AI News, View This Issue - December 2010

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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.

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.

In the meeting the majority of the national representatives spoke against delay or removal of the ban, not for substantial reasons of energy savings but because it might be seen as a precedent for delays or revisions for other products in the EcoDesign system.

There was also considerable support not to look at this issue in isolation but conflate it with the omnibus review of the regulation next year to save these civil servants from having to attend any more meetings where they are clearly completely out of their depth on fundamentals of the technologies being discussed.

The declared position of the main lighting manufacturers is as seen against the energy agency type people, but clearly their worry of losing profit is not the same as when cheap simple incandescents were legal.

It would rather seem to be a marketing exercise for manufacturers to support the more expensive halogens, also presumably having more of an 'ear to the ground' of what consumers want - compared to the civil servants and ideological fanatics as per the above.

Maybe that's their game all along - they know full well the position of agencies and Commission, and at the end of the day can simply count the profit - and reap all the subsidies - pertaining to LED manufacture and sales.

The problem, as always, is the extent that the Commission only listens to them, or indeed the national agency types or environmental pressure groups - which brings us back to the democratic acceptance of other views, and the various comments by other groups and individuals as highlighted here in recent days.

There is a further aspect to the review democracy, as highlighted by these type of meetings: Not just who is allowed to attend, and not just that others are not heard (file your opinion in the waste paper bin/trash can), but of knowing who was there in the first place.

For a preliminary report of the November 25 Consultation Forum meeting regarding the commencing review of EU light bulb regulations and involving the EU (European) Commission, national energy efficiency representatives and lighting 'stakeholders', see the post published earlier.

Here is another alternative view of the light bulb ban, and of the current issue of allowing halogens or not: Greenwashing Lamps, like Rik Gheysens in the last post, once again usefully complements what was said in the comments to the first Commission proposal post in the series, this time with a very visual perspective.

New research in January 2013 by scientists in California and South Korea found that: “The CFLs and LEDs have higher resource depletion and toxicity potentials than the incandescent bulb due primarily to their high aluminum, copper, gold, lead, silver, and zinc.

Comparing the bulbs on an equivalent quantity basis with respect to the expected lifetimes of the bulbs, the CFLs and LEDs have 3–26 and 2–3 times higher potential impacts than the incandescent bulb, respectively.”

LED lamp (complex to make and recycle) Anode, cathode, semiconductor crystal, ballast, socket transformer, capacitor, controller, heat sink, LED module, bulb and base may contain: •

[there are plenty of reference links to the below points in the pdf document, not coded in here] All currently available lamps are needed, except CFLs and high pressure mercury lamps which can and should be replaced due to mercury risk, and ‘cool white’ (light blue) LEDs which may harm vision and disrupt sleep hormones.

And as there are no good quality replacements for the R7 tubes and, G4 or G9 halogen mini bulbs, these must remain available for those who have invested in costly halogen downlight, floodlight, spotlight, or dimming systems because they wanted the best light on the market.

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.

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.

He has in the last week also covered the light bulb ban review in depth with a critical analysis - which in many ways complements the comments made here in the earlier post, in going more deeply into CFL and mercury issues and also LED environmental problems.

While much focuses on CFLs and mercury - and for the understandable quoted reasons - it is my belief that the Commission and lighting companies are actively moving away from such lighting: The recent Commission proposal, as linked above and in the document itself, hardly mentions CFLs and the LightingEurope (Philips, Osram, GE etc) statement as previously posted also entirely focuses on the 'Ledification' of society.

In the meantime, the Commission would draw the Honourable Member's attention to the fact that, under Directive 2011/65 (2), the mercury content of Compact Fluorescent Lamps (CFL) in the EU was halved as from January 2013 to a maximum of 2.5 mg (compared to 50 milligrams in cell batteries and 500 milligrams in amalgam dental fillings)

Halving the allowable mercury content makes fluorescent lighting still harder to make with acceptable performance for a given price - which perhaps is the intention, moving towards a 'de facto' ban, just as with energy usage standards on incandescents, without actually calling it a 'ban'.

SCENIHR [ed- the European Commission Scientific Committee on Emerging and Newly Identified Health Risks, link] shows the following opinion: Despite the beneficial effects of light, there is mounting evidence that suggests that ill-timed exposure to light (light-at-night), possibly through circadian rhythm disruption, may be associated with an increased risk of breast cancer and also cause sleep disorders, gastrointestinal, and cardiovascular disorders, and possibly affective states.

LED operation at too high a temperature (and therefore high junction temperature of the semiconductor) has a dramatic effect on efficiency but also on other characteristics and performance of LEDs such as the flux, the spectrum (and thus the color), the polarization voltage, and the life.

