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

Monday, December 30, 2013

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

Update, additions Jan 1 2014






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


Strange to ban a popular safe product:

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



Incandescents have many specific advantages for Canadians:

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



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

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



Local Canadian industry and jobs:

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



The ban is justified as lowering electricity consumption:

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

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

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

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

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



Alternative policies:

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

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



The "Hey don't worry everybody" message:

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

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



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

Full version   As Doc    As PDF

Content List

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




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

Tuesday, December 24, 2013

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

This old post had problems in updating, just keeping this for any incoming links:
See new post

Monday, December 23, 2013

Canadian MP Cheryl Gallant's Campaign to Stop the Canada Light Bulb Ban


On the theme of the Canada ban covered in the last series of posts,
Canadian MP Cheryl Gallant (website, facebook page) has a campaign going against it.
Interestingly, she is a member of the Government Conservative Party launching the ban.
But rather than her being an odd one out, what is odder is surely that her Conservative Party which otherwise proudly proclaims a "free market" and "free choice" agenda, should back such a state totalitarian measure.
And, yes, it is a "ban", setting standards that don't allow them obviously "bans" them, and supposedly allowed "similar" incandescent (halogen type) alternatives will be banned too on adopting US law, EISA tier 2 2014-2017 final rule requirement of 45 lumens per Watt equating to fluorescent bulbs.

For more details of the Canada Government ban proposal, and a 10 section analysis of it, see the first post of the series.
As mentioned, direct appeal to Government itself is possible, they invite comments via their stated comment line (+1) 613-996-4359 or email equipment@nrcan.gc.ca
While formally finished 19th December that does not mean not being able to still "send a message".

The same applies of course to MP Cheryl's campaign.
Albeit launched just recently, there does not seem to have been any news or updates since then. But it's still ongoing, and an MP of the same party as the Government would presumably have "the ear" of those in charge more than an effort by other people, also in any future attempt at reversing a decision, and signing the petition and supporting the campaign in other ways also gives such a backing of course.






Campaign site: stopthelightbulbban.ca
Petition signing.


Campaign site message:

Safe and Affordable
The incandescent light bulb is safe and affordable.
Starting next January, 75- and 100-watt incandescent light bulbs will become black market items, and by the end of 2014 the same will happen to 40- and 60-watt versions.
Co-sign Cheryl Gallant’s letter to the Ministers of Natural Resources, Health and Environment, and tell the Government to stop the light bulb ban.
Most Canadians do not know light bulbs will be banned. Tell your friends and family at once. Encourage everyone you know to co-sign Cheryl’s letter before it is too late!

Unsafe Disposal
Unlike incandescent lights, which can be disposed of safely in the regular garbage, CFLs contain mercury, which can have significant impacts on both human health and the environment if not disposed of properly. Consequently, these lights are generally not accepted in the regular garbage stream and need to be disposed of using a hazardous waste program.
Proper Disposal 24% Tossed In Regular Garbage 55%



Letter circulated around 14th December

Dear friends,

The countdown is on. Starting January 1, 2014 our federal government will commence the phasing out of incandescent light bulbs. The overwhelming response to the constituency survey on whether or not a further delay in the ban is needed was that the ban should not go ahead at all.

The ban arose from the Kyoto Protocol as part of the United Nations Framework Convention on Climate Change (UNFCCC), an international treaty that sets binding obligations on industrialized countries to reduce emissions of greenhouse gases. Although Canada did not ratify the agreement, the ban on incandescent light bulbs stayed on our books.

The main alternative to incandescent light bulbs is the compact fluorescent lamp (CFL). CFL bulbs cost roughly 8 times more than incandescent light bulbs. They contain levels of mercury much higher than that of incandescent light bulbs, and are potentially harmful to humans, animals, and our environment.

Mercury is a neurotoxin, and must be specially disposed of, as it can contaminate water supplies and soil if dumped into landfills. According to Environment Canada the mercury contained in a typical thermometer can contaminate five Olympic-size swimming pools to toxic levels. Less than 10 per cent of CFLs are recycled amongst the tens of millions that are sold each year in Canada.

In a recent stroke of irony Canada signed the UN’s Global Mercury Agreement, which imposes a legally binding pledge to cut atmospheric emissions and environmental releases of mercury, in an international effort to reduce global mercury pollution and protect the environment and human health.

We have 17 days to stop the ban. Will you help me?

Sincerely,

Cheryl




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.
 

Wednesday, December 18, 2013

Incandescents: The Real Green Bulbs
Also in Canada


As the Canadian comment process finishes, as an American incandescent ban largely finishes on January 1, and as the EU review process also seems to have concluded in its first phase, some concluding remarks to the last series of posts seems apt.

