EPA-AA-TAEB  76-20
     An Evaluation of the Morse Constant
            Speed Accessory Drive
                  June 1976
 Technology Assessment and Evaluation  Branch
    Emission Control Technology Division
Office of Mobile Source Air Pollution  Control
       Environmental Protection Agency

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Background

     The Environmental Protection Agency receives information about many
systems which appear to offer potential for emission reduction or fuel
economy improvement compared to conventional engines and vehicles.
EPA's Emission Control Technology Division is interested in evaluating
all such systems, because of the obvious benefits to the Nation from the
identification of systems that can reduce emissions, improve economy, or
both.  EPA invites developers of such systems to provide to the EPA
complete technical data on the system's principle of operation, together
with available test data on the system.  In those cases in which review
by EPA technical staff suggests that the data available show promise,
attempts are made to schedule tests at the EPA Emissions' Laboratory at
Ann Arbor, Michigan.  The results of all  such test projects are set
forth in a series of Technology Assessment and Evaluation Reports, of
which this report is one.

     The conclusions drawn from the EPA evaluation tests are necessarily
of limited applicability.  A complete evaluation of the effectiveness of
a system in achieving performance improvements on the many different
types of vehicles that are in actual use requires a  much larger sample
of test vehicles than is economically feasible in the evaluation test
projects conducted by EPA.  For promising systems it is necessary that
more extensive test programs be carried out.

     The conclusions from the EPA evaluation test can be considered to
be quantitatively valid only for the specific test car used, however, it
is reasonable to extrapolate the results from the EPA test to other
types of vehicles in a directional or qualitative manner, i.e., to
suggest that similar results are likely to be achieved on other types of
vehicles.

     Morse Chain, Division of Borg Warner Corporation, has developed a
variable-ratio drive to replace the fixed-ratio waterpump drive con-
ventionally used on automobiles.  Information and data supplied to the
EPA by Morse indicated that the Morse variable-ratio drive had potential
for fuel economy improvement when compared to conventional fixed-ratio
drives.  The fuel economy improvement is due to reducing the horsepower
used to drive the waterpump, and hence the engine-powered accessories.

     To attempt to quantify this potential fuel economy improvement, an
evaluation of the Morse drive was scheduled at the EPA's Ann Arbor,
Michigan laboratory.

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Test Vehicle Description

     The vehicle (furnished by Morse) used in the test program was a
1975 Chevrolet Nova powered by a 1976 305 cu. in. engine, and equipped
with a three speed automatic transmission.  The Nova was tested at an
inertia weight of 4000 Ibs.

     In the standard production configuration, the waterpump is driven
at 1.25 times crankshaft speed by means of pulleys and V-belt.  Acces-
sories (alternator, air conditioning and power steering), are driven from
the waterpump shaft with V-belts and pulleys;  The drive ratios for the
accessories must be such that adequate output can be obtained from the
accessories at low engine speeds ..(idle, stop-and-go driving, etc.).
Consequently, at high engine speeds, the accessories may be driven
faster than is necessary to provide required, outputs, and thus absorb
more power than is necessary.

     The Morse Controlled Speed Accessory Drive  (CSAD) is designed to
reduce this energy loss by using a variable-ratio drive between the
crankshaft and waterpump.  The Morse CSAD replaces the fixed pulleys on
the crankshaft and waterpump with pulleys whose  effective diameter is
controlled by engine speed (rpm).  The waterpump and crankshaft pulleys
are connected by a variable speed belt.

     The CSAD is designed to maintain a fixed ratio between crankshaft
and waterpump up to about 1100 rpm (engine speed).  As the engine speed
increases above 1100 rpm, the CSAD changes the drive ratio to maintain
constant output up to 2100 rpm (engine speed).  Above 2100 rpm, the
ratio of the CSAD is fixed, so further increases in engine speed result
in increased accessory speeds.  However, the rate of increase in ac-
cessory speeds is less than the rate of increase in engine speed.

     In the production configuration, the test vehicle is equipped with
a flex-fan.  The flex-fan is also used in the Morse CSAD installations,
and is driven on the waterpump shaft.

Test Program

     Exhaust emissions and fuel economy were measured in accordance with
the 1975 Federal Test Procedure ('75 FTP).  Emissions and fuel economy
were also measured during the EPA Highway Fuel Economy Test and under
several steeidy state conditions.  One exception  to the '75 FTP was the
ambient temperature maintained during the test program.  The test cell
temperature was maintained between 86 and 91 F during all tests.  This
was done to provide additional load on the engine accessories during
certain portions of the test program.

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     One of the problems of this test program was to generate sufficient
accessory loads during a chassis dynamometer emission test to demonstrate
the effects of the Morse CSAD.  It was anticipated that the CSAD would
show its greatest benefit under conditions of high accessory loading.
Of the accessories installed on the test vehicle, the alternator and air
conditioning compressor could provide the most easily adjustable loads
on the engine.

     Tests were conducted under two accessory loads.  For the first test
condition, no additional accessory loads were imposed on the engine.
The benefits of the CSAD were expected to be minimal under this con-
dition.  For the second test condition, the air conditioning system was
operated with driver controls set at maximum air conditioner settings,
and the high-beam headlights were turned on.  Operating the air con-
ditioning at maximum output kept the air conditioning compressor operating
continuously during the test.  Additional load was imposed on the air
conditioning system by the higher-than-normal ambient temperature main-
tained throughout the test program.  No attempt was made to vary the
power steering pump load.

     Tests were conducted with and without (baseline) the CSAD installed
on the test vehicle.  For each vehicle configuration, tests were con-
ducted with and without increased accessory load.

Test Results

     Test results, summarized below, show the effect of the Morse CSAD
on exhaust emissions and fuel economy during the '75 FTP.

                                '75 FTP*
                           Mass emissions in
                            grams per mile
                         (grams per kilometer)
                           No accessory load

                                                  Fuel Economy
                    HC        CO        NOx       (Fuel Consumption)

Baseline-avg.       0.60      6.3       2.20      14.7 miles/gal.
of 2 tests         (0.37)    (3.9)     (1.37)    (16.0 liters/lOOkm)
CSAD-avg.
of 2 tests

% Change
 0.69      8.0       2.20      14.6 miles/gal.
(0.43)     (5.0)      (1.37)     (16.1 liters/lOOkm)

 +15%      +27%        0             -1%
                                   (+1%)
* Ambient temperature between 86-91°F.

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                                 175 FTP*
                           Mass  emissions  in
                             grams per mile
                          (grams  per kilometer)
                             AC-lights  on
                    HC
          CO
          NOx
Baseline-avg.
of 2 tests
CSAD-avg .
of 2 tests
1.05
(0.65)
0.88
(0.55)
21.9
(13.6)
15.6
(9.7)
3.13
(1.95)
2.88
(1.79)
% change
from baseline
-16%
-29%
          Fuel Economy
          (Fuel Consumption)

          12.6 miles/gal.
         (18.7 liters/lOOkm)

          13.3 miles/gal.
         (17.7 liters/lOOkm)

               +6%
              (-5%)
     Similarly,  the  results  obtained  during  the Highway  Fuel  Economy
Test are  summarized  below.

                                 HFET*
                           Mass  emissions  in
                             grams  per mile
                          (grams  per kilometer)
                           No accessory  load
                    HC
          CO
Baseline-avg .
of 2 tests
CSAD-avg.
of 2 tests
0.14
(0.09)
0.43
(0.27)
5.6
(3.5)
17.8
(11.1)
1.88
(1.17)
1.72
(1.07)
% change
from baseline
+207%
+218%
                    Fuel Economy
          NOx       (Fuel Consumption)
                                                   20.1 miles/gal.
                                                  (11.7 liters/lOOkm)

                                                   20.3 miles/gal.
                                                  (11.6 liters/lOOkm)
-9%            +1%
              (-1%)
* Ambient temperature between 86-91°F.

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                                  HFET*
                            Mass emissions in
                             grams per mile
                          (grams per kilometer)
                              AC-lights on

                                                   Fuel Economy
                     HC        CO        NOx       (Fuel Consumption)

 Baseline-avg.        0.80      30.2      3.06      17.2 miles/gal.
 of 2 tests         (0.50)     (18.8)    (1.90)     (13.7 liters/100km)

 CSAD-avg.            0.93      39.1      2.63      18.2 miles/gal.
 of 2 tests         (0.58)     (24.3)    (1.63)     (12.9 lifers/100km)

 % change            +16%      +29%      -14%           +6%
 from baseline                                          (-6%)
 A detailed breakdown of '75 FTP,  HFET and steady state test  data  can be .
 found in Tables I-V1I.

 Discussion

      The effect of the  Morse CSAD on fuel economy ranged from no  change
 with no accessory load, to a 6% improvement with accessory  load.   The
 effect on exhaust emissions (during the '75 FTP) was variable,  increasing
 HC and CO emissions without accessory load, and reducing HC,  CO and  NOx
 with accessory loads.   The changes in exhaust  emissions (CSAD installation
 vs.  baseline)  could be  due to more than one effect of the CSAD.   Reduced
 engine loading with the CSAD installed would tend to increase HC  and
 CO emissions,  and lower NOx emissions.  Changes in engine cooling as a
 result of the  CSAD installation might also affect emissions  (see  the
 following paragraph).

