1

Adin, Lucas

From: Cleary, Jennifer [jcleary@AHAM.org]

Sent: Wednesday, August 07, 2013 9:44 AM

To: Adin, Lucas

Cc: 'Newsome, Hampton'; McArver, Rob; Leybourn, Steve

Subject: Follow-up on our call--Comment Period, Kitable Icemakers, and Webinar

Attachments: AHAM Request for Guidance_With and Without Icemaker_FINAL.pdf

Hello Lucas,

This is an email to follow‐up on our conversation this morning.

As we discussed, AHAM would like to respectfully request that DOE extend the comment deadline to January 31 on the

Refrigerator/Freezer test procedure NOPR, Docket No. EERE‐2012‐BT‐TP‐0016, RIN 1904‐AC76 only for issue 2

(Icemaking Test Procedure request for comments) and issue 15 (built‐in Refrigerators).  This would also include

comments regarding the test burden associated with those test proposed amendments (Issues 17 and 20).  With regard

to the non‐icemaking and non‐built‐in sections (i.e., all other issues listed in the NOPR), AHAM would request that the

comment deadline remain September 23.  We make this request because the timing of the NOPR is less than ideal.  As

we commented at the public meeting, DOE released the NOPR and scheduled the public meeting right in the middle of

the time period manufacturers were preparing their annual DOE/FTC reports.  And manufacturers are also working on

product planning, development, and testing for the 2014 transition.  Accordingly, it is difficult to find the necessary lab

time to evaluate the proposals in the NOPR.  With regard to the ice‐making section, we would also like time to be able to

coordinate with the advocates.  Thank you for considering this request.

I also mentioned that we are hoping DOE can soon finalize short‐term guidance regarding kitable models for the time‐

period in which there is a placeholder value for icemaking energy use (84 kWh).  AHAM’s original guidance request is

attached for your reference.  As it indicates, a kitable model always leaves the manufacturer’s warehouse the same

way—without an icemaker.  (I recognize that comments we submitted a couple of years ago were not clear on that

point, but our recent comments and the attached request for guidance have attempted to clarify).  Because these

models always leave the warehouse the same way, they have only one model number—manufacturers do not assign

and could not assign different model numbers to these models.  If an icemaker is installed, that installation occurs after

it leaves the manufacturer’s warehouse, and the actual icemaker installed could be the same manufacturer’s icemaker

or it could also be another manufacturer’s icemaker.  Because it is critical that we get guidance from DOE on the logistics

of certifying kitable models as well as from FTC on labeling them as soon as possible, AHAM would be glad to meet with

both agencies to further discuss this issue should you be open to such a meeting.  If there are other questions I can

address, please let me know.

Finally, if DOE would be willing to participate in a webinar with FTC and DOE regarding transition logistics, AHAM would

greatly appreciate it and I will coordinate the details.  If DOE is also willing to consider it, perhaps I could set up a quick

conference call between EPA, FTC, DOE, and me to further explain what I am suggesting so that each of you could make

a final decision regarding participation.

Thanks so much for your time today and for considering these requests.

Best regards, 

Jennifer Cleary

Director, Regulatory Affairs 

1111 19th St. NW, Suite 402, Washington, DC 20036 

t 202.872.5955 ext314 f 202.872.9354 e jcleary@aham.org

www.aham.org
2

STATEMENT OF CONFIDENTIALITY: The information contained in this electronic message and any attachments to this 

message are intended for the exclusive use of the addressee(s). If you are not the intended recipient, or the person 

responsible for delivering the e-mail to the intended recipient, be advised you have received this message in error and 

that any use, dissemination, forwarding, printing, or copying is strictly prohibited. Please notify The Association of Home 

Appliance Manufacturers at (202) 872-5955 or unsubscribe@aham.org, and destroy all copies of this message and any 

attachments.