EUROPEAN COMMISSION

Directorate-General for Communications Networks, Content and Technology Components and Systems Photonics

Green Paper "Lighting the Future: Accelerating the deployment of innovative lighting technologies" [COM(2011) 889]

Results of the Public Consultation

06 July 2012

TABLE OF CONTENTS EXECUTIVE SUMMARY................................................................................................. 3 1. 2. 3. SCOPE OF THE REPORT ......................................................................................... 5 PROFILE OF RESPONDENTS AND STATISTICAL ANALYSIS OF REPLIES RECEIVED ................................................................................................................. 5 ANALYSIS OF ANSWERS RECEIVED PER QUESTION..................................... 8 3.1 3.2 3.2 4. Key messages received to the questions concerning European Users.............. 9 Key messages received to the questions concerning SSL uptake in buildings 20 Key messages received to the questions concerning the European Lighting Industry ........................................................................................................... 22

CONCLUSIONS....................................................................................................... 30

ANNEX 1: LIST OF QUESTIONS IN THE PUBLIC CONSULTATION ..................... 32 ANNEX 2: EXAMPLES OF POSITION PAPERS RECEIVED IN THE PUBLIC CONSULTATION.................................................................................................... 33 Annex 2.1 Positions of National Parliaments and Regions ...................................... 33 Annex 2.2 Position papers of associations ............................................................... 34

EXECUTIVE SUMMARY The public consultation on the Green Paper Lighting the Future: Accelerating the deployment of innovative lighting technologies was open from the 15th of December 2011 until the 29th of February 2012. It was based on 12 decisive questions related to challenges for the wide deployment of Solid State Lighting (SSL) in Europe with regards to users, the deployment in buildings and industry. Overall, 125 valid responses were received and five written statements by national Parliaments and regions. More than 60% of the replies represent those related to the lighting industry and 15% represent citizens. Most contributions came from France, Germany, Belgium, the United Kingdom, Italy and the Netherlands. The big majority of responses received strongly support the Green Paper initiative and the special measures it proposes. They consider that the Green Paper describes correctly the SSL deployment challenges Europe is facing and add only nuances to the overall picture. Even if priorities are set differently among interest groups, they all support a strong policy framework to address the SSL challenges. This report presents the main findings of the public consultation, which are outlined as follows: Main challenges for the large deployment of SSL in Europe: The three major concerns of the respondents are poor SSL product quality, lack of information for the citizens and high initial purchase cost. Issues which many respondents highlighted for further consideration include: more coherent standards for improving SSL product quality; better coordination of existing programmes; address scarcity and recycling of raw materials; and possibly, launching new high-impact actions by getting inspiration from good initiatives existing in other regions. Reinforcement of market surveillance and role of the Member States: for most of the respondents, present market surveillance operations are not enough to ensure good quality SSL products in European markets. They call for a stronger and more transparent EU level market surveillance support by developing independent measurement/testing laboratories and agreed procedures and metrics for comparing results and publishing them via umbrella consumer organisations; or for reinforcing European standards for performance and safety. Possible actions of industry for improving SSL product quality: Whereas the feedback from the lighting industry actors is that they are already doing their part to ensure good quality SSL products, other stakeholders are of the opinion that industry could take additional measures: introduce a quality label; ensure better compatibility and interoperability with existing lamps; or, join efforts and cooperate better with public authorities and other market actors with the aim of securing good performance of SSL products. Raising awareness on SSL: All the respondents recognise the need to increase consumers' awareness of the benefits and potential of SSL lamps and luminaires. They call for measures and actions that would help consumers get a better understanding and education on SSL throughout the whole chain of educational institutions. Industry and market actors as well as public authorities are also called to cooperate to ensure that information and awareness on SSL reaches consumers in a widely understandable form. SSL deployment in buildings and the landlord-tenant conflict: Respondents acknowledge that SSL can contribute to reducing substantially the overall energy consumption of buildings. Examples of suggestions made on how to accelerate SSL deployment in buildings include: strengthen and promote the use of intelligent lighting system solutions and ensure that this is

included in relevant future regulations and directives; or provide subsidies or tax breaks when purchasing and using SSL. Public authorities are generally encouraged to become role models and first users. As for the landlord-tenant conflict, overall this is not regarded as being of major importance for the average of respondents. Support for research and innovation: It is widely acknowledged that support of strategic R&D would allow the European lighting industry to take the lead in high quality, intelligent and innovative lighting products. Examples of suggestions received include: call for better coordination and priority setting of scattered initiatives between market actors and research organisations; call for a more coherent EU vision and roadmap and a cross-Directorates General approach; benchmarking of EU's R&D initiatives on SSL against those in other regions of the world and developing and disseminating best practice examples; and supporting R&D targeting the effects on health, well being, productivity and concentration. Reinforcing manufacturing capacities in Europe: Protecting and creating new qualified jobs in manufacturing in Europe with general favourable economic framework conditions is seen as vital. This would require favourable political framework conditions and could mean financial support for pilot production lines, specific support the development of nextgeneration intelligent digital solutions and specific support for OLED manufacturing. The view taken by the majority of the industry stakeholders is that 95% of the value chain will be created in lighting solutions and only 5% in light sources. Citizens and research organizations tend to support the view that it would be beneficial for Europe to support a label "100% made in Europe". At the same time, they call for motivating manufacturing investments in Europe which consider a social and environmental sustainable perspective (creating sustainable jobs in Europe and integrating the recycling perspective when manufacturing). Reinforcing Cooperation along the value chain: Overall there is a strong agreement that supporting the whole SSL value chain will be beneficial to Europe. Some respondents call for specific measures for SMEs as they may be left out during the transition from pure lamp selling to supplying intelligent lighting systems and offering complex and modern lighting services. In addition, reinforcement of cooperation along the value chain is suggested via vocational training and education measures for all the actors of the SSL value chain. Significant gaps in standardisation: All the respondents agree that enhanced standards are of vital importance for the SSL sector. The representatives of the lighting industry and related businesses provided a detailed description of gaps not covered in current standards. In that respect, they welcome the ongoing draft standardization mandate on SSL from the European Commission to CEN & CENELEC. Support of education, vocational and lifelong learning: Respondents acknowledge that current vocational and lifelong learning and training schemes are not sufficient to meet the demand of the future SSL markets. There is a shortage of highly qualified work force and industry representatives are especially keen to indicate that this problem will increase in the future. Potential measures should focus on attracting more people into the related professions and to increase the pan-European vocational training.

1.

