SaveStageLighting

Update 5: September 10th 2018

 

ETC's Adam Bennette has written a summary of his views on the current state of the Ecodesign regulations for PLASA which can be read on the PLASA website here: 

https://www.plasa.org/wp-content/uploads/2018/09/ECO-design-regulations-summary.pdf

 

In addition, PLASA are also running a panel on the subject on the Tuesday of the PLASA Show at London Olympia, 11am-12pm.  Full details and how to register can be accessed by the following link: 

https://www.plasashow.com/session-registration-eco-design#/

 


 

Update 4: August 11th 2018

After the Noise, the Silence...

But was the silence the end, problem solved, or just the eye of the storm with more noise to follow? Well, it’s another issue of Focus, so it’s time for another update...

The last update was written just a few days after the meeting with DG Energy in Brussels, when the entertainment industry had, in effect, been asked to submit ideas for a suitable exemption for stage lighting. The proposal submitted included a reference to the existing European safety standard for stage and studio luminaires (EN60598-2-17), plus a list of lamp bases used in entertainment lighting fixtures. We felt both were required since the standard would define fixtures with built-in light sources (ie. LED fixtures) but not those using separate light sources (eg. tungsten or arc lamps), while the list of lamp bases would define those light sources, tungsten and arc, we felt were important for our work; limiting the exemption to their use in already-defined stage and studio luminaires would, it seemed to us, reduce or remove the potential for an exemption for these bulbs to be abused by people outside entertainment lighting – something DG Energy have repeatedly suggested happened with the previous entertainment lighting exemption, without ever really explaining that abuse.

That proposal was submitted through PEARLE, the pan-European producers organisation which has become our “channel” into Brussels.... and then the silence began. Silence on our side because we’d all been asked to be quiet and let the EU do its work. Silence on their side, because it was doing its work. We were told that a next draft would appear in the first week of July; we waited...

Finally, on 16 July new drafts for both the Ecodesign and EcoLabelling regulations and their corresponding Annex documents (dated 3/4 July) appeared...

Silence over, time for some new reading to begin!

The Key Change

What the reading reveals is that we have made DG Energy understand that entertainment lighting is something of a special case, that there is now language in the text very specifically about entertainment lighting – but that more discussions are required just to be clear that the exemption gives us all we need.

For us, there are two points of Annex III (Exemptions) of the Ecodesign Annex document. Point 3m details

“halogen light sources with cap-type GX9.5, GY9.5, GZ9.5, GP9.5HPM, G16d, GX16, GX16d, GY16, G22, G38, GX38, GX38Q, P28s, P40s, PGJX50, QXL, designed and marketed specifically for scene-lighting use in film-studios, TV-studios, and photographic-studios, or for stage-lighting use in theatres, discos, during concerts or other entertainment events”. That covers many lamps we use and love, including the Source Four’s HPL, the Revolution’s QXL, 1k and 2k Fresnel lamps, lamps for fixtures like the Brio, SL and CCT Freedom, lamps for older fixtures such as the Patt 23/123, Par64 lamps and more.

Point 3n details “colour-tuneable light sources” that can be set to at least the colours defined as “white light” by the EU – in effect, multi-coloured additive colour mixing LED sources.

While the EU seems to have decided not to make any reference to the EN standard we proposed, they have clarified many other points. Key is that the measurement is of the light source, outside of the optical system and excluding any other functionality; if the light source is built in to a fixture it has to be removed for testing. That should make it easier to hit both the efficiency and standby power requirements, since there are no losses through the optical train to worry about and you can remove non-lighting power consumption (displays, fans, motors).

Alongside that, it has been clarified that while a simple lumen per watt calculation is used for the new A-G EcoLabelling scheme (with “G” anything 85lm/W or below), a different, more complex calculation, including corrections for different source types and colour qualities, is the one used to determine whether a product is allowed or not. Most of the common arc sources we use seem to pass this test, as do many low-powered white LED sources, though achieving the targets for high power white LED sources will be harder. However, manufacturers have an extra year to achieve this: another key change is that the proposed start date is a year later than before, September 2021. Curiously, even products that are exempt from the Ecodesign regs will have to follow the EcoLabelling regs; that probably means no one will sell a tungsten or arc fixture with a bulb included, since without a light source the fixture itself is not subject to either regulation.

Problem Solved?

Nearly, but as ever, the devil is in the details. One particular issue is that just 17 lamp bases are included in the exemption, considerably less than the 49 we submitted. Truth be told, we never expected some of these to get through – the M16 lamp is too widely used in domestic/office lighting and is clearly a target for the EU. Some are safe because they sit above the 82000 lumen upper limit. Some – beamlight, Svoboda and ACL lamps – are potentially safe because they originally come from the marine or aero fields which have their own exemptions, though it’d be nice to be sure. The R7 linear lamp used for cyc lighting and much else is still unclear because we think there’s a typo in the current draft; we’ve asked for clarification. The rest? At the time of writing, we’re still checking.

