In response to the DOE's Notice of Proposed Rulemaking regarding the backstop requirement for General Service Lamps (GSL) and General Service Incandescent Lamps (GSIL), the Consumer Federation of America, and the National Consumer Law Center urged the agency to implement the 45 lumens/watt minimum backstop standard for household lighting products as soon a practicable. We highlighted the consumer support for more efficient lighting standards which will also save billions of dollars in energy bills and eliminate millions of tons of climate-harming emissions. This comment reiterates prior comments we have submitted to the Department on multiple occasions over the past several years in favor of the backstop and its effective date of January 1, 2020.

The delay in implementing the standard on January 1, 2020, as required by law, has already cost consumers well over a billion dollars in lost savings and caused the release of millions of tons of climate change emissions into the air. Each month of additional delay will cost consumers $300 million in higher electricity bills and result in 800,000 tons of additional carbon emissions being spewed into the atmosphere.