# 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

Michael De Boni 6302 Ventura Court Plainfield, Illinois 60586

The Honorable ErnestMoniz Secretary U.S. Department ofEnergy 1000 Independence Avenue, SW Washington, DC 20585

Dear Secretary Moniz, June 27, 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 significant financial strain on manufacturers that could only be recouped by passingthe costs to end users with significantraises inprices. Additionally, manufacturers indicate that the up-front costs required for developing and testing products will result in an immediate reduction in the variety of products available inthe marketplace. We are alarmed at the likelihood that these unintended consequences will negatively affect employment in the 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 in the restaurant industry that will be required as a result ofthe unduly burdensome cost increases. The proposedrule would place a significant economic burden on manufacturers 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 mightbe expanded to covernew standards for those with capacities above 2,500 pounds per 25-hour period. We stropgly oppose expansion ofthis rule to larger capacity commercial ice makers and urge youto 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 DOE rule does not account for research, development and productiontime frame. On average, redesigning all machines would take six to eight years ifthe parts were available atthis 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 proposedrule, 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 STAR certificationthat recognizes the most efficientproducts inthe market. In fact, EPAhas 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. We request thatthe Department enters a negotiated rulemaking with ACIM manufacturers to create a common sense energy conservation standard with an achievable compliance timeline.

Sincerely,

# ~x~ Michael De Boni Director, Customer Support Services A.J. Antunes & Co.

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, IL 60188 USA wwvv.ajantunes.com



# RECEIVED

JUL 

## 0 B 21114 

# fr-tAit S'ANITi2'.EO Ernest Moniz Secretary CJ!1J'f:.:tLJL**S1":f4~Et\~·.1** J[t (-i!C!l 1-:i:t:**.:~L;Yl 1~t** 

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



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