"Most Americans against the Light Bulb Ban"

January 8 update, new ending. [Original post also January 8]


Rasmussen Survey, conducted January 2-3 and as reported January 7 2014

Only one-in-four Americans support the ban on conventional 40- and 60-watt light bulbs in the United States that went into effect January 1, and the same number say they or someone they know stocked up on the old bulbs beforehand.

A new Rasmussen Reports national telephone survey finds that 60% of American Adults still oppose the ban on traditional light bulbs ordered by the federal government in the name of improved energy efficiency. That's down only slightly from 67% in July 2011 when the government first announced the new regulations. Twenty-five percent (25%) now support the light bulb ban, up from 20% two-and-a-half years ago. Fifteen percent (15%) remain undecided.

The national survey of 1,000 Adults was conducted on January 2-3, 2014 by Rasmussen Reports. The margin of sampling error is +/- 3 percentage points with a 95% level of confidence. Field work for all Rasmussen Reports surveys is conducted by Pulse Opinion Research, LLC.

The questions asked...

National Survey of 1,000 Adults Conducted January 2-3, 2014 By Rasmussen Reports

1* How closely have you followed recent news stories about changes in the manufacturing of light bulbs?

2* While effectively banning the sale of traditional light bulbs, a new law will allow only more expensive light bulbs that are expected to last longer and be more energy efficient. Should the sale of traditional light bulbs be banned?

3* The Energy Department says that the new light bulbs will cost more up front but save money in the long run. How likely is it that the new light bulbs will save money in the long run?

4* Is it the government’s job to tell Americans what kind of light bulb to use?

5* Suppose the new light bulbs don’t work so well and end up costing more money in the long run. How likely is it that the government will then allow the sale of traditional light bulbs?

6* Will the new fluorescent or halogen bulbs be good for the environment, bad for the environment or will it they have no impact on the environment?

7* Have you or anyone you know bought large quantities of traditional bulbs to use once they are no longer available in stores?

8* Are you buying the new energy efficient bulbs because you want to or because traditional light bulbs are no longer available?

9* Who would do a better job of providing quality products for consumers-- government planners and managers or companies hoping to make a profit?

NOTE: Margin of Sampling Error, +/- 3 percentage points with a 95% level of confidence

Today, January 8 2014 sees a new press release

January 8, 2014:

Just 18% of American Adults believe it is the government’s job to tell people in this country what kind of light bulb to use. Seventy-two percent (72%) disagree and feel it is not the government’s job to make that call. Ten percent (10%) are not sure.

Which happens to be identical to 2009

Rasmussen July 2009:

Just 18% of American Adults believe it is the government’s job to tell people in this country what kind of light bulb to use. Seventy-two percent (72%) disagree and feel it is not the government’s job to make that call. Ten percent (10%) are not sure.

This is presumably an unintentional mistake? ;-)
The comparative January 7, 2014 press release, as per above, edited to fit in

Twenty-five percent (25%) support the light bulb ban....60% of American Adults still oppose...Fifteen percent (15%) remain undecided.

For the sake of completion, the July 2011 survey

Just 20% of adults think the sale of traditional light bulbs should be banned. Sixty-seven percent (67%) oppose such a ban. Thirteen percent (13%) are undecided.

[Thank you to MB Snow, since retired, for the 2011 information, The Snow Report, which has more about that survey]



Comment

Lies, damn lies, and statistics...
There are other surveys in the past, as by USA Today (more below), purporting to show "How people welcome regulations and the great new light bulbs".

There are 2 main points here.

Firstly, how the questions are asked
(eg "are you happy about the great new bulbs" versus "should government tell you what light bulb to buy" kind of juxtapositions, with nuances in between).

Secondly, and more importantly, that bans are wrong either way.
Why?
New bulbs are desirable - No point banning old bulbs
New bulbs are not desirable - No point banning old bulbs

If new bulbs are "so great and welcome", presumably they would be bought voluntarily, and there is little savings in not allowing the presumably low sales of alternatives for those who still want them.
Conversely it's hardly great either, of course, to ban a more desirable choice.
[More cynically, one might also ask, if people really think the "alternatives are so great", why haven't they already bought them then? Standard light bulbs remain the most popular choice.]

