CFA joined fellow advocates in support of DOE's proposal to implement the backstop standard for light bulbs enacted by Congress in 2007. We agree with the agency’s findings that the law obligates the backstop standard’s implementation and that doing so will save consumers billions of dollars and eliminate millions of tons of climate-harming emissions. Prompt implementation is especially pertinent for low- and moderate-income households since they spend a disproportionate share of their incomes on energy and many lack access to efficient bulbs. Unfortunately, DOE missed President Biden’s end-of-2021 deadline for completing the rules that will implement this standard. We urge DOE to promptly finalize these important standards and to forgo delays in their implementation sought by manufacturers.