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

Thursday, April 16, 2015

The Unnecessary Continuation of the Light Bulb Ban

Updated, with added conclusion at the end, 17th April, 20 April

Energy efficiency regulations, especially on lighting, can be questioned:
>> Energy saving is not the only advantage a product can have
>> Enforcing lower energy use on any given product affects performance, usability or appearance as well as price.
>> The savings themselves are questionable at both overall life cycle and usage levels
>> Even if products needed targeting to save energy, there are better ways (consumer information, taxation+subsidy policies, assisted market competition) of doing it

Halogens are the last commonly available example of allowed incandescent technology for general service lighting
The EU has just announced a ban also on such forms, similar to current American, Australian and other legislation. This is part of the several ongoing EU review processes on lighting, of which more can be seen on the related Facebook group.

While this blog has covered why the original regulations made no sense, the irony is how in perspective of 2018 and beyond a ban not only on halogens but also a maintained ban on simpler incandescent bulbs makes even less sense than the ban in the first place.

This relates to hailed market transformation effects, and, as will be seen, CREE (USA) and other manufacturers seem to be coming round to the idea, albeit the manufacturer lobbying for the initial ban on profit motives, perfectly logical from their point of view, but wrongly conceded.

Before going on to overall discussion, some points relating to the EU decision regarding the halogen ban being shifted from 2016 to 2018.
This raised an interesting polemic between energy saving agencies and consultants (eg The Danish agency, CLASP consultancy, and the ECEEE councillors arguing for keeping 2016 versus Lighting Europe manufacturer consortium arguing for 2020)
I will likely shift specific EU decision matters to a separate post, but the general relevancies to this post will be mentioned here.

1. Whatever about temporarily allowing halogens, to 2018 and perhaps beyond that in due course, the odd maintained ban on frosted (non-transparent halogen type) incandescents that meet required standards.
This was a legal add-on, unique to the EU in worldwide legislation. Original reason for this was that
"Consumers desiring such lamps could buy CFL (fluorescent bulb) alternatives"
However, given the LED switchover drive and that LEDs can be made transparent, such a ban seems unnecessary and unduly petty.
"LED clear incandescent look-alikes are several years ahead of price and performance projections" the European Council for an Energy Efficient Economy (ECEEE) emphatically state.

2. I note several stakeholder comments of the variety
"New LEDs are/will be better and cheaper for consumer satisfaction on the lighting market"
Also statements along the lines of
"Habitual consumers will be happy with new technology once they have got used to it".

But what - exactly - is then the point in terms of any meaningful society savings of say a 2018 continued ban on what few people are assumed to still want (but might particularly appreciate)?
A new product is desirable - why ban alternatives (little society saving)
A new product is not desirable - why ban alternatives (obvious enough)

ECEEE and others of the "Let's have our cake and eat it" variety incongruously praise the "much lower prices and much better performance levels" of new LEDs and how great they are for consumers - and then the "massive multi-billion euro" saving from an early ban.
But "massive savings" assumes no-one would buy the "great" LED lamps without a ban on alternatives!

In this, they cite how badly CFLs fared....
Clear mains-voltage halogen lamps were allowed to remain on the market as a replacement for clear incandescent lamps and they were expected to constitute a relatively small share of total sales for non-directional lamps. New evidence has become available that has shown the market did not behave in this way, and instead halogen sales have quadrupled while CFL sales have declined.

Plus ca change, plus c'est la meme chose!
Organisations like ECEEE previously praised CFLs in exactly the same way that they now praise LEDs. How "great" for consumers they would be, how "great" to ban the incandescent alternatives.

one might take the line of Lighting Europe of waiting for the impact of better future LEDs and a smoother market transformation (their 2020 final ban suggestion).
Clearly LED sales are indeed increasing, but that leads to the opposite scenario:
What is the point of a ban if LEDs are indeed better, desirable, and bought, such that there are little or no society savings?
This also applies to already banned simple incandescents.

The duality was seen before.
VITO research figures ahead of 2009 suggested switchover already occuring from simple incandescents... so little savings from a ban, as highlighted by the Cambridge University Network, Scientific Alliance section:
The total reduction in EU 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
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.

The notion of "little savings" not being appealing to the EU,
an alternative in-house agency report was duly commissioned suggesting that indeed there were many light bulbs to be switched, allowing for great consumer savings after all, since they would presumably not otherwise buy the great new light bulbs (being CFLs at the time).
[Note: The EU was criticised by their own scientific advisor (duly not re-hired!) for commissioning on-message studies for a desired outcome, laying on the gravy for research agencies who naturally want repeat business: EU twisting facts to fit political agenda, chief scientist says Also see the EU Light Bulb Ban Story]

Somewhere basic points are forgotten.
Light bulbs don't burn coal or give out CO2 gas: power plants do.
So the mandates on increasing "clean" production of energy correspondingly decreases lighting effects on the environment.