SCOPE OF THE REPORT

The Green Paper 'Lighting the Future: Accelerating the deployment of innovative lighting technologies' was published by the European Commission (EC) on 15 December 20111. Its aim is to accelerate the deployment of high-quality Solid State Lighting (SSL) for general lighting and help Europe achieve its key energy efficiency, industrial and innovation targets. Together with the publication of the Green Paper, the EC sought the views of all relevant stakeholders on the main issues identified in this Green Paper through a public consultation. The consultation was open from the 15th of December 2011 until the 29th of February 2012. The public consultation was based on 12 decisive questions, which are presented in Annex 1. The questions were structured around the following main issues: Questions 1 to 5 were related to the main issues and challenges for the SSL uptake by European users (e.g., the quality and performance of SSL products, information and awareness about SSL products, cost of purchase, etc); Questions 6 and 7 were related to the specific use of SSL in buildings (issues for the SSL deployment in public and residential buildings); Questions 8 to 12 were related to issues in connection with the European lighting industry and its present and future competitive position (the SSL value chain, research and innovation aspects, the future of SSL manufacturing in Europe, standardisation, etc.); The purpose of this report is to present a detailed analysis of the responses received and the suggestions made to each of the 12 questions of the public consultation. 2. PROFILE OF RESPONDENTS AND STATISTICAL ANALYSIS OF REPLIES RECEIVED

Overall, 147 responses were submitted to the dedicated webpage which was set up for the public consultation. From those, after elimination of blank submissions and duplications, 125 responses were considered as valid for this analysis. Moreover, the EC has received by e-mail position papers from two additional organisations, whose inputs are also considered in the analysis of this report2. The respondents who gave their consent to publish their names and the inputs and position papers which they submitted in the public consultation are presented in a separate attachment to this analysis. The EC has also received by e-mail five written statements by national Parliaments and regions3. These are presented in Annex 2. However, for the sake of this analysis, these inputs are not further considered here.

1 2

COM(2011) 889 of 15 DEC 2011 These position papers were submitted by IGNES (a French industry association representing 60 companies in security lighting and electronics) and by CieloBuio (an Italian non-profit organisation, whose goal is the protection of the night sky). 3 Written statement were received from: The Senate of the Parliament of the Czech Republic; The Department for Environment, Food and Rural Affairs (DEFRA) of the Government of the United Kingdom; The Economic Affairs Committee of the Swedish Parliament; The Climate, Energy and Building Committee and the European Committee of the Danish Parliament; and, The Directorate for General Environment and Protection of the Soil and Coasts of the Region Emilia-Romagna

Citizens represent around 15% of the replies received. Those related directly or indirectly to industry make up more than 60% of the responses. They represent SMEs (~20%), large industry (~15%) and professional / industrial associations (~25%). The remainder of the replies received is as follows: public authorities (4%), research organisations and universities (~10%) see Figure 1.

Figure 1: Type of stakeholders who replied to the public consultation

Figure 2 below illustrates the responses received according to the sector of activity indicated by the respondents. In this figure, respondents who replied as "Other" are further broken down into two new categories, namely "Research" and "Consumer / Special interest group", as this was specified by the respondents. Therefore, the overall distribution of respondents per sector of activity is as follows: the lighting and luminaire sector accounts for almost one third of the respondents (32%), followed by research (15%), consumer / special interest groups (12%), electrical installation (6%), architecture / lighting design (6%) and street lighting (6%).

Figure 2: Responses received according to the sector of activity of the respondents

The majority of the answers were received from stakeholders located in France, Germany, Belgium, United Kingdom, the Netherlands and Italy. Comments from the 12 new Member States make up less than 6% of the comments received (see Table 1).
Originating countries
Aus tri a Bel gi um Bul ga ri a Cyprus Czech Republ i c Denma rk Es toni a Fi nl a nd Fra nce Germa ny Greece Hunga ry Irel a nd Ita l y La tvi a Li thua ni a Luxembourg Ma l ta Netherl a nds Pol a nd Portuga l Roma ni a Sl ova ki a Sl oveni a Spa i n Sweden Swi tzerl a nd Uni ted Ki ngdom Non-EU Tra ns na ti ona l EU Orga ni s a ti on Total Number of replies In percent of total 4 3% 17 14% 1 < 1% 0 0% 1 < 1% 2 2% 0 0% 1 < 1% 23 18% 23 18% 1 < 1% 1 1 9 1 0 1 1 9 1 1 0 0 1 3 4 1 12 2 3 1 125 < 1% < 1% 7% < 1% 0% < 1% < 1% 7% < 1% < 1% 0% 0% < 1% 2% 3% < 1% 10% 2% 2% < 1% 100%

Table 1: Replies received according to the country of origin

As mentioned above, the questionnaire consisted of 12 optional questions (see Annex 1). Actually it was not necessary for every respondent to answer every question. The most answered question was the first one, where 87% of the respondents replied and the least answered one was question 9, which was answered by 49% of the respondents. Table 2 presents the number of respondents who have answered each question and Figure 3 illustrates the percentage of questions answered by each of the different categories of Stakeholders.

Question
1 2 3 4 5 6 7 8 9 10 11 12 Total

Number of respondents
109 95 95 94 93 78 74 76 61 77 81 77 1010

In percent of total
87% 76% 76% 75% 74% 62% 59% 61% 49% 62% 65% 62%

Table 2: Number of respondents per question (the list of the 12 questions can be found in Annex 1).

Figure 3: Percentage of questions answered according to category (type of Stakeholders)

3.

ANALYSIS OF ANSWERS RECEIVED PER QUESTION

All the respondents agreed that SSL is contributing to the overall energy efficiency goals of Europe. The overwhelming majority strongly support the EC initiative to launch special support measures for SSL as described and suggested in the Green Paper. Some respondents considered that this is a very necessary and important step towards creating a more sustainable, secure, innovative and coherent lighting policy in Europe which could have been proposed earlier. Overall, it can be said that the stakeholders and industrial representatives, citizens and public authorities see the challenges as described in the Green Paper as being the correct ones. Only some further details and nuances are added to the overall picture.