      During the Highway Test, it was noted that the engine  temperature
 gauge was reading higher with the Morse CSAD installed (compared  to  the
 production configuration).  This is probably due to the slower  waterpump
 speed and resultant decrease in coolant circulation, although the cooling
 fan used during the dynamometer test does not  provide air flow equivalent
 to actual on-the-road driving.   Table VIII shows waterpump  speed  and
 crankshaft speed measured during the steady state tests.  The waterpump
 speed is reduced 22-31% in the speed range most prevalent during  the
 Highway Test,  so the change in engine temperature is not suprising.
 Inadequate cooling could be a possible problem area for a car equipped
 with the Morse CSAD.  The loads encountered in the EPA tests  do not
 impose much strain on the engine.   Higher engine temperatures would  be
 expected when  driving in mountainous terrain or when heavily  loaded
 (such as in trailer pulling).
*Ambient temperature between 86-91°F.

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     For all test conditions, the exhaust emission penalty due to air
conditioner operation was greater for the production accessory drive
than for the Morse CSAD.  The fuel economy penalty due to increased
accessory loads was 9-10% with the Morse CSAD installed and 14% with the
production accessory drive installed.

     It should be noted that normal test procedures for new vehicle
certification do not call for operation of the air conditioner at maxi-
mum output during the emissions test.  For new vehicle certification,
air conditioning load is simulated by increasing the normal road load
horsepower absorbed by the dynamometer by 10%.  Average road load for
each inertia weight class is given as part of the '75 FTP in the Federal
Register (Federal Register, June 30, 1975, Vol. 40 No. 126, Part III).

Conclusions

     1.   The Morse Controlled Speed Accessory Drive does have a bene-
ficial effect on fuel economy when the test procedure is modified to
provide conditions of high accessory load.  For the vehicle used in the
EPA test program, the improvement in fuel economy was approximately 6%.

     2.   The current design of the CSAD might not drive the waterpump
at a sufficient speed to provide adequate engine cooling under high load
conditions.  This point was not investigated during the test program,
but engine temperature was unusually high in some portions of the test
program.

     3.   The Morse CSAD reduced the fuel economy penalty caused by
operation of 'the air conditioning and headlights at maximum setting from
about 14% to,9-10%.  Savings could be greater under more severe air
conditioner requirements but this was not quantified in the EPA tests.

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       Table I

       •75 FTP
 Mass emissions in
   grams per mile
(grams per kilometer)
  No accessory load
Test t
Baseline
77-1279
77-1416
Average
Morse CSAD
77-1265
77-1420
Average
HC

0.51
(0.32)
0.68
(0.42)
0.60
(0.37)

0.76
(0.47)
0.62
(0.39)
0.69
(0.43)
CO

5.1
(3.2)
7.4
(4.6)
6.3
(3.9)

7.6
(4.7)
8.4
(5.2)
8.0
(5.0)
C02

594.
(369.)
593.
(369.)
594.
(369.)

590.
(367.)
595.
(370.)
593.
(369.)
NOx

2.27
(1.41)
2.13
(1.32)
2.20
(1.37)

2.12
(1.32)
2.28
(1.42)
2.20
(1.37)
mpg (A

14.7
(16.0)
14.6
(16.1)
14.7
(16.0)

14.7
(16.0)
14.5
(16.2)
14.6
(16.1)

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      Table II

       '75 FTP
  Mass emissions in
   grams per mile
(grams per kilometer)
    AC-lights on
Test //
Baseline
77-1386
77-1418
Average
Morse CSAD
77-1272
77-1773
Average
HC

1.02
(0.63)
1.08
(0.67)
1.05
(0.65)

0.95
(0.59)
0.80
(0.50)
0.88
(0.55)
CO

23.4
(14.5)
20.4
(12.7)
21.9
(13.6)

17.2
(10.7)
13.9
(8.7)
15.6
(9.7)
C02

687.
(427.)
645.
(401.)
666.
(414.)

643.
(400.)
638.
(397.)
641.
(399.)
NOx

3.43
(2.13)
2.82
(1.75)
3.13
(1.95)

2.76
(1.72)
3.00
(1.87)
2.88
(1.79)
mpg (H

12.2
(19.3)
13.0
(18.1)
12.6
(18.7)

13.2
(17.8)
13.4
(17.5)
13.3
(17.7)

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      Table III

        HFET
  Mass emissions in
   grams per mile
(grams per kilometer)
  No accessory load
Test #
Baseline
77-1280
77-1417
Average
Morse CSAD
77-1266
77-1421
Average
HC

0.09
(0.06)
0.19
(0.12)
0.14
(0.09)

0.37
(0.23)
0.48
(0.30)
0.43
(0.27)
CO

3.2
(2.0)
7.9
(4.9)
5.6
(3.5)

15.2
(9.4)
20.3
(12.6)
17.8
(11.1)
C02

435.
(270.)
430.
(267.)
433.
(269.)

409.
(254.)
409.
(254.)
409.
(254.)
NOx

1.96
(1.22)
1.79
(1.11)
1.88
(1.17)

1.64
(1.02)
1.79
(1.11)
1.72
(1.07)
mpg (i

20.1
(11.7)
20.0
(11.8)
20.1
(11.7)

20.4
(11.5)
20.1
(11.7)
20.3
(11.6)

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           10
      Table IV

        HFET
  Mass emissions in
   grams per mile
(grams per kilometer)
    AC-lights on
Test #
Baseline
77-1287
77-1419
Average
Morse CSAD
77-1273
77-1774
Average
HC

0.51
(0.32)
1.09
(0.68)
0.80
(0.50)

0.91
(0.57)
0.95
(0.59)
0.93
(0.58)
CO

21.4
(13.3)
38.9
(24.2)
30.2
(18.8)

36.2
(22.5)
41.9
(26.0)
39.1
(24.3)
a>2

477.
(296.)
457.
(284.)
467.
(290.)

429.
(267.)
422.
(262.)
426.
(265.)
NOx

2.97
(1.85)
3.14
(1.95)
3.06
(1.90)

2.67
(1.66)
2.58
(1.60)
2.63
(1.63)
mpg («.

17.3
(13.6)
17.0
(13.8)
17.2
(13.7)

18.2
(12.9)
18.1
(13.0)
18.2
(12.9)

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                                     11
Baseline

idle (300 sec.)

15 mph (24 kph)


30 mph (48 kph)


45 mph (72 kph)


60 mph (97 kph)



Morse CSAD

idle (300 sec.)

15 mph (24 kph)


30 mph (48 kph)


45 mph (72 kph)


60 mph (97 kph)
                                Table V

                             Steady State
                           Mass emissions  in
                            grams per mile
                          (grams per kilometer)
                           No accessory  load
                    HC
CO
C02
NOx
MPG (A/lOOkm)
0
0.01
0.04
(0.02)
0.04
(0.02)
0.20
(0.12)
0
0.09
(0.06)
0.06
(0.04)
0.11
(0.07)
0.43
(0.27)
0
0
0
0.01
13.4
(8.3)
O.lgms
0
0
1.42
(0.88)
18.5
(11.5)
498. gms
472.
(293.)
348.
(216.)
392.
(244.)
430.
(267.)
516. gms
486.
(302.)
360.
(224.)
391.
(243.)
403.
(250.)
0.87gms
0.45
(0.28)
0.86
(0.53)
1.05
(0.65)
0.81
(0.50)
1.13gms
0.51
(0.32)
0.99
(0.62)
0.99
(0.62)
2.2
(1.37)

18.8
(12.5)
25.5
(9.2)
22.6
(10.4)
19.6
(12.0)

18.2
(12.9)
24.6
(9.6)
22.5
(10.5)
20.5
(11.5)

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                                     12
Baseline

idle  (300 sec.)

15 mph  (24 kph)


30 mph  (48 kph)


45 mph  (72 kph)


60 mph  (97 kph)



Morse CSAD

idle  (300 sec.)

