Monday, 21 December 2009

EU CFL FAQ 2 - Part I

After the massive critique following the dedcision to phase out standard incandescent lamps in favor of problem-ridden CFLs, the European Commission some months ago obviously found it necessary to issue another FAQ explaining the details and rationale behind the decision and answering some of the many justified questions posed by us critics.

This one is if possible even longer and more verbose than the first FAQ that I commented on in March, so I'll have to take this one in installments and still leave some parts out as it keeps repeating the same phrases over and over, probably in an attempt to overwhelm the reader into submission and acceptance of the unacceptable.
EU FAQ: I.1. Political motivation for the phase-out

Why is it necessary to phase-out conventional incandescent bulbs?

The European Union remains committed to achieving its objectives in the fight against climate change, including the reduction of primary energy use by 20% compared to business as usual by 2020. Requirements on the energy efficiency of products are a cornerstone of the Community policy aiming to achieve this target. Lighting may represent up to a fifth of a household's electricity consumption. There is a four to five-fold difference between the energy consumption of the least efficient and the most efficient lighting technologies available on the market. This means that upgrading the lamps could reduce a household's total electricity consumption by up to 10-15% and save easily 50€ / year (taking into account the purchasing cost of lamps).
My comment: a. According to statements elsewhere in this FAQ, the Commission acknowledges the fact that there is a max 4-fold difference (and more if you bring poor power factor, light deprecation and other factors also admitted by industry and Commission both). However, the "4-5-fold" argument was used to sell the ban to politicians so I guess they feel a need to stick to it. Or they don't understand the issue well enough themselves, which is quite possible.

b. Lighting is an average of 10% of home electricity in EU, and electricity in turn is only 8.5% of total EU energy use, making lighting 0.75% of total. Of this, only around half the lamp stock is still incandescent, according to the Commission's own consultants. Half of 0.76% of = 0.38%. Of these 0.38% the EC hopes to save 65-75%, which would be 0.25-0.28% of EU total energy consumption if all lamps were replaceable with CFLs and if CFLs really saved that much, which is not the case. This is not very close to the "saving 20% by 2020" goal is it?

Section I.2. contains a description with pictures of what types of lamps will be banned and when. Short summary:

- Last (lowest wattage) standard incandescent banned by 2012.

- Affordable look-alike class C Halogen Energy Savers will be permitted until 2016. (Frosted ones are already banned, though.)

- After 2016 only the super-expensive and hard-to-find Class B Halogen Energy Savers with infrared coating and integrated transformers will be permitted as replacement lamps for standard incandescents.

- Also permitted after 2016 will be more efficient "special cap" halogen lamps, e.g. those mini-bulbs that go in halogen spotlights and the thin double-ended tubes that go in floodlight luminaires. My comment: Good! I was worried there for a while that all of those would disappear from the market with no replacements to fit in existing downlight-, uplight-, spotlight and floodlight luminaires. If the added xenon makes these more efficient than standard halogen lamps, even better.

- CFLs and LEDs will also be permitted after 2016, the latter expected to become viable alternatives in the near future as their brightness, affordability and quality improve.
D. Compact fluorescent lamps (CFLs)

Its main interest lies in its long lifetime and high efficiency, the lamp will use between 65% and 80% less energy (from a third up to the fifth of the energy) for the same light output compared to conventional incandescents.
I already pointed out in my comments to the first FAQ that you cannot claim a lamp "saves 80%" when you in the very same FAQ acknowledge the fact that:
"Today, the same quantity of light (around 750 lumens) can be produced by an incandescent bulb using 60 W, a halogen bulb using 42 W, or a compact fluorescent lamp using 15 W."
This means 75% not 80%.

