CFA joined advocates in submitting comprehensive comments on why it is incumbent upon the Department of Energy (DOE) to implement the General Service Lamp backstop as soon as is practicable. The following points were made:

• The backstop has been triggered and DOE is legally obligated to implement it as soon as practical for the expanded definition of GSLs.
• Incandescent (including halogen) bulbs still make up a very large share of current light bulb sales for both the statutory and expanded definitions of GSL.
• Delay is costly for consumers, especially those who can least afford it, and causes needless climate change emissions.
• If implemented soon, the backstop will save consumers about $20 billion and reduce CO2 emissions by 50 million metric tons by 2030.
• LED bulbs are extremely cost effective compared to the incandescent or halogen bulbs they replace.
• LED products that meet the 45 lumen per watt minimum efficiency level are widely available for the full range of products within both the statutory and expanded definitions of GSL.
• The world-wide supply chain for LED GSLs is more than capable of meeting additional LED demand.
• Manufacturers and sellers should be ready to comply.