Nothing fundamentally new has come up in the replies received. Sometimes, priorities are set differently between certain interest groups, notably those concerned with health and wellbeing as well as by the potentially adverse consequences of lighting. But even those who have a more critical view about the introduction and support of SSL into European markets strongly support the proposed policy framework to address the challenges in question. Within the responses received, the priority given to specific issues varies quite significantly. Table 3 below provides a ranked list of the main issues expressed by the respondents. The priority list is established by using the number of references made to certain key words as analysed in the answers received.
Key word Meaning specifically or making reference to
SSL product quality Performance of SSL products Standardisation for high quality SSL products Initial cost of purchase Information and awareness Market surveillance Education of consumers and vendors Value chain of SSL industry Awareness on SSL options Health and wellbeing issues Best practice of SSL applications Intelligent high quality lighting solutions Compliance to product standards Compatibility of light sources and appliances Potential adverse effects and health risks Certification of product performance Consumer confidence in technology Securing of European jobs Abundant use of light, "light pollution" EU level roadmap to increase SSL use National policy frameworks Recycling of SSL lamps

Number of references made within the replies 265 261 241 194 178 123 116 116 111 98 85 78 64 50 46 42 37 33 30 28 20 16

In percent of total contributions 26% 25% 23% 19% 17% 12% 11% 11% 11% 9% 8% 8% 6% 5% 4% 4% 4% 3% 3% 3% 2% 2%

Quality Performance Standards Cost Information Surveillance Education Value chain Awareness Health Best practice Intelligent Compliance Compatibility Risk Certification Confidence Jobs Pollution Roadmap National policy Recycling

Table 3: The list of the most quoted topics by the respondents. This list is established according to the number of references made to these topics in the replies received

3.1

Key messages received to the questions concerning European Users

Question 1 of the Public Consultation [Challenges related to the uptake of SSL by European Users]: How would you propose to overcome the challenges described in the Green Paper for the wider market penetration of Solid State Lighting (SSL) technologies in Europe?

Responses to Question 1
Ci tizen Ci ty / Muni ci pa l i ty / Loca l publ i c a uthori ty La rge bus i nes s Profes s i ona l a s s oci a ti on / NPO Regi ona l / Na ti ona l publ i c a uthori ty Res ea rch orga ni s a ti on Sma l l or medi um-s i zed bus i nes s Uni vers i ty / Hi gher educa ti on Other Not a ns wered Total

Number of responses 13 2 20 25 3 5 25 6 10 16 109

% of those answering 14% 2% 21% 26% 3% 5% 26% 6% 11% % of Total 13% 87%

Figure 4: Responses received to question 1 of the public consultation

The answers to the first question of the public consultation reflect in very general terms the opinion of the respondents about the existing main challenges for a wider market penetration of SSL. The challenges mentioned are mostly a repetition of those already presented in the Green Paper or are highlighting specific priorities. In summary, the reported key concerns and challenges are (see Figure 5): 1. Low quality of SSL products; 2. Information and awareness; 3. Initial cost of purchase & financing; 4. Conditions for good market development (market structure, supply and demand); 5. Health, safety and well being; 6. Research, innovation, development; 7. Strategic concerns related to EU policy. The first and most important challenge reported by the respondents is that of having high quality SSL products in the market (more than 40% of the replies received). The second most mentioned challenge is that of information and awareness (approximately in 35% of the replies received). The third most important concern is that of the high initial purchase cost and cost of financing of SSL technology (mentioned in more than 30% of the replies received). The first two concerns are further addressed in questions 3, 4 and 5 of the public consultation. As for the third concern (high initial purchase cost), measures suggested by the respondents include: dedicated subsidy schemes, special tax regimes and other specific financial incentives for developing more efficient technologies at local and national level, and for rewarding those who deploy energy efficient LED solutions; and, recourse to new financing models (such as Energy Service Companies ESCOs) for reducing the lifecycle cost of lighting in Green Public Procurement schemes. In Figures 6 to 8 below some of the key concerns are further divided into subcategories with the purpose of clarifying which specific aspect was considered to be of key interest. This however, does not provide any indication on suggested measures or recommendations for actions to overcome these challenges.

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Figure 5: Key concerns mentioned with regard to question 1 of the public consultation

Figure 6: An overview of the replies received to question 1 of the public consultation - key concerns expressed related to the quality of SSL products

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Figure 7: An overview of the replies received to question 1 of the public consultation Issues included under the key concern of good market development of SSL in Europe

Figure 8: An overview of the replies received to question 1 of the public consultation Issues included under the key concern for more healthy SSL products and for well being

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Question 2 of the Public Consultation [Additional Challenges related to the uptake of SSL by European Users]: Which additional challenges do you see for a wider SSL market penetration in Europe and which solutions would you propose to resolve them?
Responses to Question 2
Ci tizen Ci ty / Muni ci pa l i ty / Loca l publ i c a uthori ty La rge bus i nes s Profes s i ona l a s s oci a ti on / NPO Regi ona l / Na ti ona l publ i c a uthori ty Res ea rch orga ni s a ti on Sma l l or medi um-s i zed bus i nes s Uni vers i ty / Hi gher educa ti on Other Not a ns wered Total Number of responses 12 1 17 24 2 4 22 5 8 30 95 % of those answering 13% 1% 18% 25% 2% 4% 23% 5% 8% % of Total 24% 76%

Figure 9: Responses received to question 2 of the public consultation

Overall no new challenges were mentioned in the responses received to the ones already reported under question 1. It is worth noting, however, that some issues are mentioned repeatedly by several stakeholders: [25% of respondents] Europe is lacking coherence as regards the availability of standards for SSL product quality, which would secure faster market deployment and innovation in Europe; [14% of respondents] Consider the challenges of scarcity and of recycling of raw materials: Although the Green Paper does mention the issues of securing the supply of scarce raw materials and the recycling of end-of-life SSL, some comments underline the fact that these are important aspects and that there are still many opportunities to further green the SSL products and production processes; [12% of the respondents] Address the lack of transparency and coordination of existing programmes, which are leading to a fragmented approach along Member States and across the EU. At present the EU does not have an overall and coherent policy on SSL. The expectation of the stakeholders is that the SSL Green Paper will cover such gap; [12% of the respondents] Look at good policy initiatives in other countries and encourage EU equivalents to address the lack of cross regional benchmarking. Leading countries of the world such as USA, China, Korea and Japan have recognised the potential contribution of SSL in achieving their overall objectives in the areas of energy and environment. This has been laid down in national policy documents and is accompanied by local supportive measures, which are encouraging and stimulating local and regional businesses to enter the market; [7% of the respondents] Consider the lessons learnt during the introduction of CFL. They recommend that authorities in Europe and market actors should not repeat the mistakes made when introducing compact fluorescent lights (CFLs) to the European lighting market. Lessons learned were the lack of quality and overall performance in early products, exaggerated prices and life-cycle expectations, a growing bad reputation of the technology, lack of knowledge