It sometimes comes with an external envelope which hides the tubes and makes it even more similar to light bulbs (though decreasing its efficiency). The envelope also shields off any unwanted ultaviolet radiations and mitigates the risks connected to mercury emissions because of lamp breakage (especially if it is made of non-breakable silicone). CFLs can live between 6000 and 15000 hours, depending on type and use (as opposed to 1000 hours for an incandescent bulb).
The enveloped bulb type is harder to make long-life due to heat buildup within the outer bulb, loses more output with age and is somewhat less efficient. The Eco-Design group and its consultants already know this, yet always recommend this outer bulb type as the solution to complaints about mercury, UV, harsh light etc., while at the same time basing all savings estimates on the performance of the best, top brand, naked tube CFLs under optimal lab conditions, compared with the poorest performing incandescent!

This strikes me as manipulaitve and outright dishonest. And fooling not only fellow politicians, media and the average Joe, but also themselves, as their projections for how to meet the 2020 goal will turn out to be the fantasy it is when based on skewed calculations rather than on complex reality.
I.3. Ambition level for frosted lamps
Why go for class A and ban even class C/B frosted bulbs from the market?

During the preparatory process leading to the adoption of the Regulation, the analysis showed that among frosted lamps which diffuse light, there was reason to require the highest level of efficiency corresponding to class A of the EU energy label for lamps. 2 This level of efficiency is achievable by compact fluorescent lamps and by light emitting diode lamps. The type of soft light provided by frosted incandescent bulbs and by compact fluorescent lamps does not differ substantially for the average consumer, therefore the more efficient technology can easily replace the other.
But it does differ substantially. See my post about light quality: There is NO lamp left on the market which can replace the frosted incandescent lamp. CFL and LED lamps do not produce the same light quality, this should be visible to anyone who is not colour blind, besides being measurable by spectral analysis.

Clearly, this measure was taken in order to force that majority who prefer non-glaring frosted lamps to buy CFLs instead, by removing all frosted alternatives, including frosted Halogen Energy Savers!

For those who really cannot tolerate the substandard light quality of CFLs and LEDs, I strongly urge the Commission to reconsider this hasty decision and permit frosted Halogen Energy Savers. There is no reason whatsoever to ban those. People should have a free choice which energy saver they prefer to use.

The frosted halogen lamp is excellent for reading, for example, while clear lamps cause glare and disturbing patterns on the page. Removing all frosted incandescent and halogen lamps from the market creates a gap that no other lamp can fill, leaving elderly and vision impaired literally in the dark.

However, sometimes consumers look for the particular light quality/aesthetics delivered by transparent lamps, which provide a bright point-like light, useful e.g. in crystal chandeliers. For these applications, there is a need to keep alternatives to compact fluorescent lamps, which cannot deliver the same type of light. This means leaving less efficient, but still enhanced incandescent bulbs (of the halogen type) on the market, at least as long as there is no more efficient technology that can replace them.
Glad that the Commission recognises this at least.
Such lamps also provide alternatives for the few situations where the use of compact fluorescent lamps is not recommended due to practical reasons (such as in locations where the light is switched on rarely and for a short time only).
Non-glaring frosted Halogen Energy Savers would have been a nice option to have. Here the Commission has removed a whole product group without there being a useful alternative for elderly, vision impaired and others who need frosted incandescent light in order to see well without being blinded.
Just as I said above.
I.4. Ambition level for clear lamps

Why is the minimum efficiency requirement not raised to class A for clear (transparent) lamps too?
The requirement on clear lamps is only raised to class C until 2016 (and to class B beyond 2016), so that other efficient technologies (such as improved incandescent bulbs with halogen technology) can remain on the market. This is necessary because current-day compact fluorescent lamps and light emitting diodes cannot provide the same type of light as the conventional incandescent lamps that are being phased out.
However improved incandescent bulbs with halogen technology do, and consumers who are keen on conventional incandescent light quality for aesthetics or health reasons should have access to it.
Yes, they should. So bring back the frosted halogens!
I.5. Proportionality of the phase-out - why not voluntary approach or other measures (taxation, ETS)

Is it not disproportionate that the European Commission bans conventional incandescent bulbs from the market? Would it not be better to leave the choice to citizens or to make use of other measures to achieve the switch (such as voluntary restrictions as in the UK, information to the public or taxation)? Isn't the EU's Emissions Trading System (ETS) anyway supposed to take care of the emissions related to electricity generation? Does ETS not affect consumer choices already indirectly, through price mechanisms?