The ban, not just on light bulbs but on much else in society, is largely driven by 2 aspects, supposed savings and product progress. Both have been well covered, but product progress deserves extra mention in an overall conclusion.

Product progress?
Product progress arises from increased, not decreased, market competition.
Energy saving progress in particular has been continuous throughout history.
Fluorescents and LEDs? On the market, without bans.
Solid state transistors replacing incandescent tubes? On the market, without bans.

Light bulb manufacturers could themselves simply stop making the "terrible incandescents".
That's what the very same companies normally do in the name of progress, they already stopped making cassettes, video cartridges, 8-track systems and much else.
Certainly they got - and get - lots of taxpayer subsidy goodies to make alternative bulbs while still slapping their own patents on them for yet more profit, and certainly politicians feel obliged to further help out their subsidised buddies sell more bulbs (as the Canadian proposal says, in so many words, in justifying bans because of committed investments).

The supposed problem is therefore that idiot citizens choose not to replace all their existing bulbs with the pushed alternatives, disregarding that most citizens - as the ban brigade keep saying - indeed have bought some for the advantages that they of course also have.

Of course, politicians don't want to declare their voting citizens to be idiots in what they choose to buy. Not openly, anyway. So the roundabout talk is that
"Regulations force faster development of better new products":
"Better" always being energy saving in usage with disregard to all else, including overall savings.
Obviously by necessity this brings new alternatives, but it is development that aims to fill the gap of popular incandescents - look at all the LED incandescent bulb clones. Hardly true or exciting progress.
As said, intrinsic advantages are of incandescents as bulbs, fluorescents as tubes, and LEDs as sheets, and was the original development of the latter 2 products, before all the push to compromise them as bulbs (yes, still with advantages of their own technology, but hardly developed as such now in bulb format, eg the flexible color temperatures of RGB LEDs rather than White LED bulbs).

A further issue is that regulation cut off standards don't just ban what exists. It bans all that could have existed, and never will, despite possible advantages beyond consumption of energy in usage. This, as with all else, is the case not just with light bulbs in the worldwide totalitarian definition of progress.


Everyone can have different legitimate views of the necessity of targeting products to save energy.
But what is then surprising is the complete lack of analysis of alternative policies.
Politicans? Media? Total silence.

Alternative information, taxation, market policies as thoroughly covered in the last post.
As the most fervent political, media and lobby grouped ban supporters tend to have a green or left-wing persuasion, the avoidance of all consideration of taxation is particularly puzzling. Even a mid-size 35 million country like Canada has well over 100 million in relevant sales, while in pre-ban USA and EU it runs into 2 billion sales in each case, of a cheap easily taxable product with high turnover, that could help all the " public spend" measures these people want.
In the USA, the California government is bankrupt - yet, like Canadian British Columbia, they ban every product in sight, instead of taxing it, and could of course announce it as subsidising cheaper alternatives re any "we hate tax" issue.
The point is not that tax is good. The point is that it is arguably better than bans for those who favor bans, while the market stimulation alternative is still better on the argumentation given, if light bulb targeting is (dubiously) deemed necessary.



So, to turn it all around.
Green is a color with many hues!

The case for looking at incandescents as the true environmentally friendly bulbs has been made earlier here.

That can be expanded on, and also put into a Canadian context, given the last series of posts here. The following is based on section 10 of the reply to the Canadian proposal for January 1 regulations on light bulbs, but as seen, it is generally applicable everywhere...









M'Lords and Ladies, the case for the humble simple incandescent light bulb:


Efficient?
Certainly efficient, in making bright light using few components


Earth Saving?
Certainly sparing the earth much mining for minerals


Long Lasting?
Certainly they can last long, at least to 20,000 hours at low price, as shown by mentioned small manufacturers, when major manufacturers don't control the markets.


Sustainable?
Certainly sustainable, in being easily locally made generic patent-free bulbs,
without much transport of parts or product, and without needing recycling.


Incandescents don't burn coal and they don't give out CO2 or other emissions.
Power plants might - and might not.
If there is a Problem - deal with the Problem.

Electrical products are only indirectly coupled to any energy source use, and in turn, the main evening-night time use of incandescent bulbs really only consume small amounts of off-peak surplus capacity electricity anyway, as seen.

Power plant emissions are decreasing on present policies, both from alternative source use and in directly being reduced and treated in various ways. Small overall off-peak bulb use and coal power plant night cycle operational factors reduces if not eliminates supposed bulb ban emission savings, and in a country like Canada of 86% emission-free electricity a ban even increases emissions on the heat replacement effect.



Incandescent light bulbs:
A pointless very visual feel-good target for an agenda driven ban seeking to ensure that the world loses the simplest cheapest product it ever had to produce light from electricity,
an aesthetically pleasing versatile invention, whose doom would arise not from being unpopular, but from being popular, through the stupidity that passes for global governance.




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