CAPÍTULO IV: MARCO PROPOSITIVO
4.2 CONTENIDO DE LA PROPUESTA
4.2.2 Plan de fortalecimiento estratégico institucional
by the lighting industry are missing policies, regulations and legislation that limit the supply of the incumbent inefficient technology such as ILBs and promote and push the demand for energy efficient lighting solutions.
Lack of policy restricting supply of inefficient lamps
A missing EU regulation limiting the most inefficient lighting technologies has been considered to inhibit the uptake of energy efficient lamps by the lighting industry, therefore “Philips has been pursuing for years, that governments stimulate demand for energy saving light bulbs,[…] by […] restricting availability of high energy consuming products, e.g. a ban on incandescent light bulbs”
(OECD, 2008, p. 35). Furthermore, “Philips Lighting is interested in participating, to the extent possible, in the development of regulation. When regulation is proposed, Philips Lighting, through industry associations, tries to influence it, in particular the implementation measures under EU regulation” (OECD, 2008, p. 85). These implementation measures lead to minimum efficiency requirements that phase-out the ILB technology.
Lack of policies & laws stimulating EEL
The European Lighting Companies Federation further stressed that “[i]n addition to legislative tools setting mandatory efficiency standards for lamps, we are working on policies and measures that focus on encouraging the most efficient lighting products at European, national, regional and local levels. These include: awareness raising campaigns, the use of updated building codes, green procurement and the use of appropriate fiscal instruments” (ELC, 2007a, p. 9). This shows that the lack of these policies stimulating demand of energy efficient lighting technologies has been considered as an issue for discontinuation by the industry actors. Besides, the ELC members also
“[…] want to ensure that fiscal instruments, ranging from reduced VAT rates or subsidy mechanisms, are used to […] to overcome the barriers to much greater uptake of energy efficient lamps. […]To strengthen awareness campaigns and energy labelling, positive fiscal measures, such as reduced rates of VAT on the most efficient products […] could provide a potential incentive for consumers to switch quickly to the best options. However, these measures should be applied in a co-ordinated way across the EU in order to avoid distortions to the Internal Market and unnecessary additional administrative costs on the supply chain” (ELC, 2007a, p. 11-12).
Lack of guidelines ensuring international CFL quality standards
A further problem related to the discontinuation of the ILB technology was considered to be a lack of international guidelines regulating CFL quality standards. This deficiency is especially relevant when one takes into account that the European incumbent lighting industry would depend on imports of CFLs from especially China and India and fears sub-standard products on the European market, which would further inhibit consumers’ uptake of the efficient lamps. Hence, “working with our international colleagues on a global harmonization of energy efficient lamp criteria for CFLis in order to increase consumer confidence and harmonise performance” (ELC, 2007a, p. 10) is presented as one priority of the industry.
4.5. Technical Barriers
In the following, the issues that constitute problems for industry actors to phase-out ILBs and replace them appropriately with energy efficient lightings and purely relate to technical and technological matters will be discussed.
4.5. Technical Barriers
Low quality & low suitability of EEL
The lighting industry highlighted that the low quality and suitability of energy efficient solutions, despite lowering consumers’ confidence with that technology, constitute another purely technical obstacle to a successful discontinuation which needs to be tackled. “We do not believe there are enough quality CFLs available on the market to replace the GLS lamps that will be removed from the market. Our concern is not just volumes (production capacity) but also the quality of the lamps. We need to ensure quality lamps are used such that the final luminaire/lamp system quality is maintained. We do not want to take the risk of bad quality products” (CELMA, 2008, p. 1). In a joint paper, the IEA and OECD addressed also this specific barrier by stating “With most residential light fittings having been designed over many decades to fit the highly standardised dimensions of incandescent bulbs, the additional length and bulk of CFLs acted as a significant disincentive for residential buyers. CFLs have also had a number of quality and suitability issues to address. The first CFLs had limited colour ranges and tended to only be available in the higher cooler-light values. CFLs using magnetic ballasts were also prone to delayed starts and long warm-up times and could suffer from flicker” (Levèfre et al., 2006, p. 11).
Poor power factor and bad quality of CFLs
Another aspect is that a poor power factor, which is typical for CFLs, influences the efficacies of the energy savers in a way that the calculated energy saving potential seems to be much lower (Federale Overheidsdienst, 2008, Efficacy Requirements, para. 1). The Professional Lighting Designers’ Association (PLDA) sees problems in particular for people using micro generation in their homes due to an inappropriate power factor of CFLs. Under these conditions the lamps will need almost twice the capacity of the indicated wattage (Vito, 2009a, p.73). Besides, bad quality CFLs, imported mostly from Asia, show sensitivity to ambient temperatures (EC, 2009, pp. 76-77), need long warm-up times until they deliver their full light potential and have a shorter life time when switching frequencies are high (Danish Energy Agency, 2008, Other comments, para. 1). Having taken these issues into consideration, financial savings from decreased energy costs would not withstand which weakens the industry’s argumentation further.
Retrofitting and dimmable lamps
Some actors also pointed to problems related to retrofitting and the consumers’ wish of dimmable lamps. “Some luminaires do not accept an energy efficient retrofit lamp due to the available space and/or socket types. […] In most cases a luminaire replacement should be recommended” (Vito, 2009b, p. 109). Moreover, when CFLs are put in certain luminaires they appear to be too big and are not considered to be aesthetic by the consumers (Vito, 2009b, p. 115).
“Common to both dimmers and many electronic switches, is that ordinary CFLi’s should not be operated on them. Lamp manufacturers warn against doing so with any CFLi, which is not specifically designed and certified for this use” (Vito, 2009b, p. 183). Furthermore dimmable CFLs “[…] contain significantly more electronics than ordinary CFLi’s, and are consequently also more expensive to the user” (Vito, 2009b, p. 184). “When CFLi's are dimmed the colour temperature increases slightly [… and] special dimmable CFLs cost 20€” (Vito, 2009b, p. 185).