The European Commission did not decide on its own to phase out conventional incandescent bulbs, it is done in agreement with the European Parliament and with the Council of Member States.

So, after singlehandedly pushing this ban with extreme fervour, hiring consultants who appear to hate incandescent light with a passion and are only too happy to produce a questionable preparatory study that supports a ban, and issuing a totally misleading Technical Briefing that gave voting politicians the faulty impression that this measure will save 10-15% of the 20% goal rather than 0.25%, you now want the Parliament and Council to share the blame?!

Introducing minimum efficiency requirements for a product group such as light bulbs (rather than relying on a voluntary approach) is not disproportionate in this case. The market has clearly failed to move towards the alternatives to conventional incandescent bulbs, even though they cost much less to the consumers over their entire life cycle.
Because the main product pushed is inferior compared with incandescent lamps. It is truly as simple as that. People are not stupid. If it was a great product it would sell itself! Forcing a lower-quality product on people against their will is truly bizarre! Especially when lighting is so vital both for mood and ergonomics, it's not like regulating aquarium pumps or water beds which most can surely do without.
The European Union's Emissions Trading System (ETS) directly affects the emissions of electricity generation, however there is cost-effective saving potential also in the reduction of electricity use of households, which cannot be directly achieved through ETS. Although the indirect impact of the ETS could translate into an increase in electricity prices and therefore in the use-phase costs of an incandescent bulb, such an increase would have to be multi-fold in order to become sufficiently visible for convincing in the short term every single consumer to buy a compact fluorescent lamp instead.
But the whole point is that you shouldn't convince every single consumer to buy a CFL instead, since it is an inferior quality product, hated by many and containing mercury on top of it. Instead, you could convince enough people to turn down indoor heat or cooling one degree and save much more. You could reward utilities for handing out free dimmers, sensors and timers. Or you could regulate and tax junk food, which uses astronomical amounts of electricity in production, distribution and storage, and causes costly and disabling health problems on top of it.
Still the main point is that efficient lighting as provided for in the regulation is a way to save energy, to limit CO 2 emissions and to help consumers save money without loss of functionality.
As Peter Thornes keeps pointing out, it is not up to the Commission to save people money. This is just the usual sales propaganda from Market Transformation Programs rehashed to make it sound like a better idea than it is. For comparison, just think of the amount of money the average household would save if there was no junk food to buy in the shop! Or if alcohol and tobacco were banned. But the EC doesn't really care about people's private economy, does it?

And I still don't see an explanation why a tax or VAT won't work.
I.6. Alleged intrusion of Brussels into citizens' private lives

How come the bureaucrats of the European Commission are suddenly taking a decision that affects so much the life of every European citizen?

By adopting a regulation aiming to phase out the less energy efficient lamps, the Commission implemented the specific mandate from the European Parliament and the Council of Member States as originally laid down in the Ecodesign Directive (2005/32/EC, see point II.3 of this FAQ). In its Article 16, the Directive specifically requested the Commission to introduce implementing measures on lighting in the domestic sector through this procedure.

The importance of this measure was underlined by the Spring European Council of 2007, which invited the Commission to "rapidly submit proposals to enable increased energy efficiency requirements (…) on conventional incandescent lamps and other forms of lighting in private households by 2009" and by the European Parliament in its resolution of 31 January 2008 on the Action Plan for Energy Efficiency, where the European Parliament stressed " the importance of the Commission's keeping to the proposed timetable for the withdrawal of the most inefficient light bulbs from the market". Again, in October 2008, the Council of Energy Ministers invited the Commission to " submit in 2008 a draft Regulation that will launch a gradual process of phasing out until conventional incandescent lamps and all the worst-performing lights are banned."

