# LAKESIDE " MOVINGFOODSfRVICEFORWARDm
4900West Electric Avenue. West Milwaukee, Wiscensin 53219-1629
June 6, 2014

The Honorable Ernest Moniz Secretary U.S. Department of Energy 1000 Independence Avenue, SW Washington, 

### DC 20585
Dear Secretary Moniz,
We are writingto oppose the 

## u.s. Department of Energy rulemaking that would establish new energy efficiency standards for 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 in the 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 of manufacturers 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 passing the costs to end users with significant raises in prices. Additionally, manufacturers indicate thatthe up-front costs required for developing and testing products will result in an immediate reduction in the variety ofproducts available in the marketplace. We are alarmed atthe likelihood that these 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 small businesses across the foodservice industry with inevitable reductions in scarce manufacturingjobs and employment cuts in the restaurant industrythat will be required as a result ofthe unduly burdensome cost increases. The proposed rule would place a significant economic burden on manufacturers in both their development and product costs in orderto be compliant ofa 70% improvement in energy efficiency from the 2005 standard by 2017. Additionally, DOE announced this rule might be expanded to cover newstandards forthose with capacities above 2,500 pounds per 25-hour period. We strongly oppose expansion ofthis rule to larger capacity commercial ice makers and urge you to reconsider this decision. 

### Of greatest concern, the DOE rule 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 atthistime. As most commercial ice makers in use today do not meetthe new energy efficiency requirements, the industry will have to invest heavily in research and development. This process is already underway; however, the technologyto achieve the proposed standard is not currently available. In fact, manufacturers that supply commercial ice maker component parts confirm

USA 800.558.8565 CANADA 800.241.9944 Phone 414.902.6400 Sales & Service Fax 414.902.6446 Accounting Fax 414.902.6430 Purchasing Fax 414.902.6420 E·Mail info@eLakeside.com Web Site eLakesideFoodservice.com

# LAKESIDE" MOVING FOOD5ERVICEFORWARDm
4900 West ElectricAvenue. West Milwaukee, Wisconsin 53219-1629 the necessary energy efficient components, specified in the proposed rule, are not in the marketplace today. NAFEM members are already workingtirelessly to develop, test, and manufacture products that meet stringent energy efficiency standards to achieve the Environmental Protection Agency's (EPA) ENERGY STAR certification that recognizes the most efficient products in the market. In fact, EPA has recognized several ofthese manufacturers as "ENERGY STAR Partner oftheYear" multipletimes dating back to 2009, demonstratingtheir good faith and concern for energy efficiency. The fundamentallyflawed econo,nic and technological analyses have resulted in a proposed rule that is nottechnologically achievable within the proposed timeline. We request that the Department enters a negotiated rulemaking with ACIM manufacturers to create a common sense energy conservation standard with an achievable compliance timeline.
Sincerely,
Lakeside Manufacturing

USA 800.558.8565 CANADA 800.241.9944 Phone 414.902.6400 Larry Moon, CEO

Sales & Service Fax 414.902.6446 Accounting Fax 414.902.6430 Purchasing Fax 414.902.6420 E-Mail info@eLakeside.com Web Site eLakesideFoodservice.com

# BLAKESIDE® 4900 W. ElectricAve. WestMilwaukee,WI53219


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