On October 20, 2011, representatives of Howe Corporation, Gade Environmental, and Beecon ProfServe 

met with DOE to discuss the proposed rules EERE-2010 BT-TP-0036 RIN 1904-AC38 Energy Efficiency 

Program for Certain Commercial and Industrial Equipment: Test Procedures for Commercial Ice Makers. 

The meeting was held at the request of Howe Corporation at the DOE offices in Washington DC.

In attendance:

Ari Altman, DOE

Ashley Armstrong, DOE

Robert Bittner, Beecon ProfServe

John Cymbalsky, DOE

Mary Gade, Gade Environmental Group

Mary Howe, Howe Corporation

Charles Llenza, DOE

Jeff Mackowiak, Howe Corporation

Mark O’Malley, Gade Environmental Group

Howe Corporation introduced and discussed the following concerns regarding the NOPR. For reference, 

a copy of the comments by Howe Corporation submitted on June 3, 2011 to the DOE are attached.

1.

Howe Corporation respectfully submits that the current rulemaking process did not fully 

consider small companies due to reliance on input from member-based trade associations that 

represent large companies.

Industry Involvement in the Rulemaking Process

2.

a. Howe Corporation respectfully requests that the Ice Quality Adjustment Factor be included 

and required by the Final Rule to reflect the use of continuous production ACIM’s across all 

applications, not exclusively beverage applications. 

Ice Quality Adjustment Factor

b. In addition, Howe Corporation requests that potable water usage be stated for all 

continuous production ACIM’s in order to accurately calculate both the amount of chilled 

water that is drained away in the process of ice production and the energy used to chill this 

waste water. 

c. Howe Corporation also requests that the IQAF should provide for sub-cooled ice by allowing 

an IQAF with a value of less than one in order to accurately account for the amount of

energy expended for the actual cooling capacity of the ice. 

d. Howe Corporation respectfully submits that the Ice Quality Adjustment factor be referred to 

as the Water Content Adjustment Factor, as ASHRAE does not define Ice Quality and AHRI 

refers to Harvest Water Content. 
Re: Meeting of October 20, 2011

EERE-2010 BT-TP-0036

RIN 1904-AC38

Energy Efficiency Program for Certain Commercial and Industrial Equipment: Test Procedures for

Commercial Ice Makers

Page Two

3.

Howe Corporation respectfully requests that, until an Alternative Rating Method is in 

place, remote ACIM’s intended for use with remote parallel compressor racks be included in the 

DOE final ruling using the remote ACIM including a remote condensing unit test data as 

discussed in the NOPR Page 18434 Paragraph 1. Remote parallel compressor racks are 

inherently more efficient than a dedicated remote condensing unit as the rack systems provide 

the benefit of lower condensing temperatures, mechanical and/or natural sub-cooled liquid 

supply with efficient partial load capacity control and heat reclaim and also due to the

similarities of these systems to the remote condensing units as defined in the Rulemaking 

Framework for Commercial Refrigeration Equipment.

Remote ACIM’s

4.

Howe Corporation respectfully submits that the cost of testing was underestimated for 

manufacturers producing remote ACIM’s due to the number of available configurations of 

remote ACIM’s and would be excessive for small manufacturers. Attached is a copy of the 

updated information regarding SKU’s that was provided at the October 20 meeting. Any 

grouping of units that would allow for reduced physical testing would lessen this financial 

burden.

Cost of Testing

Submitted by:

Mary C. Howe

Howe Corporation

1650 North Elston Avenue

Chicago, Illinois 60642