To take advantage of the interesting properties of LED (flux, efficiency, durability, quality of light emitted), integrators must take into account the heat generated by the LED and qualities of this component to evacuate the heat.(Ibid., p.

the high brightness density per surface unit emitted by these very small sources.) LEDs are point sources of light that can be aggregated in lighting units to achieve high luminous flux.

Because the emission surfaces of LEDs are highly concentrated point sources, the luminance of each individual source produces very high luminance, at least 1 000 times higher (107cd/m2) than that from a traditional lighting source.

(Opinion of the French Agency for food, environmental and occupational health & safety in response to the internally-solicited request entitled 'Health effects of lighting systems using light-emitting diodes (LEDs)'19 October 2010)

Frosted (matte, pearl) light bulbs and their more opaque (white, opal, soft-tone) varieties generally go by the name 'non-clear' bulbs in legal EU terminology: In comparison with clear, transparent light bulbs the brightness in lumen output and thereby the energy efficiency varies slightly depending on the luminescence of the coating and its thickness, 5-10% either way.

[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 alternatives, but the overall point remains.

Accordingly, in their memorandum to the original 2009 legislation, the Commission stated that those 'who want non-clear lamps can buy CFLs and LEDs', presumably feeling that it would help push people to those lighting types, and ignoring all other aspects of why a particular form of lighting is chosen.

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.

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.

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).

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.

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.

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

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.

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.

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.

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.

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'.

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.

(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).

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.

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.

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.

LightingEurope has come out for the abolishment of stage 6 to keep allowing Halogens - and is also critical of the Commission suggestions to abolish special Halogen G9 and R7s types, and to enforce LED compatibility of fixtures - more of which below, which now include the Lighting Europe position statements.

This post is based on the Commission proposal from the 21st of October, to delay general service Halogen incandescent lamp phase-out by 2 years, part of an ongoing Commission review of EU light bulb regulations on general service lighting that began 2009 - more on the overall review below.

For a comprehensive rundown why the regulations don't make sense as a whole: 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.

It is envisaged that the 2 year delay will, with plenty of public subsidies, therefore allow Philips, Osram, GE & Co to make LED products that will substitute for the 2 other major lighting types on today's market.

Fluorescents (CFLs) are conspicuously ignored in the paper and likely to come under increasing phase-out pressure, either from the removal of its current mercury content exemption, similar to already banned mercury containing thermometers, barometers and other products, or from a further reduction in allowable mercury, which effectively does the same (some mercury-free alternatives have appeared but not done well on the market, and further investment by major companies seems unlikely, as also per their industry response here, eg Lighting Europe).

The overall review of the 2009-2014 ban will supposedly take place early next year in line with the 5 year review obligation as originally stated in passing the legislation, and ahead of a final consultation forum in April 2014.

However, updating this, some doubt seems to have been cast that further 2014 meetings will take place - it might just be left with this stage 6 review, in addressing light bulb availability.

Unfortunately the EU does not have great form in that regard, where the original regulation proposal never made it to the floor of the Parliament or to the accompanying media and public debate that might have taken place, debate (as it was) being cut short at the committee stage (How the EU regulated against incandescents, http://ceolas.net/#euban).

UK submissions: Efficient.Products@defra.gsi.gov.uk (DEFRA energy efficiency unit, EfficientProducts@defra.gsi.gov.uk also used) Similarly to other EU national energy efficiency units of energy or environmental agencies, several of which can be seen listed at the end of the Consultancy Report linked below, together with the names of representatives.

The Commission technical report underlying the phase-out of incandescent lighting, analysis of replacement lighting, and - at the end - the timetable of phase out dates and requirements September 2009 - September 2016 EU technical briefing on lighting phase-out and dates

changing the entry into force of the stage 6 requirements to 1 September 2018, allowing LED technology to mature further and reach an optimal time point in terms of monetary and energy savings;

In any case, temporarily or permanently, the EU should allow frosted (non-clear) halogens, a petty ban without energy saving justification, on the basis, from the underlying EU memorandum, that people 'who want non-clear lamps can buy CFLs and LEDs', ignoring all other aspects of why a particular form of lighting is chosen.

Clear LED lamps as referred to more commonly have lower brightness than clear incandescents in comparison with their respective alternatives, but the point remains, and energy efficiency differences were as said never a ban motive]

Conversely: Any general ban of mains voltage halogens removes the last possibility of using clear transparent burning filament lamps, with their unique 'sparkle' effect in lanterns, chandeliers etc, unlike clear LED clones.

