October 27, 1993

403 West Fourth Street North Newton, Iowa 50208 Telephone: 515.792.3000 MAYTAG Corporation Ms. Maria Olsen VIA FAX TO: 202-514-0452 Re: Meeting With Representatives of Maytag Company Friday, October 29, 1993 10:00 a.m. E.D.T. to Noon E.D.T. Department of Justice Room 4039 Dear Ms. Olsen: Thank you for agreeing to meet with representatives of Maytag Company. Attending on behalf of Maytag in addition to Mr. Horstman and myself will be Doug Ringger, Director, Product Planning; Dave Ellingson, Director, Advance Engineering; Randy Karn, Commercial Regional Sales Manager; and Steve Holdsworth, Product Information Specialist. I understand that attendees from your offices will include at least yourself and Mr. Wodatch. I also understand that a member of Senator Grassley's staff will also be attending. Enclosed find copies of the following: 1. My September 1, 1992 letter to Mr. Wodatch (3 pages). 2. 2. Various portions of ADA Accessibility Guidelines reference in enclosure #1 (4 pages). The Department of Justice's July 21, 1993 letter (8 pages).

As you may be aware, the Department of Energy's May 14, 1991 (56 Federal Register 22250) final rules on energy standards caused the entire laundry manufacturing industry to investigate the possibility of manufacturing horizontal axis washing machines. Historically, these types of washing machines were described as "front-loading". In general, horizontal axis washing machines use less water (including less hot water) and therefore use less energy than top-loading washing machines with which you are familiar (and may have in your residence). Several European manufacturers are currently producing top-loading horizontal axis machines. Maytag has requested this meeting because it is rapidly approaching some critical decisions concerning potential applicability of horizontal axis technology. Those decisions will take into account the additional information you will provide.

Maytag needs additional information concerning the following regulations: ADA Title III, Uniform Federal Accessibility Standards, and Housing and Urban Development. Specifically, Maytag would like to discuss and resolve the following issues: What ADA/UFAS/HUD/ANSI "requirements" apply to the "reach to load and unload clothes" from top-load clothes washers and clothes dryers (please refer to page 5, 91 of the DOJ's July 21, 1993 letter)? 01-02786 2. Do you consider the Thomson & Miele machines (pictures of which will be provided to you during our meeting) to be ADA accessible? If so, do you consider them as meeting UFAS requirements? HUD requirements? 3. Under UFAS and HUD (both based on ANSI 117.1-1986), front-load washers appear to be conclusively presumed to be accessible. Why? For example: a. Many of their containers for detergent, fabric softener, and other laundry aids (as well as coin slides) are placed over obstructions higher than 34". b. Isn't it as easy for a disabled individual to load and unload clothing from a top-loading washer as it is from a front-loading washer (for example, the Miele product)? 4. How many (number/percentage) ADA-accessible machines must be installed in the following circumstances: a. New laundry facilities (coin store, common use laundry facilities in multi-family housing/dormitories). b. "Altered" laundry facilities. c. To replace existing equipment in otherwise unaltered pre-ADA laundry facilities? At what point does replacing only equipment make the facility become "altered", thereby possibly triggering path of travel alterations? (Two machines? Three? d. Same questions concerning "front-loading" equipment 5. In addition to universities that receive Federal funds, what other types of federal involvement would constitute the "receipt of Federal funds" thereby requiring laundry areas to comply with UFAS?

6. Which, if any, of the ADA/UFAS/HUD regulations affect privately-owned multiple family dwellings? Sincerely, James M. Gran Associate Counsel cc: Doug Hortsman VIA FAX TO: 703-442-9587 Randy Karm VIA M TO: 609-988-3842 Doug Ringger Dave Ellingson Steve Holdsworth 01-02787