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Sixteen States Oppose Energy Department’s Unlawful Rollback of Lightbulb Efficiency Standards

The Energy Department’s proposal “is contrary to law, undermines EPCA’s legislative intent, and would unconscionably increase greenhouse gas emissions and consumers’ energy costs.”

Withdrawing the definition rules would result in an annual emission increase of 34 million metric tons of carbon dioxide, and cost consumers 12 billion dollars in added energy costs by 2025.


May 3, 2019
Contact: Christopher Gray

Washington, D.C. — California Attorney General Xavier Becerra led a multi-state coalition of 16 state attorneys general in submitting a comment letter opposing a proposed rule by the Energy Department rolling back federal energy efficiency standards for a wide range of commonly-used lightbulbs. The proposed rule would apply to popular three-way bulbs, as well as lightbulbs commonly used in bathrooms, chandeliers, and recessed lighting fixtures. The attorneys general noted that an estimated 3 billion light sockets contain these types of bulbs, or nearly half of all lighting sockets in residential buildings across the United States.
“It’s not very bright to cut common-sense standards that save consumers money,” said Attorney General Becerra. “The Department of Energy must get back to its mission of ensuring America’s prosperity instead of protecting the profits of companies that prefer to pollute at the expense of American consumers and our environment. We urge DOE to withdraw this senseless proposal.”
Under the terms of the Energy Policy and Conservation Act of 1975, the Energy Department is obligated to set energy conservation standards for general service lamps and general service incandescent lamps, also known as everyday lightbulbs. In 2007, Congress amended the Act to include a statutory deadline for the Energy Department to evaluate potential revisions to its lightbulb efficiency standards, and to consider whether certain types of lightbulbs should remain exempt from those standards based on the way lightbulb definitions were applied to different types of products. In response, the Energy Department completed new “Definition Rules” that discontinued these exemptions in January 2017.
The Trump administration’s proposed rule would withdraw the Energy Department’s 2017 Definition Rules and reinstate previous lightbulb exemptions. In their comment letter the AGs noted that the Energy Department’s proposal violates the Energy Policy and Conservation Act’s anti-backsliding provision, and that the federal agency had exceeded its statutory authority under the Act in attempting to exempt certain lightbulb products from its energy efficiency standards. This violates the Administrative Procedure Act as an arbitrary and capricious action.
“The Trump administration’s approach to ‘de-regulation’ is not about making the government work better or about making our economy stronger — it’s about radically altering federal regulatory policy by placing cost-savings to industry over consumer savings, human health and the environment,” said David J. Hayes, Executive Director of the State Energy & Environmental Impact Center. “Lightbulb efficiency standards save consumers billions of dollars each year, and keep millions of metrics tons of dangerous climate pollution out of the atmosphere. Unfortunately, this administration has decided that it’s more important to save a dying technology than it is to meet its statutory obligations under the law, and state attorneys general are unwilling to abide by this.”
In addition to California, state attorneys general of New York, New Jersey, Oregon, Colorado, Connecticut, Illinois, Maine, Maryland, Massachusetts, Michigan, Minnesota, North Carolina, Vermont, Washington, and Washington, D.C. joined the multi-state coalition. The City of New York joined the states in signing on to the comment letter.

The State Energy & Environmental Impact Center is a non-partisan Center at the NYU School of Law that is dedicated to working with state attorneys general to protect and advance clean energy, climate change, and environmental values and protections. It was launched in August 2017 with support from Bloomberg Philanthropies. For more information, visit our website.