Fact Sheet: Why Environmental Groups are Challenging the Light Bulb Efficiency Standards Rollback

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This fact sheet was prepared for members of the media interested in the litigation against the Department of Energy (DOE) over its rollback of the light bulb efficiency rule.

  • Several organizations, including Earthjustice, NRDC, Environment America and U.S. PIRG, are challenging a DOE rule that exempts billions of light bulbs from energy conservation standards. The plaintiffs will demonstrate that the exemption is unlawful.

  • The Energy Policy and Conservation Act (EPCA) was amended in 2007 to include the first ever national energy efficiency standards for certain types of “general service lamps” (GSLs), a term which includes incandescent light bulbs and other kinds of lighting products. Because of these standards, many of the least efficient light bulbs were removed from the market. 

  • The 2007 amendments also required DOE to amend these initial standards, and determine whether to maintain or discontinue certain listed exemptions, while ending the sale of all remaining incandescent light bulbs.

  • Instead of issuing other standards, DOE, under the Obama administration, focused on reevaluating the exemptions from the GSL definition, and then publishing two final rules that eliminated most of the exemptions. Because DOE didn’t issue any alternative standards, all incandescent bulbs should be off the market starting January 1, 2020.

  • Per a 2017 report from the Lawrence Berkeley National Laboratory, the 2020 standards would reduce CO2 emissions by 540 million metric tons by 2030, and save consumers $120 billion over 30 years.

  • On September 5, 2019, DOE issued a rule repealing the expanded definition of GSLs adopted by the previous administration. The rule not only restores all prior exemptions but also claims that standards set in the interim do not apply. As a result, the bulbs that go into roughly  half of all U.S. lighting sockets will not be subject to the lighting efficiency requirements. 

  • EPCA contains an anti-backsliding provision that prevents DOE from weakening any efficiency standard. DOE is arguing that the provision does not apply when the Department attempts to alter the scope of a standard by changing a definition. DOE additionally contends that it is not backsliding because the 2020 standards have not been triggered yet.

  • DOE’s rule is beyond the Department’s legal authority. It violates EPCA’s anti-backsliding provision. This failure means DOE cannot lawfully adopt the rule. 

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