CFA joined advocates in submitting comprehensive comments on why the Department of Energy (DOE) should expand the definitions of General Service Lamp (GSL) and General Service Incandescent Lamp (GSIL) and the associated supplemental definitions, previously outlined in the January 2017 final rules.

Prompt adoption of the expanded GSL and GSIL definitions will ensure that all consumers benefit from up-to-date, energy-saving technology for almost every bulb needed in their homes. Low-income consumers, in particular, will see even greater benefits as they have energy bills that, on average, are disproportionately higher, and a majority of them are renters. Tenants, when moving into housing, can often find pre-installed lightbulbs to be older, inefficient incandescents or CFLs. Research in Michigan found that low-income consumers have less access to affordable replacement LEDs than other consumers because the stores they often shop at do not stock them or set prices high. Research in New York also showed that urban stores stock fewer LEDs than suburban stores. New standards will ensure that all consumers have access to low-cost, energy-efficient LEDs whether they buy their bulbs at big box suburban stores, grocery stores, hardware stores, dollar stores, or corner stores.