Which path to (energy efficient) illumination?

When it comes to lighting, we have noted in this blog about the significant contribution energy efficient lighting can have on energy savings and reduction of greenhouse gases. To this end, minimum energy performance standards are indicated a key tool in transitioning to such lighting.  To this end, the Ecodesign Directive, and more specifically implementing regulations like 244/2009, have set minimum energy performance standards for most lighting products in the EU. Regulation 244/2009 introduced stages of standards which effectively began phasing out inefficient lighting (most notably incandescent bulbs). Sometimes the standards were portrayed only as bans on specific technology (i.e. banning of the incandescent bulb, which sparked controversy), but it is important to keep in mind that the standards focus on requirements for lighting efficacy (e.g. energy use per lumen output), functionality, and product information, rather than targeting specific technology per se. The standards for promotion of market for efficient lighting products were drafted in the context of their importance for the Europe 2020 agenda and its 20% energy savings target by the year 2020.

Part of the reason for bringing in the standards was to initiate a market transition to more efficient lighting, one that was possible given the technological development of lighting, but still not taking place with only voluntary and informational measures. The regulations were drafted after a preparatory study where stakeholders, including consumer organisations, NGOs and industry associations (e.g. Lighting Europe representing the lighting industry) had the opportunity to comment as well as later on the early working documents of the Commission in the Ecodesign Consultation Forum (you can find an overview of the process, reports, and stakeholder comments here).  The timeline with a staged process was designed to give the industry incentives towards energy efficiency requirements, but also time for technological development to ensure there were adequate replacements available for consumers when less efficient technology was phased out.

Ecodesign lighting reg 244

It is this timeline that became an issue when a review of the regulation included a review of the timeline and technology. The review study, relased by VHK-VITO in June 2013 in consultation with experts (whose extensive comments are included in the annexes), found that there could be substantial net job losses (the study estimated -6,800 net employment) and its projections for price and development LED technology predicted it would remain costly for some time and that efficiency gains with LEDs were still being made, which meant delaying the shift to LEDs might be preferable for environmental reasons as well (the study also assumed that CFLs were replacing incandescent bulbs, more on that later). The findings of the study, with other evidence, convinced the Commission to propose a two-year delay to Stage 6 to give LED technology more time to develop.

The proposal was not without opponents, for several reasons. The first opposition was raised on principle. Some experts and countries, most visibly Sweden, were opposed to the delay because it set a dangerous precedent with changing legislation (that had gone through a consultation process already) before implementation. Denmark along with Sweden, Belgium, as well as organizations like CLASP and ECEEE also conducted their own studies into the lighting market and the availability and cost of LEDs and found that the market was in fact developing much faster than anticipated and modeled in the VHK-VITO report. Moreover, the modelling in these reports also found that halogen lamps, more than CFLs, were replacing incandescent lamps so the earlier report had also overestimated the energy savings already occurring and underestimated the savings from the ban on halogens. The 2015 report findings instead proposed that Stage 6 should be implemented as planned as the optimal scenario.

So what was decided?  The two year delay was approved. The process raises questions about the use of updated information about technological developments – should a study not have been done until 2015 to be more accurate of the current state? But then would there be enough time for a full consultation process? How could the 2015 studies have made more of an impact on decision-making? Another could be whether now lobbying has been proven an effective strategy in delaying Ecodesign legislation.

About JL Richter

I am currently researching about policy instruments for energy efficient lighting products and how questions related to design, disposal, collection, labels and procurement can be addressed in a synergistic way.
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