Sent: Friday, February 17, 2012 8:46 AM 

To: Anderson, Wes 

Cc: kmessner@aham.org; Jennifer Cleary; Richard A Howard; Nick I Gillespie 

Subject: Cooking Products Definition Issue 

Wes: 

On December 12, 2011, I met with you and provided photographs of a KitchenAid built-in oven. This 

family of products has two separate cooking cavities, one MWO-only and one conventional-only. Both 

are controlled by a single control panel. In written comments submitted on December 22, 2011 we 

provided data to show that the conventional oven is the predominant energy user (10 times the MWO 

cavity energy consumption) and requested that DOE clarify that this product is classified as a 

conventional oven and is subject to the test procedures and standard of such a product. 

Our request would be consistent with the DOE verbiage in the March 9, 2011 Interim Final Rule for MWO. 

 In this document DOE states: "DOE determined that the test procedure would not apply to the type of cooking appliance classified by 

DOE regulations as a microwave/conventional range, which has separate compartments or components 

consisting of a microwave oven, a conventional oven, and a conventional cooking top. Id. at 12830. DOE 

noted that it will evaluate any differences among microwave ovens and combination microwave ovens, 

including installation configurations and heating features that may warrant different product classes or 

energy conservation standards during its microwave oven standards rulemaking. . . . . . .Because the test 

procedure applies only to microwave ovens and not to microwave/conventional ranges, a free-standing 

range with microwave capability in one compartment and a conventional oven in a separate compartment 

would not be a covered product under this rulemaking. Additionally, a range incorporating a single 

compartment with microwave capability and other cooking or heating means, along with a conventional 

cooking top, would not be considered a covered product because the cooking top portion would exclude 

the range from the relevant portion of the definition of ‘‘microwave oven’’ (e.g., a compartment designed 

to cook or heat food by means of microwave 

energy.)" {emphasis added} 

This clarifies that a free-standing version of the product in question is not a covered product. However, it 

does not address built-in ovens with separate MWO and conventional cavities. We believe that DOE 

must be consistent in it's treatment of similar products. 

In the February 14, 2012 SNOPR DOE stated: 

"As discussed in the March 2011 TP Interim Final Rule, DOE amended the definition of microwave oven 

in 10 CFR 430.2 to clarify that it includes microwave ovens with or without thermal elements designed for 

surface browning of food and combination ovens. DOE also discussed its determination that all ovens 

equipped with microwave capability would be considered a covered product, regardless of which cooking 

mode (i.e. , radiant heating or microwave energy) is primary. Based on its preliminary analysis, DOE 

concluded that the general standby mode and off mode operation for microwave ovens that incorporate 

other means of cooking food does not differ from that of microwave-only units. As a result, DOE amended 

the microwave oven test procedure to require that the same standby mode and off mode testing methods 

be used for all microwave ovens." 

This is not consistent with the March 9, 2011 statement. The primary mode of energy consumption must 

determine the classification of the product.. That would be clear, fair and consistent with previous DOE 

statements. 

We can address this concern in our written comments, however, any guidance you can provide at this 

time will help us to better focus those comments. Can you please advise your views on this matter? 

 Thanx!!
■ J.B. HOYT // DIRECTOR, SUSTAINABILITY & REGULATORY AFFAIRS

Office 269.923.4647 // Cell 269.277.1032 // Whirlpool Corporation // www.WhirlpoolCorp.com

2000 M‐63 North // MD 3005 // Benton Harbor, MI 49022 

NOTICE: Whirlpool Corporation e‐mail is for the designated recipient only and may contain privileged, proprietary,

or otherwise confidential information. If you have received this e‐mail in error, please notify the sender immediately

and delete the original. Any other use of the e‐mail by you is unauthorized.

 Please consider the environment before printing this e‐mail