# A.J. Antunes 

# &Co.

180 Kehoe Boulevard• P.O. Box 87700 •Carol Stream, Illinois 60188 USA PH: 630.784. 1000 • TF: 800.2 53.2991 • FAX: 630.784. 1650 • www.ajantunes.com

Steve Deppe 1250 PersimmonDrive St. Charles, Illinois 60174

The Honorable Ernest Moniz Secretary U.S. Department ofEnergy 1000 Independence Avenue, SW Washington, DC 20585

Dear Secretary Moniz, July 7, 2014

We are writing to oppose the U.S. Department ofEnergy rulemaking that would establish
new energy efficiency .standards for automatic commercial ice makers (ACIM) with capacities between 50 and 2,500 pounds per 24-hour period. We request that a collaborative process is implemented inthe form ofa negotiated rulemaking to ensure accurate data is used to establish
an energy conservation standard and compliance timeline that does not negatively affect employment ofmanufacturers and end users, which are largely comprised ofsmall restaurants. We have serious concerns thatthese new guidelines will impose a significant financial strain onmanufacturers thatcould only be recouped by passing the c0sts to end users with significantraises in prices.**Additional~y,** manufacturers indicate that the up-front costs required for developing and testing products will result in an immediate reduction in the variety of products available in the marketplace. We are alarmed at the likelihood that these unintended consequences will negatively affect employment in the manufacturing community and foodservice industry. The rule would have a direct cost to customers who will find commercial ice makers are more expensive. The rule almost exclusively impacts smallbusinesses across the foodservice industry with inevitable reductions in scarce manufacturingjobs and employment cuts inthe restaurant industry that will be required as a result ofthe unduly burdensome cost increases. Theproposed rule wouldplace a significant economi<; burden onmanufacturers in both their development and product costs in order to be compliant ofa 70% improvement in energy efficiency from the 2005 standard by 2017. Additicmally, DOE announced this rule might be expanded to cover new standards for those with capacities above 2,500 pounds per 25-hour period. We strongly oppose expansion ofthis ruleto larger capacity commercial ice makers and urge you to reconsider this decision.

BUSINESS UNITS: Antunes China Antunes Controls ROUNDUP Foodservice Equipment VIZION Water Treatment Technologies

# A.J. Antunes 

# &Co.

180 Kehoe Boulevard • P.O. Box 87700 •Carol Stream, Illinois 60188 USA PH: 630.784.1000 • Tf: 800.253.2991 • FAX: 630.784.1650 • www.ajantunes.com

Ofgreatest concern, the DOE rule does not account for research, development and production time frame. On average, redesigning all machines would take six to eight years ifthe parts were available at this time. As most commercial ice makers in use today do not meet the
new energy efficiency requirements, the industry will have to invest heavily in research and development. This process is already underway; however, the technology to achieve the proposed standard is not currently available. In fact, manufacturers that supply commercial ice maker componentparts confirm the necessary energy efficient components, specified in the proposedrule, are not in the marketplace today. NAFEM members are already working tirelessly to develop, test, and manufacture products that meet stringent energy efficiency standards to achieve the Environmental Protection Agency's (EPA) ENERGY STAR certification thatrecognizes the most efficient products in the market. In fact, EPAhas recognized several ofthese manufacturers as "ENERGY STARPartner ofthe Year" multiple times dating back to 2009, demonstrating their good faith and concern for energy efficiency. The fundamentally flawed economic and technological analyses have resulted in a proposed rule that is not technologically achievable within the proposed timeline. We request that the Department enters a negotiated rulemaking withACIM manufacturers to create a common sense energy conservation standard with an achievable compliance timeline.

J/Vsteve Deppe ;f/ Consultant A.J. Antunes & Co.

BUSINESS UNITS: Antunes China Antunes Controls ROUNDUP Foodservice Equipment VIZION Water Treatment Technologies

# "IJl.J. Antunes &

# Co.

180 Kehoe Boulevard• P.O. Box 87700 • Carol Stream, IL 60188 USA www.ajalltunes.com

Ernest Moniz Secretary**O~ROl** STR.Et\l''I ][L 601 :Jfj' JUL '1:"TI PiMi ISL

.

1,J.S. Department ofEnergy 1000 Independence Avenue, SW Washington, DC 20585 neopost/' ,. 07. 1 '1 R 12n·14

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