Attorney General Becerra Calls on Trump Administration to Preserve Cost-Saving Energy Efficiency Standards

SACRAMENTO – California Attorney General Xavier Becerra and New York Attorney General Letitia James today, leading a coalition of 15 attorneys general and the City of New York, filed comments urging the Department of Energy (DOE) to maintain stricter energy conservation standards for incandescent reflector lamps (IRLs) as statutorily required by Congress. IRLs are cone-shaped bulbs used in flood, recessed and canned lighting. Under the Energy Policy Conservation Act, Congress imposed a minimum efficiency standard for general service lamps in the event that DOE failed to complete a final rule setting standards by January 1, 2020. As DOE did not meet this deadline, all general service lamps, including IRLs, must meet a 45 lumens per watt standard. In the comment letter, the multistate coalition argues that refusing to acknowledge this baseline standard would violate the Energy Policy Conservation Act.

“The Trump Administration continues to push regressive 20th Century plans that are bad for our economy and bad for our environment,” said Attorney General Becerra. “As consumers struggle to pay their electricity bills during this economic crisis, the last thing they need is the federal government unlawfully blocking standards that make lightbulbs cheaper to run. The Trump Administration should focus its energy on solving our current problems, not creating new ones.”

DOE’s long-standing energy efficiency program has resulted in substantial economic and environmental benefits, with more than $2 trillion in projected consumer savings and 2.6 billion tons of avoided carbon dioxide emissions. Efficiency standards for light bulbs alone are expected to cumulatively save 1.5 trillion kilowatt hours of energy and reduce carbon dioxide emissions by 700 million tons, which is equivalent to taking nearly 150 million cars off the road for a year or meeting the electricity needs of every American household for one year. A DOE-funded analysis estimated that by the year 2030, applying the minimum efficiency standard for “general service lamps” to IRLs would result in up to $97 billion in energy savings and 240 million tons of avoided carbon dioxide emissions.

In 2017, DOE issued final rules expanding the definition of “general service lamps” to include seven previously exempt light bulbs, including IRLs. By including those types of light bulbs as general service lamps, the 2017 definitions subject IRLs to the congressionally-imposed minimum standard of 45 lumens per watt. But on September 5, 2019, DOE issued a final rule narrowing the definition, effectively rolling back energy efficiency standards for certain lightbulbs. In November 2019, Attorneys General Becerra and James, leading a coalition of 16 attorneys general and the City of New York, filed a lawsuit challenging the rule as a violation of the Energy Policy Conservation Act. Litigation in that case is ongoing. 

In today’s comment letter, the coalition argues that enacting a proposed standard for IRLs weaker than 45 lumens per watt would violate the Energy Policy Conservation Act. The coalition urges DOE to abide by the 2017 rules defining these cone-shaped light bulbs as general service lamps, arguing that any review of these lightbulbs based on DOE’s erroneous 2019 rule would be unlawful and without effect. 

Attorneys General Becerra and James are joined by the attorneys general of Colorado, Connecticut, Illinois, Maine, Maryland, Massachusetts, Michigan, Minnesota, Nevada, New Jersey, Oregon, Vermont, Washington, and the District of Columbia, as well as the City of New York, in filing the comment letter. 

A copy of the comment letter can be found here.