The technical review study reveals that the exception of certain halogen lamps with a G9 and R7s socket from stage 6 creates a loophole, which some manufacturers have already started exploiting with adapter-kits.

Given the low price of these adapter kits, in conjunction with the small retail price of G9 halogen lamps, it is likely that this loophole could significantly undermine the success of the stage 6 requirements as a significant portion of consumers might choose the presumably 'cheaper' option while paying more through non-realised energy savings.

Little consideration of light quality and other factors that also influence personal choice - as is obvious from their document which focuses on energy and cost in relation to lighting and the types that can relevantly be made on the basis of metered electricity usage alone.

Update: LightingEurope (the major industry stakeholder representing Philips, Osram etc) in their position statement (as also covered in Post 3 of this Light Bulb Review series) is firmly against any action against these halogen types: LightingEurope does not identify a real loophole in the exception of certain halogen lamps with a G9 and R7s socket from stage 6, nor the assumption that this loophole could significantly undermine the success of the stage 6 requirements in terms of energy savings.

However, once again, the EU Commission show their determination to get rid of 'loopholes' like lamp sizes and fitting dimensions and control gear not being LED compatible - again reducing choice, on all criteria bar supposed energy usage.

Even if the proposal is limited to just retrofit lamps as covered by 244/2009, compatibility would need to be carefully defined as hidden issues such as thermal compatibility can negate any benefits and mean a LED product is not 100% compatible in all luminaires.

It is expected that manufacturers will not produce such lamps, because the necessary investments in new technology would not be economically feasible given the expected retail price of these halogens and the expected general market transition to LEDs.

Also regarding Philips Halogen B class bulbs...from the consultancy meeting following the report (annex of report): Paul van Tichelen replies that when he looks on-line he finds also some old webpages of the Philips lamps, but they are not produced anymore.

Now the new promise is of even more profitable LED sales, since fluorescent bulbs, conspicuously absent from any mention, will likely also become banned or at least 'phased out' on the new EU mercury content regulation they were previously exempted from.

Yes, energy saving is good, but should relate to the overall picture of energy saving in society, and the many more appropriate ways to achieve it, including specifically in electricity generation, distribution and consumption: http://ceolas.net

Solid-state lighting such as LEDs and organic light emitting diodes (OLEDs) promises up to 20 times higher efficiency than the old incandescent light bulbs while offering over 25 times the product lifetime.

Fervent pro-ban supporters rather shoot-themselves-in-the -foot on this one, like the Danish Energy Agency in annex comments of consultancy report, urging a speedy ban on halogens: During the last year, we have seen a worldwide 50 % price cut for LED lamps....the LED lamps have a much higher efficiency (energy class A or A+) and actually the prices have decreased remarkably...

From the underlying research report (also linked in the introduction, above, MV = Mains Voltage): Most experts agree that LED (possibly OLED) is the designated future replacement for MV-HL technology, but at the moment there are a number of technical/functional aspects such as colour rendering, dimmability, etc.

As the report agrees, price is not the only reason people buy light bulbs - besides, there is nothing wrong with products being cheap, and you don't keep buying cheap products that don't perform satisfactorily at the price.

All lighting has advantages, the comparatively greatest technology advantages being respectively Incandescents - Bulbs Fluorescents - (Long) Tubes LED - Sheets (OLEDs) RGB LED bulbs do have color temperature flexibility, but all the focus is on fixed warm temperature white phosphorescent LED incandescent clones.

Similarly if new manufacturers of incandescents were encouraged, then longer lasting incandescents also for domestic use could break the monopoly of the short lasting types by the market controlling major manufacturers (the Phoebus cartel involving Philips-Osram-GE fixed standard light bulb life at 1000 hours, penalizing those seeking to make longer lasting ones).

The consultancy report (their 'less/negligible' emphasis in bold letters in the original text, not mine): Over a longer period till 2060 (see economics section), the LED ‘lock in’ effect (long product life prohibits application of more efficient LEDs or OLEDs), the difference becomes less/negligible and it may even be in favour of the abolishing Stage 6 from the environmental point of view.

Which ignores all the reasons one might prefer shorter lasting cheaper (dare I say incandescent) bulbs for less used lamps, or bulbs for temporary accommodation, or indeed bulbs for anyone aged over 30-40 in permanent accommodation.

As covered under Consumer Savings, below, there are several other reasons why more frequent bulb switching may occur, also in switching from old LEDs to newer LEDs, which after all supposedly become cheaper and more energy saving all the time, and are expected to become voluntarily preferable to Halogens (questioning the ban rationale in the first place).

