Last August, the U.S. Department of Energy released a proposed rule to impose more stringent energy conservation standards for beverage vending machines sold in the United States. The DOE issued the rule pursuant to a mandate included in the Energy Policy and Conservation Act of 1975 (EPCA), which regulates appliances, including refrigerated bottled or canned beverage vending machines, among other commercial and industrial equipment.
Reducing energy consumption in vending machines is an important goal. In fact, the vending industry has reduced the amount of energy consumed by vending machines by nearly 60% within the past 10 years, and has steadily increased the number of Energy Star compliant machines in the field.
After reviewing the proposed rule, the industry determined that it was neither "technologically feasible" nor "economically justified" -- two requirements mandated by the EPCA. Accordingly, the National Automatic Merchandising Association formalized a grassroots advocacy strategy to oppose the proposal, and to seek a solution that included a reasonable, attainable standard for the industry while creating a significant reduction in the amount of energy consumed by beverage vending machines, as required by the EPCA.
NAMA participated in the DOE's September 2015 stakeholder meeting with machine manufacturers and beverage companies to further educate ourselves on the proposal and begin the formal process of voicing our concern over the proposed rule. The time for comments on the proposal expired soon after the meeting. Immediately following the meeting, NAMA, industry leaders and the U.S. Small Business Advocacy Office were successful in having the comment period reopened to allow for further input on the proposal.
Upon the reopening of the comment period, NAMA built upon the relationships created with U.S. Senate offices during the 2015 inaugural Washington Fly-In, and the relationships created with the SBA and the White House at our annual Public Policy Conference. Industry leaders responded to the call in what became the largest and most comprehensive grassroots campaign in the industry's recent history.
The NAMA-led effort opposing the proposed rule included more than 1,100 comments submitted to the DOE by concerned industry leaders, the SBA, vending machine manufacturers, the European Vending Association and the American Beverage Association. Furthermore, the relationships formed during the Fly-In laid the foundation for a letter opposing the proposed standard that was signed by five U.S. Senators. In addition, one U.S. Senate office reached out to DOE and met with officials at the agency personally on the issue. The immediate support from senators and federal agencies would not have been possible without the relationships created during the Fly-In and Public Policy Conference.
In late December, the DOE issued the final rule. It will take effect on Jan. 8, 2019, and it's too technologically complex to explain in great detail in this editorial. In summary, the DOE reviewed the comments received from industry, government agencies and elected officials and ultimately agreed that the proposed standards should be amended to provide a technologically feasible and economically justified standard. Not only did the final rule create a reasonable, attainable standard for the industry, it also created a significant reduction in energy consumption -- a goal the industry agreed with as well.
The DOE estimates that the changes implemented in the final rule create a savings to small machine manufacturers of $130,000 and large machine manufacturers of $421,000 from what the impact would have been if the proposed rule had been implemented. This savings was created by the many industry volunteers who assisted in this NAMA-led effort. The savings impacts the entire industry, especially the end user: the vending operator. If the proposed rule had been implemented, there would have been a significant increase in costs of vending machines to operators.
As noted earlier, the final rule also creates significant energy consumption reductions. The rule's cumulative reduction in CO2 emissions through 2030 amounts to 1.16 MT (metric tons), which is equivalent to the emissions resulting from the annual electricity use of more than 160,000 homes. This is a fact that the industry should promote widely to consumers and potential client sites. The industry is playing an important role in furthering sustainability efforts related to energy consumption and reduction of greenhouse gases in the environment.
This campaign was an example of why industry participation in grassroots advocacy in crucial and how it works to create a win-win solution! NAMA's Government Affairs division organized and led the effort, but it was successful because of the participation of industry volunteers and the personal relationships created during events like the Washington Fly-In and PPC with elected and agency officials. This campaign demonstrates how citizen involvement in government works. NAMA's government affairs division urges industry leaders to remain vigilant and involved in advocacy issues to strengthen and protect the industry. We can't do it without you, and we look forward to seeing you in Washington on July 12 and 13 for NAMA's 2016 Fly-In.
ERIC DELL is senior vice-president of government affairs for the National Automatic Merchandising Association. He previously served as chief of staff and counsel to Congressman Joe Wilson and as vice-president of the Keelen Group (Washington, DC).
NAMA Hails Members' Support In Commenting On DOE Vending Machine Rule; Terms Standards "Unattainable"