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within consumers and vendors. A very important remedy to this would be to secure high quality standards and not to allow low quality products to ruin the market; [7% of the respondents] Consider potential health risks of SSL: Special interest groups such as astronomer and consumer associations are convinced that potential risks of SSL on human health are not explored enough and are not considered enough within the current layout of the Green Paper4. Stakeholders concerned with health risks wish for clearer and more transparent communication regarding this aspect; [6% of the respondents] Address the rebound effect: Fear for a rebound effect due to ubiquitous integration of LEDs in materials and components. A small number of replies (in each case less than 5% of those replied to question 2) are also highlighting the following issues: Include electromagnetic compatibility (EMC) in SSL product standards and market surveillance (this is reported especially by those involved in professional or amateur radio broadcasting); the need to change the image of lighting products from commodity products which are being purchased at lowest cost to life-style products which may receive a premium valuation and which are not only bought because of their price; increase efforts in education; support SME efforts to change their business models from classical lighting business to LED lighting; the need to specifically address the role of cities and to strengthen SSL uptake in outdoor and public lighting; and, the need to emphasise the fact that general lighting should not be used abundantly and that support is needed for more smart and intelligent system solutions to reduce the polluting effects of light. Figure 10 provides an overview of the main feedback received to question 2 (total of 95 replies).

Figure 10: An overview of the key concerns mentioned in the replies received to question 2 of the public consultation

This is connected with the mandate that the Scientific Committee for Emergent and Newly Identified Health Risks (SCENIHR) has already received and where final results were just published http://ec.europa.eu/health/scientific_committees/emerging/docs/scenihr_o_035.pdf

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Question 3 of the Public Consultation [The role of the Member States]: What can EU Member States do to reinforce market surveillance of product performance and safety in the area of SSL lighting products?
Responses to Question 3
Ci tizen Ci ty / Muni ci pa l i ty / Loca l publ i c a uthori ty La rge bus i nes s Profes s i ona l a s s oci a ti on / NPO Regi ona l / Na ti ona l publ i c a uthori ty Res ea rch orga ni s a ti on Sma l l or medi um-s i zed bus i nes s Uni vers i ty / Hi gher educa ti on Other Not a ns wered Total Number of responses 9 1 16 25 2 3 24 6 9 30 95 % of those answering 9% 1% 17% 26% 2% 3% 25% 6% 9% % of Total 24% 76%

Figure 11: Responses received to question 3 of the public consultation

Market surveillance is falling under the responsibility of national authorities. However, for most of the respondents, present market surveillance operations are not enough to ensure that only good quality SSL products enter the European market. In particular, stakeholders from the lighting industry and electrical installers have the opinion that if the authorities from Member States already complied with their obligation under existing law, a lot would be achieved already. Therefore, there is a call for Member States to act more proactively. Some specific actions to reinforce market surveillance are suggested repeatedly by many stakeholders: [23%] Develop measurement/testing procedures and agreed metrics for comparing results; [15%] Reinforcing European standards for performance and safety; [14%] Reinforce/create national control laboratories and accreditation systems; [11%] Member States are called to enlighten/educate consumers; [9%] Strengthen EU law for market surveillance and better control the compliance to EU regulations. Other suggestions received by a small number of respondents include: Develop a European equivalent of the CALiPER programme 5of the US Department of Energy (CALiPER is seen as a very good example to support customer confidence and establish accredited and traceable product measurements); create a single EU quality label; Member states should encourage industry to respect regulations; Make testing economically viable for SMEs as well as large industry; Call for a more coherent and wider publication of testing results, which could be made available for anyone interested via an EU-wide database for product tests. Figure 12 provides an overview of the main feedback received to question 3 (95 replies).

http://www1.eere.energy.gov/buildings/ssl/caliper.html

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Figure 12: An overview of the main suggestions received to question 3 of the public consultation

Question 4 of the Public Consultation [Actions for the SSL Industry]: What could the lighting industry do to ensure the performance of SSL products?
Responses to Question 4
Ci tizen Ci ty / Muni ci pa l i ty / Loca l publ i c a uthori ty La rge bus i nes s Profes s i ona l a s s oci a ti on / NPO Regi ona l / Na ti ona l publ i c a uthori ty Res ea rch orga ni s a ti on Sma l l or medi um-s i zed bus i nes s Uni vers i ty / Hi gher educa ti on Other Not a ns wered Total Number of responses 11 1 16 23 1 4 25 6 7 31 94 % of those answering 12% 1% 17% 24% 1% 4% 26% 6% 7% % of Total 25% 75%

Figure 13: Responses received to question 4 of the public consultation

The respondents to this question see in general the improvement of the performances of SSL products as an issue. While citizens, consumer associations and public authorities call for better performance in terms of quality of the light and reliability, the feedback from the lighting industry in general is that they are already doing their part to ensure the performance of SSL products. Some noteworthy suggestions are made on how the efforts can be strengthened and enhanced: [14%] Develop and introduce a quality label;

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 [13%] Ensure compatibility and interoperability with existing lamps; [13%] Industry should join efforts and achieve more cooperation. It could improve its cooperation with public authorities, research organisations and other market actors with the aim to secure performance of SSL products. For example, it is suggested that industry should have a better participation in the working groups and technical committees of the International Electro-technical Commission (IEC) and the European Committee for Electro-technical Standardisation (CENELEC); [9%] Industry should act to make sure that consumers are not (again) disappointed by the quality of SSL products. Industry should focus on reliability and a fair representation of SSL lifetime expectations (offer better warranty periods for at least five years); [7%] Industry should support the review of the Eco-Label and Eco Design Directive. A small number of respondents (in each case less than 5% of those replied to question 4) are also highlighting the following issues: Broaden the Apples & Pears6 initiative which is a guiding paper intended to help bring clarity by introducing a universal set of quality criteria described in IEC/PAS documents; Increase efforts to develop intelligent SSL lighting systems; call for the lighting industry to make market surveillance as transparent as possible by accepting independent testing by third parties and allowing for a wide publication of results. Figure 14 summarises the main findings to question 4 (94 replies).

