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It’s What’s Inside The Letter

It’s What’s Inside The Letter

By E Kinnersley

Part of my day involves getting very excited whenever I see a headline that starts with ‘Coalition Pens Open Letter on DOE Policy.’ And this is because I am about to read one of two things: either the DOE has set a policy that is complete nonsense, or I am about to encounter a coalition of cranks, grifters, and wackadoos. It’s literally the most fun I have at work outside of lunch breaks.

Which brings me to regulations.gov, where I found:

Re: Docket Number EERE-BT-STD-0005: Department of Energy: Energy Conservation Program: Backstop Requirement for General Service Lamps: Notification of Proposed Rule: 86 FR 70,755 (December 13, 2021).

A catchily-named open letter signed by 15 individuals with Very Important Sounding Titles from Very Important Sounding Places. And what this letter says, in short, is that the DOE has no business regulating the general service incandescent lamps (ie the lightbulb) out of existence by setting the lumens-per-watt bar out of Thomas Edison’s reach. This will leave store shelves bare of the warm, buzzy little globes for the first time in a hundred years. A stroke of the pen will end an era, and these folks cannot let this stand. And because I believe these people to be cranks, grifters, and/or wackadoos I cannot let that stand, and so here are some keystrokes on the subject.

What do they say?

 
The full text of this letter is available here: https://www.iwf.org/2022/01/31/coalition-opposes-proposed-doe-lightbulb-rule/

Let’s read this letter with the assumption that these authors are writing in good faith. So I broke it down for you.

  1. This regulation is a violation of consumer protection laws

No, it’s not.

No really, it’s just not.

The Federal Food, Drug, and Cosmetic Act. The Fair Debt Collection Practices Act, The Fair Credit Reporting Act, Truth in Lending Act, Fair Credit Billing Act, The Gramm–Leach–Bliley Act, and so on; none of these consumer protection laws have a line item preventing another law from banning something that is currently for sale, or a law or standard pushing an existing technology out of use. Otherwise, we’d be selling beer and cigarettes to minors, servicing cars without seatbelts and low-octane engines. Cocaine used to be a common food additive, where was this consumer protection for pre-1907 Colas?

Also, it’s very easy to call this law a ban on bulbs, but it’s really a requirement for lighting products. Anyone that can cook up a filament incandescent that does put 45 lumens out for every watt in can go on the shelves, the ones that can’t will be recalled, repackaged, and reshelved as heat lamps or infra-red therapy devices.

  1. Climate Change isn’t real so you can’t make us change

With all due respect and sincerity, go kick rocks.

Every study that points at man-made warming trends gets confirmed and the projections based on them are too conservative. Every study that points at anything else gets debunked.
But let’s say that wasn’t a factor.

Let’s say this is all a play to add 25% more capacity to the grid without adding one turbine, one reactor, one panel. How much more industrial capacity does that add to the US?

Let’s say we wanted to add to the buying power of the average homeowner? What does that do for local economies? Inflation? What if this is all one huge scam to be slightly better by changing light bulbs? I can see how nobody wants that.

  1. LED A19s cost 9 dollars each, and that’s too much

9 bucks? Where are you shopping? IKEA has these for a buck forty. Dollar Tree? A dollar twenty-five. Amazon basics has a two-pack of bulbs with an eight-pack of double-A batteries for eight seventy-five. Walmart sells a wi-fi-enabled Alexa and GHome compatible bulb for seven ninety-nine. If you want name brands Target has a two-pack of dimmable 60-watt equivalents for nine fifty and Home Depot sells a basic Phillips for 4 apiece.

And pointing at the upfront cost without mentioning the rate of replacement or billing changes is some real BS economics, you may as well slag off a pair of Doc Martens for costing twenty times as much as a pair of Crocs.

  1. The DOE hasn’t done enough to reduce GSILs before this ‘ban’

Maybe. That’s a weird hurdle to set. The CFL and the LED and their assorted benefits have been advertised pretty heavily for 15 years. Better lighting is the first point on every guide to saving money on energy, utilities run giveaways, offer trade-ins on bulbs, there have been hundreds of instant downstream rebates for these sorts of lamps — some of that was funded by the DOE. This point is more about delaying or distracting, you can always insist on more data and more awareness campaigns before real action happens.

This is all a really boring SWOT analysis for consumer-grade illumination products; but don’t worry, we’re done playing by good faith rules — these guys are all assholes.

Who are these people?

