# 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

David Petzel 1631 Ravine Lane Carpentersville, Illinois 60110
The Honorable Ernest Moniz Secretary U.S. Department ofEnergy 1000 Independence Avenue, SW Washington, DC 20585

Dear Secretary Moniz, July 1, 2014

We are writing to oppose the U.S. Department ofEnergy rulemaking that wouldestablish new energy efficiency standardsfor 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 inthe form ofa negotiated rulemaking,to ensure accurate data is used to establish an energy conservation standard and compliance timeline that does not negatively affect employment ofmanufacturers and end. users, which are largely comprised ofsmall restaurants. We have serious conce,ms thatthese new guidelines will impose a significant financial strain on manufacturers that could only be 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 vvill result in an immediate reducti.on in the variety of products available in the marketplace. We are alarmed at the likelihood thatthese 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 smal.l businesses across the foodservice industry with inevitable reductions in scarce manufacturingjobs and employment cuts inthe restaurant industry that will be required as a result ofthe unduly burdensome cost increases. T.he proposed rule would place a significanteconomic burdenon man.ufacturers in both

' ' ' ' their development andproduct costs in m:der to be compliant ofa 70% improvement in energy efficiency from the 2005 standard by 2017. Additionally, DOE armounced this rule mightbe expandedto cover new standards for those with capacities above 2,500 pounds per 25-hour period. We strongly oppose expansion ofthis rule 

## tolarger capacity commercial ice makers and urge you to recqnsider this decisioμ.

. . · ·

BUSINESS UNITS: Antunes China Antunes Controls ROUNDUP Foodservice Equipment VIZION Water Treatment Technologies

# .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 Ofgreatest concern, the DOE rule does not account for research, development and productiontime frame. On average, redesigning all machines wouldtake six to eight years ifthe parts were available at this time. As most commercial ice makers inuse today do not meet the new energy efficiency requirements, the industry will have to invest heavily inresearch 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 componentparts confirm the necessary energy efficient components, specified inthe proposed rule, are not inthe marketplace today. NAFEMmembers 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 certificationthatrecognizes the most efficient products in the market. Infact, EPA has recognized several ofthese manufacturers as "ENERGY STARPartner ofthe Year" multiple times dating backto 2009, demonstrating their good faith and concernfor energy efficiency. The fundamentally flawed economic and technological analyses have resulted in a proposed rule that is not technologically achievable within the proposedtimeline. We request that the Department enters a negotiatedrulemaking withACIMmanufacturers to create a common sense energy conservation standard with an achievable compliance timeline.

Sincerely,

# IJJ~, Director, Information Technologies A.J. Antunes & Co.

BUSINESS UNITS: Antunes China Antunes Controls ROUNDUP Foodservice Equipment VIZION Water Treatment Technologies

### . 

# A.J. 

# Antunes &Co.
180 Kehoe Boulevard e P.O. Box 87700@ Carol Stream, IL 60188 USA \N \!If vv
. a j a n t u n e s
. f. o m

Ernest Moniz Secretary Ct\iROL SlrlRE;AM ItIOiOl 07 J!LflL "l,'H Pf''l J L

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

# J!Jl 14 

# 20!4 MAIl ;:-,./,\clU


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