Figure 14: An overview of the main suggestions received to question 4 of the public consultation

http://www.celma.org/archives/temp/CELMA_TF_Apples_Pears(KR)009_CELMA_Guide_quality_criteria_LED_ luminaires_performance_Sept2011_FINAL.pdf

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Question 5 of the Public Consultation [Raising Awareness]: What can be done to raise awareness of consumers and professional users to SSL technologies and which specific measures and incentives would you propose for accelerating SSL uptake?
Responses to Question 5
Ci tizen Ci ty / Muni ci pa l i ty / Loca l publ i c a uthori ty La rge bus i nes s Profes s i ona l a s s oci a ti on / NPO Regi ona l / Na ti ona l publ i c a uthori ty Res ea rch orga ni s a ti on Sma l l or medi um-s i zed bus i nes s Uni vers i ty / Hi gher educa ti on Other Not a ns wered Total Number of responses 8 3 17 23 2 3 24 4 9 32 93 % of those answering 8% 3% 18% 24% 2% 3% 25% 4% 9% % of Total 26% 74%

Figure 15: Responses received to question 5 of the public consultation

The lack of sufficient awareness on the benefits and future potential of SSL lamps and luminaries is recognised by all the respondents to this question. In particular the following issues are pointed out to improve awareness of consumers and professional users: [27%] More and better information on cost/performance benefit in order to help consumers and professionals to choose; [25%] Better understanding and education concerning SSL lighting for consumers. This refers to education in schools, universities and technical colleges as well as general education open to citizens; [15%] Call for Industry and market actors to cooperate with research and academic institutions to ensure that high-quality educational information is reaching consumers; [13%] General education and increase of knowledge with the consumers cannot be achieved without independently validated and generally quality-checked data about SSL products. This also includes the issue of potential health risks, which should be part of the information made available to consumers. Figure 16 below summarises the main suggestions received to question 5. The following specific actions are proposed that could support better awareness creation: [16%] Specific awareness campaigns at national and EU level; [15%] Incentives and subsidies both for consumers and industries [10%] Promoting best practice demonstration projects; [10%] Dedicated web sites and other new or conventional media offering educational information;

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 [8%] Create an EU quality label; [6%] Promote SSL in public buildings and offices through green procurement as visibility is key for raising awareness. Figure 17 below provides an overview of the specific actions proposed by the respondents for accelerating the SSL uptake.

Figure 16: An overview of the main suggestions received to question 5 of the public consultation

Figure 17: An overview of the specific actions suggested by the respondents to question 5 of the public consultation

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3.2

Key messages received to the questions concerning SSL uptake in buildings Question 6 of the public consultation [Landlord-tenant Conflict]: What could be done to overcome the landlord-tenant conflict?

Responses to Question 6
Ci tizen Ci ty / Muni ci pa l i ty / Loca l publ i c a uthori ty La rge bus i nes s Profes s i ona l a s s oci a ti on / NPO Regi ona l / Na ti ona l publ i c a uthori ty Res ea rch orga ni s a ti on Sma l l or medi um-s i zed bus i nes s Uni vers i ty / Hi gher educa ti on Other Not a ns wered Total

Number of responses 9 1 15 19 2 2 22 3 5 47 78

% of those answering 9% 1% 16% 20% 2% 2% 23% 3% 5% % of Total 38% 62%

Figure 18: Responses received to question 6 of the public consultation

The landlord-tenant conflict is not considered to be a major issue for the average respondents since almost 40% of them did not answer this question. Among the ones who replied, a large group supports the ideas of the CELMA/ELC Position Paper (see Annex 2.2). This conflict is generally perceived to be of different nature between respondents coming from different Member States. Also, it differs according to the type of ownership structure, be it in residential or nonresidential buildings. The main measures proposed by the respondents to address this conflict are: [27%] Create new opportunities for lease or elaborate new savings/leasing models with EC support; [23%] Fix the energy cost for tenants and allow the investing landlords to receive paybacks; [12%] Reward tenants aiming to realize energy saving works using the SSL technologies and incentives for tenants to buy SSL lamps/luminaires; [12%] Examine how the conflict is addressed in different EU member states in order to identify best-case examples and promote those best-cases in order to create awareness how the conflict can be overcome; [9%] Introduce LED interoperability and compatibility with the installed base of existing electrical installations in order to reduce the needed investment and operating costs (since there will be no need to change mechanical or electronic switch or luminaires decreasing the initial upfront investment costs and lessening the scope of this problem). Figure 19 below summarises the main replies received to question 6 (78 replies).

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Figure 19: An overview of the main suggestions received to question 6 of the public consultation

Question 7 of the public consultation [Additional Measures in Buildings]: Which additional measures to the ones listed in the Green Paper could help accelerate SSL deployment in buildings?
Responses to Question 7
Ci tizen Ci ty / Muni ci pa l i ty / Loca l publ i c a uthori ty La rge bus i nes s Profes s i ona l a s s oci a ti on / NPO Regi ona l / Na ti ona l publ i c a uthori ty Res ea rch orga ni s a ti on Sma l l or medi um-s i zed bus i nes s Uni vers i ty / Hi gher educa ti on Other Not a ns wered Total Number of responses 7 2 16 15 2 4 21 1 6 51 74 % of those answering 7% 2% 17% 16% 2% 4% 22% 1% 6% % of Total 41% 59%

Figure 20: Responses received to question 7 of the public consultation

It is generally acknowledged by the respondents that SSL can make an important contribution to reducing the overall energy consumption of buildings. There are various suggestions on how to accelerate SSL deployment in buildings. They are all based on the precondition of availability of high quality SSL products. The main measures suggested are as follows: [23%] Strengthen and promote the use of intelligent lighting system solutions (systems equipped with dimming, daylight and occupancy detection). Promoting such systems implies that the whole value-chain for lighting related design, decision-making, selection of products and installation needs to be strengthened;

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 [14%] Provide subsidies and financial incentives or tax breaks for those purchasing and using SSL and lighting controls; [8%] Introduce the deployment of intelligent digital lighting systems (SSL and controls) as an integral part of an Energy Performance of Buildings Directive (EPBD). Other suggestions proposed by a small number of respondents (less than 5%) include: more awareness raising measures, for example specific approaches for caretakers and / or facility managers; public authorities should act as role models (become first users and provide the good example); push the deployment of low power grids within buildings and develop incentives to refurbish. Figure 21 below summarises the main replies received to question 7 (74 replies).

Figure 21: An overview of the main suggestions received to question 7 of the public consultation

3.2

Key messages received to the questions concerning the European Lighting Industry

Question 8 of the public consultation [Support of Research and Innovation]: What measures, beyond the ones listed in the Green Paper, could further support research and innovation and the reinforcement of the SSL value chain in Europe?