In parallel to these mandates, the Commission's services developed a draft regulation on non-directional household lamps. The procedure started already in December 2006 through a preparatory study. After a thorough technical-environmental-economic analysis of the available household lamps and their improvement potential, which was carried out openly with the involvement of stakeholders, a working document based on these recommendations was discussed with Member States and stakeholders (including a wide range of NGOs and industry) in the Ecodesign Consultation Forum in March 2008.

Building on the opinions expressed in the Forum, and on a parallel impact assessment, the Commission's services prepared the text of the draft regulation, which was fully endorsed in the Regulatory Committee on 8 December 2008, without opposition from any of the Member States.
The Environment Committee of the European Parliament discussed the measure on 17 February 2009 and decided not to object to it. Finally, the European Commission adopted the Regulation on 18 March 2009.

This exhaustive preparatory process has ensured that the interests of European citizens were well represented during the development of the regulation.

Hardly. Few of those directly affected were even told of this impending decision before it was too late, and not exactly informed on how to protest. And the discussion/vote was rushed through several weeks before the three month objection time was up.

Peter Thornes describes the whole charade from beginning to end here:

I.8. The quantity of savings compared to other sectors and countries

How do the estimated savings compare to the total electricity consumption the EU? Are they not insignificant, considering that household lighting itself is only a small share of the total consumption? Is it not superfluous to adopt measures that bring so little improvement compared to the whole? Other sectors and other countries could make more important savings. Why bother with light bulbs?

When comparing the estimated saving potential of the regulation (39 billion kilowatthours per year by 2020) to the electricity consumption of the EU, it may seem insignificant (1,4 % of the total final electricity consumption of the 27 Member States in 2006, which was 2826 billion kilowatthours).

Let's see how the "1,4%" was arrived at:
Some figures for EU-27 in 2006:

Final energy consumption (all fuels, all sectors): 1177 Mtoe (megatons of oil equivalent)

Final electricity consumption (all sectors): 2826 billion kWh or 243 Mtoe

Final energy consumption of households (all fuels): 304.9 Mtoe

Final electricity consumption of households: 807 billion kWh or 69.4 Mtoe

Electricity consumption of household lighting: 105.89 billion kWh or 9.1 Mtoe = 13% of household electricity consumption, 3% of total household energy consumption, 1.4 % of total electricity consumption (all sectors)

Well, I'm very glad to find a previously unseen effort to separate sectors and not confuse electricity and total energy consumption (could it perhaps be inspired by my energy statistics posts)? Seems we arrived at fairly similar figures anyhow (= lighting around 3% of household energy use). Except on that last one. Unless my calculator is playing tricks on me, I get 0.77%, not 1.4%.
However, the total electricity consumption of the EU includes the consumption of all sectors, namely industry, transport, agriculture etc., not just households. It is clear that in order to fight climate change effectively, all sectors need to contribute. The regulation on non-directional household lamps affects lamp types that are primarily used in households (although to some extent also in non-household applications such as restaurants, hotels, shops etc.). Therefore it is fair to compare the estimated savings to the electricity consumption of the household sector in the EU, which was 807 billion kWh in 2006, of which 5% will be saved.
Here we go again using the old electricity confusion stunt to muddle the waters and make savings sound more than they truly are. 5% = 1.14% of total household energy consumption. That is, if the phase-out will truly save this much (which is won't, see below).
The estimates above are based on the assumption that households will be using a mixture of improved incandescent bulbs with halogen technology and compact fluorescent lamps. However, switching to the exclusive use of compact fluorescent lamps and LEDs makes economic sense for households, who would save much more energy and money.
We have heard this argument a million times. It still does not address the quality issues with CFLs and LEDs. If the lamps had good enough light quality and fit everywhere, people would buy them without force, especially now that price is going down and relative quality (compared to earlier models) up. No one wants to waste energy. But some of us do care about being able to see well and have a warm relaxing lighting environment in our own homes and do not find even the best CFLs or LEDs fulfilling those requirements.
If all households switched to the exclusive use of compact fluorescent lamps and LEDs, at the EU level we would be saving 86 billion kilowatthours by 2020, which is 11% of the electricity consumption of households.
If lighting is estimated (with much encertainty) at under 13% of household electricity (I assume this is your source for that number: Residential Lighting Consumption and Saving Potential in the Enlarged EU) and CFLs save (optimistically) 66-75% of those almost 13%, how does that make 11%? 66-77% of 13 is 8.58-9.75%.