Overall,
as the more detailed surveys also show, people certainly have bought new kinds of bulbs.
They just don't want all their light bulbs to be non-incandescent (and as per other posts, halogen replacement incandescents are also legislated to be banned in North America, Europe and Australia on tier 2 regulations).
Switch all your bulbs and save money, is like saying
Eat only bananas, and save money.

See the issues around these kind of surveys, as already summarized in the "How Regulations are Wrongly Justified" 14 points rundown.



To illustrate some of this:

The USA Today paper has in the past put out survey results showing how "Americans welcome the regulations" and indeed new light bulbs themselves.

Nearly three of four U.S. adults, or 71%, say they have replaced standard light bulbs in their home over the past few years with compact fluorescent lamps or LEDs (light emitting diodes) and 84% say they are "very satisfied" or "satisfied" with the alternatives

.... which incidentally applies to switching one or more bulbs, not a total switchover - again statistical manipulation!
As it happens, the same article author had 10 days earlier pointed out

Types of lightbulbs consumers have in their homes:
Incandescents 82%
Compact fluorescent 72%
Halogen 39%
Light emitting diodes 27%
Source: Sylvania Socket Survey

As for the more recent 2013 Sylvania socket survey, it finds that

65 percent of Americans plan to switch to more energy-efficient lighting technologies, as a result of federally mandated legislation that is increasing efficiency standards     [well, they hardly have a choice!]
More than half (59%) of consumers are excited about the phase out, as it will help Americans use more energy efficient light bulbs.     [why - who was stopping them using them?]

Conversely, it also says

30 percent of consumers say that they plan to buy a lot of traditional light bulbs where still available and will continue using them. This is a sharp increase from the 2012 Socket Survey which showed just 16 percent said that they plan to stockpile bulbs.

Given what was said about different lighting having different advantages, this is hardly surprising, the contradiction is only apparent.
Yet, most US media seem unable to make balanced appropriate remarks:
"Liberal/Eco" side focusing on the "welcome" bit, "Republican/Conservative" side on the "stockpiling" bit, others seemingly "perplexed" at the findings, which are therefore not really contradictory at all.

It's a bit tiring to be an assumed retrograde lover of obsolescent technology.
It seems incredibly hard for some to understand that being against a ban does not necessitate being against other forms of lighting.
Of course, fluorescent bulbs or LEDs have disadvantages too, but disadvantages are also naturally highlighted in objections, if one is forced to use such lighting where incandescents would have been better (and yes it is a "ban" on incandescents including halogens, for reasons covered at length elsewhere, including tier 2 US/EU etc law references).
All lighting has different advantages for different uses.
Politicians that have something in their heads that can be likened to a brain might understand this. Then again, they might not.



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.
 

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.
 

Learning from History: Audio Incandescent and Solid State

Revision, additions: December 2, November 29     Original Post: November 28

The beginning of the EU review of the 2009 light bulb regulations which sees the November 25 launch of the EU (European) Commission alteration proposals has been covered here earlier with extensive analysis.
Subsequent posts have covered industry views, mainly LightingEurope (Philips, Osram and other manufacturers).

The main recommendation here as part of the first stage 6 review by the Commission, concerning the future of halogen replacements, is to allow frosted halogen bulbs, which were not banned for any energy efficiency reason but rather to push sales of CFLs, an outdated legacy ban given that solid-state LEDs exist in both clear and frosted versions and will "be bought more and more" according to both the Commission and its energy efficiency advisers, on the basis of becoming "ever better and cheaper", which rather takes away the whole point of the ban.


Compare the close historical relationship to incandescent audio tubes/valves...
after all, who are the major light bulb manufacturers?



source  vintage ad browser

     





The tubes (structurally like incandescent bulbs) were not banned in radios and other audio equipment when "ever better and cheaper" solid-state transistors (structurally like LE diodes) came along: manufacturers - not governments - supplied energy-efficient market demand.


Today's EU Commission would have jumped on top of the "energy-guzzling" tubes.


Never mind that they have retained niche uses - and launched a rock and roll guitar amplifier age.
As with light bulbs, the Killjoy Commission would have been at the forefront of ban implementation to make sure that never happened - which just goes to show that setting usage standards does not just ban existing products - they ban what could have existed, and never will.
Relating such argument to light bulbs, see the post "What We Will Never See".




