Dubrovnik Summer Festival has joined the campaign to stop the changing of the EU regulation that would ban the use of Tungsten light sources even in cultural institutions and organizations. Theatre lighting has, until now, had an exemption from this ban thanks to the so-called 'entertainment clause' from 2013. We believe that the change of this regulation - if accepted - would be disastrous for both Croatian and European culture.
Petition letter is taken from the teatar.hr site, stated as follows:
Att: Mrs Nina Obuljen Koržinek, Minister of Culture of Republic of Croatia,
Mrs Biljana Borzan, Representative in the European Parliament
Mr Ivan Jakovčić, Representative in the European Parliament
Mrs Ivana Maletić, Representative in the European Parliament
Mrs Marijana Petir, Representative in the European Parliament
Mr Tonino Picula, Representative in the European Parliament
Mr Jozo Radoš, Representative in the European Parliament
Mrs Dubravka Šuica, Representative in the European Parliament
Mr Ivica Tolić, Representative in the European Parliament
Mrs Ruža Tomašić, Representative in the European Parliament
Mrs Željana Zovko, Representative in the European Parliament
Re: Tungsten lighting ban in EU
Dear Minister of Culture and Croatian representatives in the European Parliament,
The European Commission has begun the process of changing the regulation (EC) NO 244/2009, (EC) 245/2009 and (EU) NO 1194/2012 on the ecodesign requirements and (EU) NO 874/2012 on conditions of the energy marking of lighting products, which – if accepted – would be disastrous for both Croatian and European culture.
Namely, according to the proposed changes of the Regulation, from September 2020 the circulation and usage of lights with filament (the so-called tungsten lighting) would be banned in the European Union, even in cultural institutions and organisations which have so far been exempted from it according to the so-called Entertainment clause from 2013.
Such ban would mean that all Croatian theatres, and many other cultural institutions and organisations, and companies dealing with the theatre, TV and film lighting, would have to provide completely new lighting equipment, and discard the existing one by September 2020. The currently used lights with filament would have to be replaced with LED lights.
For instance, over the past ten years the Dubrovnik Summer Festival spent 1,3 million kunas on the tungsten lighting equipment. In case of the ban of tungsten lights production, the Dubrovnik Summer Festival would have to spend around 5,6 million kunas for the basic part of the LED technology equipment which would replace its current lighting equipment (without increasing the number of lights). In view of the fact that the Festival organises open air events, it needs at least the IP64 rating outdoor equipment, which is 30% more expensive than the „regular“ (indoor) equipment. Thus, the Dubrovnik Summer Festival would actually have to spend around 7,3 million kunas (VAT not included!) for new lighting equipment and new stands that enable operation of lighting systems over 2 DMX universe, and scrap the existing lighting equipment.
Please note that this estimation of costs does not include protection boxes (LED devices require fragile shipment), education of technicians who would operate the new equipment, and the entire required DMX and ARTnet infrastructure (cables, splitters, signal amplifiers, routers, wireless modules, etc.).
Repertory theatres would have much higher expenses because, apart from the purchase of new equipment, they would have to pay construction costs for the laying of new installations, the costs of additional engagement of lighting designers for each of their shows who would have to adapt their previous authorial works to new technology, and last but not least, the cost of education of the entire lighting equipment personnel.
Deni Šesnić, Head of the Zagreb Academy of Dramatic Art's Set Design Department estimates that only the purchase of new lights (without accessory equipment, construction works, education, etc.) could cost the Croatian culture tens of millions of euros, while the majority of smaller institutions – such as culture centres and houses – and independent producers could simply not bear such infrastructure investments. For the sake of comparison, the Ministry of Culture has secured 23.701.578,50 kunas, or approximately 3,1 million euros, from the budget for the programmes of all professional theatres in Croatia!
In addition to all aforementioned harmful financial and organisational consequences of possible passing of this ban, equally important are professional consequences. Namely, various light sources - such as tungsten light bulb, fluorescent light bulb, LED light bulb – differ in their visual characteristics, particularly in the way they reproduce colours: the colour of sets, the colour of costumes, the colour of human face. In this respect, tungsten light bulbs are still unparalleled, while LED light bulbs still cannot replace them despite all the advances in technology.
The legislator explains the forthcoming ban with his wish to make it easier for the Commission to implement the Regulation failing to bear in mind specific features of different cultural institutions, and with his wish to reduce electricity consumption and other harmful influences on the environment. However, according to professional evaluations, for instance in theatres, less than 10% of total electricity consumption in individual institutions goes to stage lighting, and the European Commission has been informed accordingly several times by the International Association of Lighting Designers (IALD).
You are therefore kindly asked to do everything in your power to prevent the passing of this ban, which would irretrievably jeopardise Croatian culture.
Deni Šesnić, Associate Art Professor at Zagreb Academy of Dramatic Art's Set Design Department
Boris Popović, Full Art Professor at Zagreb Academy of Dramatic Art
Dinka Jeričević, Set Designer and Full Art Professor at Zagreb Academy of Dramatic Art
Miljenko Bengez, Lighting Designer
Aleksandar Čavlek, Lighting Designer
Elvis Butković, Mag.Art., Lighting Designer
Saša Fistrić, Lighting Designer
Marino Frankola, Mag Art., Mag. Pol., Lighting Designer
Bojan Gagić, mutimedia artist
Vesna Kolarec, Mag. Art., Lighting Designer
Zoran Mihanović, Lighting Designer
Marko Mijatović, Mag. Art., Lighting and Video Designer, Dubrovnik Summer Festival
Aleksandar Mondecar, Set Lighting Designer
Davor Punda, Acting Technical Director, Croatian National Theatre of Split
Zdravko Stolnik, Set Lighting Designer
Ivana Medo Bogdanović, Dubrovnik Summer Festival Executive Director
Goran Golovko, Croatian National Theatre of Split Director
Jasna Jakovljević, Croatian National Theatre of Varaždin Director
Snježana Abramović Milković, Zagreb Youth Theatre Director
Boris Svrtan, Gavella Dramatic Theatre Director
Višnja Babić, Trešnja Theatre Director
Drago Utješanović, Žar Ptica Theatre Director
Nataša Rajković, Zagreb Student Centre Director's Cultural Assistant
Zvonimir Dobrović, Queer Zagreb / Perforations Festival Artistic Director
Petra Glad, Zagreb Dance Ensemble Director
Emina Višnić, RIJEKA 2020 d.o.o. Director
Franka Perković Gamulin, Associate Art Professor and Dean of Zagreb Academy of Dramatic Art
Snježana Banović, Full Art Professor, Dr.Sc., Zagreb Academy of Dramatic Art's Production Department
Ivana Bakal, Predsident of Croatian Society of Fine Art Artists
Perica Martinović, President of Croatian Society of Dramatic Artists
Hrvoje Hribar, Upravni odbor FERA Board of Directors (Federation of European Film Directors)
Neda Terešak, MTTN d.o.o. Procurator
Dražen Goreta, Culture Factory
Nora Krstulović, Director, Editor of Teatar.hr Portal
 Official estimation of the Dubrovnik Summer Festival’s Technical Department
 «Simplify the ecodesign regulations for lighting products by integrating the three existing Regulations into one and unifying the way in which requirements are set. This is expected to reduce the administrative burden for the Commission and for industry and to facilitate market surveillance.» Explanatory Memorandum - EG - review lighting 20171110.doc, p. 3.