The 2020 CO2 emission savings data uses EU Impact assessment data from 2009, as quoted in the consultancy report - and the data was old even in 2009 (I saw the original EU memorandum) yet it is still as seen dug out and projected far into the future for big easily quotable supposed savings: Ignoring EU 2020 emission reduction initiatives and further 2030-2050 measures in the same vein.

The same applies to mercury emissions: The use again of old emission data projected to 2020-2030, still stating 'coal plant mercury emissions from incandescent use are worse than CFL related mercury', ignoring the accord negotiations promoted by the EU with UNEP, finalised earlier this year (Brussels, 19 January 2013, Commission welcomes new global agreement to tackle mercury, here).

As from US Dept of Energy and EU institutional data, about 1% of grid electricity and a fraction of 1% of overall energy use is saved (further covered in the points rundown energy section) Certainly: Still substantial in megawatt terms, but it therefore raises the perspective of relevance compared to all other ways of dealing with generation, distribution and society consumption, as extensively covered on the ceolas.net site.

Mostly after 7pm (DEFRA, Intertek referenced), off-peak in generation terms - which is why electricity is cheaper - no reason to deny Johnny use of whatever bulb he wants on energy availability grounds (and 5-7pm peak period lighting is a miniscule fraction of use, heating, cooking etc coming on, and added peak generation is usually low emission gas or hydro anyway).

Turning coal plants down and up has several maintenance cost issues, and while newer plants accommodate greater cycling, the operatively justified base load night cycle levels more than cover any consumer electricity demand at such times - which is also a reason electricity is so cheap then, on time-based pricing.

Lowering coal plant levels 'to account for incandescent savings' (already small in grid demand percentage terms) is not an option given that operative levels are based on cost and wear and tear and slow stoking up to daytime use (see government and institutional references about this, as per above linked energy section).

No consideration is given in report or proposal to incandescent heat replacement benefit (Finnish, Canadian, UK, German studies (http://ceolas.net/#li6x) to CFL/LED power factor issues effectively using more energy on phase differential grounds (same site, or the energy sections of the regulation criticism page on the left here).

Leaving light on may be seen to influence public and commercial activities more than domestic users: Public and office buildings left lit all the time, albeit for security reasons and the maintenance cost of more frequently changing fluorescent lights that are switched on and off.

Compare: Simple incandescent products easily locally made with little energy or emissions and if need be long lasting of at least 20 000 hours (as for mining industry etc, eg Aerotech 2 dollar 100W 20 000hr bulbs), without recycling requirement.

With: Complex rare earth mineral depleting patented CFL/LED alternatives that are less easily locally made and involve more mining, component manufacture, product assembly, and recycling when not dumped (referenced US analysis below recommending recycling also of LEDs, on toxicity grounds).

In addition, an electricity usage that not only as mentioned is small and largely off-peak and therefore electricity that is available anyway - but also which, if emission-free, may actually lead to an increase in emissions with replacement bulbs and room heating from oil or other potentially pollutant sources, as referenced with different research studies.

The update on health aspects did not identify any significant negative or positive impacts from the stage 6 requirements, or from a possible ban of halogen technology, due to the availability of suitable replacement options and the inclusion of certain information requirements in EU legislation.

The issues with flourescent (CFL) bulbs are well known with respect to mercury, UV radiation, light quality and other issues - and also recognized as such by health and environmental agencies, for example in clean up mandates of bulbs and in recommendations of minimal distances and/or doubly enclosed CFLs for close usage.

particular concern is the dumping of CFLs rather than going to recycling, with the associated risks of released mercury, as highlighted in a Swedish scandal in recent years - and Sweden tends to be seen as an environmentally conscious country, similar problems are not necessarily raised for attention elsewhere!

limit: 500) render all except low-intensity yellow LEDs hazardous' Because the bulbs have very different expected lifetimes, they “normalized” their data on resource depletion and toxicity potential by using data for fifty incandescents, five CFLs, and one LED bulb.

Even after normalizing their calculations, the team found that CFLs have from three to 26 times higher resource depletion and toxicity potential than incandescents and LED bulbs have two to three times higher potential.

LEDs 50 000 hour assumed life can similarly be questioned - it arises out of lab specifications rather than real life use, as covered here, and similarly with assuming CFLs to last 10x longer than standard incandescents.

As it happens, the German Baubiologie association, on building construction, has in a recent 30th October article just warned against LED lighting on flicker grounds, not necessarily noticeable by the human eye, leading to people feeling unwell in the different ways described.

The official French health agency ANSES in 2013 again pointed out issues seemingly unadressed by the EU, relating to source glare and blue light issues, originally highlighted by them in extensive 2010 research.

recommendation for EU labelling to more clearly show light quality and photobiological risk according to norm NF EN 62 471 LED blue light has diverse health problems as easily seen by several other studies online.

