What do electric utilities across America, low-income consumer groups, national and local environmental organizations, 24 governors from both Republican and Democratic states, 17 state attorneys general, almost 18,000 individual letter-writers, and the American Chemical Society have in common?
They all sent in letters urging the U.S. Department of Energy (DOE) to abandon a reckless proposal to roll back federal light bulb energy efficiency standards. Their comments were unanimous in their support for the common-sense lighting standards that will save consumers and businesses $12 billion in 2025 and avoid the need to generate 25 large power plants’ worth of electricity.
The DOE is considering whether to remove the bulbs that go into 2.7 billion sockets (almost half of all U.S. household sockets) from the efficiency standards going into effect on Jan. 1, 2020. If the DOE goes forward with this proposal despite all the opposition comments, inefficient 3-way bulbs, reflector bulbs used in recessed cans and track lighting, round globe bulbs, and candelabra bulbs commonly used in chandeliers would needlessly be exempted from the regulations.
If the DOE succeeds in rolling back the standards, the additional energy waste will not only hurt Americans’ budgets, the extra electricity generation will create more pollution that harms the environment and contributes to health problems like asthma. In fact, the additional pollution would equal the amount of annual tailpipe emissions from 7 million cars.
This proposed rollback is totally baseless, both legally and as a matter of policy as energy efficient LED light bulbs already exist for each of these types of bulbs. LED bulbs do everything incandescent bulbs were able to do except waste massive amounts of energy. Without efficiency standards, consumers can’t be guaranteed that each bulb they buy will be an efficient one.
As part of the rulemaking process, DOE asked for public comment by May 3. While not all of the comments may be publicly available online yet, we do know that almost 18,000 individual comment letters were received—many with more than one signer (more than 44,000 people signed a petition led by NRDC, for example). With the exception of some manufacturers who want to sell inefficient incandescent and halogen light bulbs indefinitely, and a few commenters who simply oppose regulations of any kind, the comments were almost entirely in support of the standards. Common themes included:
The rollback proposal is illegal
Congress laid out a clear process in the 2007 federal energy bill for the United States to transition to more energy efficient lighting. As required by law, DOE updated the definition for general service lamps (GSLs), the legal term for everyday light bulbs, in 2017 to include the bulbs DOE now wants to exempt from the 2020 standards. The attorneys general from more than a dozen states, as well as leading environmental groups like Earthjustice and NRDC submitted technical comments to the docket pointing out why DOE’s proposal to rescind the updated and expanded definition is unlawful and that lawsuits will likely follow if DOE does so. The key point being that Federal law prohibits DOE from weakening its energy efficiency standards.
Utilities broadly support the standards
Utilities from 42 states and the District of Columbia, serving a combined total of almost 55 million households and businesses, submitted a joint letter to DOE urging the agency to abandon its proposal to prevent the 2020 light bulb standards from moving forward (See this blog from my colleague Ralph Cavanagh about this historic stand by utilities large and small for the public interest). Other utilities, including National Grid and Pacific Gas and Electric, submitted separate letters opposing the rollback, meaning that utilities serving almost half of America’s electricity customers are against it. These utilities have been planning for the guaranteed energy savings and reduced electricity demand the 2020 standards are due to provide. The electricity savings become even more valuable as utilities increasingly shift to solar and other renewable power, because more efficient light bulbs provide relief to the grid at night when most lights are switched on and the sun isn’t shining. As the utilities note, efficiency improvements reduce the amount of infrastructure they need to build, improve the reliability of supply, and lower customer costs.
All consumers benefit from the standards
An analysis from the Appliance Standards Awareness Project shows that each U.S. household will save $100 per year on their electric bill due to the expanded scope of the lighting standards that DOE wants to repeal. (To see the state-by-state breakdown, click here.) The Consumer Federation of America, which represents consumer groups from across the country, and the National Conservation Law Center that advocates for low-income consumers, voiced their strong support for the standards and included the results of new polling data showing that close to three-quarters of respondents support the light bulb efficiency standards and that 90 percent of those with LED light bulbs are satisfied with their performance. Meanwhile, the U.S. Climate Alliance—a bipartisan coalition of 24 governors representing 55 percent of the U.S. population and over 60 percent of the U.S. economy—expressed their opposition to the rollback and told DOE that it will hurt American consumers’ pocketbooks and health.
No date has been set for DOE to act on the proposal, but everyone has been planning for the standards to go into effect on Jan. 1. Let’s hope that this overwhelming outpouring of support for these common-sense lighting efficiency standards prompts DOE to do the right thing and move forward with the 2020 regulations that will phase out inefficient incandescent and halogen light bulbs. Otherwise, the United States is poised to become one of the last dumping grounds for inefficient bulbs. Europe banned inefficient light bulbs in 2018 and numerous other countries around the world are due to adopt similar policies.