DEPARTMENT OF ENERGY

Office of Energy Efficiency and Renewable Energy

Energy Conservation Program for Consumer Products ; Denial of the Application

for Interim Waiver and Publishing of the Petition for Waiver from Clothes

Dryer Test Procedure of Miele Appliance Inc. (Miele ), ( Case No . CD-001)

AGENCY: Office of Energy Efficiency and Renewable Energy, Department of Energy

SUMMARY: Today's notice publishes a letter denying an Interim Waiver to Miele

from the existing Department of Energy (DOE or Department) clothes dryer test

procedure for its clothes dryer, models T1515A, T1520, T1565CA, and T1570C,

with a reverse tumble feature which Miele contends allows them to use a

smaller capacity drum for a larger clothes dryer load. The existing clothes

dryer test procedure does not have any recognition of the reverse tumble

design feature.

Today's notice a lso publishes a "Petition for Waiver" from Miele. Miele's

Petition for Waiver requests DOE to grant relief from the DOE clothes dryer

test procedure relating to its clothes dryer, models T1515A, T1520, T1565CA,

and T1570C.

Miele seeks to revise the definitions of compact and standard size clothes

dryers in the test procedure. DOE is soliciting comments and information

regarding the Petition for Waiver. Specifically, the Department is seeking

technical information/data on how the reverse tumble feature affects test load

N:\CE-40\CE-43\43COMMON \ LAFRANCE\MIELEdis.002

-1- August 3, 1994

 EE-RM-93-701 COMMENT 14

DEPARTMENT OF ENERGY , 

Office of Energy Efficiency and Renewable Energy 

Energy Conservation Program for Consumer Products; Denial of the Application 

for Interim Waiver and Publishing of the Petition for Waiver from Clothes 

Dryer Test Procedure of Miele Appliance Inc. (Miele), (Case No. CD-001) 

AGENCY: Office of Energy Efficiency and Renewable Energy, Department of Energy 

SUMMARY: Today1s notice publishes a letter denying an Interim Waiver to Miele 

from the existing Department of Energy (DOE or Department) clothes dryer test 

procedure for its clothes dryer, models T1515A, T1520, T1565CA, and T1570C, 

with a reverse tumble feature which Miele contends allows them to use a 

smaller capacity drum for a larger clothes dryer load. The existing clothes 

dryer test procedure does not have any recognition of the reverse tumble 

design feature. 

Today1s notice also publishes a "Petition for Waiver" from Miele. Miele1s 

Petition for Waiver requests DOE to grant relief from the DOE clothes dryer 

test procedure relating to its clothes dryer, models T1515A, T1520, T1565CA, 

and T1570C. 

Miele seeks to revise the definitions of compact and standard size clothes 

dryers in the test procedure. DOE is soliciting comments and information 

regarding the Petition for Waiver. Specifically, the Department is seeking 

technical information/data on how the reverse tumble feature affects test load 

-1- N:\CE-40\CE-43\43COMMON\LAFRANCE\MIELEdis.002 

August 3, 1994 
capacity.

DATES: DOE will accept-comments, data, and information not later than (30

days from publication).

ADDRESSES: Written comments and statements shall be sent to: Department of

Energy, Office of Energy Efficiency and Renewable Energy, Case No. CD-001,

Mail Stop EE-431, Room 5E-066, Forrestal Building, 1000 Independence Avenue,

.SW, Washington, DC, 20585 (202) 586-7140.

FOR FURTHER INFORMATION CONTACT:

P. Marc LaFrance

U.S. Department of Energy

Appliance Standards Division

Office of Codes and Standards

Office of Building Technologies

Office of Energy Efficiency and Renewable Energy

Mail Stop EE-431

Forrestal Building

1000 . Independence Avenue, SW

Washington , DC 20585

(202) 586-8423

Eugene Margolis, Esq

U.S. Department of Energy

Office of General Counsel

Mail Stop GC-72

Forrestal Building

1000 Independence Avenue, SW

Washington, DC 20585

(202) 586-9507

SUPPLEMENTARY INFORMATION:

The Energy Conservation Program for Consumer Program Products (other than

N:\CE-40\CE -43\43C0MM0N\LAFRANCE \MIELEdis.002

-2- August 3, 1994

 EE-RM-93-701 COMMENT 14

capacity. 

