CHARLES W. DENT 15TH DISTRICT, PENNSYLVANIA
COMMITTEE ON APPROPRIATIONS
COMMITTEE ON ETHICS 

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The Honorable Ernest Moniz Secretary U.S. Department ofEnergy 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 vvww.dent.hollse.gov twitter,comldentpresssh 0 p www.facebook.comlcan9ressmandent

RE: Proposed Rulemaking on Energy Efficiency Standards for Commercial Ice Makers Dear Secretary Moniz: I am writing to requestthatyou 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 ofa piece ofcorrespondence I recently received from one ofmy 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 EPAregulations pertaining to the viability ofcomponent parts. Thank you for your consideration ofmy request and I look forward to your timely response. Sincerely,

# C~)\N.~ Charles W. Dent Member ofCongress
CC: Mr. Steven Follett, President and CEO, Follett Corporation


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## , !.EH1GH VALLEY 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

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May 5,2014
The Honorable Charles W. Dent Member ofCongress, FifteenthDistrict ofPennsylvania 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 Standardthat the Department ofEnergy (DOE) is enacting. The DOE has published aNotice ofProposed 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 onthe 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% ofthe market). In addition, over 75% ofthe icemakers that Follett manufacturers that qualify for consideration under the current ENERGY STAR ice maker program are ENERGY STAR certified. With orwithout the DOErule, 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 ofthe impact ofenergy-efficient components on overall machine efficiency • Underestimation oftiming, capital, resources, and product costs ofimplementing said technology • Impact ofenergy-efficient components on the reliability ofthe machines and the costs to manufacturers and end users to service and maintain the machines • Lack ofanalysis ofall icemaker categories in the proposed ruling • Disregard for impact ofpending EPA refrigerant legislation (SNAP) • Lack ofregard for impact on machines sold outside the USA • Disregard for opportunity cost ofdedicating resources to implementing required changes • Underestimation ofeffect on employment levels Follett Corporation and other ice maker manufacturers are in the process ofcommenting onthe 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.-2- Follett Corporation is a small business withjust over 400 employees, most ofwhich 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 oftheir 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 ofsupport. 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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