BRADLEY S. SCHNEIDER 10TH DISTRICT, ILLINOIS COMMITTEE ON FOREIGN AFFAIRS SUBCOMMITTEE ON MIDDLE EAST AND NORTH AFRICA SUBCOMMITTEE ON TERRORISM, NONPROLIFERATION AND TRADE COMMITTEE ON SMALL BUSINESS SUBCOMMITTEE ON HEAL TH AND TECHNOLOGY SUBCOMMITTEE ON ECONOMIC GROWTH, TAX AND CAPITAL ACCESS 

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The Honorable David Danielson Assistant Secretary March 29, 2013

Office ofEnergy Efficiency and Renewable Energy U.S. Department ofEnergy 1000 Independence Ave, SW Washington, DC 20585-0121 317 CANNON BUILDING WASHINGTON, DC 20515 (202) 225-4835 DISTRICT OFFICE: 111 BARCLAY BLVD, SUITE 200

LINCOLNSHIRE, IL 60069 (847) 793-0625

RE: Energy Conservation Standards for Battery Chargers and External Power Supplies (DocketNumber EERE 2008-BT-STD-0005) Dear Assistant Secretary Danielson: I write to you on behalfofmy constituent, Schumacher Electric Corporation ("Schumacher"), to ask thatthe Department ofEnergy enact a July 1, 2014 manufacturing deadline for compliance with the new energy standard. First, let me emphasize that I appreciate the work the Department ofEnergy (DOE) has done thus far onthe rulemaking for the Energy Conservation Standards for Battery Chargers and External Power Supplies. Furthermore, Schumacher is supportive ofthe DOE's efforts to develop stronger efficiency standards. However, a near-term compliance deadline would create significant challenges for Schumacherthat other manufacturers in the industry will not face. SchumacherElectric Corporation, based in Mount Prospect, Illinois, is the leading manufacturer ofautomotive battery chargers sold inthe United States. Its battery chargers and maintainers lead the market for agricultural, automotive, marine, recreational and specialty applications. As a result ofthis significant market share, Schumacherhas invested considerable capital to improve the efficiency ofits products while ensuring that its customers are able to purchase safe, reliable and cost-effective chargers and maintainers. It is myunderstanding that some industry commentators have requested that the DOE enact a near immediate effective date for its newbattery charger rule, forgoing its long-held practice withregard to the issuance ofguidance. Many ofthese commentatorsproduce rechargeable batteries that are used in consumer products, such as those for laptops, electric toothbrushes and cell phones that contain or utilize a battery charger. Schumacher, onthe other hand, is unique inthat the consumerproduct it produces is a battery charger, for example to be used tojumpstart a carbattery in an emergency.

PRINTED ON RECYCLED PAPERFor the vast majority ofmanufacturers, they will simply need to package theirproduct with a newbattery charger, but otherwise the product itselfwill not demand significant packaging changes. Because ofthe distinct type ofbattery chargers Schumacherproduces, the company's entire supply chain will be impacted. Schumacher will be required to provide new packaging with new SKU numbers for retailers, which could also likely result in a large inventory ofexisting products returned by retailers. Additionally, all ofthe new models will require agency approval from UL. As you know, UL has a standard lead time for approval of each SKU submitted. When applied across Schumacher'sproduct line, a compliance date earlier than July 1, 2014 would be extremely difficult, ifnot impossible, to achieve. Due to the unique circumstances surrounding Schumacher's production ofbattery chargers that will be impactedbythe DOE'srule, I respectfully request that the agency consider a July 1, 2014 compliance deadline for such dedicated battery chargers. Thank you for your attention to this matter. Please do not hesitate to contact me ormy staff, ifwe canbe offurther assistance as the DOE completes its work onthis pending rule.

cc: Sincerely,

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Mr. Jeremy Dommu, Office ofEnergy Efficiency and Renewable Energy, Building Technologies Program, EE-2J, jeremy.dommu@ee.doe.gov Mr. Michael Kido, U.S. Department ofEnergy, Office ofthe General Counsel, Michael.Kido@hg.doe.gov