DATES: DOE will accept-comments, data, and information not later than (30 

days from publication). 

ADDRESSES: Written comments and statements shall be sent to: Department of 

Energy, Office of Energy Efficiency and Renewable Energy, Case No. CD-001, 

Mail Stop EE-431, Room 5E-066, Forrestal Building, 1000 Independence Avenue, 

SW, Washington, DC, 20585 (202) 586-7140. 

FOR FURTHER INFORMATION CONTACT: 

P. Marc LaFrance 

U.S. Department of Energy Appliance Standards Division 

Office of Codes and Standards 

Office of Building Technologies Office of Energy Efficiency and Renewable Energy Mail Stop EE-431 

Forrestal Building 1000 .Independence Avenue, SW 

Washington, DC 20585 

(202) 586-8423 

Eugene Margolis, Esq 

U.S. Department of Energy Office of General Counsel 

Mail Stop GC-72 

Forrestal Building 1000 Independence Avenue, SW 

Washington, DC 20585 

(202') 586-9507 

SUPPLEMENTARY INFORMATION: 

The Energy Conservation Program for Consumer Program Products (other than 

-2- N:\CE-40\CE-43\43COMMON\LAFRANCE\MIELEdis.002 

August 3, 1994 
automobiles) was established pursuant to the Energy Policy and Conservation

Act (EPCA), Public Law 94-163, 89 Stat. 917, as amended by the National Energy

Conservation Act (NECPA), Public Law 95-619, 92 Stat. 3266, the National

Appliance Energy Conservation Act of 1987 (NAECA), Public Law 100-12, the

National Appliance Energy Conservation Amendments of 1988 (NAECA 1988), Public

Law 100-357, and the Energy Policy Act of 1992, Public Law 102-486, 106 Stat.

2776, which requires DOE to prescribe standardized test procedures to measure

the energy efficiency, energy use, or estimated annual operating cost of

covered consumer products, including clothes dryers. The clothes dryer test'

procedure, among other things, provides a means of calculating an energy

factor, a measure of energy efficiency, which is used to determine if a

product is compliant with the minimum energy conservation standards. The

Department imposed amended energy conservation standards requiring minimum

energy factors for four of the five classes of clothes dryers in a final rule

(56 FR 22279) issued May 14, 1991, and which is effective for products

manufactured on or after May 14, 1994. These test procedures appear at 10 CFR

Part 430, Subpart D.

DOE amended the prescribed test procedure by adding 10 CFR 430.27 on

September 26, 1980, creating the waiver process (45 FR 64108). Thereafter,

DOE further amended the appliance test procedure waiver process to allow the

Assistant Secretary for Energy Efficiency and Renewable Energy (Assistant

Secretary) to grant an Interim Waiver from test procedure requirements to

manufacturers that have petitioned DOE for a waiver of such prescribed test

procedures (51 FR 42823, November 26, 1986).

N:\CE-40\CE-43\43C0NP10N\LAFRANCE\MIELEdis.002

-3- August 3, 1994

 EE-RM-93-701 COMMENT 14

automobiles) was established pursuant to the Energy Policy and Conservation 

Act (EPCA), Public Law 94-163, 89 Stat. 917, as amended by the National Energy 

Conservation Act (NECPA), Public Law 95-619, 92 Stat. 3266, the National 

Appliance Energy Conservation Act of 1987 (NAECA), Public Law 100-12, the 

National Appliance Energy Conservation Amendments of 1988 (NAECA 1988), Public 

Law 100-357, and the Energy Policy Act of 1992, Public Law 102-486, 106 Stat. 

2776, which requires DOE to prescribe standardized test procedures to measure 

the energy efficiency, energy use, or estimated annual operating cost of 

covered consumer products, including clothes dryers. The clothes dryer test' 

procedure, among other things, provides a means of calculating an energy 

factor, a measure of energy efficiency. which is used to determine if a 

product is compliant with the minimum energy conservation standards. The 

Department imposed amended energy conservation standards requiring minimum 

energy factors for four of the five classes of clothes dryers in a final rule 

(56 FR 22279) issued May 14, 1991, and which is effective f.or products 

manufactured on or after May 14, 1994. These test procedures appear at 10 CFR 

Part 430, Subpart D. 

