# 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

Glenn R. Bullock 839 Newberry Drive Batavia, Illinois 60510

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 inthefonn ofa negotiated rulemaking to.ensure accurate data is usedto establish
an energy conservationstandard and complia)lce timeline that does not negativelyaffect employment ofmanufacturers· and end users, which are largely comprised.ofsmall restaurants. We have serious concernsthatthese new guidelines will impose .asignifieant financial strain onmanufacturers that could onlybe recouped by passing the costs to end users with significantraises in prices. Additionally, manufacturers.indicate that the up-front costs required for developing and testing products will result in an immediatereduction in the variety of products available in the marketplace. We are alarmed at the likelihood that these unintended consequences will negatively affect employment inthe manufacturing community and foodservice industry. The rule would have a direct costto customers who will find commercial ice makers are more expensive. The rule almost exclusively impacts small businesses across the foodservice industry with inevitable reductions in scarce manufacturingjobs and employment cuts inthe restaurant industry thatwill be required as a result ofthe unduly burdensome cost increases. The proposedrule would place asignificant economic burde)lonmanufacturers inboth their developmentand product costs in order to becompliant

# ofa 70%improvement in energy efficiency from the 2005 standard by 2017. Additiomdly, DOE annonnced thisrule might be expanded to .cover new standards for those with capacities above 2,500pounds per 25-hour period; We strongly oppose expansion.ofthisruleto larger capacity commercial ice makers and urge you to reconsider this decision.

BUSINESS UNITS: Antunes China Antunes Controls ROUNDUP Foodservice Equipment VIZION Water Treabnent 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,(om
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 component parts confirm the necessary energy efficient components, specified inthe proposed rule, are not inthe 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 STARcertificationthat recognizes the most efficient products in the market. In fact, EPAhas recognized several ofthese manufacturers as "ENERGY STARPartner ofthe Year" multiple times dating backto 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 theproposed timeline, We request thatthe Department enters a negotiated rulemaking with ACIM manufacturers to create a common sense energy conservation standard with an achievable compliance timeline.

Sincerely,

Glenn R. Bullock ChiefExecutive Officer A.J. Antunes & Co.

BUSINESS UNITS: Antunes China Antunes Controls ROUNDUP Foodservice Equipment VlZION Water Treatment Technologies180 Kehoe Boulevard**~** P.O. Box 87700**~** Carol Stream, IL 60188 USA wWV\J,ajantunes.(om

Ernest Moniz Secretary C:,?l, R:OL.

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U.S. Department ofEnergy 1000 Independence Avenue, SW Washington, DC 20585