Have you asked Miele or your installer about this requirement? How are you handling the ventilation requirement on page 185 of operating and installation manual? I would have hoped that your kitchen designer would have checked all installation instructions during the kitchen design phase. I know mine reached out to Miele directly about my ovens as she had not dealt with a CSO before (my XL Model was new to US market at the time). Please let us know what you find out.

In 2018 I installed a 24" Miele CSO XXL (plumbed) under the island counter when I remodeled the kitchen in my previous house. The Miele installation instructions had a page with the details for an under counter installation. Had no issues with the CSO in that location.

Just looked through my files and took a photo of the spec/installations sheets that my contractor used for the installation.

Apparently Miele is taking this requirement very seriously as it's not only on the drawings, but it's highlighted in text "Observe the required minimum installation height of 36" (914 mm)." Page 178.

I would bet its a safety concern rather than an operational concern. I could see a child opening the oven with the steam feature in operation and getting scalded/burned. Maybe this happened and Miele has stopped providing/support of under counter installation. Of course this could happen with a range and I think Thermador makes a range that has the steam oven as one of the ovens.

" I have since looked at a similar wolf product and I don’t see any mention of this."

No, the Wolf installation instructions do not show the oven installed under a counter. These ovens do, however:

• Fisher & Paykel Series 7 Contemporary Series OS24NDLX1
• Fisher & Paykel Series 9 Contemporary Series OS24NDB1
• Fulgor Milano 700 Series F7SCO24S1

The door opening effect is no different with the lower steam oven than with a standard range oven roasting something at high temperature. Hot is hot.

It's actually highlighted in the installation section at least three times!

It also has this, which may be one of the reasons for the installation instructions.

The steam oven must be positioned so that you can see the contents of a cooking container placed on the top shelf level. Otherwise there is a risk of injuries or spillages of hot food.

For what it's worth, I wouldn't install any wall oven under the counter -- generally, they're much closer to the floor than an oven in a range. Your oven is not b/c it's a small oven, but it's still too low, IMHO!

You might be able to go ahead and install it, but be aware that if anything happens, the warranty will likely be voided b/c it was not installed to spec. It might also be a reason for an insurance company not to cover damage if something happens b/c of the oven. Is the latter likely, probably not. However, the former is more likely if you get a "lemon" and need repairs or replacement.

ETA: Are the installation specs for the Wolf or other steam ovens that don't require 36" the same as that of the Miele (e.g., cutout size)? If so, you might see if you can return the Miele and get one of the others.

The LG Studio WSES4728F has two steam cooking modes and can be mounted under a counter.