What do a car and a light bulb have in common?
It sounds like a joke, but clean energy advocates are not laughing. The two products have been gaining in efficiency for years, but the Trump administration is expected to take steps to slow or roll back that progress for each.
The Trump Administration has methodically targeted energy policies it considers too-costly or restrictive. While the focus has often been on the President's broader decisions — exiting the Paris climate accord, or blocking implementation of the Clean Power Plan — analysts say less-noticed issues like energy efficiency rollbacks could have a significant impact on consumers.
Several appliance standards remain delayed and tied up in litigation. The Environmental Protection Agency is expected to rescind California’s authority to set its own emission standards for automobiles, and to freeze federal vehicle efficiency standards at 35 miles per gallon — rather than the 50 mpg target for 2025 finalized by the Obama administration.
"The light bulb standards are far and away the biggest energy efficiency saver of any standard —aside from vehicle — that the government has ever issued."
Andrew deLaski
Executive Director, Appliance Standards Awareness Project
Against that backdrop, rules for the ubiquitous light bulb may not seem so important. But the energy efficient products are saving consumers billions, say experts, and tighter standards are expected to continue to increase savings.
"The light bulb standards are far and away the biggest energy efficiency saver of any standard — aside from vehicle — that the government has ever issued," Andrew deLaski, executive director of the Appliance Standards Awareness Project (ASAP), told Utility Dive.
Not typically controversial
Light bulbs are not typically a controversial topic, and efficiency standards in general tend to be bipartisan efforts. The first national appliance standards were signed into law by President Reagan in 1987, and were accelerated by President Obama.
But heading into the 2016 election ASAP and its parent organization, the American Council for an Energy-Efficient Economy (ACEEE), issued a report outlining the stakes: The next President would oversee updates to existing lighting and efficiency standards that by 2050 could slash carbon emissions and lower consumer bills by $65 billion per year.
In the 18 months of Trump's presidency, the White House has searched for ways to keep struggling coal and nuclear plants online, proposed greatly expanding offshore drilling, attempted to reduce emissions restrictions on oil and gas drilling, and has given more flexibility to how states handle the waste of coal plants.
Thus far, the battle over energy efficiency has been largely relegated to the appliance standards the Administration has balked at finalizing. But that may soon change.
"This is huge. Bigger than big," said Noah Horowitz, director of the Center for Energy Efficiency Standards at the Natural Resources Defense Council. "There are about 50 sockets in every home, and there are still billions of inefficient light bulbs in them."
Once the inefficient halogens and incandescent bulbs are replaced, Horowitz said the more-efficient LEDs will result in about $22 billion in annual savings
6 billion sockets
Congress and President Bush enacted minimum energy efficiency standards for light bulbs in 2007, with the first standards effective in 2012. Then last year, the Department of Energy widened the range of light bulbs that must comply with the second set of standards set to go into effect in 2020.
The first stage of light bulb standards applied only to the standard bulbs found in virtually every home, and required energy savings of 25% to 30% compared to traditional incandescent bulbs.
According to ASAP and ACEEE, the new batch of standards will cover a wider range of bulbs and will deliver significant additional savings — particularly given the scale of the market. There are more than six billion light bulb sockets in U.S homes, the groups say, and the second phase of standards would save a typical household about $180 per year by 2025 — similar to customers getting two or three months of free electricity, deLaski points out.
On a cumulative, national basis, consumers will realize more than $665 billion in electricity bill savings by 2050 as a result of the higher standards, according to an ASAP analysis.
But last year a group representing light bulb manufacturers, the National Electrical Manufacturers Association (NEMA), sued DOE and called for the government to implement "economically justified" standards and to not artificially accelerate the transition to LED bubs.
"NEMA's view is that the marketplace is doing an excellent job of transitioning to more efficient lighting solutions," the group said in a statement.
The lawsuit resulted in a settlement that requires DOE to propose new rules this year. While the settlement is not specific, in a recent issue brief deLaski writes that "it suggests that the administration may attempt to carry out the manufacturers’ rollback wishes."
The backstop
However, because the federal government has been known to occasionally miss deadlines, Congress included a "backstop" in the efficiency standards that directed manufacturers towards a long-term efficiency target of at least 65% to 70% savings.
According to deLaski, DOE ultimately failed to meet the statute's requirement to update the standards — triggering the backstop of a minimum efficacy standard of 45 lumens per watt.
ASAP contends the backstop was triggered for several reasons, but key among them is that DOE did not complete a final rule by Jan. 1, 2017. The agency did, however, complete rules to define the scope of bulb types covered by the backstop standard: in addition to the standard light bulb found in a typical home, the 2020 standards would apply to a wider range of bulbs.
But efficiency advocates are gearing up for a fight if DOE proposes a new rule that would keep the 2020 standards from applying to new products or enact a lower standard — something generally outlawed. DOE is prohibited from enacting a new standard that is less stringent than the one it replaces, said deLaski, which has generally helped keep the efficiency rules safe from Trump's rollback efforts.
"Because of the anti-backsliding clause, there's been no push to remove standards that are in place," said deLaski. But the group is sounding the alarm over the lighting standards.
ASAP's brief explains the situation thus: the DOE settlement with NEMA "does not mention the backstop standard, but it implies that DOE still has to decide whether to issue new standards for incandescent bulbs, which would illegally roll back the backstop if they set minimum efficiency at less than 45 lumens per watt."
NEMA's legal argument is that the backstop has not been triggered, and DOE can still complete the rulemaking which had been due in January, meet the minimum savings requirement and avoid implementing the backstop.
"They want to continue to sell the inefficient light bulbs," said deLaski. "The reason is, you sell one every single year. When you buy an LED light bulb, you're now set for the next decade. ... Parts of the industry would like to see incandescent light bulbs continue to have a significant market share."
Incumbents pushing for roll back
"Not all companies," deLaski added. "It's the old companies, the incumbents, that drive NEMA and are pushing for the roll back."
"Some of them have old incandescent and halogen plants, and they want to milk them for all they can," said NRDC's Horowitz.
NEMA represents more than 300 electrical equipment and medical imaging manufacturers, including some of the largest lighting companies like GE, Signify (formerly Philips Lighting) and Sylvania. The organization did not respond to requests for comment on this story, while the Department of Energy said it does not comment on rulemaking proceedings.
The new standards are designed to "force the scaling up of market," said deLaski. "It's going to bring prices down. You'll have an LED for every socket; you're going to sell fewer of these incandescent light bulbs, whether that's traditional or halogen."
Even if lighting manufacturers are successful in slowing the implementation of phase 2 standards, deLaski said that a new presidential administration could reverse that course quickly.
"Even if the Trump administration were to determine that the backstop doesn't apply, a new administration could change that interpretation," said deLaski, noting that manufacturers would be taking a risk if they chose not to improve the efficiency of their light bulbs. "It could be turned around very quickly."
California was able to adopt the 2020 federal standards two years early, due to certain provisions in the federal legislation. In January, the 45 lumens-per-watt standard went into effect "and the transition has occurred without a hitch," Noah said.
"These standards make a lot of common sense," said Horowitz. "The industry knew this was coming back since 2007, and had more than 12 years to gear up for it. All the major manufacturers make a wide range of LED products. There is no reason these standards shouldn't move forward.
But for now there is little to do but wait, as DOE finalizes its rule.
"There are a lot of moving pieces with this situation," said deLaski. "But accelerating the transition to LEDs is a huge benefit to American consumers and for energy savings. Slowing that down just doesn't make sense."
