The Cost of Further DOE Delays: $300 Million a Month

The Department of Energy has taken the long awaited first step toward implementing the statutorily required phaseout of inefficient incandescent light bulbs. The phaseout was due to go into effect on January 1, 2020 but was rolled back due to illegal actions taken by the Trump administration. 

Each month of additional delay results in the ongoing sales of inefficient incandescent light bulbs costing consumers nearly $300 million in lost utility bill savings over the bulbs’ lifetime and result in another 800,000 tons of easily avoided carbon emissions according to a recent analysis by the Appliance Standards Awareness Project (ASAP). In their written comments to the DOE docket, the lighting industry requested at least another full year of delay after DOE publication of a final rule even though that would cost US consumers up to $3.4 billion and result in an additional 9.5 million metric tons of CO2. This is a price that neither consumers nor the environment can afford.

DOE is working to reinstate the minimum efficiency standards for everyday light bulbs which by statute must meet a 45 lumen per watt (LPW) minimum, where lumens are the amount of light produced and watts the power consumed. The LED light bulbs that will replace the old incandescent and halogen bulbs work just as well, use up to 85% less power to deliver the same amount of light and last a lot longer—10 to 25 years for LEDs compared to around a year for the most common types of incandescent bulbs.

In joint comments submitted in response to DOE’s Request for Information, NRDC, ASAP, other leading efficiency advocates, and groups that represent consumers and low-income households urged the agency to:

• Implement the 45 lumen per watt minimum standard without further delay.
• Reinstate the 2017 definition for general service lamps (i.e. everyday light bulbs) which added the bulbs that go into around 2 billion sockets into the scope of the regulations. These common bulbs include: 3-ways, candelabra and flame shaped bulbs, round globe bulbs, and the reflector bulbs that go into track and recessed lighting fixtures. (Note, exemptions for bulbs where an efficient alternative doesn’t exist, like the incandescent appliance bulbs used in an oven, were left in place.)
• Deny requests by the lighting industry to delay enforcement of the standards for extended periods of time.

In a letter delivered to U.S. Energy Secretary Jennifer Granholm today, we urged her to “explore every option” for ending the delays as soon as possible.

The market is ready

LED bulbs of virtually every shape, light output level, hue (warm white to cool white), and base type found in our homes are manufactured by a broad range of manufacturers and are widely available today at retailers, both in stores all across the country and on the internet. The photo shown above from a big box retailer is indicative of the variety of LED bulbs that are already on store shelves and offered today. 

According to data from Apex Analytics, LED bulbs comprised 60% of all bulb sales in 2019, more than triple the sales share in 2015, just four years earlier.

The DOE national lighting efficiency standards are needed to complete the transition away from inefficient incandescent and halogen light bulbs, as they still represented more than a third of all bulb sales in 2019. California and Nevada, which were granted special regulatory treatment in the 2007 federal energy legislation, successfully implemented a 45 LPW standard on January 1 2020 and January 1 2021, respectively, and the statewide switch to LEDs went smoothly.

Timing and sell through of existing stock

Retailers and manufacturers have known since 2007 that the 45 LPW minimum standard was due to go into effect on January 1, 2020 and after that date it would be illegal to offer incandescent or halogen bulbs for sale. As part of President Biden’s Executive Order and fact sheet issued on the first day of his term, DOE was instructed to undo the rollback of the light bulb efficiency standards, which provided the industry with additional warning that they wouldn’t be able to sell these inefficient bulbs much longer and should avoid stockpiling them. 

Given the maturity and well-developed worldwide LED bulb supply chain, there will be plenty of manufacturing capacity to meet increased U.S. demand. For example, lighting manufacturers successfully met the increased demand for LED light bulbs in mid-2018 created by the phaseout of incandescents and halogen bulbs in all 27 countries that comprised the European Union and have a combined population of about 450 million (considerably larger than the US population of 331 million). These same factories are poised to meet increased orders for the U.S. market caused by the standards.

The 2007 law that established the light bulb efficiency standards is based on a date of sale prohibition. In other words, after the phase-out date no more incandescents can be sold, regardless of when they were manufactured. This mechanism is unambiguous, fast acting, and discourages retailer stockpiling that would meaningfully delay the savings and benefits from the standards. In addition, enforcement is greatly simplified as any incandescent or halogen bulb on the shelf (or offered for sale on the internet) covered by the regulations after the effective date is illegal, period. No further investigation is needed to determine the date of manufacture or date of import. The lighting companies are asking DOE to instead base their enforcement on the date of manufacture and are seeking two years from the date of publication of a final rule implementing the standard for retailers to sell through their existing inventory. This alternate mechanism not only further delays the benefits of switching to LEDs and vastly complicates enforcement, it’s not the path Congress chose.

Its Time for DOE to Act

DOE has a non-discretionary legal obligation to implement the light bulb efficiency standards and we urge them to do so as soon possible and without further delay. The savings are massive and unlike most appliances where it may take 10 or more years for the installed stock to turn over, most incandescent light bulbs fail within a year or two under normal use—allowing the carbon and utility bill savings due to the standard to occur quickly.

The lighting industry has had notice of these changes for well over a decade. When Congress called for this transition, they did so because they knew it was right for the planet and right for consumers. DOE can’t let short-sighted corporate interests derail that now.