So who do the Commission talk to about all this?
"Stakeholders".
Ordinary people are never seen by the EU as stakeholders. They just have to swallow what's coming to them.
In fairness, "everyone can't be heard", but Consultation Forums that fill the room with Energy Agency Yes-Men hardly make for balanced conversation.

This is also why alternative views to the EU process have been posted here in recent days.




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.
 

Preliminary Report: November 25 EU Consultation Forum

Concerning the EU (European Commission) Light Bulb Review and their proposal to alter the regulations as laid out in detail previously:

Yesterday saw the previously mentioned meeting in Brussels of the Consultation Forum involving the Commission, national energy representatives and a few lighting "stakeholder" delegates.
I will expand on anything arising out of this: Suffice to say that while LightingEurope (representing Philips, Osram, GE and other major manufacturers, pre-meeting official statement of their position) and a few other lighting representatives were for the continuation of halogens without time limit, most of the energy agency type people predictably wanted to keep the 2016 ban, with some national representatives (eg Germany, Austria and Italy) wanting at least a delay, in that sense siding with the Commission 2 year delay proposal.
As this was just a consultation, decisions will take some time yet. Final decision on all aspects of the regulation review will be made by April 2014.

The most surprising aspect of the meeting was the focus on clamping down on "rough service" type industrial bulb sales to ordinary consumers - EU light bulb sales inspectors will likely be authorised to patrol the sale outlets of member nations, as already demanded by Energy Commissioner Oettinger for his native Germany. The idea therefore already has strong backing from the boss - and this time nearly all are for it, including the major manufacturers, as a lot of those bulbs are cheap Chinese imports. Thereby also "useful EU job creation" achieved. General applause.
What, the consumer? When were consumers ever important?!




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.  
 

EU Commission Light Bulb Ban Review 3: LightingEurope Industry Statement

Continuing the series on the EU Light Bulb Ban Review.

Recap
The first post covered the details of the review of the 2009 light bulb regulations that has been started by the EU (European) Commission, and the Commission's proposed 2 year delay on the stage 6 phase out of halogen replacements.

The second post covered the lighting industry position ahead of the EU proposal, mainly that of the major LightingEurope stakeholder (Philips, Osram etc), where they advocated a 3 year delay.
As seen, the representatives were unhappy about cheap lower quality LED imports, hoping for stricter rules in the meantime, rather than being particularly keen to maintain a halogen (let alone standard incandescent) choice for consumers.
My comments criticized this accordingly.

Of course, a few representatives do not necessarily speak for the whole association.
In any case, as per the subsequent released official position of LightingEurope on the issue, they advocate abolition of the stage 6 phase out, and are certainly supportive of halogen lighting alternatives.

An outsider would consider this completely normal:
After all, what manufacturer normally welcomes a ban on what they can or can't make?
Yet, as the history of regulation shows, the major manufacturers have hitherto done just that, on the basis of forced switchovers to more profitable alternatives. A cynical view is that allowing halogens is a magnanimous meaningless gesture to the manufacturer profit bottom line (halogen replacements being far more expensive than regular incandescent bulbs for marginal usage savings, and they were unpopular as a mains voltage choice while regular incandescents still existed). But at least it maintains more choice for consumers.


Should be seen below as a scrollable PDF document:
LightingEurope position on the review of the Stage 6 Requirements of Commission Regulation (EC) No 244/2009

Commenting follows below.






Comment

Conclusions

LightingEurope welcomes Commission’s proposal to postpone the entry into force of the stage 6 requirements. Nevertheless, the LightingEurope recommends the abolishment of Stage 6 requirements, allowing LED technology
to mature further and to grow to a level of market penetration that made it a viably alternative for all EU citizens after having reached an optimal point in terms of monetary and energy savings, without compromising jobs.

Clearly welcome.
Interestingly, as seen LightingEurope is also critical of the Commission suggestion to ban special R7 and G9 halogen types, and to enforce LED compatibility on new fixtures - as covered in the updated first post in this series.