15 mph  (24 kph)


30 mph  (48 kph)


45 mph  (72 kph)


60 mph  (97 kph)
                                Table VI

                              Steady State
                           Mass emissions  in
                             grams  per mile
                          (grams per kilometer)
                              AC-lights on
                    HC
CO
C02
NOx
0.9gms    495gms    2.53gms
mpg (H/100km)
1.19
(0.74
0.87
(0.54)
0.05
(0.03)
0.82
(0.51)
0
1.07
(0.67)
1.07
(0.67)
0.44
(0.27)
1.18
(0.73)
13.2
(8.2)
21.0
(13.1)
2.0
(1.2)
35.0
(21.8)
l.Sgms
11.2
(7.0)
25.1
(15.6)
28.7
(17.8)
49.4
(30.7)
548.
(341.)
441.
(274.)
465.
(289.)
436.
(271.)
511. gms
584.
(363.)
406.
(252.)
404.
(251.)
426.
(265.)
1.26
(0.78)
0.68
(0.42)
1.75
(1.09)
4.27
(2.65)
2.74gms
1.15
(0.71)
0.64
(0.40)
1.30
(0.81)
3.26
(2.03)
15.5
(15.2)
18.6
(12.6)
18.9
(12.4)
18.0
(13.1)

14.7
(16.0)
19.8
(11.9)
19.7
(11.9)
17.5
(13.4)

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                                                 Table VII

                                Individual Bag Emissions in Grams per Mile

                              Bag 1:  Cold Transient          Bag 2:  Stabilized          Bag  3:  Hot  Transient
Test *                      HC   CO   C02   NOx   MPG     HC   CO   C02   NOx   MPG     HC   CO   C02    NOx  MPG

Baseline:  No accessory load

77-1279                     1.3210.0608.  3.39  14.1    0.09   2.6616.  1.62  14.3    0.70   6.4540.  2.65  16.1
77-1416                     1.25  9.4 610.  3.58  14.1    0.31   5.0 618.  1.39  14.2    0.94 10.6 534.  2.44  16.0

Morse CSAD:  No accessory load

77-1265                     1.98 14.7 587.  3.12  14.4    0.30   5.2 620.  1.48  14.1    0.69   6.9 535.  2.60  16.2
77-1420                     1.33  9.9 603.  3.47  14.3    0.25   6.8 627.  1.63  13.9    0.81 10.5 530.  2.61  16.2

Baseline:  AC - lights on

77-1386                     1.53 20.6 702.  4.93  12.0    0.74 21.7 717.  2.77  11.8    1.17 28.6 618.  3.58  13.3
77-1418                     1.40 13.8 666.  4.48  12.8    0.75 19.5 676.  2.05  12.5    1.46 27.2 570.  3.06  14.4

Morse CSAD:  AC - lights on

77-1272                     1.38 13.9 656.  4.00  13.0    0.61 16.5 680.  2.05  12.5    1.28 21.1 563.  3.17  14.8
77-1773                     1.24 10.2 651.  4.43  13.2    0.61 13.7 668.  2.32  12.8    0.82 17.2 571.  3.23  14.8

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                                    14
Vehicle Speed

Idle (neutral)

Idle (drive)

15 mph (24 kph)

30 mph (48 kph)

45 mph (72 kph)

60 mph (97 kph)
            Table VIII

           Morse CSAD
Crankshaft rpm vs. Waterpump rpm

                               Waterpump rpm

                                    750
Crankshaft rpm

     600

     550

     800

    1100

    1600

    2250
                                    600

                                    900

                                   1100

                                   1250

                                   1550

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                                    15
                        TEST VEHICLE DESCRIPTION

            Chassis model year/make -   1975  Chevrolet Nova
            Emission control system -   1976  Engine, OC/EGR/EFE
Engine
type	4  stroke, Otto Cycle, V-8 ohv
bore x stroke  ..........  3.74  x  3.48  in./95 x 88.4mm
displacement	305 cu.  in./4999cc
compression ratio   	  8.5:1
maximum power @ rpm	140 hp/104kW at  3800 rpm
fuel metering  ...  	  2  barrel carburetor
fuel requirement	91 RON,  unleaded

Drive Train

transmission type   	  3  speed automatic


Chassis

type	Front engine, rear wheel drive
tire size	•	FR 78 x 14
curb weight	3797  lbs/1722 kg
inertia weight	4000  Ibs.
passenger capacity  	  5

Emission Control System

basic type	OC/EGR/EFE
oxidation catalyst location ....  Underfloor
  substrate.  	   Pellet
  volume	260 cu. in./4261cc
  loading	05 troy oz./1.56gm
EGR type	Ported
durability accumulated on system .  33000  mi/5300km

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                                             LIBRARY C;:;-Y DC XOT HEMOVE


                                                 EPA-AA-TEB-511-82-14
         EPA Evaluation  of  the P.A.S.S. KIT Device Under
Section 511 of  the  Motor Vehicle Information and Cost Savings Act
                               by

                      Edward Anthony Earth
                         September, 1982
                   Test and  Evaluation Branch
               Emission Control Technology Divison
                    Office of  Mobile  Sources
              U.S.  Environmental  Protection Agency

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EPA Evaluation of  the  P.A.S.S.  KIT Device Under  Section  511  of the Motor
Vehicle Information and Cost Savings Act

The  Motor Vehicle  Information  and  Cost  Savings Act  requires  that  EPA
evaluate  fuel economy  retrofit  devices  and  publish a  summary  of  each
evaluation in the Federal Register.

EPA evaluations  are  originated  upon  the  application of  any  manufacturer
of a  retrofit  device,  upon the  request  of the  Federal  Trade Commission,
or upon the motion of  the EPA Administrator.   These  studies  are designed
to determine  whether  the  retrofit device  increases  fuel economy  and  to
determine whether  the  representations made  with respect  to the device are
accurate.   The  results  of such studies are  set  forth  in  a  series  of
reports, of which this is one.

The  evaluation  of  the   P.A.S.S KIT   device  was  conducted  upon  the
application of  the marketer  of  the  device.   This device is  claimed  to
eliminate the  load of air  conditioning  compressor when  accelerating  and
thereby improve  fuel economy  and performance.   The  device  is  an intake
manifold vacuum switch that is  designed  to  disengage  the air conditioning
compressor during periods of high power demand.

The following is  a summary of the information on the device as supplied
by the Applicant and the resulting EPA analysis and conclusions.

1.  Title;

    Application for  Evaluation of the P.A.S.S.  KIT Device Under Section
    511 of the Motor Vehicle Information and Cost Savings Act

2.  Identification Information;

    a.   Marketing Identification of the Product;

         Model Number - 07-06-10

    b.   Inventor and Patent Protection;

         (1)  Inventor

              Fasco Industries Inc.
              1100 Airport Road
              Shelby, NC  28150

         (2)  No patent at this -time. Patent application being prepared.

    c.   Applicant;

         (1)  Cartel Products Division
              Vandenberg Corporation
              3133 Madison SE
              Grand Rapids, MI  49508

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         (2)  President:  Charles Vandenberg
              Executive Vice President:  Gene Goulooze
              Vice President:  Jay Kuiper

         (3)  Jay Kuiper  is  authorized  to  represent the  Cartel  Products
              Division  of  the  Vandenberg  Corporation  in  communication
              with EPA.

    d.   Manufacturer of the Product:

         (1)  Cartel Products Division
              Vandenberg Corporation
              3133 Madison SE
              Grand Rapids,  MI  49508

         (2)  President:  Charles Vandenberg
              Executive Vice President:  Gene Goulooze
              Vice President:  Jay Kuiper

3.  Description of Product (as supplied by Applicant);

    a.   Purpose;

         "The  objective  of  this  product  is  to  provide  a  means  of
         eliminating  the  power   requirement  of   the   air   conditioner
         compressor  during  periods  of  high  engine  power  demand,  in  an
         effort to reduce fuel  consumption with no  increase  in  pollutant
         levels."

    b.   Theory of Operation;

         "During  acceleration  or  passing,  a  higher than average  power
         output  is   required of   an automotive  engine  resulting  in  a
         corresponding  drop  in  manifold  vacuum.   When  this   reducing
         vacuum signal  falls  below  a  predetermined  level, the  diaphragm
         operated switch  provided  in this  'kit'  breaks  the electrical
         circuit  to  the  air conditioner  compressor  clutch.   This  action
         renders  the  compressor inoperative  until manifold vacuum  again
         rises above  the  preset  level  causing the  switch to close  thus
         allowing the air conditioner compressor to operate again."

    c.   Construction and Operation;

         "Exhibit attached."  The  exhibit was a sample of  the  product.

    d.   Specific Claims for the Product;

         "We feel that positive  claims  can be  made  in  two categories  in
         future media and printed  advertising.

         (1)  "Regarding  fuel  mileage  when  the  air  conditioner  is  in
              operation,  we  feel  there  is a  definite  increase  in  fuel
              economy.    However,   we   have   no    certified   tests   to
              substantiate this.

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         (2)  "Additional  power is  available  for  passing,  acceleration
              and   maintaining   speed   on   upgrades   by   temporarily
              eliminating  the  power  requirements of the  air conditioning
              compressor.  We  are  aware  that  the  EPA  has evaluated  a
              similar product  and  has published its  findings in  the  EPA
              Environmental News  on  August  27, 1980,  which stated  that
              the device  produced  an increase  in gas  mileage without  an
              increase in pollutant emissions."

    e.   Cost and Marketing Information (as supplied by Applicant);

         "Suggested retail price is  $15.95 per  kit.  Methods of  marketing
         are through  the  standard  automotive parts distribution channels
         which are  Warehouse,  Jobber and  Dealer.   Final  sale  is  to  the
         end user who would purchase from a dealer."