No changes to legislation: Overall monetary savings for consumers up to 2025 compared to scenario I, taking into account higher acquisition costs and lower running costs: 9 billion EUR

year delay to stage 6 legislation: Overall monetary savings for consumers up to 2025 compared to scenario I, taking into account higher acquisition costs and lower running costs: 15.3 billion EU

As based on consultancy report data (MV= mains voltage): The MV-HL lamp has 36W power (500 lm, 14 lm/W), 2000h product life and a list purchase price of € 3.

Both are assumed to have an operating time of 500h per year and thus the MV-HL uses 18 kWh/year (€ 3.96/year in electricity at a 2016 electricity rate of € 0.22/kWh) and the LED lamp uses 2.7 kWh/year (€ 0.60/year at the same rate).

In that case, if people switch bulbs more often, and LED energy efficiency progresses as the Kemna report also suggests, then the usage savings keep increasing anyway, stage 6 or no stage 6 (see energy comment, lock-in effect, above).

Bulb Usage The consultancy figures, while not assuming a high 3 hr daily average usage per bulb (1000 hrs per annum), still come out at a rather high -roughly- 1 1/2 hrs (500 hours p.a.) or 45 mins (250 hours p.a.) daily average usage assumption per bulb.

In fairness, the most used bulbs would likely be replaced first, so there would be an initial stacking of higher average use among those bulbs, but this would therefore soon become progressively lower, as less used bulbs become replaced, particularly on assuming legacy incandescent short lifespan stock are fitted.

Replacing commonly used bulbs with LEDs has a desirable payback logic for the consumer, but this decreases more and more for less used bulbs, and resistance to purchase (and using stocked bulbs, smuggled bulbs, allowable halogens) may be expected, unless LEDs hit the 3 euro kind of level assumed for halogens.

second reason for increasing consumer resistance is that lighting situations that don't suit LEDs would increasingly come up eg dedicated dimmer, timer, sensor circuits, old fittings, etc, and in fairness the consultancy report mentions this, along with brightness requirements that in particular the cheap LEDs would hardly match, and the Colour Rendering Index (CRI) which is maximal 100 for incandescent lighting (Aside note: hence the clamour for a new Colour Quality Scale (CQS) index that, er, shows LEDs in a better light.

Conversely 'energy shocks' (Germany?) might raise prices, but hardly in equivalent fashion, and overall the future in terms of varied available energy sources for electricity is assured, even with lots of green fingered interference.

Hence the mentioned incandescent heat benefit and the inferior CFL/LED power factors both lower supposed switchover savings, the latter also in any costly countermeasures that utility companies may have to take (which is why industrial users are cost penalised if presenting power factor disadvantages to the grid).

Also as mentioned, the consumer reactive activities - using more dim bulbs to compensate for the lack of omnidirectional bright ones, or preferring brighter halogens (with higher electricity usage per bulb) for the same reason.

Power utilities are also subvented for expected lower sales and/or they are allowed to raise prices for expected lower electricity sales arising out of consumer energy efficiency measures such as on light bulbs, as seen in UK, Germany and likely elsewhere.

The EU already acknowledged loss of at least 5000 EU jobs in the initial 2009 shift from simple incandescents - and that was just in the final phase, as manufacturers had already begun to adjust for assumed (and promised) legislative changes.

Manufacture in China Aside from any loss of EU jobs, note the less environmental conditions of production processes from mining to coal plant powered manufacture to bunker oil fueled ships to Europe, and possible return of recycled reprocessed parts.

Local manufacture In this case, politicians can no longer ignore the manufacture energy use - which goes beyond the commonly quoted Osram and similarly based data which while showing 6-10x differential for CFLs over incandescents (and as per consultancy report US Dept of Energy referenced study, much more for LED manufacture) still only relate to assembly of components, largely ignoring component manufacture and certainly the other life cycle energy and emission issues already mentioned.

It can therefore hardly matter on any meaningful energy saving grounds, added to all the other stated referenced reasons that the savings are not there - and may for that matter give greater savings, as per point B.

Since all seem to agree that LEDs will also continually become more energy efficient, then whether or not there is a lock-in effect (from purchased long lifespan LEDs not getting changed), stage 6 can be abandoned also on those grounds: 1.

This is of course itself only a small part of why banning cheap popular safe electrical products makes no sense: Unlike - say - usual cars, light bulbs are only indirectly related to the energy used and any associated emissions, and a predominant evening-night off-peak surplus supply use along with fractional grid demand negates any reasonable justification to ban a popular choice of artificial lighting, which people spend much of their lifetimes using.