DOE amended the prescribed test procedure by adding 10 CFR 430.27 on 

September 26, 1980, creating the waiver. process (45 FR 64108). Thereafter, 

DOE further amended the appliance test procedure waiver process to allow the 

Assistant Secretary for Energy Efficiency and Renewable Energy (Assistant 

Secretary) to grant an Interim Waiver from test procedure requirements to 

manufacturers that have petitioned DOE for a waiver of such prescribed test 

procedures (51 FR 42823, November 26, 1986). 

-3- N:\CE-40\CE-43\43COMMON\LAFRANCE\MIELEdis.002 

August 3. 1994 
The waiver process allows the Assistant Secretary to temporarily waive the

test procedures for a particular basic model when a petitioner shows that the

basic model contains one or more design characteristics which prevent testing

according to the prescribed test procedures or when the prescribed test

procedures may evaluate the basic model in a manner so unrepresentative of its

true energy consumption as to provide materially inaccurate comparative data.

Waivers generally remain in effect until final test procedure amendments

become effective, resolving the problem that is the subject of the waiver.

The Interim Waiver provisions, added by the 1986 amendment, allow the

Assistant Secretary to grant an Interim Waiver when it is determined that the

applicant will experience economic hardship if the Application for Interim

Waiver is denied, if it appears likely 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 relief pending a determination on

the Petition for Waiver. An Interim Waiver remains in effect for a period of

180 days or until DOE issues its determination on the Petition for Waiver,

whichever is sooner, and may be extended for an additional 180 days, if

necessary.

Miele filed a Petition for Waiver and an Application for Interim Waiver on

April 5, 1994 which was amended on April 20, 1994 and April 22, 1994,

regarding its clothes dryers, models T1515A, T1520, T1565CA, and T1570C, with

a reverse tumble feature. Miele states, "The specific design characteristics

of the Miele clothes dryer make the classification of the product as "compact"

totally unrepresentative of the products' true energy consumption

N:\CE-40\CE-43 \43COt410N \LAFRANCE\MIELEdis.002

-4- August 3, 1994

 EE-RM-93-701 COMMENT 14

The waiver process allows the Assistant Secretary to temporarily waive the 

test procedures for a particular basic model when a petitioner shows that the 

basic model contains one or more design characteristics which prevent testing 

according to the prescribed test procedures or when the prescribed test 

procedures may evaluate the basic model in a manner so unrepresentative of its 

true energy consumption as to provide materially inaccurate comparative data. 

Waivers generally remain in effect until final test procedure amendments 

become effective, resolving the problem that is the subject of the waiver. 

The Interim Waiver provisions, added by the 1986 amendment, allow the 

Assistant Secretary to grant an Interim Waiver when it is determined that the 

applicant will experience economic hardship if the Application for Interim 

Waiver is denied, if it appears likely 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 relief pending a determination on 

the Petition for Waiver. An Interim Waiver remains in effect for a period of 

180 days or until DOE issues its determination on the Petition for Waiver. 

whichever is sooner, and may be extended for an additional 180 days, if 

necessary. 

Miele filed a Petition for Waiver and an Application for Interim Waiver on 

April 5, 1994 which was amended on April 20, 1994 and April 22, 1994, 

regarding its clothes dryers, models T1515A, T1520, T1565CA, and T1570C, with 

a reverse tumble feature. Miele states, liThe specific design characteristics 

of the Mie,le clothes dryer make the classification of the product as "compact" 

totally unrepresentative of the products' true energy consumption 

-4- N:\CE-40\CE-43\43COMMON\LAFRANCE\MIELEdis.002 

August 3, 1994 
characteristics and provides materially inaccurate comparative data.". The

existing clothes dryer test procedure does not have any recognition of the

reverse tumble design feature in determining dryer size or class.

On April 27, 1994, the Department received a letter dated April 22, 1994, from

the Whirlpool Corporation (Whirlpool) opposed to Miele's Petition for Waiver

and Application for Interim Waiver. On April 29, 1994, the Department

received a letter from the General Electric Company (GE) also opposed to

Miele's Petition for Waiver and Application for Interim Waiver. Miele was

provided with copies of both Whirlpool's and GE's letters on April 29, 1994.

