The Consumer Federation of America recently submitted comments to the U.S. Department of Energy on its Proposed Determination that finds that new lighting efficiency standards are not needed and that essentially rolls back efficiency levels of general-service incandescent lamps. According to CFA, DOE’s justification for its rulemaking is riddled with factual errors and based on flawed assumptions and methodology, and will cost consumers more than $80 billion in lost energy savings over 30 years.