4.  Product Installation,  Operation,  Safety  and Maintenance  (as supplied
    by Applicant);

    a.   Applicability;

         (1)  "This product  is applicable  to  all  automobiles   and  light
              trucks using gasoline  engines  with carburetion type intake
              systems.  The product will operate properly with all engine
              sizes, ignition types and transmission types.

              "The  product  is  not  generally  applicable   to   gasoline
              engines using  fuel   injection  or  turbocharged type  intake
              systems.

              "The product is  not  generally applicable  to  diesel  engines."

         (2)  "Applicability   is  not  affected, in  our   experience,   by
              weather  conditions,   types  of  driving,  or   topographical
              differences."

    b.   Installation -  Instructions, Equipment, and Skills  Required;

         "Please  refer to Exhibit A  attached,  (maintenance  procedures)."
         Exhibit  A is Attachment A to this  evaluation.

    c.   Operation;

         "Please  refer to Exhibit A  attached,  (maintenance  procedures)."
         Exhibit  A is Attachment A to this  evaluation.

    d.   Effects  on Vehicle Safety;

         "Not applicable."

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    e.   Maintenance:

         "No maintenance,is  required  of the installed  product.   However,
         the vacuum hose added by  this  installation should be included in
         the periodic inspection of  all engine vacuum  hoses  and fittings
         - for signs of  deterioration or aging.  The use  of  this product
         should not  cause  any effect in the normal maintenance schedule
         for the vehicle."

5.  Effects on Emissions and Fuel Economy (submitted by Applicant);

    a.   Unregulated Emissions;

         "Not applicable."

    b.   Regulated Emissions and Fuel Economy;

         "Not applicable."

6.  Analysis

    a.   Description;

         (1)  As  stated  in  Section  3a,  the  primary  purpose  of  the
              P.A.S.S.  KIT is  to eliminate  the power requirements  of  the
              air conditioning  compressor when the engine  is  operating
              under   heavy  load  and  thus reduce   the  fuel  consumption.
              This is in agreement with the theory of  operation given in
              3b and the  function  of the sample  of the device  submitted
              with the application.   That is,  the product  operates  as an
              engine intake  manifold vacuum switch  that   is capable  of
              interrupting the  electrical power  to the  air  conditioner
              clutch when  the engine  is under heavy  load,  and  thereby
              disengaging the air conditioner (A/C).

         (2)  The theory of operation given in  Section  3b  is  judged to be
              correct but  incomplete.   As stated,  manifold  vacuum  drops
              as the power output  is  increased by  depressing a  vehicle's
              accelerator pedal.  This  vacuum  signal  can be  readily used
              to automatically  declutch  the air  conditioning  compressor
              with a  vacuum  switch   like  the   P.A.S.S. KIT.   This  will
              provide more  power   for   hill  climbing   or  accelerating.
              However,   this   theory   does  not  give  a  reason  why  fuel
              economy might be expected  to improve.

              Generally,  vehicles  are designed to  provide their  optimum
              fuel efficiency  while   cruising  and  thus  are  not as  fuel
              efficient  when  accelerating.   Air  conditioning imposes  an
              additional load which  tends to cause a  vehicle to  consume
              fuel  even   less  efficiently.    By  disabling   the   air
              conditioner   compressor   when   accelerating,    the    air
              conditioning  load is imposed on  the engine only when  it is
              operating  in  a more  fuel efficient  regime.    However,  the

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          fuel  economy  benefit,  if  any,  actually  obtained  would
          depend on the vehicle  and  how well the device is matched to
          the vehicle.

     (3)  The  P.A.S.S. KIT device  provided  consisted  of a  vacuum
          switch and all  the hardware necessary to install the device
          on an air conditioned  vehicle.  The  switch itself consisted
          of a  normally open  switching  element encased  in a  plastic
          housing.  The  switch is connected to the vehicle as shown
          in Attachment  A.  Under high manifold  vacuum,  e.g., light
          loads,  the  switch contacts are  closed, thus  allowing  the
          air conditioning compressor to operate.

     (4)  In  Section  3d,   the  applicant   claimed the  device  would
          improve  the  fuel economy  and  performance  of  a  vehicle.
          These claims  are in agreement with  the purpose,  theory of
          operation  and  construction   of   the  device.   However  no
          specific   numerical   improvements   were   claimed.    The
          applicant was advised  by letters  (Attachments  B,  D,  and I)
          and at several meetings  that  substantiating test data would
          be  required.   The  applicant  requested  the evaluation  be
          conducted without this data based on the similiarity of  the
          function  of the  P.A.S.S.   KIT device  to  the   Pass  Master
          device previously tested by EPA.

     (5)  The  cost   of  the  device   plus   installation   would   be
          approximately $26.00 for those users who elect  to have  the
          device installed by a  mechanic.   This is based  on a  cost of
          $15.95  plus  $10.00   for   installation  (1/2   hour   of  a
          mechanic's labor at  $20.00  per hour).  However, as noted in
          Section 6b(2), the installation  is relatively easy and most
          individuals with  basic mechanical skills should  be  able to
          install the device themselves.

b.   Installation, Operation, Safety and Maintenance;

     (1)  Applicability;

          The applicability of the device   is  adequately  described in
          Section 4b.  However,  it should   be  noted  that  the P.A.S.S.
          KIT  is  only  applicable  to vehicles with  air  conditioning
          systems.

          Also,  the  air   conditioning   systems of  many  late  model
          vehicles have devices  to turn off the compressor under some
          operating conditions.  For  example,  the  A/C systems  of some
          GM vehicles  turn  the  compressor  off when  accelerating in
          the  lower  transmission  gears.    Some   Chrysler  cars  have
          switches  that   disengage   the   compressor   based   on  the
          position  of  the  throttle.   Also, a number  of  other  late
          model vehicles  are  equipped  with  devices  similar   to  the
          P.A.S.S. KIT.

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              Therefore,  EPA asked  the  applicant  to indicate  for which
              vehicles  the  sales  literature  and  packaging would  state
              that the device did not apply.

              The  response of  the  applicant  (Attachment  H)  stated that
              the device  packaging would show  the device was not intended
              for diesel  vehicles, 1982 Ford Escort and Mercury Lynx with
              automatics,  1982  Buick  and  Oldsmobile  4 cylinder  and  V-6
              with  automatics,   and   1982   Cadillacs.    This  labeling  is
              incomplete  because  it  fails  to  list the many  vehicles  for
              which  the  device  would  have  no  benefit  since it  would
              either duplicate an existing  vehicle device  or not function
              (diesel,  fuel  injection, turbocharged).   As a  result,  the
              potential  customer for  the  device  would  be  expected  to
              determine   if  his  vehicle  was  already  equipped  with  a
              similar device.

         (2)  Installation - Instructions,  Equipment and Skills Required;

              The  installation  instructions   (Attachment  A)  that  were
              provided  with  the application did not  adequately  describe
              how  the  user should make  the optional adjustments  to  the
              device.   As a  result   of  several  discussions and  letters
              (Attachments D, E,  F,  G, and H),  the applicant revised  the
              installation instructions  to include  the changes given  in
              Attachment  G.

              These modified  instructions  are  judged to  be  adequate  for
              the  installation  and  adjustment  of  the P.A.S.S.  KIT  by
              persons with average  mechanical  skills.*   Installation  and
              adjustment  will require a minimal  amount of  tools  (drill,
              knife,  and screwdriver).   Installation  should  require  no
              more than 15 to 30 minutes.

         (3)  Operation;

              In Section  4c,  the applicant  referred to  the installation
              instructions for  operating information.  These instructions
              contained   no  specific  operating  instructions.   However,
              since  the  device  is  designed  to   function  automatically,
              none were judged to be necessary.

         (4)  Effects on  Vehicle Safety;

              The  applicant   states   that   the  P.A.S.S.  KIT  should  not
              affect  vehicle   safety.    The  device   actually has  the
              potential  to improve  vehicle safety when  the  A/C  is  in
              operation by providing additional power for passing.
*However, as  noted by EPA  in Attachment A,  the installer  may encounter
moderate difficulty in locating  the  proper  vacuum line for connecting the
device.

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         (5)  Maintenance;

              The  recommended maintenance  requirements given  in Section
              4e are judged to be adequate.

         Effects on Emissions and Fuel Economy;

         (1)  Unregulated Emissions;

              Since  the  device   does not   change  the  emission  control
              system  of a  vehicle  but  only  changes  the  engine load  a
              small amount, the device is  judged to be unlikely to affect
              unregulated emissions.

         (2)  Regulated Emissions and Fuel Economy;

              The  applicant  did  not  submit  test data  in  accordance  with
              the  Federal Test  Procedure  and  the Highway Fuel  Economy
              Test.   These  two   test procedures   are  the  primary  ones
              recognized  by  EPA  for  evaluation  of  fuel  economy  and
              emissions  for  light  duty  vehicles.   The  requirement  for
              test  data  following   these   procedures   is  stated  in  the
              policy  documents  that  EPA sends  to potential  applicants.
              Other  data which  have been  collected  in  accordance  with
              other    standardized    procedures    are   acceptable    as
              supplemental  data   in  EPA's   preliminary  evaluation  of  a
              device.

