# 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

Cheri Panasik, Ph.D. 4N610 Deerslayer Drive Elburn, Illinois 60119 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 would establish new energy efficiency standards for automatic commercial ice makers (ACIM) with capacities between 50 and 2,500 pounds per 24-hourperiod. We request that a collaborative process is implemented in the form ofa negotiated rulemaking to ensure accurate data is used to establish an energy conservation standard and compliance timeline that does notnegatively affect employment ofmanufacturers and end users, which are largely comprised ofsmall restaurants. We have serious concerns that these new guidelines will impose a significantfinancial strain on manufacturers that could only be recouped by passing the costs to end users with significantraises inprices. Additionally, manufacturers indicate that.the up-front costs required for developing andtesting products will result in an immediate reduction in the variety of products available inthe marketplace. We are alarmed at the likelihoodthat these unintended consequences will negatively affect employmentinthe manufacturing community and foodservice industry. The rule would have a direct costto 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 manufacturingjobs and employment cuts inthe restaurant industry that will be required as a result ofthe unduly burdensome cost increases. The proposed rule would place a significant economic burden onmanufacturers in both their development and product costs in order to be compliant ofa 70% improvement in energy efficiency from the 2005 standard by 2017. Additionally, DOE announced this rule might be expanded to covernew standards for those with capacities above 2,500 pounds per25-hour period. We strongly oppose expansion ofthis rule to larger capacity commercial ice makers and urge you to reconsider this decision.

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

# 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 Ofgreatest concern, the DOErule does not account for research, development and production time frame. On average, redesigning all machines would take six to eight years ifthe parts were available atthis time, As most commercial ice makers in use today do notmeet 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 confirmthe necessary energy efficient components, specified inthe 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 STARcertificationthatrecognizes the most efficientproducts in the market In fact, EPA has recognized several ofthese manufacturers as "ENERGY STARPartner ofthe 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 nottechnologically achievable within the proposedtimeline. Werequest that the Department enters a negotiated rulemaking with ACIM manufacturers to create a common sense energy conservation standard with an achievable compliance timeline,

Sincerely,

Cheri Panasik, Ph.D. Vice President Vice President, Engineering A.J. Antunes & Co,

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

# A.J. Antunes &Co.
180 Kehoe Boulevard@ P.O. Box 87700**~Carol** Stream, IL 60188 USA w 1;v w . a j a n t u ri e s
. t o m


# RECEIVED JUL 0820!4 MAIL SANITIZED ErnestMoniz Secretary Ci:O.ROL STREAM It'6!.')1 CQ 3Ut**"Ji:'~** PM l L

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

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