The main argumentation, extracts, inserted comments in italics:

Impact on European Consumers
Each technology produces light with a different distribution pattern.
Halogen lamps are omni-directional point sources,
CFL lamps are omni-directional diffuse sources,
LED chips are directional point sources.
[All lighting forms have their own advantages..indeed]

Luminaires designed for halogen lamps are generally designed for omni-directional point sources.
Other lamp types may or may not function properly in a luminaire in a specific application.
[Note the implied criticism of the EU proposal to enforce LED compatible fixtures]

It is up to the user to determine whether or not a CFL or LED replacement lamp is acceptable.
[An extraordinary statement, for anyone who has read their past communications]

In many applications they are acceptable, but in many other applications they are not.
It needs to be pointed out in this context that learnings from the phase out of incandescent lamps that started in 2009 should be taken into account when determining stage 6 requirements. Upholding these requirements or even postponing them to only 2018 would lead to a factual and unintended phase-out of well established and demanded products on the European lighting market. [Implied objection to EU regulatory rule - again extraordinary - hopefully the authors of this don't get sent to Siberia or whatever the equivalent EU punishment is... and it continues:]
It is to be expected that the consumer’s outrage might be comparable to the one in 2009.
In some applications, a halogen lamp is required for the luminaire to function properly in terms of light emission, quantity of light, light distribution, dimmability, heat management and quality of emission.
If no halogen lamp is available anymore, the only other option is to completely replace the luminaire which would have a severe negative economic impact on the consumer.

Reasonable estimations from industry side indicate that more than 200 million luminaires [fittings etc] in European households would factually become unusable under implementation of stage 6 requirements.
Given this, also a transition period until 2018 would give only five years to European consumers to replace their luminaires.
In the end (costs minus savings) until 2025 consumer would have costs for replacing luminaires of 1.9bn€!
Together with the additional costs €3.1 to €4.6bn caused by a ban as calculated in Table 19 of the review study (p. 40) the overall costs for the keeping stage 6 becomes: €5 to 6.5bn until 2025.

A ban of mains-voltage halogen lamps could have a negative effect on future savings...if consumers are
forced to use CFLi / LED as early as 2016, sockets will be blocked to further improvements of energy efficiency for the next 10/25 years

Savings in 2020 Abolishing stage 6 vs keeping stage 6 and moving to LED: 18.6-9.2= 9,4TWh
Savings in 2020 Abolishing stage 6 vs keeping stage 6 and moving to stage 6 MV-HL: 18.6-14.1= 4,5TWh
Savings until 2060 abolishing stage 6 vs keeping stage 6 and moving to LED: 252,9-218,4= 34,5TWh
Savings until 2060 Abolishing stage 6 vs keeping stage 6 and moving to stage 6 MV-HL: 221,9-218,4= 3,5TWh

They understandably still welcome LED development of course...

LightingEurope is convinced that the increasing “ledification” of light and the related disruptive changes to the entire lighting sector should be seen as opportunities for the European lighting industry.

As a critical aside, to what is obviously otherwise a surprisingly positive statement:
To the extent a push for LEDs might be backed by campaigns, subsidies and maintained existing regulations as on regular incandescents, one might ask if that means a ledification....or leadification of the light bulb sector
Both literally and metaphorically.

Literally in the lead content of LEDs
Department of Chemical Engineering and Materials Science, University of California, USA analysis:
Excessive levels of copper (up to 3892 mg/kg; allowable limit: 2500), Pb (up to 8103 mg/kg; limit: 1000), nickel (up to 4797 mg/kg; limit: 2000), or silver (up to 721 mg/kg; limit: 500), rendering all except low-intensity yellow LEDs hazardous....

Metaphorically, in dulling down a lighting industry, by decreasing rather than increasing choice and competition between different technologies (also by focused subventions on LEDs to the exclusion of alternatives) leaving the LEDs as some sort of sole saviour of humanity.

Bluish LED light forms are already taking over as car headlights, bicycle lamps, torches (flashlights), and at this time, Christmas lights - and not always with a pleasant or even useful light quality.

LED development, in overcoming some of its disadvantages, is welcome and useful - but not to the exclusion of all else.
All lighting has advantages and disadvantages.
It is good and welcome that Philips, Osram and others are beginning to recognize this.
If they haven't quite "seen the light", they have at least shown some "illuminating" development.
 