Please do look at the list, compare it to the fixtures you have or love to use, and shout if anything’s missing.

For LED colour-mixing sources, there is a little concern about the way such a fixture is defined by having at least red, green and blue emitters of quite tightly defined colour ranges and purity; the spec for the green emitter is a slight cause for concern.

These are all issues that require clarity and a bit more discussion. The same team of people who presented to the EU in May and then submitted the exemption proposal – which includes representatives from PLASA, VLPT, OETHG and the IALD as well as the ABTT – have already started informal discussions through PEARLE while continuing to analyse the documents. Within the EU, the documents now move in to “interservice consultation”, which is when the other EU departments (culture, environment, employment) get to comment on the new draft. After that, the expert groups for the Member States get to work on the draft. The entertainment industry will be continuing, through PEARLE, to talk to DG Energy through this process to achieve the clarifications and, if necessary, changes that are required.

So: we are making progress. Things are looking much better than they did a few months ago. But having got this far, we just need to make sure we keep paying attention and working the details to really make sure that we can continue to get the tools we love (or, in the case of tungsten, can continue for as long as the manufacturers keep making it!)

 


UPDATE 3 : 18th May 2018

A group of professionals from across member organisations, manufacturers and designers in the live entertainment industry (including Pearle, SOLT/UK Theatre, the ALD, the Association of Swedish Lighting Designers, the IALD, OETHG, PLASA and VLPT)  had a very productive meeting in Brussels on 17 May with DG Energy.

As a result we have agreed to channel our work into seeking to draft a specific, technically based, exemption for lighting uses in the Stage and entertainment industries in the new proposed Eco Regulations planned for 2020. This work needs to happen quickly with our collective comments being channelled through Pearle to DG Energy in advance of the next draft of the regulations due in late June. 

In order to allow for this process to run as smoothly as possible, the campaign’s social media platforms will remain dormant until such a time as we have further updates. 

Many thanks for your continued support.

The #SaveStageLighting team


 

UPDATE 2: 22nd JUNE 2018

ECO Design regulation: news of our industry’s petition to save stage lighting.

Theatres will not go dark due to ECO design rules’

On 20 June 2018, the period of public consultation for the proposed ECO design regulation – that will affect lighting products of all types – expired. The EU DG Energy department has passed on a revised draft to the next stage of the legislative process. We expect to know its content within a few weeks as it progresses through the committee stages of the process of turning it into a law. Although much still remains to be known, the situation now is far more positive than many had feared and greatly improved since our public meetings earlier this year. 

Our petitioning team made a clear case for exemptions for our industry – including for stage, studio, film and live event purposes – and we have received strong indications that the main arguments of the case have been accepted. There will be a list of exempted lamp base types that will include many of the specialised tungsten and discharge lamps we use.  We can expect the list to be comprehensive, but we should also expect that a few types we have been using will not be exempted if they are in use for other common non-entertainment purposes.  There will be an exemption for colour-tunable light sources, but the details have not yet been provided.

The text of the regulation will be published publicly in November this year and is to be enacted in law in September 2020. More specific details will be available shortly, and these will be disseminated as soon as they are confirmed. There may be more work to do and more details to clarify but, until we see the revised draft, it would be prudent to remain calm and patient.

Adam Bennette (PLASA), Christian Allabauer (OETHG), Randell Greenlee (VPLT) & Silke Lalvani (PEARLE), on behalf of the Professional Entertainment Lighting Products ECO design task group.


 

UPDATE 1: 16th JULY 2018

The next draft of the EU’s proposed Ecodesign and Eco Labelling regulations became available on July 16th.

A quick initial reading of the documents shows that the EU has recognised the special requirements of entertainment lighting, with exemptions included for both ‘colour tuneable’ LED lighting fixtures and for a number of tungsten lamp bases commonly used in entertainment lighting. Notably, the start date for the regulations has also been revised from September 2020 to September 2021.

Teams from the ALD and others in the entertainment industry are currently scrutinising the drafts to understand exactly what they offer, what they don’t offer and how they will impact entertainment lighting.

 

More on this to follow soon…

 


 

The Association of Lighting Designers has launched a campaign to protect the futures of venues and theatres across Europe.  There is currently an enormous threat being made to the way theatrical productions are presented.

The European Union (EU) is proposing, in its Eco-design Working Plan 2016-2019, to change the rules that govern the light sources used in theatrical productions. In effect, they want to bring the vast majority of quality theatre lights under the same rules that govern domestic and office and industrial lighting.

These new regulations are intended to start from 1 September 2020 and if implemented as written, would dramatically impact all areas of entertainment lighting and all who work in this field – lighting creators, lighting users and lighting manufacturers. The impact on theatrical production across Europe would be immediate, and overwhelming.

Follow this link to read and download a little ‘primer’ guide to the current and proposed rules, mainly aimed at collecting all of the information together into one place. There is some confusion or uncertainty about just what is being proposed and just why it’s such a problem.  Compiled by the Save Stage Lighting team and other members of the entertainment lighting community, this document aims to establish what is currently being proposed and the potential effect on our industry.