 
It’s a long list of people signed to this letter, so I will be brief:

  • Ben Lieberman, is a Senior Fellow at the Center for Energy and Environment at Competitive Enterprise Institute, which was founded in the 1960s specifically to overturn the claims of environmentalism. Their primary financial backer until 2006 was ExxonMobil. The group’s founder likes how warm it’s gotten over the past few years. They once ran PSA-styled ads about the many benefits of CO2.
  • Steve Milloy from JunkScience.com is a regular guest on Fox News. He’s called for the abolition of the office of the surgeon general, he’s claimed that the World Trade Center attacks would have been less disastrous if the building still had asbestos, he cashes a lot of checks from ExxonMobil.
  • David Stevenson, is the Director Center for Energy & Environmental Policy Caesar Rodney Institute, a group tied to the State Policy Network and the Franklin News Foundation, both “free market” advocacy groups with ties to the Koch family funding operations.
  • E. Calvin Beisner, Ph.D. is the President at The Cornwall Alliance for the Stewardship of Creation. His PhD is in Scottish History, but his BA was in religion. The Cornwall Alliance says that rising temperatures and wild weather are the results of intelligent design. Doctor Beisner also holds a position at the Heartland Institute, a think tank in the pay of the Koch family’s advocacy arm and General Motors. Heartland ran those billboard ads about the Unabomber endorsing decarbonization, by the way.
  • Tom Pyle, the President of Institute for Energy Research is anti- all regulations and gets most of his funding from Koch-funded think tanks, ExxonMobil, the American Petroleum Institute, and Peabody Coal
  • Bette Grande from the Roughrider Policy Center is a former North Carolina Republican and the policy center has ties to coal lobbyists.
  • Carrie Lukas leads the Independent Women’s Forum a group that has never had anything to do with consumer advocacy or environmental issues, but receives checks from Koch-funded outreach, and noted climate change deniers the Scaife Foundation.
  • Heather R. Higgins and the Independent Women’s Voice are a subsidiary of the IWF (from the bullet above) and act as Koch operatives with a side of DeVos fundraising.
  • Beverly McKittrick at the Regulatory Action Center of FreedomWorks Foundation are Tea Partiers, the populist arm of the GOP and paid for by Koch Industries’ non-profit efforts.
  • Donna Jackson leads Project 21 under the National Center for Public Policy Research ( presided over by David Ridenour, who signed this letter a little further down) a group that spends most of its time going on cable tv to deny climate science and occasionally aids and abets wire fraud of the federal government and Native American tribes.
  • Paul Gessing is the President of the Rio Grande Foundation. They hate trains, government spending of any sort, income taxes, and the idea of eminent domain. No, I don’t know why they care about light bulbs either, but maybe it’s because they get tens of thousands of dollars a year from Koch-owned NPOs.
  • Richard Manning at Americans for Limited Government is only recently politically active but already likes to blame the ills of America on George Soros.
  • Saulius “Saul” Anuzis is a never-was Republican politician turned Tea Party hack; the 60 Plus Association advocates for privatizing any and all social programs for seniors and are funded by (drumroll) by the KochPAC and associated groups.
  • Adam Houser is National Field Director Committee for a Constructive Tomorrow, an organization funded by Chevron, ExxonMobil, the Carthage Foundation, the Scaife Foundation and Donors Trust. Those last three all have ties to the Koch Industries.

So, Koch Industries and their many not-for-profit advocacy groups…

 
That name shows up a lot back there, didn’t it? The surviving members of the Koch family own the second-largest privately-held business in the US. That business is petrochemicals and minerals; extracting them, refining them, and shipping them. Also, it is hard to tell what they’ve spent more money on: EPA fines or conservative think tanks and lobbyists that attempt to reduce EPA regulations on their business.

Does this mean that these men are sitting in the middle of some great web manipulating multiple levels of government and the private sector to spread misinformation and gaslight the public?

Don’t be stupid. That’s not how anyone does anything.

These people are businessmen, they buy influence cheaply and place it carefully. All of these groups that signed off on this letter are registered non-profits. Not one of them has a stated annual budget of more than $300,000. No Koch-backed group has donated more than $10,000 to any one of them in a year. Furthermore, all of these foundations, alliances, and networks are stuffed with people with Important Titles. Split that amount that many ways and the people that signed this letter sold out to big oil for what might well be minimum wage. But all of them will have a new reason to book appearances on the talking-head-sphere and stamp their feet about the tyranny of lighting bulbs for a week. And next week the donors and the think tanks will be onto batteries, or single-use plastics, or recycling fees, or trying to say that windmills give you brain cancer.

If this was about GSILs it would be sad and small and petty, but this is all just SABERmetrics for assholes. Keep enough idiots mad about enough things and no one will notice that every grid in the US is at as close to capacity as it can be and you can keep the price of heat and light high for everybody and quarter-over-quarter profits on the rise for hydrocarbon barons.

For one more baseball metaphor, Astroturf is the name brand for a petroleum by-product pretending to be grass in sports fields. From a distance, a casual observer can’t tell it from the real deal. But a pro that hits the field needs to know what he’s playing on and how to adjust for it.

Be a pro, pay attention to what you’re standing on and who put it down in the first place.

 

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