Finally,
any continued allowance of halogen lighting should include frosted, softer tone (EU term "non-clear") light bulbs, needlessly banned along with all other such incandescent bulbs. They were by far the most popular bulbs before the ban, with less point source glare.
It might be said that stage 6 only deals with already specified halogens. But - as from the EU Commission's own proposal ("extending the stage 6 requirements to halogen lamps with G9 and R7s socket") this does not hold up: the Commission themselves already added clauses, in terms of banning GP and R7s socket bulbs, and in mandating LED compatibility of new fixtures.
So clearly (or non-clearly!) they could move to alter stage 6 requirements to allow such halogen light bulbs.

Even in the underlying research report, the point is made by one of the consultants behind it that such light bulbs are often more - not less - energy efficient than the clear transparent bulbs

Paul van Tichelen replies that we have to make distinction between clear and frosted equivalent.
A clear lamp is always in the lower lumen output.
The lamps we found with above 800 lumen output were for frosted lamps (higher lumen output than clear lamps).

[Note: "(higher lumen output than clear lamps)" albeit emphasized, is the original quote, it is not a comment addition]

Clear LED lamps as referred to more commonly have lower brightness than clear incandescents in comparison with their respective non-clear alternatives, but the overall point remains.
Frosted brightness will depend on luminescence and thickness of coating in being more or less energy efficient. Overall, it is a marginal issue, as also acknowledged by the EU Commission:
The original ban argument that "people can buy CFLs/LEDs if they want non-clear lamps" obviously ignores all the other reasons why particular lighting is chosen.
The EU legislators often say they are not the only ones banning bulbs.
But no other jurisdiction than the EU maintains such a petty specific ban on frosted 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.
 

EU Commission Light Bulb Ban Review 2: Lighting Industry Views

See a previous post which covers all the details of the review of the 2009 light bulb regulations that has been started by the EU (European) Commission.


LEDs Magazine is an excellent USA based publication covering mainly technical issues relating to LED lighting.
While obviously supportive of LED development (and why not), the October article covering the upcoming EU review of lighting regulations was surprisingly critical of the EU phase out - as were the industry representatives interviewed, although obviously from a perspective of their own eventual successful sales.
A delay of the halogen phase-out to 2019 is proposed, which as it happens is close to the EU proposal of a delay to 2018.


Regarding LightingEurope, the industry association covered in the article, quoting from their website introduction:

LightingEurope is an industry association representing leading European lighting manufacturers, national lighting associations, and companies producing materials. We are committed to innovation, sustainability, quality and leadership. We contribute to shape policy and establish industry standards and guidelines.
We are dedicated to promoting efficient lighting practices for the benefit of the global environment, human comfort, and the health and safety of consumers [and our profits].

If incandescents were so bad, then they could of course just stop making these "terrible" bulbs!
Manufacturers change standards all the time - without government bans.
"Unfortunately" someone else would of course then make the cheap popular bulbs.
Hence the irony: if incandescents were not so popular, there would be no "need" to ban them.

Incidentally, it is perfectly alright and even to be expected, that GE, Philips, Osram et alia lobby for a ban on patent expired cheap generic popular incandescents for their own profits from expensive patented alternatives.
The issue is with politicians - and people like the EU bureaucrats - handing them profits on a plate, to the detriment of consumers and their free choice, and with little if any overall energy saving for the extensive reasons provided elsewhere here (see pages on the left), which also answers "green" concerns in terms of which bulbs are actually "green".


Below article:
Energy efficiency may come at the cost of consumer confidence
Caroline Hayes, LEDs Magazine October 2013

Comment

LightingEurope believes that no LED-based lamps will meet the Stage 6 requirements of European Commission (EC) Regulation 244/2009.... LightingEurope advocates that 2019 is a more realistic date for halogen bulbs to be replaced, rather than the current deadline of 2016. There are several reasons for this request: affordability, a desire for consumer choice, and quality issues....
Jürgen Sturm, secretary general of Lighting­Europe, is concerned that an accepted technology is taken away with no viable alternative offered...

A delay is better than an immediate ban, and overall the conclusion is welcome, although if LEDs "keep getting better and cheaper" then presumably consumers would want to buy them - voluntarily - without bans on alternatives.

