On October 20, 2011 , representatives of Howe Corporation, Gade Environmental, and Beecon ProfServe met with DOE to discuss the proposed rules EERE

- 2010 BT

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- 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
Jo hn 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

c onsider 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 t he Final Rule to reflect the use of continuous production ACIM’s across all applications, not exclusively beverage application s

. 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 acc urately 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. H owe Corporation respectfully submits that the Ice Quality Adjustment factor be referred to
as the Water Content Adjustm ent 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.
H owe Corporation respectfully requests that , until an Alternative Rating Method is in place, remote ACIM’s intended for use with remote parallel compressor rack s be included in the
DOE final ruling using the r emote ACIM including a r emote c ondensing u nit 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 part ial load capacity control and heat reclaim and also due to the
similarities of these systems to the remote condensing units as defined in th e 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

rem ote 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