The Department of Energy (DOE) is proposing to amend the definition for Class A refrigerated bottled or canned beverage vending machines (beverage vending machines) to more clearly differentiate Class A from Class B equipment as well as amend the definition of combination vending machines.
NAMA is actively working with U.S. Senators to finalize a letter to the DOE opposing the proposed standards as well as enlisting the assistance of the Small Business Administration’s Advocacy Office and the industry.
“The DOE’s proposed rule is overly burdensome on the industry both technologically and economically,” explained Eric Dell, NAMA senior vice president of Government Affairs. “The Energy Policy and Conservation Act of 1975 (EPCA), which is the law that DOE is promulgating these standards under requires that any new or amended energy conservation standard must be designed to achieve the maximum improvement in energy efficiency that is technologically feasible and economically justified.” NAMA does not believe the new rules are feasible or justified under the circumstances.
NAMA is asking that DOE revisit this proposal by working more closely with industry leaders to revise the standard to something attainable and reasonable that would not be enforceable until 2022.
Industry members are encouraged to add their voice to this matter by commenting before the November 23 deadline.
"This issue should be in the front on minds for operators and the entire industry because DOE has proposed standards that would create an increase in the price of vending machines and one that is not technologically feasible or economically justified at this point in time," said Dell. "It would especially impact the bottom line of small business operators by increasing their costs to run their businesses and making it more difficult to compete. Due to the slim profit margins in the vending industry, the downstream effect is price increases for consumer who buy from vending machines."
Industry stance
NAMA and the industry is opposed to the DOE’s proposed energy conservation standards for the following reasons:
- The standards are not technologically feasible.
- The standards are not economically justified due to the burden they pose on an industry which is comprised largely of small business entities already attempting to simultaneously update refrigerants to meet other EPA mandates and comply with new DOE testing procedures.
- The standards propose a definition of “combination vending machines” that is not consistent with industry practice and knowledge and has not been tested to the proposed standard.
- The standards would eliminate the current ENERGY STAR specification as being the “most efficient” standard causing confusion and removing the credibility of ENERGY STAR in the industry.
- The DOE has not provided industry or consumers with proof to substantiate their claim that beverage machines using CO2 that meet the proposed standard levels are already available.
Background
In July 2015, the Environmental Protection Agency (EPA) announced that they will ban the use of the most widely used Freon refrigerants in vending machines and replace them with more “environmentally friendly” refrigerants including CO2 and propane. This EPA rule will result in mandatory redesigns of every vending machine and will likely result in less efficient operation of the machines. The refrigerant ban becomes effective at the end of 2018, but in the engineering and manufacturing business this is truly a very tight schedule.
Later in July a second regulation was issued impacting beverage vending machines. This regulation was released by the Department of Energy and it revised the energy consumption test procedure. The new test procedure will result in a higher measured energy consumption and will machine manufacturers to improve machine efficiency by nearly 5%. This follows an increase in efficiency in vending machines of approximately 60% to comply with 2012 rules.
In August, DOE proposed another rule to further increase efficiency by another large percentage effective in 2019. The comment period initially closed on this rule and was recently reopened to provide for the industry and stakeholders to submit more comments. NAMA and almost every machine manufacturer have filed comments opposing the new standards. The new comment period closes Monday, November 23, 2015.
