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The same rules apply to any type of washing machine. If by "be set" you are refering to the top of the standpipe the 36" it will depend on what level the trap is set at. According to the Plumbing code the height of the top of the stand pipe is required to be from 18" to 30" above the top of the trap. Sometimes the trap is hidden inside the wall and it is hard to know at want level it was installed but in any case 36" off the floor will work.

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Q: Can a standpipe for a front loading washing machine with a counter above it be set at a height of 36 inches off the floor?
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