property and Environment Research Center (PERC), a nonprofit research institute in Bozeman, Montana, dedicated to improving environmental quality through property rights and markets.

This complements a January 1 article by Tim Carney at the Washington Examiner.
Tim Carney has for several years covered the industrial policy behind the USA ban.

Industry, not environmentalists, killed traditional bulbs
Say goodbye to the regular light bulb this New Year.

For more than a century, the traditional incandescent bulb was the symbol of American innovation. Starting Jan. 1, the famous bulb is illegal to manufacture in the U.S., and it has become a fitting symbol for the collusion of big business and big government.

The 2007 Energy Bill, a stew of regulations and subsidies, set mandatory efficiency standards for most light bulbs. Any bulbs that couldn't produce a given brightness at the specified energy input would be illegal. That meant the 25-cent bulbs most Americans used in nearly every socket of their home would be outlawed.

People often assume green regulations like this represent the triumph of environmental activists trying to save the planet. That’s rarely the case, and it wasn't here. Light bulb manufacturers whole-heartedly supported the efficiency standards. General Electric, Sylvania and Philips — the three companies that dominated the bulb industry — all backed the 2007 rule, while opposing proposals to explicitly outlaw incandescent technology (thus leaving the door open for high-efficiency incandescents).

This wasn't a case of an industry getting on board with an inevitable regulation in order to tweak it. The lighting industry was the main reason the legislation was moving. As the New York Times reported in 2011, “Philips formed a coalition with environmental groups including the Natural Resources Defense Council to push for higher standards.”

Industry support for the regulations struck lawmakers and journalists as a ringing endorsement of the regulations. Republican Congressmen Fred Upton, who has since flip-flopped and attacked the regulations, cosponsored the light bulb provision in 2007. His excuse, according to conservatives I spoke to: It couldn't be that bad if the industry supported it.

Liberals used this very argument to ridicule Republicans' 2011 efforts to repeal the law. Democratic congressman Steny Hoyer defended the rule by saying, “The standards are supported by the lightbulb industry.”

Joe Romm at the Center for American Progress pinned repeal efforts on the “extremist Tea Party wing of the party, which opposes all government standards, even ones that the lightbulb industry itself wants.”
That “even” signifies that the industry’s support indicates consensus. Instead, it signifies how consumers lose.

Competitive markets with low costs of entry have a characteristic that consumers love and businesses lament: very low profit margins. GE, Philips and Sylvania dominated the U.S. market in incandescents, but they couldn’t convert that dominance into price hikes. Because of light bulb’s low material and manufacturing costs, any big climb in prices would have invited new competitors to undercut the giants — and that new competitor would probably have won a distribution deal with Wal-Mart.

So, simply the threat of competition kept profit margins low on the traditional light bulb — that's the magic of capitalism. GE and Sylvania searched for higher profits by improving the bulb — think of the GE Soft White bulb. These companies, with their giant research budgets, made advances with halogen, LED and fluorescent technologies, and even high-efficiency incandescents. They sold these bulbs at a much higher prices — but they couldn’t get many customers to buy them for those high prices. That's the hard part about capitalism — consumers, not manufacturers, get to demand what something is worth.

Capitalism ruining their party, the bulb-makers turned to government. Philips teamed up with NRDC. GE leaned on its huge lobbying army — the largest in the nation — and soon they were able to ban the low-profit-margin bulbs.

The high-tech, high-cost, high-margin bulbs have advantages: They live longer and use much less electricity. In the long run, this can save people money. But depending on your circumstances, these gains might be mitigated or eradicated.

The current replacement for traditional bulbs are compact fluorescents (those curly bulbs). They give off UV rays, contain mercury gas, take a while to get bright and don’t last any longer than regular bulbs if you flip them on and off a lot.

Newer technologies, like LED bulbs, are better than CFLs, and they supposedly last 20 years. But they cost even more. In your office building, they probably make sense. In your house? Well they won't last two decades in a house full of kids who wrestle with the dog and throw footballs around the living room (maybe Congress should ban domestic wrestling and passing).

There is a middle ground between everyone using traditional bulbs and traditional bulbs being illegal. It's called free choice: Let people choose if they want more efficient and expensive bulbs. Maybe they'll chose LEDs for some purposes and cheap bulbs for others.

But consumer choice is no good either for nanny-staters or companies seeking high profit margins.

