Attorney General Bonta Continues to Urge DOE to Cease Unlawful Delays of Energy Efficiency Standards

OAKLAND — California Attorney General Rob Bonta today led a coalition of ten attorneys general and the City of New York in submitting a comment letter to the United States Department of Energy (DOE) urging the department to allow energy efficiency standards for commercial refrigeration equipment to take effect. This month, DOE issued a rule 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. In today’s comment letter, the Attorney General highlights how this unlawful delay would have harmful consequences for consumers, businesses, and the environment.  

“Not only is this delay unlawful, but it will also prevent businesses and consumers from significant savings that cut harmful emissions,” said Attorney General Bonta. “With today’s comment letter, we urge the DOE to immediately implement these standards that will drive innovation and protect both economic and environmental interests.”  

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 March 7, 2025, DOE published a rule that delayed the effective date for energy efficiency standards for commercial refrigeration equipment, including commercial refrigerators, freezers, and refrigerator-freezers, that were finalized on December 20, 2024. The notice pushes back the effective date from March 24, 2025, to May 20, 2025.  

In the comment letter, 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• Without efficiency improvements, businesses and consumers will continue using outdated, energy-wasting equipment, leading to higher electricity and gas costs over time.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. The particular standards delayed here will save consumers up to $4.61 billion over 30 years of product sales.
• These energy efficiency standards will not only lead to lower operational costs for businesses, but will also help decrease greenhouse gas emissions, resulting in estimated cumulative carbon dioxide emission reductions of 19.7 million metric tons over 30 years. 
• This delay of energy efficiency standards for commercial refrigeration equipment violates both the Energy Policy Conservation Act and the Administrative Procedure Act. 

Attorney General Bonta leads the attorneys general of Connecticut, Illinois, Massachusetts, Minnesota, New York, Oregon, Vermont, Washington, and the City of New York, in submitting this comment letter.  

A copy of the comment letter can be found here.