Keep stage lighting exempt from proposed legislation changes.

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We the undersigned strongly request that the EU Cultural and Energy directorates maintain the exemption afforded to all stage lighting equipment (EN 60598-2-17, "IEC 60598-2-17:2017) from legislations which would prohibit their manufacturing and sale.

The proposals in the Energy Directorate’s Eco-design Working Plan 2016-2019 pose an enormous threat to the way theatrical productions are presented. The impact of these proposals across Europe would be immediate, and overwhelming.

Tungsten light bulbs would rapidly become unavailable. This would mean that the majority of lighting fixtures in the majority of theatres - big theatres, small theatres, amateur theatres, colleges, schools, clubs, pubs, village halls - would immediately become obsolete. Fixtures that have given tireless service for years, sometimes for decades, with just a little regular maintenance and a new bulb every now and again would become yet more scrap metal and glass.

Replacing those lighting fixtures with new EU-approved sources would be expensive as it would mean buying an entirely new rig of EU-approved, efficient, LED lighting fixtures. It would actually be more costly still because it would likely involve replacing the building’s entire lighting infrastructure - dimmers, cabling and control consoles. For larger venues, this would be both hard to budget for and impossible to implement within the next two years. For smaller venues, it would be ruinous. They would, quite literally, go dark.

More troubling still: there are very few theatrical-quality LED lighting fixtures that come close to matching the beauty, subtlety, richness and poetry of tungsten light sources. The only option available would be much poorer quality lighting fixtures, and as a result a considerable degradation in the quality of production lighting and so in the quality of productions.

We are not against conserving the world’s precious resources. However stage lighting is not a big user of power: the lighting is only on for the relatively short duration of a performance and there are a relatively small number of performances per week; all of the lights in the rig are rarely, if ever, on at the same time, and because those lights that are on are rarely turned up to full. Several studies in recent years have shown that stage lighting typically accounts for less than 5% of a theatre’s total energy consumption.

We strongly request that specialist entertainment lighting equipment and light bulbs be exempt from these proposed regulations and from any future legislation which has the potential to directly impact the access to and availability of this equipment.



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