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Responses to Question 8
Ci tizen Ci ty / Muni ci pa l i ty / Loca l publ i c a uthori ty La rge bus i nes s Profes s i ona l a s s oci a ti on / NPO Regi ona l / Na ti ona l publ i c a uthori ty Res ea rch orga ni s a ti on Sma l l or medi um-s i zed bus i nes s Uni vers i ty / Hi gher educa ti on Other Not a ns wered Total

Number of responses 6 0 16 18 1 4 22 3 6 49 76

% of those answering 6% 0% 17% 19% 1% 4% 23% 3% 6% % of Total 39% 61%

Figure 22: Responses received to question 8 of the public consultation

Suggestions for research directions include support of strategic R&D to allow the European lighting industry to take the lead in high quality, intelligent and innovative lighting products. In particular, suggestions call for: [25%] Better coordination and priority setting of scattered initiatives between market actors and research organisations; [24%] Benchmarking of EU initiatives on SSL against corresponding initiatives in other regions of the world; [19%] Elaborate a coherent EU vision and roadmap and a cross-Directorates General approach; [15%] Develop prominent best practice examples; [14%] Support R&D beyond general illumination. For example, R&D should also target the effects on health, well being, productivity and concentration; [8%] Enable a strong collaboration of research, universities, industry, applied science and engineering including all players such as component manufacturers, software engineers, biological and psychological experts, architects and designers; [6%] Support the development of OLEDs and the integration of lighting into design objects; [3%] Include and strengthen the role of SMEs in relevant research programs. Many of the above suggestions seem to be similar to those proposed by CELMA/ELC in their position paper (see Annex 2.2). Figure 23 below summarises the main replies received to question 8 (76 replies).

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Figure 23: An overview of the main suggestions received to question 8 of the public consultation

Question 9 of the public consultation [Reinforcing Manufacturing Capabilities in Europe]: What other actions beyond the ones listed in the Green Paper, could be taken by industry to reinforce sustainable SSL manufacturing capacity in Europe?
Responses to Question 9
Ci tizen Ci ty / Muni ci pa l i ty / Loca l publ i c a uthori ty La rge bus i nes s Profes s i ona l a s s oci a ti on / NPO Regi ona l / Na ti ona l publ i c a uthori ty Res ea rch orga ni s a ti on Sma l l or medi um-s i zed bus i nes s Uni vers i ty / Hi gher educa ti on Other Not a ns wered Total Number of responses 6 0 13 14 1 5 17 3 2 64 61 % of those answering 6% 0% 14% 15% 1% 5% 18% 3% 2% % of Total 51% 49%

Figure 24: Responses received to question 9 of the public consultation

The issue of reinforcing sustainable SSL manufacturing capacity in Europe is addressed by less than 50% of the respondents, who are mainly large businesses, SMEs and professional associations. In particular, the European lighting industry, represented by CELMA/ELC and national industrial associations, takes the stand that 95% of the value will be created in lighting solutions and only 5 % in light sources, i.e. the direct manufacturing of hardware (LED chips) will only represent a minor share of the market of the lighting sector. Respondents propose a large range of actions that could be taken by industry to reinforce sustainable SSL manufacturing capacity in Europe:
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 [27%] properly adjust political framework conditions: this is considered to be the decisive parameter to enable sustainable production of SSL in Europe on all levels; [13%] Job creation through innovative design of LED based luminaires; [13%] Provide specific support to OLED manufacturing; [10 %] Develop smart, intelligent, innovative lighting system solutions and cater for fashion needs through innovative design of LED luminaires; [10%] take action to counteract the fact that SSL markets are strongly subsidised in other parts of the world, e.g., measures for protecting qualified jobs in Europe; more automation to reduce labour cost; create import taxes; make standards to guarantee a good quality of the products and make these standards mandatory by directives; [5%] set up dedicated RDI programs supporting the involvement and participation of SMEs, the development of next-generation intelligent digital solutions, financial support for pilot production lines and new business models that would help increase the output and yield to gain a competitive advantage and create an entire European based SSL production value-chain from chip to lighting systems. Additional suggestions were received mainly by citizens and research organizations (less than 5% of the replies) and point to: Stress the label "100% made in Europe"; Motivate investment from a social and environmental sustainable perspective (creating sustainable jobs in Europe, with recycling as an integral element which is beneficial to Europe); Help establish strong IP cross-licensing between European companies; Make capital investment in European manufacturing rather than importing and marketing as European. Figure 25 below summarises the main replies received to question 9 (61 replies).

Figure 25: An overview of the main suggestions received to question 9 of the public consultation

Question 10 of the public consultation

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[Reinforcing Cooperation along the Value Chain]: What additional actions beyond the ones listed in the Green Paper can reinforce cooperation along the value chain, in particular with architects and lighting designers, electrical installers and with the construction and building industry? What should be the role of the Member States and the EU in making it happen?
Responses to Question 10
Ci tizen Ci ty / Muni ci pa l i ty / Loca l publ i c a uthori ty La rge bus i nes s Profes s i ona l a s s oci a ti on / NPO Regi ona l / Na ti ona l publ i c a uthori ty Res ea rch orga ni s a ti on Sma l l or medi um-s i zed bus i nes s Uni vers i ty / Hi gher educa ti on Other Not a ns wered Total Number of responses 8 0 16 16 2 3 23 2 7 48 77 % of those answering 8% 0% 17% 17% 2% 3% 24% 2% 7% % of Total 38% 62%

Figure 26: Responses received to question 10 of the public consultation

There is strong agreement that supporting the whole value chain of SSL lighting will be beneficial to Europe, creating and securing good jobs, enabling efficient lighting solutions and improving the competitive position of the European industry at a global level. However, some respondents fear that a transition from pure lamp selling to offering more complex and modern services to supply intelligent lighting system solutions will leave out the vast majority of SMEs. Involving and strengthening the participation of SMEs in this general business transition is therefore seen as paramount. Further reinforcement of cooperation along the value chain is suggested via: [29%] Ensuring good vocational training and education of all value chain actors; [23%] Establishing and promoting SSL product quality standards and securing compliance with standards along the value chain. Other suggestions proposed by a small number of respondents (less than 5%) include: Facilitating a better cooperation and information exchange between value chain actors also by implementing and enforcing green procurement schemes; Develop and support inter-clustering activities at the European level; Organising information and awareness campaigns, also directed to SMEs, to ensure market actors understand the business opportunities and developments of SSL; Speed up the adaptation of intelligent SSL solutions in public buildings. Those stakeholders representing consumers or associations of astronomers who are concerned with potential health effects also call for a broader, more detailed information policy concerning this issue. Figure 27 below summarises the main replies received to question 10 (77 replies).