Notice also that EU analysis is always about projected savings.
The current EU "reviews" of different lighting regulations conspicuously avoids any research to see if any savings have actually accrued from preceding regulations.
As will be seen, there are several reasons to doubt the savings...

3. In overall Ecodesign terms

(i) That energy saving is not the only advantage a product can have

(ii) That, unfortunately, enforcing lower energy use on a given product changes its characteristics eg usability, performance, appearance, as well as price, as per linked product examples http://ceolas.net/#cc21x covering buildings, cars, as well as washing machines and other household products.
The same document also deals with the specific advantages of halogens and of simpler incandescents, and extends other arguments made here.

(iii) That "efficiency" is not "energy efficiency" but also about deliverance capability, such as the great difficulty to produce bright 100W+ omnidirectional lighting with fluorescent/LED bulb alternatives.
That "efficiency" can moreover relate to the few components incandescents need to produce such bright lighting.

(iv) That supposedly old outdated technology is also well known technology in health and environmental perspectives.
LED flicker, point source glare, blue light and other issues have all been highlighted in recent years - including by LED proponents like the authoritative US journal "LEDs Magazine", for example the lighting program manager at the US Department of Energy in the "12 lessons" article

Complex LED lighting is also environmentally resource demanding.
Recent French documentary on TV highlighted the multi-mineral content (as with pushed CFL or LED light substitutes) and consequent enormous resource loss of unrecycled "E-waste", EU sponsored recycling paybacks (as with VAT) leading to illegal dumping, or illicit deals with China etc that alternatively loses such mineral resources for the EU.

(v) That supposed energy savings do not hold up on life cycle factors, especially with complex multi-component substitutes, not just in the sole assembly energy use that the EU and Osram confine themselves to measuring, but taking account of every life cycle stage all the way from mining and component manufacture through
assembly, delivery and final recycling - and the transport of all components in all stages, including that of bunker oil powered ship transports from (and back to) China - compared to easily locally manufactured patent-free simple incandescent bulbs for true sustainability and local jobs - the EU admitting to 5000 job losses in the final years alone relating to the incandescent 2009 ban.

(vi) That in relation to incandescent technology, the fact of a Phoebus cartel between major manufacturers giving 1000 hour limited standard incandescent lifespan does not relate to a true potential incandescent lifespan of 20 000 - 25 000 hours as per incandescents principally made for the mining industry at low cost eg Aero-Tech bulbs around 1.50 euro per bulb.
Encouraging open free market competition brings out the best products, rather than banning generic patent expired unprofitable choices.

(vii) The further light bulb specific issues of a heat benefit payback for most industrialised countries as per referenced Finnish, German, UK and Canadian research.
Side by side bulb comparisons also do not take into account power factor (PF) issues of CFLs and LEDs affecting practical energy use, or actual usage situations, such as using several directional LEDs as replacements for omnidirectional incandescents, or indeed in touted money savings for consumers for rarely used bulbs in 30-40 lighting point households, or temporary usage.
Talk of "reducing consumer bills" carries little weight when electricity providers raise consumer charges to compensate for the shortfall and/or are compensated by the taxpayers via governments, as in the UK and several US states.
Unnecessary use is a waste, personal choice is not, for what after all is about electricity use - not about the use of lighting as such.

Turning therefore to electricity use,
"20% lighting use in society", "millions tons CO2 saved" has nothing to do with actual fractional percentage electricity grid savings (as referenced, EU and US Dept of Energy data) from banning defined and domestically dominated lighting:
and even of that, a main usage in off-peak evening and night hours of low electricity demand does not not tax power plant electricity production anyway, specifically with "culprit" coal as also referenced, where commercially a minimal night level is maintained for wear and tear cost reasons and reason of slow stoking up to daytime level, a minimal level therefore not lowered further and that more than covers whatever bulbs people are using, therefore in effect without society energy/emission saving at such times.

4. Even if targeting bulbs was still deemed necessary:
Why does the EU not consider taxation (EU set VAT directives on products), a more conventional way of lowering consumption, where even a relatively low taxation can act to cost cover subsidies for products judged more desirable, and thus equilibrate markets sufficiently to dampen "wrong" demand while still allowing choice for the most needy users.
Of course higher VAT also brings national governments - and the EU -a direct "own resource" income.
Bans give no such income.
Specific carbon taxes are an alternative.
Taxation is more flexible than blunt permanent bans at arbitrary cut-off points, and can cease when market transformation is deemed sufficient.

