The Consumer Federation of America submitted these comments in strong opposition to the Department of Energy’s (DOE) September 5, Notice of Proposed Determination in which the agency concludes that energy conservation standards for General Service Incandescent Lamps (GSILs) do not need to be amended.

CFA believes that the DOE’s Proposed Determination not to amend the standards for GSILs is so fundamentally flawed that the agency should withdraw it. It is riddled with errors, many of which were pointed out in our earlier comments in a prior proceeding and in our comments in the Department’s broad docket on Regulatory Reform, and all of which are correctible.