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Figure 27: An overview of the main suggestions received to question 10 of the public consultation

Question 11 of the public consultation: [Hampering Gaps in Standardisation]: Are there gaps in standardisation today which hamper SSL innovation and deployment? If yes, where are such gaps and how can they be addressed?
Responses to Question 11
Ci tizen Ci ty / Muni ci pa l i ty / Loca l publ i c a uthori ty La rge bus i nes s Profes s i ona l a s s oci a ti on / NPO Regi ona l / Na ti ona l publ i c a uthori ty Res ea rch orga ni s a ti on Sma l l or medi um-s i zed bus i nes s Uni vers i ty / Hi gher educa ti on Other Not a ns wered Total Number of responses 6 0 18 20 1 3 21 3 9 44 81 % of those answering 6% 0% 19% 21% 1% 3% 22% 3% 9% % of Total 35% 65%

Figure 28: Responses received to question 11 of the public consultation

There is a strong agreement from respondents that enhanced standards are of key importance. The representatives of the lighting industry and related businesses make a detailed description of six gaps which are not covered in current standards. These are related to: Lifetime of LED luminaires; Acceptable colour shift and power consumption over lifetime; Enhanced quality of metric definitions; Flicker and stroboscopic effects; Non-visual effects on humans; Chromaticity coordinates. A more detailed list is given in the CELMA/ELC Position Paper.

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Some stakeholders mention also gaps related to: Compatibility with existing electronic systems especially dimmers and switches; minimum information in the packaging; internationally harmonized testing standards addressing LED performance; and, minimum quality of the light. The respondents welcome the ongoing draft standardization mandate on SSL from the European Commission to CEN & CENELEC as it will address the main gaps not covered in current standards. Those stakeholders professionally related to the lighting industry also call the European Commission to increase its involvement in running global programmes by the International Electro-technical Commission (IEC), the Commission on Illumination (CIE) and the industry-wide cooperation aimed at the development of standard specifications for the interfaces of LED light engines (Zhaga). Those stakeholders representing amateur radio operators concerned with the electromagnetic compatibility (EMC) of SSL underline that some low voltage LED devices are not properly checked for EMC, because they do not fall under the relevant European standard. Those stakeholders from consumer and astronomer associations concerned with potential health risks stress that light could potentially influence public health negatively. They call to establish a multidisciplinary committee working on this issue and developing biological safety standards that refer to LED influence on, amongst others, sleep, diurnal rhythm, concentration, production of vitamin D and visual comfort. A suggestion here is to strengthen and perhaps broaden the SCENIHR mandate and make the results more transparent. Figure 29 below summarises the main replies received to question 11 (81 replies).

Figure 29: An overview of the main suggestions received to question 11 of the public consultation

Question 12 of the public consultation [Support of Education, Vocational and Lifelong Learning]: Which actions should Member States and industry take to support education, vocational and lifelong learning and training on SSL and to address the adaption of educational curricula to include the latest lighting technologies?

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Responses to Question 12
Ci tizen Ci ty / Muni ci pa l i ty / Loca l publ i c a uthori ty La rge bus i nes s Profes s i ona l a s s oci a ti on / NPO Regi ona l / Na ti ona l publ i c a uthori ty Res ea rch orga ni s a ti on Sma l l or medi um-s i zed bus i nes s Uni vers i ty / Hi gher educa ti on Other Not a ns wered Total

Number of responses 9 0 16 15 1 4 23 2 7 48 77

% of those answering 9% 0% 17% 16% 1% 4% 24% 2% 7% % of Total 38% 62%

Figure 30: Responses received to question 12 of the public consultation

Education and information are seen as key to increasing overall awareness of the consumers. Part of the problem is considered to be based on a general lack of knowledge on the fundamental physics of modern lighting systems, as well as the general potential effect on humans. Therefore, stakeholders call for an education on lighting throughout all educational stages beginning at school and carrying on to colleges and universities. Current vocational and lifelong learning and training schemes are not seen to be sufficient to meet the demand of the future SSL markets. There is a shortage of highly qualified workers and especially industry representatives are keen to indicate that this problem will increase in the future. Suggestions provided to address the problem are the following: [30%] Starting educational campaigns with schools and universities on bringing the topic into the curricula; [17%] Support and work on lighting design to become more attractive and a socially recognised profession; [14%] Attract talents outside Europe to Europe, limit barriers towards the labour market. A very small number of respondents (less than 5%) also provided the following inputs: Elaborate good demonstration materials for professionals and teachers and support hands-on experiences and competition schemes amongst students; Develop "train the trainer" concepts in cooperation with industry; Set up accreditation schemes, incentives for trainings, and training cheques; Facilitate knowledge transfer between SMEs and research; and, possibly, start up an independent light academy. Again, those stakeholders representing consumer and astronomer associations concerned by potential health risks and adverse consequences of light underline that education should also include overall effects that light might have on the well-being of people. Figure 31 below summarises the main replies received to question 12 (77 replies).

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Figure 31: An overview of the main suggestions received to question 12 of the public consultation

4.

CONCLUSIONS

The majority of the respondents consider the challenges reported in the Green Paper as being correct. They support the measures presented and do not come up with any fundamentally new approach or issue. The Green Paper states many ongoing and existing policies that relate to general lighting. The overall impression it creates is that the picture might seem fragmented and that the EU policy in lighting seems to lack coherence. Stakeholders strongly support the Green Paper because they see it as a means to end this perceived coherence gap. From the replies received, the major concerns are poor SSL product quality, lack of information for the citizens and high initial cost of purchase. These aspects have a strong horizontal perspective and it seems to be essential to address them to enable a large deployment of SSL in the European markets. To address the main concern of perceived poor SSL product quality standards need to be established, promoted and compliance secured with standards along the value chain. Furthermore, market surveillance operations need to be reinforced and be supported by independent testing laboratories using harmonised testing procedures and providing unbiased information to the consumers. Information for the consumers in all forms is equally important. Consumers need to be educated, market actors trained and high quality information on all application options and possibilities needs to be available to all. SSL advantages and disadvantages, best practice, pilot actions, research results and intelligent solutions need to be communicated at European level. The high initial purchase cost is another main concern both for consumers and for the professional sector. There is a call for economic stimuli for facilitating the market introduction of LED-based innovative technologies such as subsidies, incentive schemes or tax benefits for cities

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and local authorities. Recourse to new financing models (such as ESCOs) can be made for reducing the lifecycle cost of lighting in Green Public Procurement schemes. Governments can help users by subsidy schemes or tax benefits, but this should always be based on an objective assessment of the true energy-saving potential of the SSL products. More policy coherence, securing and maintaining high quality of SSL and triggering a broad landscape of high-level information will be the most important aspects of ensuring that SSL will contribute successfully to the overall European objectives for 2020.