Technologies often run the course from breakthrough innovation to obsolete. Think of the 8-track, the Model T or Kodachrome film. But the market didn’t kill the traditional light bulb. Government did it, at the request of big business.

Timothy P. Carney, The Washington Examiner's senior political columnist, can be contacted at tcarney@washingtonexaminer.com His column appears Sunday and Wednesday on washingtonexaminer.com.

Comment

A lot more on the industrial policy behind the banning of light bulbs in the USA, Europe and elsewhere: http://ceolas.net/#li1ax
Specifically in an American context, also the "I Light Bulb" eBook by M.P. Leahy and Howard Brandston.
Howard Brandston, a well known New York lighting designer, was involved from the start in recurrent Senate hearings, and has covered the strange workings of the NEMA sub-committee (Philips, GE, Osram/Sylvania) in seeking the USA 2007 ban and indeed in their seeking to uphold it through 2011 (and no doubt 2014) reviews and bill attempts at tightening legislation further. His specific webpage and campaign against the regulations: http://www.concerninglight.com/commentary.html

The major manufacturers not unnaturally want to sell more profitable patented expensive alternative bulbs, and feel that any obstruction would be reneging on "promises" by politicians to smooth the way for them through initial consultation and legislation as per 2007 US law, 2008 Canada law, or 2009 Australia and EU laws.
Philips, GE, Osram/Sylvania cooperated to ensure incandescents did not have more than 1000 hour lifespan (the Phoebus cartel) and then cooperated to get rid of them altogether. Slam-Dunk.



Paul Wheaton

Note the irony:
Any outsider would of course consider it unusual that manufacturers would voluntarily seek to legally limit what they are allowed to make, and to welcome such laws once they are made.
The manufacturers are therefore repeatedly lauded by perennially clueless journalists for their "great green conscience", and of course happily strengthen such an image in their press releases.

Somewhat more perceptive observers remark that the manufacturers could have voluntarily stopped making the bulbs, just like they stop making much else in the name of progress - but that would therefore have allowed small and new and local manufacturers to happily and profitably make the patent expired generic cheap bulbs, without global distributive overheads or commitments to expensive alternatives.

In turn misunderstanding the process, "progressive green" people claim that legislation was necessary or the manufacturers would "never" have stopped making the old bulbs.
Apart from ignoring that incandescent lighting might have light quality and other advantages beyond crass economic or energy use reasoning (and the supposed savings not being there anyway as per other argumentation), this ignores what "progress" is: and it is hardly expensively imitative replacement clones of incandescent bulbs.
Increased - not reduced - competition drives progress, and it is conveniently forgotten that CFLs and LED bulbs were invented in the presence - not the absence - of incandescent competition, moreover that new inventions can always be helped to market albeit without continuing subsidies, allowing the best alternatives to flourish, with "expensive to buy but cheap in the long run" advantages highlighted by imaginative advertising, as is done for other products.

Overall it is of course odd to ban popular safe products just to reduce electricity consumption.
There are plenty of ways to reduce say coal use or emission or electricity, whether by legislation or taxation, and plenty of informative possibilities to say encourage lighting to be switched off rather than to ban a particular choice of it.

There is nothing but idiocy behind this banning of light bulbs.


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.
 

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".
Good.
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.

Ergo:
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

Thereby:
• 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.
 

Howard Brandston Appeal Letter

Letter from Howard Brandston 1 October 2012 to New York Times and the Wall Street Journal.
Reproduced by kind permission of the author.

Howard Brandston, as seen from previous posts and the resource links section of the blog, is an internationally highly regarded and experienced lighting designer.
He has as seen been directly involved in Congress US light bulb regulation discussion, as via his participation in several Senate hearings, including the last one on the topic in 2011.

Amidst passionate political debate, let’s not lose sight of the looming incandescent light bulb ban, a grave concern affecting every American’s health, well-being and freedom of choice, regardless of one’s party preference.
This ban is not the result of technological advancements, but instead is the careful orchestration of profit-seeking lamp manufacturers and uninformed ‘Green’ advocates.

The purported benefit of the bulb ban is energy savings – better for us, better for our environment. Nothing is farther from the truth: the incandescent ban is the best big business marketing scheme ever devised.

