From: Adin, Lucas 

Sent: Thursday, March 21, 2013 2:40:26 PM (UTC-05:00) Eastern Time (US & Canada) 

To: 'EARL.JONES@GE.COM'; AS_Waiver_Requests 

Cc: Berringer, Bryan; Armstrong, Ashley 

Subject: Re: GE Refrigerator Application for Interim Waiver and Petition for Waiver

Earl,

That is the understanding that I have from our conversation. Thank you for providing that clarification.

Lucas

From: Jones, Earl F (GE, Appl & Light) [mailto:EARL.JONES@GE.COM] 

Sent: Thursday, March 21, 2013 02:27 PM 

To: AS_Waiver_Requests 

Cc: Berringer, Bryan; Adin, Lucas; Armstrong, Ashley 

Subject: RE: GE Refrigerator Application for Interim Waiver and Petition for Waiver 

Bryan and Lucas – following up on our just-concluded discussion and to further 

elaborate on the response in 4, below, GE’s proposed test procedure would apply 

to products with separate defrosts for the fresh-food and the freezer 

compartments and any other separate compartments that a model might have. 

Thus, a T2i would be run for each evaporator defrost.

Let us know if there are any additional questions.

Earl

From: Jones, Earl F (GE, Appl & Light) 

Sent: Thursday, March 21, 2013 12:14 PM 

To: 'AS_Waiver_Requests' 

Cc: Berringer, Bryan; Adin, Lucas; Armstrong, Ashley 

Subject: RE: GE Refrigerator Application for Interim Waiver and Petition for Waiver

  

Bryan – please see below GE’s responses interspersed in the questions posed in 

your 3/14 email. Unfortunately, I mistook the waiver mailbox in my Inbox as a 

possible spam and didn’t open it so thanks for the heads-up during our call this 

morning. 

Earl

From: AS_Waiver_Requests [mailto:AS_Waiver_Requests@ee.doe.gov] 

Sent: Wednesday, March 13, 2013 3:23 PM 

To: Jones, Earl F (GE, Appl & Light) 

Cc: Berringer, Bryan; Adin, Lucas; Armstrong, Ashley 

Subject: RE: GE Refrigerator Application for Interim Waiver and Petition for Waiver

  

Earl,
  

DOE has some additional questions pertaining to the your attached waiver request for residential

refrigerators with non‐uniform cycling compessor:

  

1) It appears based on GE's description of the proposed test and the provided test cycle diagram

that the test period for the second part of the proposed test procedure begins and ends when

the compressor cycles on.  Please confirm that this is what GE intended.

That is correct.

2) DOE understands that GE cannot use the existing section 4.2.1.1 of Appendix A to test these

models and is proposing a modified test period.  It appears that the second part of the proposed

test includes energy use associated with "precool" cycles, which the section 4.2.1.1 of Appendix

A requires, but this is not explicitly clear.  Please confirm that GE's proposed method is in fact

intended to address precool energy.

GE’s proposed test procedure would mandate that the compressor cycle 

before defrost is always included, plus any additional cycles required to 

bring the average compartment temperatures within .5 °F of the average 

compartment temperature achieved in Part 1.

3) GE’s discussion of the second part of the test refers to "section 4.1.2.1," which does not exist.  

DOE presumed that this was a reference to section 4.2.1.1 of Appendix A, but please confirm.  

Yes, the reference was intended to be to section 4.2.1.1. 

4) Based upon GE's description of these models and inclusion in the description of the energy use

equation for models with multiple defrost cycle types, DOE understands them to use multiple

defrost cycle types, which would require use of the provisions for these types of systems in

section 4.2.4 of Appendix A.  However, this was not explicitly clear in the proposal.  Please

confirm that this is the case.

Section 4.2.4 is limited to uniform-cycling compressor models, and 

therefore, cannot be used to test the new model. Hence GE has filed this 

waiver request to create a test procedure for non-uniform-cycling 

compressor models. 

  

Thanks,

Bryan Berringer

(202) 586‐0371

From: Jones, Earl F (GE, Appl & Light) [mailto:EARL.JONES@GE.COM] 

Sent: Tuesday, February 19, 2013 2:59 PM 

To: AS_Waiver_Requests 

Cc: Berringer, Bryan 

Subject: FW: GE Refrigerator Application for Interim Waiver and Petition for Waiver

  
Please see correction in below cover email to clarify that GE seeks a waiver from 

the refrigerator and refrigerator-freezer test procedure, as indicated in the subject 

line, not clothes dryers. 

From: Jones, Earl F (GE, Appl & Light) 

Sent: Friday, February 15, 2013 4:52 PM 

To: 'AS_Waiver_Requests@ee.doe.gov' 

Cc: Bryan Berringer 

Subject: GE Refrigerator Application for Interim Waiver and Petition for Waiver

  

Dear Mr. Assistant Secretary:

GE Appliances, an operating division of General Electric Co., ("GE") is a leading 

manufacturer and marketer of household appliances, including, as relevant to 

this proceeding, refrigerators and refrigerator-freezers, files this Application for 

Interim Waiver (“Application”) and Petition for Waiver ("Petition"). GE requests 

that you grant it a waiver from certain parts of the Uniform Test Method for 

Measuring the Energy Consumption of Refrigerators and Refrigerator-Freezers

promulgated by the Department on the grounds that the basic design of the 

product prevents testing in accordance with the prescribed test procedure. This 

request, which is attached, is filed pursuant to 10 C.F.R. §430.27.

I have also attached a Certificate of Service attesting to the fact that I have 

provided notice and copies of the Application and Petition to the parties listed 

thereon.

Earl F Jones

Sr. Counsel, Government Relations & 

Regulatory Compliance

GE Appliances & Lighting 

AP2-225

Louisville, KY 40225

(502) 452-3164 – office 

(502) 452-0347 – fax 

(502) 287-7770 - cell