The National Electrical Manufacturers Association (NEMA) recently sent comments to the Department of Energy in response to a Notice of Proposed Rulemaking (NOPR) for general service fluorescent lamps and incandescent reflector lamps. NEMA claims that some of the efficacy levels for certain fluorescent lamps and for incandescent reflector lamps are not economically justified. They also say these rules could result in elimination of some types of bulbs which are in fact quite energy efficient. To solve these issues, NEMA proposed that DOE adopt amended standards for fluorescent lamps and incandescent reflector lamps.
NEMA also claimed DOE failed to appreciate marketplace dynamics that have already occurred and will continue to occur in the coming years. For one thing, NEMA says "higher standards for U-shaped lamps cannot be economically justified because of the impact on competition and because it makes certain U-shaped lamps unavailable leaving no energy efficient U-lamp options with 6-inch leg spacing for users with installed 2x2 foot luminaries for this lamp type."
NEMA recently made its comments to the DOE publically available. You might say they 'illuminate' the current problems of making efficient fluorescent bulbs, including the idea that China may be trying to corner the market on making certain types of bulbs by refusing to export some of the rare earth elements used in their manufacture.
You can read a PDF of the whole report here:
http://www.nema.org/gov/energy/efficiency/upload/Comments_DOELampRule%20.pdf