              The   applicant   was   fully    aware   of  this   requirement
              (Attachments  B and  D)  but  requested   (Section  3d(2)  and
              Attachment  G)  that the evaluation  be  conducted using  the
              information available on a similar device,  the  Pass Master,
              which was  previously  tested  and evaluated by the EPA.   EPA
              agreed to  conduct  the  evaluation  without  test  data on  the
              P.A.S.S.  KIT  but informed  the applicant  that no  specific
              fuel economy benefits could be claimed  (Attachments  D  and  I
              and meetings with the applicants).

         EPA Test Results on a Similar Device:
         EPA  previously  tested  and  evaluated  another  air  conditioner
         cutoff device  called  Pass Master*.   EPA  found that  the  reduced
         engine loading of this device would result in a small but real
*"EPA  Evaluation of  the  Pass  Master  Vehicle  Air  Conditioner  Cut-Off
Device",  EPA-AA-TEB-511-80-5.

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         reduction in vehicle emissions and  fuel consumption.**  However,
         although  the  P.A.S.S.  KIT  and   Pass  Master   operate  in  an
         identical manner,  their  A/C on/off set  points are significantly
         different.  EPA has no information  available  to  evaluate whether
         one device  would  function better  than  the other.  Thus,  EPA is
         unable  to  quantify the  fuel  economy benefits  for the  P.A.S.S.
         KIT based on the testing of the Pass Master.

         Potential Effectiveness of an Air Conditioning Cutoff Device;

         Since  the  P.A.S.S.  KIT  is  similar to  the  device  previously
         tested  and evaluated,  most  of  the  previous  statements  still
         apply, and are included in the following:

         (1)  Usage

              (a)  The device is generally  applicable  to  gasoline-powered
                   vehicles with  carbureted  engines which are  equipped
                   with air conditioning systems.

              (b)  The  device  functions  only   when  the  A/C  system  is
                   turned on.   The device is then supposed  to  negate part
                   of the fuel  economy  penalty  incurred by using  the air
                   conditioner.   This  important  characteristic  of  the
                   device is  called  the  "buy-back".   This  is  the  amount
                   of the  fuel economy  penalty  due  to the  A/C that  is
                   saved by the device.

         (2)  Effect of air conditioning design

              There are  several  types of  air  conditioning systems found
              on American  cars.   While most  systems incorporate  similar
              major   components   (compressor,    condenser,   evaporator,
              receiver-dryer,   and   expansion   valve),   the    method   of
              controlling   the   interior  temperature   of  the   vehicle
              varies.  The effect of the  "P.A.S.S.  KIT" compressor cutout
              switch will depend  on the  type of system installed  in the
              vehicle and to what position the A/C control unit is set.

              Present air  conditioning systems  sense  an evaporator  coil
              parameter  such  as refrigerant  pressure  or   temperature  or
              outlet air  temperature and  use this parameter  to  control
              the amount of refrigerant to the evaporator  coil.  The
**The fuel economy  gains  with the "Pass Master"  device  varied from  0  to
4%  depending  on  the  vehicle  and  test conditions.   These  tests  were
designed to  give  the  device the  best  opportunity to display  the  maximum
benefit in that they  were conducted with the  A/C set to maximum  cooling
and  the  windows open.  Given the similarity  of  the devices,  it   is  our
engineering judgment that such tests reasonably quantify  the maximum fuel
economy benefit of either the Pass Master or the P.A.S.S.  KIT devices.

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                                                               10
method  of  controlling the  refrigerant  varies.   The cooling
of the  vehicle  interior  is controlled by opening or closing
baffles  which control  the air  flow, not  the  refrigerant,
and by  reheating  the  air if necessary.   There are basically
two refrigerant control  systems:

(a)  The Thermostatic  Switch  type  and the Accumulation type
     sense the  evaporative  temperature  or pressure and turn
     the  compressor  clutch on  or off  to maintain  proper
     evaporator  temperature.   This  is  called  the "Cycling
     Type".

(b)  Three  other types,  (1)  the  Suction  Throttling  Valve
     (STV) type,  (2)  the Valves  in Receiver (VIR) type, and
     (3) Evaporator Pressure  Regulator  (EPR)  type regulate
     the  refrigerant  to  the  compressor to maintain  proper
     evaporator    temperature.     This    is    called    the
     "Continuous"  type.    The  Compressor  runs  continuously
     when the air conditioner is turned on.

Several  vehicle  manufacturers have incorporated  both  types
of control  on  vehicles.  When  the A/C  switch is on "Max
Cool",  the compressor  runs  continuously.   When  at Normal or
"FE" (Fuel Economy) settings,  the  compressor cycles.

The P.A.S.S.  KIT device  will  work  best  on systems designed
to operate in a  "Continuous"  mode.  During the  acceleration
modes,  the  compressor will be cut  out  by the "P.A.S.S. KIT
device.   Since   the   compressor   will   run  enough  during
nonacceleration  modes  to  control evaporator  temperature,
the reduced engine  load  in acceleration may  result  in some
fuel economy savings (buy-back).

On "Cycling"  type systems,  the P.A.S.S. KIT  may  or  may not
have  an  effect.   If   the   car  accelerates   while  the
compressor is  not  engaged, the  P.A.S.S.  KIT will have  no
effect.   If  the  compressor  is  engaged,  the P.A.S.S.  KIT
will  disengage  the  compressor  and  allow   the  engine  to
accelerate the  vehicle with a reduced  load on  the  engine.
Upon completion of  the   acceleration,  the compressor  will
run to   restore  the evaporative  pressure/temperature.   The
fuel saving  will  be  caused  by  making  the  compressor  run
during  a  more  efficient  operating  mode  (cruise  versus
acceleration).   Due  to   the  intermittent  cycling  and  the
delayed  compressor  operation,   less  fuel  economy   gain
(buy-back) is expected on this type of system.

Obtaining the optimum match of an  A/C cutout  device  to each
type of vehicle would be an impossible  task with all the
varied  engine  sizes,  manifold  vacuum  modifiers,  vehicle
sizes,   axle ratios, and   transmissions  that are available.

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                                                                            11
              The  P.A.S.S.  KIT partially  overcomes  this difficulty  by
              allowing  the  user to adjust  the cutout point.   The cut-in
              (on) setting for  the P.A.S.S. KIT is fixed.

         (3)  Operating Variables

              The final considerations  on  the  potential  effectiveness are
              the operating variables.

              (a)  Since the  device  only functions when the  A/C  is used,
                   the  overall  benefit would depend on how  much  the
                   vehicle A/C  is used.

              (b)  Higher  ambient  temperatures   and humidity  cause  a
                   greater  fuel economy penalty  due  to   the  use  of  A/C
                   and,  thus,   offer  the  opportunity   for  a   greater
                   buy-back.

              (c)  The effectiveness  will also depend upon driving habits
                   of  the  operator.    Thus  drivers  who  repeatedly  use
                   heavy  acceleration,  and  thereby  activate the  device
                   more frequently,  will realize  a  greater  benefit  from
                   the  device   than   drivers  who   use  more   moderate
                   accelerations.

              (d)  The  type  of driving  cycle used  will influence  the
                   effectiveness of the device.   The system  will  be  more
                   effective   in  urban   driving   with   its   increased
                   acceleration  modes  operation  than in  highway  steady
                   state driving.
              (e)
The effectiveness  will also depend  on the  penalty in
comfort the operator is willing  to accept.   Usually, a
vehicle is in  a heavy  acceleration mode  for  only 5 to
30 seconds.   Since the evaporator  fan remains  on and
there is  stored cooling,  only a slight change  in air
conditioning   comfort   would    be   noted.    However,
prolonged  steep grades or  heavy loads may  cause the
device to  cut  out  excessively  and  thereby  noticeably
reduce the cooling.   This also  will  tend to  occur as
the device  is  adjusted  to maximize  the fuel economy
buy-back  by  adjusting  the  P.A.S.S.   KIT to  activate
sooner.
8.  Conclusions
    EPA  fully  considered  all  of   the   information   submitted   by  the
    applicant.  The  evaluation of  the  P.A.S.S. KIT device was  based  on
    that information and the results  of the  EPA confirmatory testing of a
    similar device.   The  overall conclusion is  that  P.A.S.S.  KIT should
    recover part  of  the  emissions  and fuel  economy  penalty  incurred  by
    using the air conditioner of some vehicles.