But that would be assuming a) that the 13% of of electricity use is an accurate estimation; b) that those lamps are all incandescent (which they are not, see below); c) that all CFLs work as well as claimed (consumer tests show many don't, or else we wouldn't need new quality labels); d) that they don't have poor power factor (which most standard CFLs do), e) that there was no heat replacement effect in cooler regions (which there is, according to studies), f) that people wanted to buy them despite the quality issues (many don't or they wouldn't be hoarding incandescents), and g) that it was even possible to replace all lamps with LEDs or CFLs (which is not the case, even according to your own consultants):
VITO: "...some customers have a few light points left where they prefer to keep the GLS due to barriers for CFLi as explained in chapter 3 (e.g. requirements to color rendering, sparkling effect etc.) or because of the lamp has little usage such as in cellars, staircases or storage rooms and where full lighting is also needed immediately."
Therefore the fantasy of replacing all home lamps with CFLs or LEDs remains a fantasy - the If-game. Let's stick to reality, please.

The electricity consumption of household lighting is a minor part (3%) of the total energy consumption of a household (heating and water heating included).
Now we're getting back to the proper perspective!
However, it should also be underlined that the regulation on non-directional household lamps is just one of a series of 30 or more Commission regulations (already adopted or being prepared for adoption in the near future) concerning the energy efficiency of different product groups such as televisions, heating boilers, water heaters, electric motors etc. These regulations all contribute to a combined impact that will make the real difference in terms of our objectives to reduce energy use and combat climate change.
But isn't it true that light bulb regulation was sold to voting politicians as The Big Thing - that One Green Measure that was going to get us massively closer to the 2020 goal? Could it have been my pointing out what a drop in the energy ocean home lighting actually is in my energy statistics post, that has prompted this unconvincing retort?

And it's not exactly a good defense of the first unpopular regulation, to state that there will be more unpopular regulations added to get an effect. I assume Heat Replacement Effect are not calculated for the other products either?

It also puzzles some of us how EU on the one hand takes the liberty of actually banning a non-harmful product, totally in opposition with the free market guideline, and strongly promoting a competing product which may harm both health and the environment and is already doing much damage to both in China*, while at the same time objecting to member state governments recommending people to buy locally produced food in order to minimise emissions from transport.** Food transport is a huge polluter and energy consumer and the less of it the better for the planet, no?

* "'Green' lightbulbs poison workers"
** "Swedish food guidelines meet protests from the EU" (unfortunately, this article is now removed).

I.9. Market share of different bulb types

How many conventional incandescent bulbs are in use at present in the EU, compared to energy saving bulbs?

In 2006, there were 5.1 billion lamps installed in EU households. Of these, 4.2 billion lamps were non-directional lamps, the remaining 0.9 billion reflector lamps.
Having lamps installed is not the same thing as having lamps in use. If calculations on lighting part of household energy use are based on number of lamps installed, this could make lighting appear to use a much larger part of home electricity than is actually the case. This also omits counting dimmers and sensors and how many houshold's have learned to turn the lights off when leaving the room in order to save electricity. The EU lighting consumption study appears to confirm this:

EU lighting study: "It is not easy to compile accurate and comprehensive data on the total end-use consumption of individual equipment and appliances, as these are not usually separately metered."

