NEMA, Rosslyn, Va., recently submitted comments to the Department of Energy (DOE) on the Notice of Proposed Rule, Energy Conservation Standards for General Service Fluorescent Lamps and Incandescent Reflector Lamps. NEMA's 31-page document includes several scenarios that would result in the phase-out of the T12 lamp without causing disruption in the marketplace.

NEMA and its members have called upon DOE to adopt new minimum lamp-efficiency standards that would lessen the disruptive impact on residential consumers and users of lighting products, while effectively transitioning the country to take advantage of more efficient lighting products as they become available.

According to NEMA President and CEO Evan R. Gaddis, these proposals also stress the challenges faced by manufacturers in making high-efficiency lighting products. These include the looming shortage of rare earth phosphors, which are used in making fluorescent lamps; technology limitations that are critical for safety and longer-life lamps; and the sizable investments required for the radically shrinking market for some of these lamps.

The full text of the comments can be downloaded from the NEMA Web site.