In written comments filed with the U.S. Department of Energy by the National Electrical Manufacturers Association (NEMA), U.S. lighting manufacturers reaffirmed their position that consumers should have multiple options when selecting the type of light bulbs to purchase. NEMA's comments took issue with requirements in a Department of Energy (DOE) proposed energy efficiency rule aimed at forcing the exclusive adoption of LED bulbs, thereby denying consumer choice and disrupting the ongoing and rapid market transition to energy-efficient lighting.

For the more than three billion lamp "sockets" in American homes, consumer demand for new, innovative, ever-more-efficient lighting technologies, including LED bulbs, demonstrates a market working the way it should. The NEMA Lamp Index reveals that in the first three months of 2016 LED shipments exceeded compact fluorescent (CFL) ones for the first time and by a comfortable margin. Now representing 26 percent of general-service light bulb shipments, LED sales have been accelerating consistently quarter over quarter, while shares of CFL and incandescent bulbs have declined.

NEMA argues a proposed DOE rule would implement a light-bulb efficiency standard that would effectively eliminate energy-efficient halogen bulbs, CFL bulbs, and many specialty incandescent bulbs. (Photo courtesy of NEMA)

"The speed with which prices for common LED bulbs have declined and the corresponding consumer acceptance of this technology have exceeded manufacturers' expectations," said NEMA President and CEO Kevin J. Cosgriff. "Based on current trends, which we expect to continue, the LED lamp is expected to replace most general-service CFL and halogen bulbs in the coming years. Importantly, this will occur without any unnecessary governmental action. Market transformation occurs and in fact is enhanced when consumers have a range of technology choices among quality lighting products. Rather than the DOE prescribing one technology over all others by fiat, this seems like a good time for government to let the citizens decide the composition of lighting products' use in their homes, the pace of change to more efficient options, and how best to manage their own pocketbooks."

The proposed rule would implement an efficiency standard for general-service light bulbs that would effectively eliminate energy-efficient halogen bulbs, CFL bulbs, and many specialty incandescent bulbs starting January 1, 2020. Halogen bulbs have been widely available since 2012, and the industry invested millions of dollars to produce these incrementally more efficient bulbs in the U.S., employing hundreds of people. The DOE also seeks to regulate a variety of decorative light bulbs, such as those used for chandeliers, requiring that they be LED-only by 2020—regardless of whether acceptable replacements are technically feasible.

In its comments, NEMA encouraged the DOE to adopt new energy conservation standards for general-service LED lamps and some specialty lamps where it was economically justified and technologically feasible. "Most specialty bulbs are installed in too few sockets and consume too little electricity to meet Congress' threshold for DOE regulation," said NEMA's vice president for government relations, Kyle Pitsor. "The cost to produce additional efficiency improvements in the general-service halogen bulb cannot be economically justified because over a real-world expectation of bulb life consumers will never see a positive payback in lower energy bills. Furthermore, manufacturers will not make new bulbs if consumers are unlikely to buy them."

The DOE will publish the final ruling before January 1, 2017. If the NEMA recommendations are not adopted, consumer choices will be dramatically more limited, while lighting producers will be left with stranded U.S. manufacturing investments and at-risk jobs. In place of disrupting the industry and market by eliminating whole classes of light bulbs, the NEMA comments offer an alternative path.

"It seems to us it would be wiser for the DOE to take into account already-occurring market changes and respect the consumer's right to decide which light bulb options meet her or his specific lighting needs," Cosgriff said.

The National Electrical Manufacturers Association (NEMA) represents nearly 400 electrical, medical imaging, and radiation therapy manufacturers on the forefront of electrical safety, reliability, resilience, efficiency, and energy security. Our combined industries account for more than 400,000 American jobs, and more than 7,000 facilities across the U.S. Domestic production exceeds $117 billion per year.