The Washington Post recently criticized the Trump administration for proposing to eliminate an Obama administration rule that would extend minimum lightbulb energy efficiency standards to specialty bulbs and add them to a list of incandescent lights that will be effectively banned in 2020. The Post argues that the policy of imposing energy efficiency standards on lightbulbs “has no downside.” Energy efficiency regulations are often described as the equivalent of a free lunch, but these rules, like all regulations, have both benefits and costs.
Lightbulb efficiency standards were included in the Energy Independence and Security Act of 2007 (EISA), which established efficiency standards for “general service lamps.” These standards applied to various technologies, including traditional incandescent bulbs, CFLs, and LEDs, but excluded many types of specialty bulbs, such as decorative candelabra bulbs. The act also required the Department of Energy (DOE) to initiate procedures to determine whether the lightbulb standards should be increased and required a final rule to be published before 2017. If the DOE was unable to fulfill this requirement, the act created a backstop that would impose a 45 lumen (a measure of light intensity) per watt (lm/W) minimum on lightbulbs starting January 1, 2020. A traditional 100 watt incandescent bulb emits 1600 lumens of light, only 16 lumens per watt, and thus would be banned.
After passage of the EISA, Republicans in Congress stymied implementation of the standards by inserting language in DOE appropriation bills prohibiting the use of federal money for their implementation and enforcement. During the Obama administration the DOE attempted to circumvent the appropriation restrictions by creating new rules that expand the lighting standards to include many of the originally exempted lightbulbs and apply the 45 lm/W backstop in 2020. These regulations were published shortly before Trump’s inauguration in January 2017. The new proposed rules eliminate the Obama revisions.
Despite the Post’s assertion, the Obama regulations do impose costs. As the 2017 rule notes,
DOE acknowledges that manufacturers may face a difficult transition if required to comply with a 45 lm/W standard. Manufacturers have voiced concern regarding the loss of domestic manufacturing jobs, the stranding of inventory, the ability to meet the demand for all general service lamps with lamps using LED technology, and the burden associated with testing and certifying compliance for all general service lamps.
The fact that manufacturers are upset by the rule indicates there are some costs. Furthermore, limiting consumer choice itself is costly; some specialized incandescent bulbs may not be available after 2020.
The benefits of the standards also may be small. The Post states that the lack of the mandate would cost consumers $12 billion per year and 140 billion kilowatt‐hours in energy waste. But these estimates assume that consumers will not choose LED and more energy efficient lamps over incandescent bulbs on their own.
Ever since the first oil shocks in the 1970s there has been a debate about the necessity of energy efficiency standards for autos, trucks, and appliances. Consumer groups and engineers, often working at federal energy laboratories, have argued consumers fail to purchase vehicles and appliances that are more expensive initially but save money over time through less energy use. Economists have responded with evidence that consumers make appropriate tradeoffs between initial costs and savings over time and that public programs to promote energy conservation have costs that are greater than benefits.
As I have previously summarized, the most extensive evidence exists for cars. According to this research, consumers are quite willing to pay more initially for a vehicle that saves them money in gasoline costs over the ownership life. The same argument applies for appliances and lightbulbs. As the president of the Alliance to Save Energy, a pro‐efficiency standard group, argued,
There aren’t many people out there clamoring for outdated light bulbs that use four or five times as much energy. Consumers have moved on and embraced high‐efficiency bulbs like LEDs because prices are plummeting and because they’re getting a better‐performing, longer‐lasting product that saves them money.
I recently replaced the incandescent candelabra bulbs in the outdoor lights outside my front door that used 40 watts of electricity with LED equivalents that used 4. The market provided me with an energy saving option even though no regulation required it to do so. If the light is used 3 hours a day 365 days a year and the electricity costs 10 cents per kWh, then the annual savings is $3.94 per year ($4.38 annual costs for the 40 watt bulb vs. $.438 for the 4 watt) which pays for the $8.26 cost of the LED bulb in a little over 2 years.
As the economic literature, manufacturers, and even some proponents of efficiency standards recognize, I am not unique. Consumers understand the cost savings of LEDs, so the economic and environmental benefits propounded by the Post will occur without the tradeoffs required by government mandate.
Written with research assistance from David Kemp.