On May 13, 1994, Miele provided rebuttal comments to the Whirlpool and GE

letters. On May 13, 1994, the Department received a letter dated May 5, 1994,

from the Speed Queen Company (Speed Queen) opposed to Miele's Petition for

Waiver.

On May 20, 1994, Miele also provided additional information on the impact of

reverse tumble action on drying large loads. The Department has reviewed all

the comments and believes that the majority of these comments relate to

technical issues which should be fully debated during the Petition for Waiver

comment period. The Department is interested in the maximum load capability

of compact clothes dryers and any data regarding energy consumption with

larger loads.

Relative to showing economic hardship, GE points out that Miele is a U.S.

subsidiary of a large European multinational appliance manufacturer. Miele

stated that neither Whirlpool nor GE challenged Miele's submission in regards

N:\CE-40\CE-43 \43C0MMON\LAFRANCE\MIELEdis.002

- 5- August 3. 1994

 EE-RM-93-701 COMMENT 14

characteristics and provides materially inaccurate comparative data.". The 

existing clothes dryer test procedure does not have any recognition of the 

reverse tumble design feature in determining dryer size or class. 

On April 27, 1994, the Department received a letter dated April 22, 1994, from 

the Whirlpool Corporation (Whirlpool) opposed to Miele's Petition for Waiver 

and Application for Interim Waiver. On April 29, 1994, the Department 

received a letter from the General Electric Company (GE) also opposed to 

Miele's Petition for Waiver and Application for Interim Waiver. Miele was 

provided with copies of both Whirlpool IS and GEls letters on April 29, 1994~ 

On May 13, 1994, Miele provided rebuttal comments to the Whirlpool and GE 

letters. On May 13, 1994, the Department received a letter dated May 5, 1994, 

from the Speed Queen Company (Speed Queen) opposed to Miele's Petition for 

Waiver. 

On May 20, 1994, Miele also provided additional information on the impact of 

reverse tumble action on drying large loads. The Department has reviewed all 

the comments and believes that the majority of these comments relate to 

technical issues which should be fully debated during the Petition for Waiver 

comment period. The Department is interested in the maximum load capability 

of compact clothes dryers and any data regarding energy consumption with 

larger loads. 

Relative to showing economic hardship, GE points out that Miele is a U.S. 

subsidiary of a large European multinational appliance manufacturer. Miele 

stated that neither Whirlpool nor GE challenged Miele's submission in regards 

-5- N:\CE-40\CE-43\43COMMON\LAFRANCE\MIELEdis.002 

August 3, 1994 
to Miele experiencing economic hardship if the Application for Interim Waiver

is denied.

GE also indicated that Miele waited until the last moment to submit their

Petition for Waiver and Application for Interim Waiver. The Department

realizes that Miele only submitted their Petition for Waiver and Application

for Interim Waiver a little over a month prior to the effective date of the

new standards, however, the Department does not believe, that by itself, this

would be grounds for denial.

Whirlpool indicated that they redesigned their compact dryer to meet the new

energy conservation standards, instead of asking for such a waiver. Whirlpool

also indicated that they could meet the "standard" capacity minimum energy

conservation standard (7 pound performance rating) with their dryer of

capacity less than 4.4 cubic feet. Whirlpool further states that their

competitive advantage would be eroded if they allowed a competitor to be

granted a waiver. The Department does not believe that "competitive

advantage" is pertinent nor a reason to deny Miele an Interim Waiver.

Miele states in its initial submission to the Department, that "Miele

Appliance, Inc. is a small company with under 50 employees and will suffer

great and irreparable economic hardship if it cannot sell its line of clothes

dryers as standard". Miele further states that since their clothes dryer is

intended to be sold with their standard size front loading clothes washer,

that "an inability to sell the clothes dryer as standard will cripple sales of

washing machine as well". Miele also states that "since the revenue from the

sale of laundry products is essential to the financial well being of the

N:\CE-40\CE-43 \43COMMON\LAFRANCE\MIELEdis.002

- 6- August 3, 1994

 EE-RM-93-701 COMMENT 14

to Miele experiencing economic hardship if the Application for Interim Waiver 

is denied. 

GE also indicated that Miele waited until the last moment to submit their 

Petition for Waiver and Application for Interim Waiver. The Department 

realizes that Miele only submitted their Petition for Waiver and Application 

for Interim Waiver a little over a month prior to the effective date of the 

new standards, however, the Department does not believe, that by itself, this 

would be grounds for denial. 