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ANNEX 1: LIST OF QUESTIONS IN THE PUBLIC CONSULTATION (1) (2) (3) (4) (5) How would you propose to overcome the challenges outlined above for the wider market penetration of SSL technologies in Europe? Which additional challenges do you see for a wider SSL market penetration in Europe and which solutions would you propose to resolve them? What can Member States do to reinforce market surveillance of product performance and safety in the area of SSL lighting products? What could the lighting industry do to ensure the performance of SSL products? What can be done to raise awareness of consumers and professional users to SSL technologies and which specific measures and incentives would you propose for accelerating SSL uptake? What could be done to overcome the landlord-tenant conflict? Which additional measures could help accelerate SSL deployment in buildings? What measures, beyond the ones above, could further support research and innovation and the reinforcement of the SSL value chain in Europe? Which other actions could be taken by industry to reinforce sustainable SSL manufacturing capacity in Europe? Which additional actions can reinforce cooperation along the value chain, in particular with architects and lighting designers, electrical installers and with the construction and building industry? What should be the role of the Member States and the EU in making it happen? Are there gaps in standardisation today which hamper SSL innovation and deployment? If yes, where are such gaps and how can they be addressed? Which actions should Member States and industry take to support education, vocational and lifelong learning and training on SSL and to address the adaptation of educational curricula to include the latest lighting technologies?

(6) (7) (8) (9) (10)

(11) (12)

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ANNEX 2: EXAMPLES OF POSITION PAPERS RECEIVED IN THE PUBLIC CONSULTATION Annex 2.1 Positions of National Parliaments and Regions The following authorities submitted written position papers: The Senate of the Parliament of the Czech Republic The Senate of the Parliament of the Czech Republic welcomes the initiative of the Green Paper. It considers that the high purchase prices, the influx of low quality SSL products and the lack of information and awareness are the major obstacles for the acceptance of SSL by the consumers. The Senate calls for the creation of a unified EU platform for information exchange; the creation of a reference authority which would provide unbiased information to the consumers; intensifying SSL RDI activities in Europe; and, the establishment of national certification laboratories under the umbrella of a European authority. The Department for Environment, Food and Rural Affairs (DEFRA) of the Government of the United Kingdom DEFRA welcomes the Green Paper on behalf of the UK Government. DEFRA sees it important that governments work together with industry, consumer groups and other interested parties to overcome barriers to the wider deployment of SSL in Europe. New SSL products increase consumers' choice. Moreover, SSL offers customised solutions to specific user requirements. DEFRA welcomes the intentions of the EC to continue to monitor potential health risks of SSL. The UK Government participates in the IEA 4E7 SSL Annex and encourages the EC to engage too, as the Annex is working to provide better information to Governments and consumers. The Economic Affairs Committee of the Swedish Parliament The Committee welcomes the Green Paper and emphasises the importance of energy efficient lighting solutions towards achieving the general European energy efficiency targets by 2020. It sees most measures highlighted in the Green Paper as being urgent, whilst at the same time stressing that an over-regulation at EU level should be avoided. Finally, the Committee calls for the further monitoring of possible effects of SSL lighting on human health. The Climate, Energy and Building Committee and the European Committee of the Danish Parliament The Committees of the Danish Parliament welcome the Green Paper and give specific answers to all the 12 questions posed by the European Commission. The issue of SSL product quality is seen to be of great importance and the allocation of sufficient resources of all EU Member States to establish effective market surveillance is underlined as well as the need for a functioning internal market at EU level for green products, technologies and services. The Committees stress that the Commission should also consider the Member States' costs of implementation of such control measures when it lays down regulations. The Directorate for General Environment and Protection of the Soil and Coasts of the Region Emilia-Romagna

International Energy Agency Efficient Electrical End-Use Equipment.

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The Region of Emilia Romagna fully supports the aim and goals of the Green Paper. The Region has already put in place regional policies which concern especially the reduction of energy consumption and of light pollution. The Region considers the promotion of innovative lighting solutions as crucial for environmental protection. At the same time it calls the Commission to further analyse the potential biological hazards of LED on human health and the increase of light pollution by launching relevant studies evaluating these issues. Annex 2.2 Position papers of associations The CELMA / ELC Position Paper Together with their reply to the public consultation, CELMA/ELC published a position paper on their own web site (see below). About 30 respondents to the public consultation, mostly national industrial lighting associations, seem to reflect the same or similar positions to the ones published by ELC/CELMA. About 55 more stakeholders seem to partially or fully agree with the positions of CELMA / ELC. The CELMA/ELC position paper can be found at: http://www.celma.org/archives/temp/CELMA-ELC_LED_WG(SM)064A_Final_ELCCELMA_response_Consultation_EU_Green_Paper_Lighting_the_Future_02022012.pdf IGNES IGNES (Industries de Gnie Numrique, Energtique et Scuritaire is a French industry association representing 60 companies in security lighting and electronics with more than 15,000 direct employees. IGNES agrees with the main challenges identified in the SSL Green paper. Additional challenges to address include: interoperability and compatibility of SSL products with electronic switches and lighting systems; lack of coordination of existing programmes and of cross regional benchmarking; scarcity of raw materials and lack of good substitutes. Member States have to improve market surveillance if they want to guarantee a level playing field for the European Industry. As for the IGNES replies to the other questions of the public consultation, these are very much in line with those already reported in the main part of this document. The full position paper of IGNES can be found in the separate attachment to this report providing the names and inputs / position papers received from the public consultation. The CieloBuio Position Paper CieloBuio is a non-profit Italian organisation whose goal is the protection of the night sky. The position paper submitted by the organisation represents a quite detailed summary of concerns against SSL potential negative effects on human health and about light pollution in general. The positions expressed are shared by around 21 more respondents to the public consultation. The Position Paper comes with a reference list of 38 studies or research publications indicating health risks of artificial light. The full position paper of CieloBuio is found in the separate attachment to this report providing the names and inputs / position papers received from the public consultation. Working Group Dark Sky of the Association of Amateur Astronomers The comments received by the Working Group Dark Sky of the Association of Amateur Astronomers support the more detailed Position Paper of the CieloBuio Association. In their paper, the working group requests the inclusion of regulations to limit the content of blue light, the amount of artificial light wasted (notably towards the sky) and the total amount of artificial light. The full position paper can be found in the separate attachment to this report providing the names and inputs / position papers received from the public consultation.

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