Since the middle of April, the campaign has accelerated and there has been an increasing amount of press coverage on the issue. We continue to collate the coverage (predominantly from the UK) on this page which includes links to the original articles elsewhere online

The #SaveStageLighting Campaign aims to demonstrate to the EU Energy Directorate the widest possible cultural opposition to these proposals.  We are encouraging everyone to sign and share the petition here and to contact their MEPs.

It is absolutely essential that we are successful in our endeavour of securing an exemption for stage lighting from these proposals. This has the potential to harm everyone from technicians, actors and designers to agents, critics and audience members. The consequences of failure would be catastrophic to the entertainment industry and European culture.

 


 

TEN POINT SUMMARY IF YOU READ NOTHING ELSE!

 

1. New regulations proposed for September 2020 will impose a minimum efficiency of 85 lumens per watt and a maximum standby power of 0.5W on all light sources (lamps or self-contained fixtures) to be sold in the EU.

 

2. The existing version of these regulations includes an exemption for stage lighting. The new regulations do not (though they do include exemptions for video projection, and suggest an exemption for stage lighting that appears to have mis-understood the light levels/power requirements of most theatrical lighting fixtures).

 

3. No tungsten fixtures meet this requirement. Many LED-based entertainment fixtures do not meet those requirements. After September 2020 no new stocks of such equipment can be supplied to the market in the EU.

 

4. Manufacturers suggest that the limits of optical design and LED efficiency mean that they will not be able to create certain types of fixtures that do meet the requirements by September 2020.

 

5. Nothing in the rules stops you from using existing fixtures. But bulbs can’t be supplied to market and once you can’t get new bulbs, existing fixtures become worthless - effectively scrap. It is unknown how long existing stocks of bulbs will remain available.

 

6. Replacing your existing fixtures might well mean replacing your entire dimming and control infrastructure.

 

7. All this for power savings that might be relatively small, given the way entertainment lighting is typically used, and will likely be far outweighed by the scrap created and the energy required to manufacture and distribute new fixtures.

 

8. Important tools from a lighting designer’s toolkit will be lost within the EU, some forever.

 

9. This will dramatically affect performance venues and productions of all types and scales, including new and existing (long-running, long-standing rep) productions

 

10. There are very few precedents for technologies to be banned if they are not unsafe to use.

 


 

Documents to Read

There are a number of documents that describe the proposed legislation, the ALD response to the initial January 2018 consultation, and what we understand the proposals mean for the future of stage lighting equipment and the craft of its practitioners should they be enacted as currently written.

ALD document on our understanding to the current and proposed rules, mainly aimed at collecting all of the information together into one place. A less technical document is available via the next link.

Used to present the case to government departments, theatre organisations, producers and others rather than lighting specialists. It includes information  on the impact these rules would have on those using lighting both artistically and financially, and also looks at the environmental issues around these regulations.

ECO Design regulations: Possible effects on the entertainment lighting industry. Call to arms to manufacturers, sellers and installers of entertainment and specialist lighting equipment.

Julie’s Bicycle is a leading international charity that works at the intersection of the creative sector and climate and the environment, supporting the arts and creative industries to understand and take action on their environmental impacts. This is their response to the new draft regulations on lighting proposed under the Eco-Design directive 2009/125/EC as part of the Eco-Design Working Plan 2016-2019.

A second submission made to EU as part of the spring 2018 Public Consultation phase of EU Eco-Design Proposals outlining everything discovered and learned on the subject since the original response made in January 2018 (see below)

A response to the request for comments on the EU’s Eco-design and Energy Efficiency of Light Sources proposals, an effect of which would be to ban the supply of light sources which are heavily used in entertainment lighting. 

An appendix to the main consultation document submitted to the EU that included various contributions received on why the imminent ban of supply would be bad for the art of lighting design in live performance as well as the effect it may have on venues who will need to replace equipment that would be rendered obsolete by the implementation.

 Joint statement: Call for a realistic timetable for transitioning to new lighting technologies. "We, the undersigned associations, support the objectives of Eco-design, Energy labelling and RoHS. We call on regulators to adopt a pragmatic and realistic transition timetable to substitute lighting technologies and products. This timetable needs to respect the established maintenance and repair cycles of the end-users of these lighting products". 

You can access, read, download and generally digest all of the relevant documents concerning the Eco-design Working Plan 2016-2019 and the proposed legislation that is driving the campaign from our public Dropbox folder.

 


 

Be Part of the Conversation

It is important to keep the discussion going and bring more voices forward discussing how it will affect both the practice of lighting designers and practicalities and costs that venues will face should this go through.

The Save Stage Lighting Campaign can be found:
Facebook:  https://www.facebook.com/SaveStageLighting/
Twitter:      @SaveLighting 
Email:       savestagelighting@ald.org.uk

A list of those companies and individuals who are Standing With Us and supporting the campaign, while the coverage we have received from press and media outlets can be found here.