Why the eternal assumption that we, as consumers, are idiots?
And why the assumption that we are idiots because we may think (Shock, Horror!) that lighting products should primarily be judged on lighting ability.


As it happens, it's hardly out of worry for consumer choice that the manufacturers want a delay - rather that there are still too many cheap alternatives that might, er, distract consumers from their own expensive wares...

[Jürgen Sturm]...the fear is that halogen bulbs will be phased out before the market is mature, leaving low-quality LEDs to be seen as the only option, based on prices. This will be detrimental to the maturing market, Sturm warns...
A related issue is that there is no provision for what Sturm calls "market surveillance." Each EU member state is to be responsible for policing the pricing and quality of LED replacements. What is affordable in Sweden may be unacceptable in Romania, for example, he points out. The lack of market surveillance in member states is a particular worry for LightingEurope...

[Nick Farraway]...there will be many products imported without quality controls and sold alongside the expensively produced ones.... consumers, buying cheaper brands, are left with a poor impression of LED lighting.

A worry then that cheap (Chinese) imports will displace profits from their expensive bulbs - with an ominous call for market surveillance.

It is perfectly understandable that a maker of a quality product does not like that his/her product might get a bad name from rival manufacturers making cheaper, worse, similar ones.
If technical specifications are not met by the imports there is obviously a legal case as well, and imported bulbs like all bulbs should meet whatever the label holds on lifespan and other criteria.
But regulating "quality" is a questionable business - and the manufacturers seem to have regulation on the brain.

There is a market, and there is an ability to sell: Show it, folks.

Market surveillance is needed for dangerous-to-use products.
If market surveillance is called for here, why doesn't Big Gov stop people buying anything cheap and shoddy.
Hey, ban fast food - expensive high quality food is better for us!
Hey, ban cheap batteries and washing up liquids - so we only buy the good expensive alternatives!
(Which are advertised as such of course "expensive to buy but cheap in the long run" and/or otherwise in having better performance quality - and which light bulb manufacturers could too, instead of crying like this all the time).

This is also of course similar to why incandescents were banned in the first place (getting cheap popular competition out of the way).
It is also similar to the "call for shop inspections" by a sympathetic Commissioner Oettinger, to get rid of the legal rough service incandescents that people again "unfortunately" might buy.

For hotels and commercial installations, the payback period should be 6–12 months, but for homes, where lights are used less, the payback may be extended to a period of 3–4 years, which is not such an obvious financial return for consumers.

Well, well. There's an admission.
Although 3-4 years is still far too low for the infrequent usage of most household bulbs (average 20-25 bulbs per household in the EU, more in North / West European households) - as covered elsewhere here.
Longer time still, when taken as the unsubsidised payback cost per LED to the taxpayer.

For Farraway, there are other flaws in the EcoDesign Regulations.
One is that the low specified CRI (color rendering index) may deter end users from LED lamps. Halogen lamps are popular with consumers because they render color well, he says, enhancing interiors. He is concerned that the EU is allowing quality to be diluted.

He fears lessons have not been learned from the introduction of energy-efficient compact fluorescent bulbs. "Compact fluorescent is a good technology to save money, but is a poor light, and therefore unpopular," he says, referring to its green hue. He wants a much more stringent color metric for replacement bulbs. The EU wants 80 CRI, but Farraway wants 95 CRI or greater, although he concedes that the obstacle to this is a more difficult and more costly process technology.

While recognizing the central issue all bulbs have advantages - as it happens, incandescents have a maximal Color Rendering Index of 100 - it's hardly "progress" to push for expensive LED clones in such respects.
CFLs and LEDs have advantages other than CRI.
Imposing incandescent-style CRI standards just shows how messed up the regulatory thinking is - by all sides concerned.

[Farraway]...the price will decrease as volume increases for an affordable product that can last 40,000 hours, compared to an incandescent bulb's 700 hours.

700 hours?
If your associates didn't stick with Phoebus cartel standards for household consumers - and even that is 1000 hrs - then they could last 20,000 hrs and more, as per Aerotech and other incandescent bulbs for industry.
Conversely, the lab specificed 40,000 hr life is doubtful on several grounds in real life (including the dimming with age of LEDs) - and even the EU Commission's own VHK/VITO research report uses 20, 000 hrs.




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.