Sixteen Attorneys General Applaud Next Efficiency Step for Lightbulbs

New York, N.Y. — A coalition of 16 attorneys general led by New York Attorney General Letitia James filed comments yesterday in support of the Department of Energy’s (DOE) proposal to amend its definitions of general service lamps and general service incandescent lamps. Calling the changes “long overdue,” the coalition noted that if adopted, the changes “could save billions of dollars in energy costs and avoid millions of metric tons of greenhouse gas emissions annually.” The AGs urge DOE to finalize the action and issue a determination that the statute’s “backstop” efficiency standard applies to these bulbs.

“This action illuminates the energy savings potential of the energy efficiency program,” said Jessica Bell, Deputy Director of the State Energy & Environmental Impact Center. “It’s time to ensure that consumers and the environment benefit from more robust requirements for this common consumer product.”

“Our nation’s energy efficiency program is a critical component of any plan to combat climate change and protect our planet,” said California Attorney General Rob Bonta in a statement highlighting several sets of recent comments to DOE on efficiency standards. “Energy efficiency standards are a win-win, saving consumers and small businesses money on their electricity bills, while also helping save the planet. I support the Department of Energy’s efforts to reverse Trump-era regulations that undermined this program. There’s no time left to waste. We must get this program back on track.”

Background — In January 2017, the Department of Energy (DOE), pursuant to a congressional directive in the Energy Independence and Security Act, released two rules that broadened the definitions of general service lamps (GSL) and general service incandescent lamps (GSIL) to make a number of different lightbulb types more energy-efficient, and to gradually phase out less efficient ones by January 2020. But in February 2019, before the rules took effect, DOE issued a notice of proposed rulemaking to redefine GSLs and GSILs. These new definitions excluded almost three billion commonly used lamps from efficiency standards that would have an associated reduction of greenhouse gas emissions (GHG) by conserving 80 billion kilowatt-hours of electricity, which is approximately equivalent to the amount of GHGs emitted by over 12 million cars a year. In addition, the standards would have brought savings to consumers of at least $12 billion annually, as stated in comments filed by a sixteen AG coalition. Despite the concerns voiced by state attorneys general and others, DOE finalized the rule, withdrawing the January 2017 definitions.

In response, California AG Xavier Becerra and New York AG Letitia James led a coalition of sixteen AGs in filing a petition for review to challenge the final rule. They argued that DOE violated the Energy Policy Conservation Act, which prohibits the agency from reversing or weakening energy efficiency standards already set for appliances (including lightbulbs). The case is currently being held in abeyance.

In August 2021, under the guidance of the Biden administration, the Energy Department proposed to restore the 2017 definitions, which would expand the scope of lightbulbs considered in a future standard.

The attorneys general of California, Colorado, Illinois, Maine, Massachusetts, Maryland, Michigan, Minnesota, Nevada, New Jersey, New Mexico, Oregon, Vermont, Washington, Washington D.C., and the City of New York joined AG James in filing yesterday’s comments.

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About the State Energy & Environmental Impact Center:
The State Energy & Environmental Impact Center at NYU School of Law is a nonpartisan academic center at NYU School of Law. The Center is dedicated to working towards a healthy and safe environment, guided by inclusive and equitable principles. The Center studies and supports the work of state attorneys general (AGs) in defending, enforcing, and promoting strong laws and policies in the areas of climate, environmental justice, environmental protection, and clean energy.