"The first important point is that lighting data is very scarce, as is most of the different electricity enduse data for the residential sector. While it is easier to calculate the national consumption of large appliances such as refrigerators and washing machines is (equipment stock, user habit, and other influencing factors are well known), with regard to lighting data about the power installed, the number of lamps, the burning hours is often missing."
And without the burning hours, you're left guessing - and easily overestimating.
EU FAQ: The total stock of lamps affected by this regulation (all sectors including household, tertiary etc.) was 3.9 billion lamps in 2007. 1 billion lamps (25% of the total) were compact fluorescent lamps, and 2.1 billion were incandescent bulbs.

Source: Preparatory Study for Eco-design Requirements of EuPs – Domestic lighting, Chapter 2 available at
Always trying to make it sound as much as possible while still making things less than clear. This is what the study actually says:
VITO: Based on surveys of 500 consumers in 11 countries, the EU-27 average share per household 2007 was estimated at:
• 54% of the lamps incandescent (and decreaseing)
• 18% of the lamps low-voltage halogen (and increasing)
• 5% of the lamps mains-voltage halogen (and increaseing)
• 8% of the lamps linear flourescent
• 15% of the lamps CFL with integrated ballasts
It also indicates that incandescent lamps were expected to keep decreasing dramatically, even in the "business-as-usual" scenario (= without a ban)!!

Now, 54% 2007 means probably less than 50% today. That means 50% of those alleged but uncertain almost 13% = 6.5%. And then 66-75% of those = 4.29-4.87% of electricity, assuming a) - g) above, which again is contrary to known and provable facts, so more likely around 50%, generously speaking. Now we are down to 3.25% of household electricity consumption. Which can easily be saved by other means.

I.11. Role of the lamp industry

Did the Commission take this decision under the influence and in the interest of lamp companies?

The European Commission did not decide on its own to phase out conventional incandescent bulbs, it is done in agreement with the European Parliament and with the Council of Member States. Regulation 244/2009 was developed by the Commission on a mandate from the Ecodesign Directive (2005/32/EC) of the European Parliament and of the Council of Ministers of the Member States. The request to phase out conventional incandescent bulbs was made by the European Council in 2007 and further reinforced by the European Parliament and by the Council of Energy Ministers in 2008. The Regulation itself was prepared in an open process lasting two years with the formal involvement of stakeholders such as consumer and environmental NGOs. European industry was also consulted, they claimed initially that the provisions of the planned measure would be much too ambitious in terms of timing and requirements. However, the Commission and the Member States decided to maintain the level of ambition, with the support of the other stakeholders. In the framework of their right of scrutiny, both the Council of Ministers and the Parliament decided not to object to the draft Regulation before it was adopted by the Commission in March 2009.
That manufacturers needed longer to adjust their production once the goal was within reach does not mean that the idea of getting rid of their most unprofitable but popular lamp once and for all, didn't originate within the industry. The global anti-lightbulb campaign, via Market Transformation Programmes, has been one of the most well-coordinated, persistent and far-reaching propaganda acts in history.

That the Commission and most EMPs have swalloed all the usual PR lines (which all you need is a manufacturer catalogue and a calculator too see are exaggerated, and which I believe was also communicated by PLDA before the EMP debate and final vote) does not inspire trust in our leader's judgement.

Let me just emphasise that I am not against energy saving and making more efficient products. But it is not acceptable to be forced to use a lower quality product for something as important as lighting.

The Commission now keeps repeating that Halogen Energy Savers and LEDs are also available, but these products are not easy to find and were not even included in the preparatory study; all calculations were based on the naked tube CFL. This is clearly the lamp which the Commission and industry both hope we will all use in most of our lamps, despite its looong list of problems, including the mercury content. I find this more than a little strange.

1 comment:

  1. thanks... glad to link to it from