Your Sofu.tions Tartner 

June 5, 2014 

The Honorable Ernest Moniz 

Secretary 

U.S. Department of Energy 

1000 Independence Avenue, SW 

Washington, DC 20585 

Dear Secretary Moniz, 

DUKE MANUFACTURING CO 

2305 N. Broadway 

St. Louis, MO 63102 

800-735-3853. FAX 314-231-5074 

www.dukemfg.com 

We are writing to oppose the U.S. Department of Energy 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 in the form of a negotiated rulemaking to ensure accurate data is used to establish 

an energy conservation standard and compliance timeline that does not negatively affect 

employment of manufacturers and end users, which are largely comprised of small restaurants. 

We have serious concerns that these new guidelines will impose a significant financial 

strain on manufacturers that could only be recouped by passing the costs to end users with 

significant raises in prices. Additionally, 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 small businesses across the foodservice industry with inevitable 

reductions in scarce manufacturing jobs and employment cuts in the restaurant industry that will 

be required as a result of the unduly burdensome cost increases. 

The proposed rule would place a significant economic burden on manufacturers in both 

their development and product costs in order to be compliant of a 70% improvement in energy 

efficiency from the 2005 standard by 2017. Additionally, 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 rule to larger capacity commercial ice makers and 

urge you to reconsider this decision. 
Of greatest 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 if the 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 confi= the necessary 

energy efficient components, specified in the proposed rule, 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 that recognizes 

the most efficient products in the market. In fact, EPA has recognized several of these 

manufacturers as "ENERGY STAR Partner of the 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 with ACIM manufacturers to 

. create a common sense energy conservation standard with an achievable compliance 

timeline. 

Sincerely, 
"Your Solutions Partner" 

DUKE MANUFACTURING CO. 2305 N. BROADWAY- ST. WUlS, MO 63102 

J. Hake 

RECEIVED 

JUN 12 2014 

MAIL SANITIZeD The Honorable Ernest Moniz 

Secretary 

u.s. Department of Energy 

1000 Independence Avenue, S.W. 

Washington, DC 20585 

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