Alternatively, "Expensive to buy but cheap in the long run"
advertising is used by battery and washing up liquid manufacturers - LED manufacturers can do likewise, rather than lobbying for bans on patent expired unprofitable simple bulbs.
Philips slumbering lighting division bounced up to record profits on LED sales before (ironically) suffering from Chinese competition.

Susanne Hammarström of Sweden was head of the main Brussels based PR
agency Diplomat-PR engaged in the lobbying on behalf of the light bulb
manufacturers. Translated from the largest Swedish business paper,
Dagens Industri, she says:
The ban would never have happened, without the large and extensive lobby campaign, in all member countries, as well as towards The European Commission and the media

In Summary
Any energy saving directive should take into account
A. The effect of legislation
B. The concomitant value of any saving acquired.

Even within the Ecodesign doctrine, light bulb regulations are uniquely questionable.
A particularly simple technology that is particularly effective in purpose, namely to produce powerful bright light, is banned in favour of particularly complex technologies that with difficulty reach such bright levels.
Moreover, it is a technology with recognized output quality, producing omnidirectional broad spectrum light with a colour rendering index of 100%, and without the health and environmental recycling concerns raised by the pushed alternatives.

On an open market any lighting product would be more reflective of inherent usage advantages:
= Incandescents as bulbs,
= Fluorescents as long tubes,
= LEDs as sheets,
as also originally developed in each case.
Today sees the oddity of heavily promoted expensive complex LED clones striving to approximate what simple incandescents can do.
It's as if all giraffes were destroyed, with the proponents excitedly proclaiming
"But hey everybody, look at the elephants with longer necks that we are breeding!"

The savings relate to the actual amount of switched bulbs pertaining to a ban, product related life cycle and usage effects, and factors related to electricity production

Again, light bulb regulations are particularly questionable, in terms of comparative life cycle energy usavings when all stages are included, as well as in actual usage, and in grid electricity saving perspectives, as has been described.
René Kemna of the Dutch VHK research group has been leading the studies into the regulations, and stated at the last 5 February meeting:
"A 100% primary energy input at the power plant actually results in 1% useful light."
Fractions of 1% in improved energy efficiency at the delivery end would therefore seem to be of negligible consequence in an overall perspective, all the more so taken with all the other mentioned factors.

The time element is also relevant:
If a market switchover transformation has already occurred, little or no extra gain is achieved with a ban, and regressive purchase activity is presumably limited for the reasons given, including new LEDs being so "attractive for consumers".

Indeed, CREE LED manufacturer in the USA has publicly announced that
"Incandescent bulb legislation doesn't matter"
Extracts put together:
Even as consumers continue to evaluate and make lighting choices in favor of energy-efficient LED bulbs, many regulators are still concerned that the unenforced incandescent ban could set the country back in the execution of energy-efficient policies.
This would be true and problematic if the industry and consumers weren't already headed in the direction of energy efficiency. According to Cree's own consumer surveys, the ability to reduce in-home energy costs without compromising the lighting experience is the most important factor for consumers when they're choosing a light bulb. We've also found that most consumers are interested in LED bulbs because they last longer than traditional incandescent bulbs, and are environmentally friendly. Look at the consumer lighting market today and you'll see a wide range of energy-efficient options that didn't exist a few years ago. In the past two years alone, the quality of light from LEDs has risen sharply and the price has significantly dropped.
In the end, consumers are making educated, well thought-out choices in lighting, with or without legislation or its enforcement. The legislation and its enforcement are simply needless.

LEDs are better - why ban incandescents
LEDs are not better - why ban incandescents
More to the point, all lighting types have advantages in specific uses, including mercury containing fluorescent tubes that may soon be targeted, and should not be banned unless health and safety in usage demands it.
Some consider the saving of energy for society to be a priority concern - and why not.
But as shown this is minimal in terms of targeting light bulbs, and even if it was not, alternative policies would be better anyway, based on:
>> consumer information including clearer labelling (as is being introduced), or
>> taxation and subsidies as described, or
>> free market competition where "desirable" bulbs can still be helped to market and imaginative advertising applied, as happens with other initially expensive but long term saving products.

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.

Monday, June 9, 2014

Cartoons reacting to the ban

Not had any "On the Light Side" (section link) posts for a while... banning bulbs sure has its absurd side.
The second one is from a while back here, many others been put online since then - some of the quirkier ones...


joe heller

source victoria times?

mackay 250news via paul fbook

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.

Friday, June 6, 2014

"EU Twisting Facts to fit Political Agenda"

It is only human to decide what is right or wrong - and look for facts to prove you are right.
Certainly, a case could be made that it is done here, though I would argue that any such emphasis is to balance official information in support of bans.
For example, I think fluorescent bulbs are also useful and should not be banned.
Nevertheless, the original ban on incandescents was largely defended on supposed energy saving of fluorescent bulbs, which have many disadvantages as replacements, hence the criticism, and the same can be said of LED bulbs, hence the critical reviews on this site in being pushed as replacements.