Whirlpool indicated that they redesigned their compact dryer to meet the new 

energy conservation standards, instead of asking for such a waiver. Whirlpool 

also indicated that they could meet the II standardll capacity minimum energy 

conservation standard (7 pound performance rating) with their dryer of 

capacity less than 4.4 cubic feet. Whirlpool further states that their 

competitive advantage would be eroded if they allowed a competitor to be 

granted a waiver. The Department does not believe that IIcompetitive 

advantage II is pertinent nor a reason to deny Miele an Interim Waiver. 

Miele states in its initial submission to the Department, that IIMiele 

Appliance, Inc. is a small company with under 50 employees and will suffer 

great and irreparable economic hardship if it cannot sell its line of clothes 

dryers as standardll • Miele further states that since their clothes dryer is 

intended to be sold with their standard size front loading clothes washer, 

that lIan inability to sell the clothes dryer as standard will cripple sales of 

washing machine as well il• Miele also states that IIsince the revenue from the 

sa 1 e of 1 aundry products is essenti alto the fi nanci a 1 well bei ng of the 

-6- N:\CE-40\CE-43\43COMMON\LAFRANCE\MIELEdis.002 

August 3, 1994 
company, the regulatory prohibition of sales of the clothes dryers as standard

will jeopardize the company and result in loss of employment".

In order for the Department to be able to grant Miele an Interim Waiver, one

of the three criteria stated above must be met. First, in regards to

"economic hardship", Miele has indicated that failure to sell their clothes

dryers as "standard size" will impact the sale of their laundry products and

result in loss in employment. However, Miele did not specify any historical

nor future anticipated revenue from these particular models in question.

Furthermore, Miele did not provide any financial data relative to their

company nor the financial affiliation of their parent company. The Department

agrees that the loss of sales of any product will financially affect a

company, however the Department does not believe that Miele has demonstrated

that it would cause economic hardship.

Second, in regards to "it appears likely that the Petition for Waiver will be

granted", the Department has concerns about the validity of the Petition for

Waiver. This concern is primarily raised by the appearance that Miele is

actually submitting the Petition for Waiver to allow its products to meet the

minimum energy conservation standard versus the test procedure providing

results which are materially unrepresentative. On the other hand, the

Department is aware that the reverse tumble feature improves efficiency and

reduces drying times for some types of drying loads, although these types of

loads are not tested by the test procedure. Therefore, the likelihood of a

Waiver being granted is unknown at this point in time and that is why the

Department is requesting additional information relative the reverse tumble

N:\CE-40\CE-43\43COMM0N \ LAFRANCE\MIELEdis.002

-7- August 3, 1994

 EE-RM-93-701 COMMENT 14

company, the regulatory prohibition of sales of the clothes dryers as standard 

will jeopardize the company and result in loss of employmentll • 

In order for the Department to be able to grant Miele an interim Waiver, one 

of the three criteria stated above must be met. First, in regards to 

lIeconomic hardshipll, Miele has indicated that failure to sell their clothes 

dryers as II s tanda rd s i zell wi 11 impact the sa 1 e of thei r 1 aundry products and 

result in loss in employment •. However, Miele did not specify any historical 

nor future anticipated revenue from these particular models in question. 

Furthermore, Miele did not provide any financial data relative to their 

company nor the financial affiliation of their parent company. The Department 

agrees that the loss of sales of any product will financially affect a 

company, however the Department does not believe that Miele has demonstrated 

that it would cause economic hardship. 

Second, in regards to lIit appears likely that the Petition for Waiver will be 

grantedll , the Department has concerns about the validity of the Petition for 

Waiver. This concern is primarily raised by the appearance that Miele is 

actually submitting the Petition for Waiver to allow its products to meet the 

minimum energy conservation standard versus the test procedure providing 

results which are materially unrepresentative. On the other hand, the 

Department is aware that the reverse tumble feature improves efficiency and 

reduces drying times for some types of drying loads, although these types of 

loads are not tested by the test procedure. Therefore, the likelihood of a 

Waiver being~granted is unknown at this point in time and that is why the 

Department is requesting additional information relative the reverse tumble 

-7- N:\CE-40\CE-43\43COMMON\LAFRANCE\MIELEdis.002 

August 3, 1994 
feature in today's notice.

