American Council for an Energy-Efficient Economy

We are writing to provide comments on DOE’s May 31, 2006 Federal Register notice and Rulemaking Framework document on energy efficiency standards for general service fluorescent lamps, incandescent reflector lamps and general service incandescent lamps. In general, we are pleased to see DOE begin this rulemaking and think that DOE’s proposed approach is generally acceptable. However, we do have some serious concerns and some suggestions on ways to improve the process and analyses. At the workshop, the Department expressed its intent to issue a final standard by the end of June 2009. The Department should take great care that, in working to complete the rulemaking within three years, it also complies with its obligations to conduct complete and unbiased analysis. We start with some general comments and then proceed to product-specific comments.