The point therefore is that political institutions should have an open perspective from the start.
Lighting choice issues apart, ruling authorities in the USA, EU and elsewhere see usage energy saving as some Holy Grail, getting even that wrong for several reasons.
However, in the context here, it is also that they do not even consider factors not fitting in with their agenda, and when such factors (heat issue, full life cycle, power plant off-peak operation, environmental and health effects of replacement bulbs) are hard to measure, it provides an extra imperative to have follow up studies to see if supposed savings and usage safety were actually there.

The issue becomes particularly poignant when the institution has a monopoly of launching legislative proposals for 500 million citizens - like the European Commission in the EU - and decisions, once taken, are hard to change.

Insider or whistleblower criticism of political process gives extra credibility, as here.

Recent article May 27 2014 by Frederic Simon on EurActiv site, extracts, my emphases:

EU Twisting Facts to fit Political Agenda

A big challenge for the next European Commission will be to disconnect its evidence gathering processes from the “political imperative” that’s driving policy proposals, according to Anne Glover, the EU’s chief scientific advisor.

Speaking before the EU elections last week, Glover reflected upon her role, which was introduced by the outgoing President of the European Commission, José Manuel Barroso.

Glover was appointed in December 2011 to provide the President of the EU Executive with first-class independent scientific advice. A trained biologist who holds a chair in Molecular and Cell Biology at the University of Aberdeen, she previously served a as chief scientific advisor for Scotland (2006-2011).

More than two years into her job, she seems to have learned a great deal about the internal working of the EU’s flagship institution.

And her assessment of what goes on inside the Commission’s walls is not rosy.

“When I spoke to president Barroso about taking up this role, I said to him that for me it would only be attractive if I was regarded as an independent chief scientific advisor,” Glover told a briefing organised on 21 May by Eurochambres, the Association of European Chambers of Commerce and Industry.

“What I said to him was that, for me to have any value or credibility, I need to focus on evidence and not on political considerations,” she recalled...

A big challenge for the next European Commission will be to disconnect its evidence gathering processes from the “political imperative” that’s driving policy proposals, according to Anne Glover, the EU’s chief scientific advisor.

Illustrating her point, she used a fictitious example:
“Let’s imagine a Commissioner over the weekend thinks, ‘Let’s ban the use of credit cards in the EU because credit cards lead to personal debt’.
So that commissioner will come in on Monday morning and say to his or her Director General, ‘Find me the evidence that demonstrates that this is the case.’” The Commissioner’s staff might resist the idea but in the end, she says, “they will do exactly what they’re asked” and “find the evidence” to show that credit card use leads to personal debt, even though this may not be the case in reality.
“So you can see where this is going,” Glover said: “You’re building up an evidence base which is not really the best.”

To back its policy proposals, the Commission often outsources the evidence-gathering part of the job to external consulting firms, which provide ‘impact assessment studies’ or ‘research’ that are often branded as ‘independent’.
However, Glover says such consultancies have little incentive to produce evidence that contradicts the Commission’s political agenda.
“If they want repeat business, [they] are not going to go out and find the evidence to show that this is a crazy idea,”
she says.

To be fair, the Commission is not alone in trying to distort facts, Glover said. The same goes for the other two EU institutions – the European Parliament and the EU Council of Ministers, which represents the 28 EU member states.

“What happens at the moment – whether it’s in Commission, Parliament or Council – is that time and time again, if people don’t like what’s being proposed, what they say is that there is something wrong with the evidence. So everybody blames the evidence and nobody is honest about the fact that in many cases, understanding the evidence is the best possible platform to make the logical extension into policy. But they don’t like it so they say ‘We need more evidence’...

Crucially, Glover says transparency in the evidence-gathering process would be key, so that every stakeholder - whether a citizen, a business, a politician, a scientist – can look at the reasoning that’s behind policy proposals. "And that is all doable, it is not a fantasy. It would be quite easy to achieve," she says.


This is not surprising, given the VITO and other test labs behind the light bulb ban, their assumptions without real life comparisons, and the current lack of 5-year review studies to see if supposed savings actually occurred, as covered before.

Hardly a thoughtful European policy for the good of European citizens, who are never considered "stakeholders" in any decision affecting them.

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.

Friday, May 16, 2014

"How Regulations are Wrongly Justified"

A reminder that separately from postings here, the page "How Regulations are Wrongly Justified" as linked below gets continuous major and minor updates, with the major updates noted at the top. In the last couple of days there have been several revisions and additions as seen.

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.