Dr. Uwe Mette 

Department of Energy 

Washington, DC 20585 

March 30, 2011 

Director, Engineering Laundry Products 

BSH Home Appliances Corporation 

5551 McFadden A venue 

Huntington Beach, CA 92649 

Dear Dr. Mette: 

This letter is in response to your December 28, 2009, petition for waiver and application for 

interim waiver on behalf of BSH Home Appliances Corporation (BSH) from the test procedure 

applicable to residential clothes dryers under Title 10 of the Code of Federal Regulations (10 

CFR), Part 430. For the reasons discussed below, the U.S. Department of Energy (DOE) grants 

an interim waiver to BSH from the test procedure set forth in 10 CFR Part 430, Subpart B, 

Appendix D for BSH's condensing clothes dryers, models Bosch WTC82100US and Bosch 

WTE86300US. 

Under 10 CFR Part 430, the Assistant Secretary for Energy Efficiency and Renewable Energy 

(the Assistant Secretary) will grant an interim waiver from test procedure requirements if it is 

determined that the applicant will experience economic hardship should the appli cation for 

interim waiver be denied. An interim waiver will also be granted if it appears li kely that the 

petition for waiver will be granted and/or the Assistant Secretary determines that it would be 

desirable for public policy reasons to grant immediate reli ef pending a determination on the 

petition for waiver. 10 CFR 430.27(g). 

DOE has determined that BSH's application for interim waiver does not provide sufficient 

market, equipment price, shipments, and other manufacturer impact information to enable DOE 

to evaluate the economic hardship that BSH might experience absent a favorable determination 

on its application for interim waiver. DOE understands, however, that absent an interim waiver, 

BSH 's products could not be tested and rated for energy consumption on a comparable basis 

with equivalent General Electri c (GE), LG. Miele and Whirlpool products for which DOE has 

previously granted waivers. In 1995, DOE granted Miele a similar waiver because the clothes 

dryer test procedures were not applicable to Miele condenser clothes dryers given the lack of an 

exhaust port for mounting the required exhaust restrictor. DOE granted Miele an interim waiver 

for similar additional products in 20 II . DOE granted LG a waiver for condensing clothes dryers 

in 2008 and similar waivers to Whirlpool and GE in 2009 and 2010, respectively. DOE believes 

that the aforementioned BSH condenser clothes dryers will encounter the same testing problems 

that prompted DOE to grant waivers for similar product designs, and thus, it is likely that BSH's 

petition for waiver will be granted. In addition, DOE believes it is in the public interest to have 

similar products tested and rated for energy efficiency on a comparable basis. DOE has 

determined that it is desirable for public policy reasons to grant BSH immediate relief pending a 

determination of the petition for waiver. 
Therefore, BSH shall not be required to test its condenser clothes dryer models Bosch 

WTC82100US and Bosch WTE86300US according to the applicable DOE test procedure, which 

is found in 10 CFR 430, Subpart B, Appendix D. 

This interim waiver is conditioned upon the presumed validity of statements, representations, and 

documents provided by the petitioner. DOE may revoke or modify this interim waiver at any 

time upon a determination that the factual basis underlying the petition for waiver is incorrect. 

The interim waiver shall remain in effect for a period of 180 days or until DOE issues its 

determination on the petition for waiver, whichever occurs first, and may be extended by DOE 

for an additional 180-day period, if necessary. 

If you have any questions concerning this interim waiver, please contact Dr. Michael Raymond 

of my staff, at (202) 586-9611. 

Sincerely, 

Otl2f7J~~ Kathleen Hogan 

Deputy Assistant Secretary for Energy Efficiency 

Office of Technology Development 

Energy Efficiency and Renewable Energy