Third, in regards to "it would be desirable for public policy reasons", Miele

has indicated that denial of the Waiver would be destructive to the company

and anticompetitive. The Department does not believe that either conclusion

was demonstrated by Miele. Furthermore, they indicated that denial of the

Waiver blocks innovative, improved. designs. The Department believes that the

validity of the innovative and/or improved designs relative to clothes dryer

capacity will be fully discussed in response to comments from the Petition for

Waiver. The Department does not believe this would be a concern for public

policy. Rather, what it shows is that manufacturers can not wait until the

"eleventh hour" to file a petition and make a point relative to public policy.

Miele's submission also indicated that they made a significant investment for

their products to comply with recognized U.S. safety testing standards. The

Department is perplexed as to how a major european manufacturer who is

certainly aware of numerous, multinational energy conservation programs, would

not be aware of the U.S. mandated minimum energy conservation standards for

clothes dryers. If Miele had known about the required U.S. minimum energy

conservation. standards, then product development for safety standards could

have been done concurrently with energy efficiency improvements.

Therefore, for the reasons stated above, the Department denies Miele's

Application for Interim Waiver from the DOE test procedure for its clothes

dryers, models T1515A, T1520, T1565CA, and T1570C. Pursuant to paragraph (e)

of §430.27 of the Code of Federal Regulations Part 430, the following letter

denying the Application for Interim Waiver to Miele was issued.

N:\CE-40\CE -43\43COMMON\LAFRANCE\MIELEdis.002

-8- August 3, 1994

 EE-RM-93-701 COMMENT 14

feature in today's notice. 

Third, in regards to "it would be desirable for public policy reasons", Miele 

has indicated that denial of the Waiver would be destructive to the company 

and ~nticompetitive. The Department does not believe that either conclusion 

was demonstrated by Miele. Furthermore, they indicated that denial of the 

Waiver blocks innovative, improved ~esigns. The Department believes that the 

validity of the innovative and/or improved designs relative to clothes dryer 

capacity will be fully discussed in response to comments from the Petition for 

Waiver. The Department does not believe this would be a concern for public 

policy. Rather, what it shows is that manufacturers can not wait until the 

"eleventh hour" to file a petition and make a pOint relative to public policy. 

Miele's submission also indicated that they made a significant investment for 

their products to comply with recognized U.S. safety testing standards. The 

Department is perplexed as to how a major european manufacturer who is 

certainly aware of numerous, multinational energy conservation programs, would 

not be aware of the U.S. mandated minimum energy conservation standards for 

clothes dryers. If Miele had known about the required U.S. minimum energy 

conservation standards, then product development for safety standards could 

have been done concurrently with energy efficiency improvements. 

Therefore, for the reasons stated above, the Department denies Miele's 

Application for Interim Waiver from the DOE test procedure for its clothes 

dryers, models T1515A, T1520, T1565CA, and T1570C. Pursuant to paragraph (e) 

of §430.27 of the Code of Federal Regulations Part 430, the following letter 

denying the Application for Interim Waiver to Miele was issued. 

-8- N:\CE-40\CE-43\43COMMON\LAFRANCE\MIELEdis.002 

August 3, 1994 
Pursuant to paragraph (b) of 10 CFR Part 430.27, DOE is hereby publishing the

"Petition for Waiver" in its entirety. The petition contains no confidential

-information. DOE would appreciate comments, data and, other information

regarding the petition discussed above.

Issued in Washington, DC

Christine A. Ervin

Assistant Secretary

Energy Efficiency and Renewable Energy

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-9- August 3, 1994

 EE-RM-93-701 COMMENT 14

Pursuant to paragraph (b) of 10 CFR Part 430.27, DOE is hereby pub1ishing the 

"Petition for Waiver" in its entirety. The petition contains no confidential 

- infonnation. DOE would- appreciate conments, data and. other infonnation 

regarding the petition discussed above. 

Issued in Washington, DC 

Christine A. Ervin 

Assistant Secretary Energy Efficiency and Renewable Energy 

-9- N:\CE-40\CE-43\43COMMON\LAFRANCE\MIELEdis.002 

August 3, 1994