The truth is dating back to the 1980s when lamp manufacturers introduced residential Compact Flourescent Lamps (CFLs), consumers never really accepted them as demonstrated by poor sales and low corporate revenue. Quality of light; health, safety and environmental issues; shorter than reported life expectancy; poor fit with existing fixtures outline some CFL problems.

The truth is instead of responding to these important consumer issues, lamp manufacturers protected their CFL investment and used the influence and the dollars of their lighting lobbies to pressure the government to ban the competition -- the all-pervasive incandescent light bulb. Their accompanying marketing strategy was brilliant: join the global warming bandwagon.

The truth is lamp manufacturer and government propaganda and misinformation worked. In 2014, the incandescent light bulb will be relegated to the dustbin of history unless consumers really pressure legislators to repeal the ban.

Consumer pressure is working elsewhere around the world. Lighting designers, scientists, and everyday citizens are publicizing the consequences they have endured caused by the mandated ban. The truth is consequences far outweigh benefits. In the US, the amount of money the lobbies have lavished on politicians has sustained the planned ban to date. Only a groundswell of consumer revolt will restore common sense and protect our freedom to live our lives in safety.


Howard M. Brandston, FIES, Hon. FCIBSE & FSLL, FIALD
www.concerninglight.com

Howard Brandston is an internationally recognized expert on lighting for more than 50 years most well known for lighting the Statue of Liberty.

For more on Howard's writing on light bulb regulation issues,
see http://concerninglight.com/commentary.html
 

Howard Brandston interviewed on CBN

 
CBN News video and transcript article, June 1, including a Mark Martin interview with well known lighting designer Howard Brandston, of whom more in the Resource Links and earlier posts on this blog.






Some of the transcript:

Lights Out: Congress Making 100-Watt Power Grab?
HOLLOWVILLE, N.Y.
For more than 130 years, Thomas Edison's incandescent bulb has lit up homes around the world. Now, the light bulb as we know it may soon be a thing of the past.

Beginning this year, the federal government plans to phase out traditional incandescent light bulbs. The first to go is the 100-watt bulb.

It's all a part of the Energy Independence and Security Act of 2007. Republicans in Congress are fighting its enactment. But if they fail, the law will go into effect later this year.

Is this an energy-saving move or another example of a government power grab?


Energy-Saving Move?

The law requires basic light bulbs to be about 25 percent more efficient and would remove traditional incandescent bulbs from the market.

"I think it's very wise because maybe 40 or 50 years ago, it wouldn't have worked because there weren't alternatives," Sandra Miles, a veteran of the telecommunications and lighting industries and president of the Goeken Group Corp., told CBN News.

"But now you have plenty of great energy efficient alternatives that give you the same look and feel of an incandescent," she explained.

Those alternatives primarily fall into two categories: CFLs, known for their curly shape, and light-emitting diodes or LEDs. They're supposed to save energy and last a lot longer than traditional light bulbs.

However, lighting professional Howard Brandston isn't ready to give up on a bulb that's not broken. Brandston is known for lighting structures like the Statue of Liberty and Malaysia's twin towers.

Brandston stands by Edison's invention, using traditional incandescent bulbs to light his home.


Save the Bulb

Under current law, the standard 100-watt incandescent light bulb is to be phased out this year, a move he strongly opposes.
In fact, Brandston considers it a moral obligation to speak out against the phasing out of incandescent bulbs.
He's even launched a campaign entitled, Save the Bulb.

"Look at all the people who have lost their homes," he told CBN News. "Look at all the people who are out of work. Look at all of that, and now we're going to impose a new... a new financial burden on them."

On his website, Brandston wrote, "I see no good reason to relegate one of America's greatest inventions to the dustbin of history -- other than to suit the particular interests of uninformed politicians, light manufacturing giants, and their lobbyists, and energy zealots."

"I know a couple of senior researchers in the lighting industry, who've started to hoard light bulbs, and me included, because I might not win this fight, although I'm dedicated to it," he said.

That dedication includes a lifetime supply of bulbs stored in his basement.


Light Bulb Socialism

Miles hopes the attraction of energy savings and long life will win over consumers.

Brandston bases his skepticism on the uninterrupted, smooth color spectrum emitted by Edison's safe, low-cost bulb.

But his opinion may not matter unless the new effort by conservatives in Congress can stall what has been called "light bulb socialism."

