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 co mpartments that a model might have.

Thus, a T2 i 

### would be run for each evaporator defrost.

Let us know if there ar e 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 inte rspersed 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 than ks 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, pl us any additional cycles required to

bring the average compartment temperat ures 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 unifo rm-cycling compressor models, and

therefore, cannot be used to test th e 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 Ge neral Electric Co., ("GE") is a leading

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

this proceeding, refrigerators and refriger ator-freezers, files this Application for

Interim Waiver (“Application”) and Petiti on 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 Se rvice attesting to th e fact that I have

provided notice and copies of the Applicat ion 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