Attorney General Bonta to DOE: Unlawful Delay in Energy Efficiency Rules Would Increase Consumer and Business Costs

OAKLAND — California Attorney General Rob Bonta today led a coalition of eight attorneys general and New York City in submitting two comment letters to the United States Department of Energy (DOE) urging the department to allow energy efficiency standards for gas-fired instantaneous water heaters and walk-in coolers and freezers to take effect. Last month, DOE issued rules delaying the effective date of these standards and signaled that it is considering following its initial delay with further delays of the Biden Administration’s energy efficiency standards for these products. In today’s comment letters, the Attorney General highlights how the delays are not only unlawful, but would have harmful consequences for consumers, businesses, and the environment. 

“President Trump promised to ‘immediately bring prices down, starting on day one’ of his presidency. Instead, he’s delaying rules that were designed to lower energy costs for businesses and consumers, a critical step toward an affordable future for all Americans,” said Attorney General Bonta. “Not only are Americans missing out on these critical savings, but these unlawful delays ignore the climate crisis we are seeing every day from ravaging wildfires to record-breaking droughts. California will continue to oppose any attempts to delay these standards, and we call on the federal government to immediately implement them.” 

On January 20, 2025, President Trump issued the “Regulatory Freeze Pending Review” memorandum, which ordered all federal departments and agencies to consider postponing for 60 days the effective date of certain rules published in the Federal Register for the purpose of reviewing any questions of fact, law, and policy that the rules may raise, and to consider opening a comment period to allow interested parties to provide comments about issues of fact, law, and policy raised by the rules postponed under the memorandum.

Citing that memorandum, on February 20, 2025, DOE published two rules that delayed the effective dates of energy efficiency standards for gas-fired instantaneous water heaters and walk-in coolers and freezers. The two delay rules push back the effective dates for both rules from March 11, 2025, and February 21, 2025, respectively, to March 21, 2025.  

In the comment letters, Attorney General Bonta writes that: 

• Without efficiency improvements, businesses and consumers will continue using outdated, energy-wasting equipment, leading to higher electricity and gas costs over time. DOE has projected that its energy efficiency standards will collectively provide nearly $1 trillion in consumer savings over 30 years, with  $3.1 billion in savings from gas-fired instantaneous water heaters and $6.5 billion from walk-in coolers and freezers over 30 years of product sales.
• Inefficient walk-in coolers and water heaters burn more fossil fuels, contributing to climate change and worsening air quality. DOE estimated that its energy efficiency standards will collectively reduce greenhouse gas emissions by 2.5 billion metric tons or more—an amount roughly equivalent to the emissions of 18 million gas-powered cars, 22 coal-fired power plants, or 10.5 million homes over 30 years. The particular standards delayed here will reduce carbon dioxide emissions by 71 million metric tons.
• The delays for the two-consumer product energy efficiency standards are in violation of the Energy Policy Conservation Act and the Administrative Procedure Act. 

Joining Attorney General Bonta in submitting these comment letters are the attorneys general of Connecticut, Illinois, Massachusetts, Minnesota, Oregon, Vermont, Washington, and the City of New York.   

A copy of the comment letters can be found here and here.