LAKESIDE " 

MOVING FOODSfRVICE FORWARDm 

4900 West 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 writing to 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 of a 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 of small 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 that the up-front costs required for developing and testing 

products will result in an immediate reduction in the variety of products available in the marketplace. 

We are alarmed at the likelihood that these unintended consequences will negatively affect 

employment in the manufacturing community and food service 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 manufacturing jobs and employment cuts in the restaurant industry that will be required as a 

result of the unduly burdensome cost increases. 

The proposed rule would place a significant economic burden on manufacturers in both their 

development and product costs in order to be compliant of a 70% improvement in energy efficiency 

from the 2005 standard by 2017. Additionally, DOE announced this rule might be expanded to cover 

new standards for those with capacities above 2,500 pounds per 25-hour period. We strongly oppose 

expansion of this 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 at this time. As most commercial ice makers in use today do not meet the new energy 

efficiency requirements, the industry will have to invest heavily in research 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 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 FOOD5ERVICE FORWARDm 

4900 West Electric Avenue. 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 working tirelessly 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 of these manufacturers as "ENERGY STAR Partner ofthe Year" multiple times 

dating back to 2009, demonstrating their good faith and concern for energy efficiency. 

The fundamentally flawed econo,nic and technological analyses have resulted in a proposed 

rule that is not technologically 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. Electric Ave. 

West Milwaukee, WI 53219 

RECEIVED 

JUN 1 6 2014 

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