# A.J. Antunes 

# &Co.

180 Kehoe Boulevard • P.O. Box 87700 • Carol Stream, Illinois 60188 USA PH: 630.784. I000 • TF: 800.253.2991 ' FAX: 630.784. 1650 • www.ajantunes.com

Carlos Corcelles 74 Glenbrook Circle Gilberts, IL 60136
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 ofEnergyrulemaking that would establish new energy efficiency standards for automatic commercial ice makers (ACIM) with capacities betweenSO 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 compliancetimeline 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 onmanufacturers that could onlybe recoupedby passing the costs to endusers with significantraises inprices. Additionally, manufacturers indicate that the up-front costs required for developing and testingproducts will result in an immediate reduction inthe 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 inthe restaurant industry that will be required as a result ofthe unduly burdensome costincreases. The proposed rule would place a significant economic burden on manufacturers inboth their development and product costs in orderto be compliant ofa 70% improvementin energy efficiency from the 2005 standard by 2017. Additionally, DOE armounced this rule mightbe expandedto cover new standards for those with capacities above2,500 pounds per 25-hour period. We strongly 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: 630.734.1000 'Tf: 800.253.2991•FAX:630.784.1650 • www.ajantunes.com

Ofgreatest concern, the DOE rule does not account for research, development and production time frame. On average, redesigning all machines wouldtake six to eight years ifthe parts were available at this time. 

### As mostcommercial ice makers inuse today do notmeetthe 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 confirmthe 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, EPAhas recognized several ofthese manufacturers as "ENERGY STAR Partner ofthe Year" multiple times dating backto 2009, demonstrating their good faith and concern for energy efficiency. The fundamentally flawed economic and technological analyses have resulted in a proposed rule thatis 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.

Sincerelyr**.~**

Car 

# s Corce les Vice'President Human Resources A.J. Antunes & Co.

BUSINESS UNITS: Antunes China Antunes Controls ROUNDUP Foodservice Equipment VIZION Water Treatment Technologies

# A.J. 

# Antunes & 

# Co.
180 Kehoe**Boulevard~** PO 

### B- 8 7 ·-**---~······** w w w a J. an_,. · · ox 7 00 ®Carol Stream IL 60188 USA

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# RECEIVED JUL 06**20\~** 

## MAJ!:: S-ANIT!;lEB

;;;: - ;; JLl _J • ErnestMoniz Secretary (Ii.£ J!UL 2014

U.S. Department ofEnergy JOOO Independence Avenue SW Washington, DC 205&5 '