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Comments to DOE on Proposed Efficiency Standards for General Service Lamps and Distribution Transformers

We submitted comment letters to the Department of Energy (DOE) on its proposed rules to strengthen energy conservation standards for general service lamps and distribution transformers. Our comments applaud the agency for appropriately applying the social cost of greenhouse gases to estimate the climate benefits of the proposed standards. We also suggest that DOE apply additional analysis to each rule using draft updated climate-damage valuations that the Environmental Protection Agency released in November 2022.