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                                                                             12
    The amount  of  this fuel  economy  benefit depends  on  several factors.
    The  most  important  factor  is  the  amount  that  the  vehicle  air
    conditioner  is  used.   Drivers  in  warm climates  who  frequently  use
    their air  conditioner would  experience the  greatest  change  in fuel
    economy  when driving  in  situations   that   frequently  activate  the
    device.   The second important factor is the  suitability of the device
    to  the  manifold  vacuum  characteristics  of  the  particular  vehicle.
    The improvement  in fuel economy with the  air conditioner on can range
    up  to  a few  percent  depending  on  the  vehicle and  the  specific
    adjustments  the   user  performs  to  match  the  P.A.S.S.   KIT  to  his
    vehicle.  Another factor  affecting the  performance  is  the  type  of
    vehicle  air  conditioning  unit   to   which   the  "P.A.S.S.  KIT"   is
    applied.  Systems which operate  continuously should realize  a larger
    benefit  than those which cycle.    The final  factor  is  the  type  of
    driving.  The "P.A.S.S. KIT"  system is expected  to show the greatest
    improvement in urban stop-and-go driving.

    The emissions from vehicles  operating with  the air conditioning  on
    are expected to  be reduced when the "P.A.S.S. KIT" is used.

FOR  FURTHER INFORMATION  CONTACT:   Merrill  W.  Korth,  Emission  Control
Technology  Division,  Office  of Mobile Sources,   Environmental  Protection
Agency, 2565 Plymouth Road, Ann Arbor,  Michigan 48105, (313) 668-4299.

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                                                                            13
Attachment A
Attachment B
Attachment C
        List of Attachments

P.A.S.S.  KIT  Installation Instructions  (provided with
511 Application).

Letter of  December  14,  1981 from EPA  to  Jay Kuiper of
Cartel  Products  providing  information   on  the  511
evaluation process.

Letter of  December  22,  1981 from Jay  Kuiper of Cartel
Products   to   EPA   acknowledging   receipt   of   511
evaluation information.
Attachemnt D
Letter of  January 28, 1982  from EPA to  Jay  Kuiper of
Cartel   Products    acknowledging    receipt   of   511
application    for    P.A.S.S.    KIT   and   requesting
clarification and additional information.
Attachment E
Letter  of  April  13,  1982  from Jay  Kuiper  of  Cartel
Products  to EPA discussing  proposed  changes  to  the
P.A.S.S. KIT device.
Attachment F
Attachment G
Attachment H
Attachment I
Letter  of  April  19,  1982  from  EPA  to  Jay  Kuiper  of
Cartel  Products  requesting  copy  of proposed  changes
for P.A.S.S. KIT.

Letter  of  April  27,  1982  from  Jay  Kuiper  of  Cartel
Products   to    EPA   providing  modified   installation
instructions for P.A.S.S. KIT.

Letter  of  May  18,  1982  from Charles  Vandenberg  of
Cartel Products  to  EPA discussing P.A.S.S.  KIT sample
variability   and   providing   additional    proposed
installation instructions and device applicability.

Letter of June  10,  1982  from EPA  to  Charles  Vandenberg
of   Cartel   Products  stating   application  was   now
complete but that,  since no testing was  performed,  no
specific  percentage  improvements  could  be  cited  in
this evaluation.

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                                                                                            14

                                                                                        ATTACHMENT A
           INSTALLATION INSTRUCTIONS

1. Select a mounting location In the engine compartment to allow the leads from
  the P.A S S. KIT in reach the A/C compressor electrical iead(s). and the rubber
  hose supplied to reach the carburetor vacuum line.
2. Locate a suitable existing mounting bolt, or drill a 1/8" hole and mount the unit
  with the sheet metal screw provided.
3. Cut one of the wires connected to the A/C compressor clutch. Strip about 3/8"
  of insulation (rom the ends Attach to the P.A.S.S. KIT leads with th»? wire nuts
  provided. Push the wire terminals over the terminals w the base of thePA SS
  KIT.
4. Locale the "Manifold vacuum" line. The "manifold vacuum" source will be near
  Ihr base of the carburetor bolow Ihrj throttle plate(i> if hi-, is tho -same vacuum
  source thai is connected to the distributor vacuum advance  mechanism. *
  Note:
  — DO NO? connect to the auxiliary vacuum pump
  — DO NOT use the vacuum hose connected to the charcoal liltcr lit has a con-
     stant vacuum)
  — Some cars may require trial and error to find the correct vacuum source
  •especially those with fuel injection.
  If you cannot locale the vacuum source, ask a mechanic.
5 IF YOUR CAR HAS A RUBBER VACUUM LINE  cut the vacuum hose near Its
  source • Insert the appropriate TEE provided, and attach to the P.A.S.S. KIT
  with the rubber  hose provided.
  IF YOUR CAR HAS A METAL VACUUM LINE cut the line with a tubing culteror
  hacksaw. Do  not use slrlo cutters as (hey will close the end ol the tubing. Cut
  two 1" pieces from the rubber hose provided. Slide one onto each end of the
  metal tubing. Insert the Tee. and push the rubber hose over the nipple on the
  Tee and the P.A S S  KIT
6 You have now complelrd the Installation of your P.A SS. Kir ThH unit has
  been preset al lhefaclory.however.il is adjustable lo switch off earlier or later
  as follows.
  1  Remove black protective cap.
  2. To have compressor  clutch cut out earlier, turn screw clockwise one/tenth
     turn at a time.
  3. To  have compressor clutch cut out  later, turn screw counter clock-wise
     one/tenth turn at a time
  4 Replace black protective cap. (The black protective cap must be replaced.)
                                             WARNING: Do not connect to auxiliary vacuum pump.
         VACUUM MOSf TO PASS PICKUP
                                   SWITCH SPECIFICATIONS
                            Switch- Vacuum

                            Contact* • Silver, Heavy Duly

                            Electrical • Automotive Clutch Lo»d
               Ollphrtgm • Metal

               Set Point • On • 8" Vacuum
                       •Oil  4" V«cuum

               'Ad|usl*t>le: From 2.5" Vacuum to 5" V»cuum
                              COMPLETE
           READY TO INSTALL
                                               PRODUCTS DIV.
  AOJUSlUtNl

* EPA NOTE:   The installer may  encounter moderate3irMul9y'in  locating  the proper vacuum
  line.   Vacuum port  elevation/location is not  always indicative of .the type of  vacuum  signal.
  Also,  some  Fords have dual  advance  (two vacuum lines).

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                                                       Attachment B
\        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
 o
                        ANN ARBOR. MICHIGAN 48105
 December 14, 1981                                                  OFFICE OF
                                                              AIR. NOISE AND RADIATION
 Mr. Jay Kuiper
 Carter Products Division
 Vandenberg Corporation
 3757 Lake Drive                                                         '
 Grand Rapids, MI  49506

 Dear Mr. Kuiper:

 This is in response to your recent inquiry regarding an EPA evaluation of
 your Pass Kit  device.   The  Environmental Protection Agency is charged by
 Congressional  mandate  to  evaluate  fuel  economy  and  emission  control
 devices.  While the EPA does not actually "approve" such devices, it does
 conduct evaluations for the purpose of increasing the  common knowledge in
 the area.   For this  reason,  the outcome of  any testing  by  EPA becomes
 public information.  It is  this information which may be  cited, although
 no claims can be made  that  any EPA findings constitute "approval" of the
 device or system.

 Enclosed with this letter is a packet of materials which you will need to
 apply  for  an  EPA  evaluation  of  your device.   This  packet  consists  of
 1) an  application  format,  2)  a  document  entitled  "EPA Retrofit  and
 Emission Control Device Evaluation Test Policy", 3) "Basic Test Plans and
 Testing Sequences", and 4)  a  copy of the applicable Federal Regulations.
 In  all of  these  documents  the term  "device"  includes  fuel additives.
 Motor vehicle  oils,  lubricants and oil  additives do  not  fall under the
 provisions  of  Section  511  of the  Motor  Vehicle  Information  and Cost
 Savings  Act.   However, EPA is  prepared to  work with  manufacturers  of
 these  products, using the same  procedures  and  protocols  defined in the
 enclosed documents.

 In order  for  the  EPA  to  conduct an  evaluation of your  device,  we must
 have an  application.   Once you  have reviewed  all  the  documents  in the
 packet,  you  should  prepare  an  application   in  accordance  with  the
 guidelines of the application  format.  A critical part of  the  application
 is the substantiating test data.  The  required test results will have to
 be  obtained at  a  laboratory  of  your  choice.   Such  testing would  be
 conducted at your  expense.   A list  of  laboratories,  which are  known  to
 have the  equipment  and personnel  to perform  acceptable  tests,  has been
 included  in  the  enclosed  packet.   The  laboratory  list  is  revised
 periodically,  so  be  certain  that  the  list  you are  using  is  current.
 Please allow EPA to comment on your test plan  before beginning testing at
 an  independent  laboratory.   If  you  desire,  we  can   assist  in  the
 development of a satisfactory  test plan.

 There  are,  however,  several  aspects  concerning testing  at  an outside
 laboratory which I would like  to bring  to your  attention  at this time;

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                                                                       16
Minimum  Test Requirements — Although different types of  devices may
require a more  complex  test  plan,  the minimum we require involves two
vehicles  and  two  test sequences  run  in  duplicate.   The  vehicles
should be  selected from those  listed in Table 1;  if  possible.   Each
vehicle is  to be set to manufacturer's tune-up specifications for tbe
baseline tes'ts.

