Mon 11/4: Hello, light bulb industry! You may have noticed our climate crisis. No “relaxing” for you. Comment TODAY by 11:59 pm EST.

Proposed Rule Rollback:  “Relaxing energy-efficiency standards. Energy Conservation Program: Energy Conservation Standards for General Service Incandescent Lamps.” Yes, they actually use the word “relaxing”! The proposed changes would eliminate requirements that most light bulbs sold in the United States — not only the familiar, pear-shaped ones, but several other styles as well — to be either LEDs or fluorescent to meet new efficiency standards. The rules to increase light bulb efficiency started in 2007 under President George W. Bush and if the new rule were to start in 2020 as planned, inefficient incandescent bulbs would largely be eliminated. “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,said Andrew deLaski, executive director of Appliance Standards Awareness Project.

This rollback proposal is dangerous for our environment, expensive for our pocketbooks and hazardous for our health, and therefore we declare it to be an un-American action.

  • Comment here.
  • Proposal here.
  • Inspiration: read other comments here. Please, do not submit an identical comment, as it will be culled. Channel your creative writing classes.

Why do we need this?

Embed from Getty Images

Wasting energy with inefficient light bulbs isn’t just costly for homes and businesses, it’s terrible for our climate.” – Jason Hartke, president of the Alliance to Save Energy, a nonprofit coalition of business and environmental groups.

Inefficiency = more power plants: Eliminating inefficient bulbs nationwide would save electricity equivalent to the output of at least 25 large power plants, enough to power all homes in New Jersey and Pennsylvania, according to an estimate by the Natural Resources Defense Council.

chart2_puv3gri.pngSource: Appliance Standards Awareness Project

Inefficiency = costs consumers: Based on ASAP and ACEEE analysis published last year, eliminating the 2020 standards for all light bulbs would cost US consumers up to $14 billion annually, which works out to more than $100 in lost bill savings every year per household.

Inefficiency = more emissions: The rollback would increase annual climate-change emissions by about 38 million metric tons per year, or approximately the amount emitted by 8 million cars. Pollution increases would include an extra 19,000 tons of nitrogen oxides, 23,000 tons of sulfur dioxide, and 34 million metric tons of climate-changing carbon dioxide emissions each year by 2025.”

Inefficiency = poisoning people: This additional energy waste would cause more power plant pollution which harms the environment and contributes to health problems like asthma.

Inefficiency = stifles innovation: Rule rollback eliminates a powerful regulatory incentive for manufacturers and retailers to invest in high quality, energy-efficient LED light bulbs. LEDs (light emitting diodes), already a great deal for consumers, are available in a wide range of shapes, sizes, color and light output. LEDs cost slightly more than other bulbs, but they pay consumers back through lower electricity bills within a few months, and last 10 years or longer.

Most people already understand this: (ASAP)At the previous comment period to rollback light bulb energy efficiency, there was opposition to this un-American proposal by a huge, varied range of “stakeholders”, which includes everybody with light bulbs in their home. The Department of Energy (DOE) website got over 64,000 comments, including from: 

  • 43 Electric utilities from across the U.S., including some of the largest and smallest
  • 26 consumer, environmental, and energy efficiency advocacy groups
  • 24 Governors (through the bi-partisan U.S. Climate Alliance)
  • 15 U.S. Senators
  • A coalition of 54 U.S. corporations, and
  • More than 60,000 individual citizens
  • a group of 15 state attorneys general plus the city of New York and the District of Columbia provided detailed legal comments explaining why the proposed rollback violates the law. 
  • Natural Resources Defense Council and Earthjustice further developed the legal case for why the rollback, if finalized, will land DOE in court. 
  • Here’s a complete list of all the organizations that commented.”

Who wants to stop this? Why don’t conservatives want to “conserve?”

Light bulbs makers: (ASAP) “The only organizations that support the proposal are manufacturers of inefficient light bulbs and their industry trade associations. General Electric, Philips and Sylvania all sell high-quality LED light bulbs that comply with the 2020 standard, but they also produce and sell inefficient bulbs which may be more profitable for them. LEDs last fifteen years or longer, but inefficient halogen light bulbs usually burn out much more quickly, needing to be replaced every year or so as shown below. These large, well-known companies are fighting a rear-guard battle to delay the demise of an obsolete technology, at the expense of consumers and the environment.”

(Utility Dive) “(It’s) Not all companies. It’s the old companies, the incumbents, that drive NEMA and are pushing for the roll back.” (Andrew deLaski Executive Director, Appliance Standards Awareness Project) “Some of them have old incandescent and halogen plants, and they want to milk them for all they can.” said NRDC’s Horowitz.


The Trump administration: They insist that the changes would benefit consumers by keeping prices low and eliminating government regulation, especially regulation that interferes with high-paying lobbyists and the fossil fuel industry. They have already worked to repeal 84 environmental protection rules. These include weakening methane regulation, freezing fuel efficiency standards, eliminating the clean power plan, promoting drilling on public lands and offshore, and boosting fossil fuel companies by weakening protections for endangered species. The president assists where he can by tweeting out factually incorrect nonsense about climate warming.

The fossil-fuel people: If you’ve never read the “Action Plan” for the Trump Administration written by Robert E. Murray of Murray Energy (now going bankrupt), it’s most instructive. Our government, instead of working to keep our air, land and water clear for the American people, has transformed into an arm of an old man’s coal company, and have completed or are on track to complete  16 of his detailed commands.  But it’s not just Mr. Murray by himself. (NYTimes) “Much of the support for these rollbacks has come instead from a small group of conservative, free market organizations, many allied with the fossil fuel industry. For example, a secretive policy group financed by corporations, the American Legislative Exchange Council, worked alongside the gasoline producer Marathon Petroleum to urge legislators to support weakening the clean-car rules.”

Extra credit: Contact the manufacturers behind “relaxing” standards.

  • General “Imagination at Work” Electric: email here.
  • Philips: Email their CEO here. (tip for writing CEO’s here)
    BTW: Philips is not an American company. It’s a Dutch multinational conglomerate corporation headquartered in Amsterdam, one of the largest electronics companies in the world, currently focused in the area of healthcare and lighting.
  • Sylvania: email here.




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