2012-04-16 Comment response to the NOPR stating that the rule should be accepted as proposed.

I believe that the rule should be accepted as proposed. Typically, the industry of electrical engineering is one relatively insulated from the lobbying of industries or particular products. As long as a resistor is made of the proper materials, it operates as well as another resistor of the same type. Thus, it would be wise to accept what would be considered the best industry practice for testing LED lamps. Additionally, adopting the rule as proposed would cut down on the necessary amount of time for testing LED lamps. With new technology, an LED lamp can last for a significant amount more time than the old incandescent lamps. Whereas testing an incandescent lamp to the end of its lifetime may have only taken a matter of days, it could be months of continuous use before an LED lamp becomes ineffectual. This use of time would be a waste of energy and funds, and is unnecessary. The rule as proposed would allow for a determination of the LED lamp's lifetime while reducing these costs.