The  tests are  conducted in  a  "back-to-back"  manner,  once  with the
vehicle  in baseline  condition,  and  again  with the device installed
with  no  vehicle  adjustments  between tests.   If installation of the
device also  involves some  adjustments,  e.g. timing, fuel-air mixture,
choke or idle  speed,  another test  sequence with  only  these adjust-
ments  should be inserted between the  first  and  last.   If mileage
accumulation  is necessary in order  to realize the full benefit, the
same number  of  miles that are  accumulated  before  the test runs must
also be accumulated before baseline  runs.  In addition,  the method of
mileage  accumulation should be  kept constant.   Also,  as  a  minimum,
the test  sequence shall consist of  a hot-start LA-4 portion (bags 1
and 2) of the Federal Test Procedure (FTP)  and a Highway Fuel Economy
Test  (HFET).   The  details   of  these  tests  are   contained  in  the
enclosed  packet.   Although  only  a  hot-start FTP is  required  to
minimize  the costs  to  you,  you are  encouraged to have  the  entire
cold-start: test  performed, since any confirmatory testing  and evalua-
tion performed  by EPA will be based on the  complete FTP,  and you may
wish  to know how a vehicle with  your  device performs  over  this
official test.   As a final requirement,  the personnel of  the outside
laboratory  you  select  should  perform  every  element   of  your  test
plan.  This  includes preparation of  the test  vehicle,  adjustment of
parameters, and installation of the device.

Submission of Data - We require that all test  data obtained  from the
outside  laboratories in support of  your application be  submitted to
us.  This  includes any  results you  have which were declared void or
invalid  by the  laboratory.   We also  ask that you notify us of the
laboratory you  have chosen,  when testing is scheduled, to  begin, what
tests you have  decided  to conduct, allow us to maintain contact with
the laboratory  during the course of  the testing,  and allow  the test
laboratory  to directly  answer  any  questions at ..any  time about the
test program.

Cost  of   the  Testing  -  The  cost  of  the  minimum test  plan  (two
vehicles, two  test sequences in duplicate)  described above should be
less than $3000 per  vehicle and less  than $6000 for the  total test at
any of  the laboratories on  the list.   It  should  be recognized that
additions  to the  minimum test  plan (such  as mileage  accumulation,
parameter  adjustment,  or  additional  testing)  will  result  in  addi-
tional costs.   In any  case,  you will have to contact  them  individ-
ually to obtain  their latest prices.

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                                                                            17
    Outcome of  the Tests -  In  order for EPA to  best utilize our  facil-
    ities, confirmatory  testing  will be performed only  on those  devices
    that  demonstrate  a  statistically  significant  improvement  in  fuel
    economy or emissions based on data from an EPA-recognized  independent
    laboratory.  We have established  some  guidelines which will help  you
    determine whether the test results with your device  should be  consid-
    ered encouraging.  These values have been chosen  to  assure both of us
    that a  real difference in fuel  economy  exists,  and that  we are  not
    seeing only the variability in the results.  The  table  below presents
    the minimum number of cars that need to be tested for varying  degrees
    of fuel economy improvement, assuming a typical amount  of  variability
    in fuel economy measurement.  For a  minimum  test plan which was con-
    ducted on a  fleet of two cars,  the  average  improvement should  be at
    least 6%.  If at least a 6% difference in average fuel  economy  can be
    shown, then  we would  be  able to say  statistically at  the 80% con-
    fidence level that there is a real improvement.

    Similarly, we would expect a minimum of 3% improvement  for a fleet of
    5  vehicles.   Test results  which display  a  significant   increase  in
    emission levels should be reason for concern.

         Minimum Fuel Economy Improvements  versus  Size of Test  Fleet

         Fleet Size                   Average  Improvement Required
             ~2                                  6%
              3                                  5%
              4                                  4%
              5                                  3%
             10                                  2%

Once we receive your application, it will  be  reviewed to determine  if it
meets the requirements listed  in the format.  Please do not  submit con-
fidential, trade secret, or  proprietary  information  as  EPA cannot  assure
that  such information can  be  protected  in  all  situations.   If  your
application is not complete,  we  will ask  you  to  submit further  informa-
tion  or  data.  After  any missing  information  has  been submitted,  your
application will be reconsidered, and once it meets our  requirements,  you
will be advised of our decision whether  or not EPA will perform any con-
firmatory testing.  Any  EPA  testing  will be  performed at.no cost  to  you
and you will be given the opportunity to concur with  our test  plan.   Once
this testing  is  complete,  an evaluation report  will be written.   If  no
further testing  is required, the  report will be  written  solely on  the
basis of the test data submitted  and  our  engineering  analysis.

EPA intends  to  process your  application in as  expeditious a manner  as
possible.  We have established a goal of twelve weeks from  the receipt of
a complete application to the announcement of our report.   The attainment
of this objective  requires  very  precise  scheduling,  and we are  depending
on the applicant  to  respond  promptly to any questions,  or  to submit  any
requested data.  Failure to  respond  in  a timely  manner  will unduly  delay
the process.  In the extreme case, we may  consider  lack of response as a
withdrawal of the application.

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                                                                           18
I hope the information above and that contained in the enclosed  documents
will aid you  in the preparation of an acceptable  application for an  EPA
evaluation of your  device.   I  will be your contact  with EPA during  this
process  and  any  subsequent  EPA  evaluation.   My  address is  EPA, Motor
Vehicle  Emission   Laboratory,  2565  Plymouth  Road,  Ann  Arbor,  Michigan,
48105.  The telephone number is (313) 668-4299.  Please contact me if  you
have any questions or require any  further information.

Sincerely,
Merrill W. Korth
Device Evaluation Coordinator
Emission Control Technology Division

Enclosures

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                                                                ATTACHMENT C    19

£OT1EL PRODUCTS DIV.                                                     \
                 December 22, 1981
                 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                 Ann Arbor, MI  48105

                 ATTN: Mr. Merrill  W.  Korth
                 Device Evaluation  Coordinator
                 Emission Control Technology Division

                 Dear Sir,

                 I wanted to take this opportunity to thank you
                 for your help in providing the information
                 necessary to complete our application for
                 a EPA evaluation.

                 After compiling the necessary documentation,
                 we will be forwarding the application to  you.

                 Have a joyous holiday season.

                 Sincerely,
                 cc
                              VANDENBERG CORPORATION
           3133 MADISON AVE.. S.E. GRAND RAPIDS. MICHIGAN 495O8 » PHONE (616) 243-O457

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                                                            ATTACHMENT' D      20

iS:/?,   UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
       »
                          ANN ARBOR. MICHIGAN 48105
                                                              OFFICE OF
                                                       AIR AND WASTE MANAGEMENT
   January 28,  1982 .
   Mr. Jay Kuiper, Vice President
   Cartels Product Division
   Vandenberg Corporation
   3133 Madison, SE
   Grand Rapids, MI  49508
   Dear Mr. Kuiper:                    .

   We  received your letter of January  13,  1982 in which you applied for  an
   EPA evaluation  of the P.A.S.S. KIT, a fuel economy retrofit device.

   Our Engineering Evaluation Group  has made  a preliminary review of your
   application.  Although the application  is essentially complete, we x*ill
   need additional information in the two areas  discussed below.

   Exhibit  A, installation  instructions,   shows that the  off  set-point  is
   adjustable.   Although  you  do  provide instructions for making this adjust-
   ment,  you  provide no guidance on how to determine the most desireable set
   point  for the  user's  specific  vehicle  and  driving conditions.  The in-
   stallation instructions   should either describe  such  a  procedure   or
   include  a  list  of settings for  specific vehicles and driving  conditions.
   Please send us  any  information on  adjustment procedures or  recommended
   settings.   ':   •.-.•'      ...                '              •-.'•-

   As  you noted in Section  3d(2)  of your application,  EPA has  previously
   tested and evaluated another air conditioning compressor cut-off device
   called Pass  Master.   Although  your  device  operates  in  an  identical
   manner,   the  on/off  set points   of   your   device   are  significantly
   different.   Thus,, we  are unable  to quantify  any fuel  economy  benefits
   which  may be attributed  to  your  device.  In  order  to  support  specific
   claims for your device, it will  be necessary for  you  to have it tested  at
   an  independent  laboratory. We will  be  glad  to assist you in developing a
   test plan.  Please inform  me  if you plan  to undertake  such  testing.  For
   your information, I  have  enclosed the EPA test report  on  the Pass Master
   and a  copy of  the  manufacturer's literature vrhich  lists the  off/on set
   points for his  various models.

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                                                                        21
We will  need your response to  the  preceding items  to  properly evaluate
your device.  In  order  to  process applications  efficiently,  we establish
a  schedule for  each one.  I ask  that you  respond to  this  letter  by
February 20 and plan to complete your testing by March 20.   If you have
any questions or  require further information, please contact me at (313)
668-4299.