 

More Dim Issues with Philips new LED Bulb

 
Continuing the Philips prize awarded LED bulb saga,
Kevan has confirmed some dimming and the issues of the bulb as also found by the US Government L Prize test review and designated lab reports in the main post earlier.

From Save the Bulb blog, 13 May 2012
(original post has some more images)

L Prize (Fail!)
I have spent the last couple of weeks in San Francisco and taken the opportunity to observe the impact of the Californian ban on incandescent lamps that was implemented in January 2011. Basically it has had zero effect. Standard incandescent lamps are freely available through all retail supply outlets. I have checked corner stores, supermarkets, neighborhood hardware stores and DIY sheds all have a full range of conventional incandescent lamps. The “Energy Saving” options vary considerably. Most stores have a reasonable complement of CFLs some have halogen incandescent replacements but only on hardware store and the DIY sheds carry any LED incandescent replacements and just the DIY shed had the L prize lamp that I was very keen to get my hands on. These LED options are all selling in the range $17 to $24.


There has been so much store set by the quality of the L prize lamp that I was very keen to get one as it seems unlikely we will get them in the UK anytime soon. The first thing that surprised me was the extent of packaging for what is supposed to be an environmentally friendly product.

When first switched on I have to concede that the appearance of the light was OK in comparison to the GE Reveal lamp that it was replacing. The reveal is an incandescent with a slight blue tint.


As expected when dimmed things changed dramatically:....



The L prize got cooler in appearance and the perceived colour rendering became much worse casting a gloomy grey in the space. the lamp also suddenly went out about half way through the travel of the dimmer’s slider, the GE lamp dimmed right down to the minimum setting. What was really alarming was that the L prize lamp would not switch on at dimmer settings below about 70%. This was a serious problem in this location where three way switching was installed.


Really I am somewhat disappointed in a product that cost me $19.75 and does not work reliably at less than full power even when it claims to be dimmable. Solutions such as this must be made fully compatible with existing wiring infrastructure.

Another point about the massive cost for these lamps is whether or not the claimed savings are realistic in domestic use. How many people will be using the same lighting after 22 years? How many will still be living in the same house or apartment? At 58 years old I have to question whether I will still be alive to realise these claimed savings! It really is not good enough that the best of these lamp replacement products should be priced so high and fail to meet reasonable performance expectations that at least they do not risk leaving people in darkness! I do feel that the general lamp buying public are being conned into overspending for overcomplicated and ineffective products.

This page from EarthLed shows a dissection of the L prize lamp. It really does question the holistic sustainability of replacing such an elegantly simple device as the traditional incandescent lamp with something that requires computing power that would shame the flight computers of the Mercury and Gemini space programmes and has more electronic components than a transistor radio! All in all the resources used to make this thing are truly excessive for the required functionality.

Comment

The mentioned Earthled dissection of the bulb is also on the post "(S)tripping the Light Fantastic", with extensive commenting.

On the Dimming issue,
unsurprisingly it mirrors CFL problems since LEDs also have spiky emission spectra and with these LED types also use similar (phosphorescent) coating to help spread the light.
And dimming after all is also an “energy saving” benefit, that ban proponents welcome!

Dimming and other problems were as said also highlighted in the official committee test review and designated test lab reports on
“All about the new Philips LED Bulb, and how it won the L-Prize”

Renowned lighting designer and Congress lighting consultant Howard Brandston concurs on the dimming and other issues..

"The testing of this LED lamp was very narrow in scope and did not include some of the most important aspects of residential lighting.
As a lighting designer my primary concerns is the quality of the color of light emitted throughout the complete cycle of being dimmed, a common situation in homes.
In this use the lamp leaves much to be desired so I would never specify it."

A further interesting observation today (May 16) by Kevan

Apparently what I have is not the L Prize lamps but a confusing look-alike also sold by Philips!
This one is a Chinese made version, The L prize version itself is ”Assembled in the USA”.
So Philips are knocking off their own products!
The L Prize version is obviously too expensive for normal retail and is going out through specialists such as EarthLed!

... So are Philips using L Prize specs highlighted in reviews (eg a comparatively high lumen per watt efficiency), and the “kudos” from winning the L Prize, to push sales of cheaper inferior Chinese versions in ordinary stores for Joe Public who is assumed not to question quality and specs?

No! Never! ;-)
 

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:
http://www.c-spanarchives.org/program/S39&start=6050&end=6500

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.






Comment

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)
 

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.