The Consumer Federation of America recently submitted comments to the U.S. Department of Energy on its Proposed Determination that finds that new lighting efficiency standards are not needed and that essentially rolls back efficiency levels of general-service incandescent lamps. According to CFA, DOE’s justification for its rulemaking is riddled with factual errors and based on flawed assumptions and methodology, and will cost consumers more than $80 billion in lost energy savings over 30 years.
In a press statement, CFA said:
The DOE’s decision to roll back money saving lighting requirements is based on analyzing only one single technology that is extremely and unjustifiably high in cost ($7.00/bulb), low in efficiency (only 34.5 lumens/watt) and has a very short lifespan (1,000 hours). The best alternative available in the market is less than half the cost ($3.00/bulb), almost three times more efficient (88.9 lumens/watt) and lasts fifteen times as long (15,000 hours). Had the DOE used today’s technology to evaluate the effectiveness of the standard, there’s no way the agency could ever be justify not taking action.
The DOE’s faulty analysis assumes that over one-third of consumers would behave irrationally and purchase inferior lighting technology over today’s energy efficient lights. However, even if consumers opted for the older low-tech lighting options, and only 1 in 20 chose new technology, the benefit of staying with the standard would far outweigh the cost.
CFA concluded:
For the Department of Energy to fail to recognize the best and increasingly most prevalent technology when evaluating the merits of standards is simply gross negligence. If the DOE had analyzed the lighting technologies available today, rather than only older high cost, low efficiency, short-life options, it would have concluded that a reasonable, performance based standard would save consumer billions while addressing climate change at the same time.
CFA also analyzed the macroeconomic impact of DOE’s Proposed Determination. In the aggregate, taking a thirty-year time horizon, CFA’s analysis estimates the following costs would be imposed on consumers:
• It would cost consumers over $80 billion.
• The environmental/public health costs would be nearly $20 billion.
• Macroeconomic losses would be $73 billion.
