CHARLES W. DENT 

15TH DISTRICT, PENNSYLVANIA 

COMMITTEE ON APPROPRIATIONS 

COMMITTEE ON ETHICS 

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The Honorable Ernest Moniz 

Secretary 

U.S. Department of Energy 

1000 Independence Ave, SW 

Washington, DC 20585-0900 

May 16, 2014 

2455 RAYBURl~ HOUSE OFFICE BUILDING 

WASHINGTON, DC 2051[> 

(202) 225-6411 

FAX: (202) 226-0778 

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RE: Proposed Rulemaking on Energy Efficiency Standards for Commercial Ice Makers 

Dear Secretary Moniz: 

I am writing to request that you work with commercial ice makers and interested parties in good 

faith on any proposed rule that would modify efficiency standards for commercial ice makers 

with capacities between 50 and 2,500 pounds per 24-hour period. 

Attached herewith is a copy of a piece of correspondence I recently received from one of my 

constituents. Based upon his comments, I am concerned that your agency has not fully taken into 

consideration the impact this proposed rule will have on the commercial ice maker industry. 

Additionally, the proposed regulation, as currently written, contradicts existing EPA regulations 

pertaining to the viability of component parts. 

Thank you for your consideration of my request and I look forward to your timely response. 

Sincerely, 

C~)\N.~ Charles W. Dent 

Member of Congress 

CC: Mr. Steven Follett, President and CEO, Follett Corporation 

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3900 HAMILTON BOULEVARD, SUITE 207 

ALLENTOWN, PA 18103 

i6la) 770-3490 

FAX: (610)770-3498 

BERKS COUNTY 

61 NORTH 3RD STREET 

HAMBURG, PA 19526 

(610)562-4281 

FAX: (610) 562--4352 

LEBANON COUNTY 

. 342 F. WrtST MAIN STREET 

ANNVILLE, PA 17003 

(717)867-1026 

FAX: (717) 867-1540 

DAUPHIN COUNTY 

250 WEST CHOCOI.A'fE AV~NUE, SUITE 2 

HERSHEY, PA 17033 

(717) 533-3959 

FAX: (717) 533-3979 
#bZZEII® 

Innovative solutions, inspired by ice 

May 5,2014 

The Honorable Charles W. Dent 

Member of Congress, Fifteenth District of Pennsylvania 

3900 Hamilton Blvd., Suite 207 

Allentown, PA 18103 

Dear Charlie: 

801 Church Lane, Easton, PA 18040 

(800) 523-9361· (610) 252-7301· Fax (610) 250-0169 

www.fol/ettice.com.._ 

I am writing to request your support rebutting an Energy Conservation Standard that the 

Department of Energy (DOE) is enacting. The DOE has published a Notice of Proposed 

Rulemaking for Automatic Commercial Ice Makers EERE-201O-STD-0037. This standard is 

scheduled to be published on January 1, 2015, with implementation within a three-year period. 

The DOE is proposing standards that are so stringent that they would have a significant negative 

impact on the industry as a whole and on Follett Corporation individually. 

Follett Corporation supports the DOE initiative to call for more efficient energy and water usage 

standards. We have consistently designed equipment with sustainability in mind. Follett's ice 

machines, for example, use 40% less water than typical batch type icemakers (which represent 

over 80% of the market). In addition, over 75% of the icemakers that Follett manufacturers that 

qualify for consideration under the current ENERGY STAR ice maker program are ENERGY 

STAR certified. With or without the DOE rule, Follett Corporation will continue to invest 

resources in developing energy-efficient equipment. 

The DOE has performed an analysis to determine acceptable efficiency standards. However, the 

analysis has many flaws, including, but not limited to, the following: 

• Overestimation of the impact of energy-efficient components on overall machine efficiency 

• Underestimation of timing, capital, resources, and product costs of implementing said 

technology 

• Impact of energy-efficient components on the reliability of the machines and the costs to 

manufacturers and end users to service and maintain the machines 

• Lack of analysis of all icemaker categories in the proposed ruling 

• Disregard for impact of pending EPA refrigerant legislation (SNAP) 

• Lack of regard for impact on machines sold outside the USA 

• Disregard for opportunity cost of dedicating resources to implementing required changes 

• Underestimation of effect on employment levels 

Follett Corporation and other ice maker manufacturers are in the process of commenting on the 

rulemaking, but we are concerned that the data provided by ice maker manufacturers will not be 

enough to alter the flawed analysis and impact change on the current proposal. 
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Follett Corporation is a small business with just over 400 employees, most of which live in the 

Lehigh Valley. Over the last four years, we have added over 120 employees. The DOE 

determined that the business case for small businesses would result in a -78.6% NPy. 

A fellow ice maker manufacturer has enlisted the support of their local congressman in Georgia, 

Mr. Lynn Westmoreland. His letter is attached. The DOE requires written input by May 16. We 

would appreciate a similar show of support. I am available to discuss this rulemaking at your 

convenience to explain our position in greater detail. Thank you for your attention in this matter. 

Sincerely, 

FOLLETT CORPORATION 

Steven R. Follett 

President and CEO 

Attachment 
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