As DOE continues it attack on lighting efficiency standards, CFA joins with advocates in 2 different sets of comments responding to the Department of Energy’s Request for Information (RFI)  explaining why certain types of lighting products, Incandescent reflector lamps (IRLs) and general service florescent lamps (GSFLs) should be subject to higher efficiency standards.

One comment states that DOE has a legal obligation to set a higher standard for IRLs according to provisions in the Energy Policy and Conservation Act.

A second comment points out DOE’s legal obligation but also notes that the outcome of pending litigation on IRLs is uncertain, and goes more in-depth on steps and considerations regarding efficiency standards for IRLs, GSFLs and other specific types of reflector lamps in the event DOE decides to move ahead before the case is decided.