Sincerely,
Merrill W. Korth, Device Evaluation Coordinator
Test and Evaluation Branch

Enclosures

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 PRODUCTS mif                                   ATTACHMENT E    22
      April  13, 1982
       United States Environmental
       Protection Agency
       Ann Arbor, Michigan  48105                                         M*M«»

       Attn:  Merrill W. Korth
           •  Device Evaluation Coordinator
             Test and Evaluation Branch
       Dear Mr.  Korth:

       Chuck  and I enjoyed our meeting and  appreciated your
       constructive comments.  We are rewriting the instruction:
       sheet  so  that it reflects the changes we have made in the
       P.A.S.S.  Kit.

       The changes center around the fact that we have physically
       identified the setting for 4-6-8 cylinder cars and have also
       made a suggestion to the do-it-yourselfer how he can set the
       device to cut out the air conditioner to fine tune it even
       further.

       In the next few weeks we will set up a meeting and present
       the changes to you.

       Looking forward to working with you.

       Sincerely,
                    VANDENBERG CORPORATION

3133 MADISON AVE.. S.E. GRAND RAPIDS. MICHIGAN 495O8  •  PHONE (616) 243O457

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                                                      Attachment F          „.,
        UNITED STATES ENVIRONMENTAL PROTECTION  AGENCY

                       ANN ARBOR. MICHIGAN 48105
April 19, 1981                                                     OFFICE OF
                                                             AIR. NOISE AND RADIATION
Mr. Jay Kuiper, Vice President
Cartels Product Division
Vandenberg Corporation
3133 Madison, SE
Grand Rapids, MI  49508

Dear Mr. Kuiper:

You stated  in your letter of  April 13 that you had  modified set  points
and installation instructions for the P.A.S.S. KIT.  On the other hand,  I
was disappointed that  you  did not actually include this information  with
your letter hut intend to present it to us at  a future  date.

I feel  th.it  a meeting would be more  productive  if this information  were
available beforehand.   Accordingly,  I ask that  you  submit it  by May  3.
If you  have  any questions  or require further information, please contact
me.

Sincerely,
Merrill W. Korth
Device Evaluation Coordinator
Test and Evaluation Branch

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 PRODUCTS                                      ATTACHMENT G   24

     April  27,  1982
     United States  Environmental
     Protection  Agency
     Ann  Arbor,  Michigan  48105                                           MEMBE*

     Attn:   Merrill W. Korth                                           .
            Device  Evaluation Coordinator
            Test and  Evaluation Branch
     Dear Mr.  Korth:

     As  of today,  I have sent you two new P.A.S.S.  KITS via UPS. for your
     evaluation.   The switches are prototypes and when completed will have
     much sharper  engine type numbers on the flange of the switch.

     Enclosed  for  your evaluation are changes which we propose in the
     instruction sheet as they relate to items 2 and 6 of the Instal-
     lation Instructions.

     At  our last meeting, you challenged us to develop a switch that can be
     set for 4-6-8 cylinder engines.  We have also  proposed changes in the
     instructions  which would give the installer the ability to further
     adjust the switch to its most optimum position.

     In  the E.P.A. evaluation 'of the "Pass Master Vehicle Air Conditioner
     Cut - Off Device" you state that the largest drawback with the
     "Pass Master" device is that it is not optimized for each type of
     vehicle.  We  hope that our proposed changes in items 2 and 6 in the
     installation  instructions will give the installer an opportunity
     to  "fine  tune" the device so that it will operate correctly for each
     vehicle.

     With the  changes we have submitted, I would hope that you can
     release a report similar to the report prepared for the "Pass Master".

     Thank you for your suggestions and encouragement.

     Sincerely,
     JK/rt

                    VANDENBERG CORPORATION
3133 MADISON AVE.. S.E. GRAND RAPIDS. MICHIGAN 495O8 • PHONE (616) 243-O457

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                                                                        25
                         P.A.S.S. KIT


Additional Proposed Installation Instructions.



New Instruction #2:
                                      '    "   '   *
   Set red dot on adjusting screw (found under removable
   rubber cover) to line up with the 4,6, or 8 cylinder
   setting position shown on the body of the switch.
   Locate a suitable existing mounting bolt, or drill  a
   1/8" hole and mount the unit with the sheet metal  screw
   provided.  Mount switch to allow screwdriver access
   to adjustment screw.


New Instruction #6:    .

   You have now completed the installation of your
   P.A.S.S. KIT. .However, if you wish, additional
   "fine tuning" can be accomplished as follows:

   1.  Remove black protective cap.
   2.  To have compressor clutch cut out earlier,  turn screw
       clockwise one/tenth turn at a time.

   3.  To have compressor clutch cut out later, turn  screw
       counter clockwise one/tenth turn at a time.
   4.  Replace black protective cap.  (The black protective  cap
       must be replaced.)

     The above described fine adjustment is  easily accomplished if
you can hear or "feel" your A/C disengage.  If not -  we suggest
that you temporarily run a wire from the P.A.S.S.  KIT switch into
the passenger compartment.  Connect to a 12  volt'bulb or  circuit
tester and run wire back to the A/C clutch lead.  When bulb  is
lit, A/C clutch is engaged.  When bulb is off,  A/C clutch is
disengaged.
     When adjustment is completed, remove wire and indicator light
from passenger compartment and connect electrical  leads permanently
as described in instruction #3.

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                                                   ATTACHMENT H    26
  PRODUCTS DIV.
    May 18, 1982
    United States Environmental
    Protection Agency
    Ann Arbor, Michigan  48105
    Attn:  Merrill W. Korth
           Device Evaluation Coordinator
           Test and Evaluation Branch
     Dear Merrill:

     In  response  to your discovery of the variation in the
     upper  Con) set point of our P.A.S.S. KIT vacuum switches,
     we  have bench tested the switches on hand and found that
     approximately 12% of those tested exceeded 9" Hg..  We subse-
    quently discovered that the latest shipment of these switches
     supplied by  our vendor were manufactured to a tolerance of
     7-10"  Hg instead of our requirement of 8"±1" Hg.

     Although our vendor has taken steps to preclude this from
     happening again, we will do a spot check in our shop as
     standard operating  procedure in the future.

     I have enclosed a revised copy of the "Additional Proposed
     Installation Instructions", and copy for the exterior of the
     package regarding vehicles to which the kit does not apply.

     Please feel  free to contact Jay or me if there is any additional
     data required to write a draft of your report.

     Thank  you very much foryour help Merrill and Tony, we
     look forward to hearing from you.
                                                                         MEM»E»
     Charles Vandenber

     CV/rt

     Enclosures

     cc:   Tony Barth
                    VANDENBERG CORPORATION
3133 MADISON AVE.. S.E. GRAND RAPIDS, MICHIGAN 495O8 • PHONE (616)2430457

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                                                                     27
                        P.A.S.S. KIT


Additional  Proposed  Installation Instructions, (revised 5/11/82)


New Instruction #2:

    Set  red  dot on adjusting screw (found under removable "
    rubber cover) to  line up with the 4,6, or 8 cylinder
    setting  position  shown on the body of the switch.
    Locate a suitable existing mounting bolt, or drill  a
    1/8" hole and mount the unit with the sheet metal screw   .
    provided.  Mount  switch to allow screwdriver access
    to adjustment screw.


New Instruction #6:

'    You  have now completed the installation of your
 '   P.A.S.S. KIT.  However, it is adjustable to switch!
    off  earlier or later if you wish.  The objective
    being to achieve  a minimum of A/C compressor
    operating time -  while still maintaining acceptable
    cooling  under your normal driving conditions.  This
    additional  "fine  tuning" can be accomplished as
    follows:

    1.  Remove black  protective cap.           .
    2.  To have compressor clutch cut out earlier, turn screw
        clockwise one/tenth turn at a time.

    3.  To have compressor.-clutch cut out later, turn screw
        counterclockwise one/tenth turn at a time.

    4.  Replace black protective cap.  (The black protective cap
        must be replaced.)
      The above described fine adjustment is easily accomplished if
 you can hear or "feel" your A/C disengage.  If not, we suggest
 that you temporarily run a wire from the P.A.S.S. KIT switch  into
 the passenger compartment.  Connect to a 12 volt bulb or circuit
 tester and run wire back to the A/C clutch lead.  When bulb is
 Tit, A/C clutch is  engaged.  When bulb is off, A/C clutch is
 disengaged.

      When adjustment is completed, remove wire and indicator  light
 from passenger compartment and connect electrical leads permanently
 as described in instruction #3.

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                                                                    28
                        P.A.S.S.  KIT

                    Application Notice
NOTICE


     Some 1982 vehicles have been factory equipped  with
a device similar to P.A.S.S. KIT.  Therefore,  the P.A.S.S. KIT
would not be effective on the following vehicles:


        1982  Ford Escort with automatic transmission

        1982  Mercury Lynx with automatic transmission

        1982  Cadillac, all models.

        1982  Buick.Oldsmobile - 4 cylinder and  V-6 with
              automatic transmissions.
P.A.S.S. KIT is NOT recommended for use on  vehicles  with
Diesel engines as they do not have a reliable source of
"manifold vacuum".

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                                                      Attachment I
                                                                            29
        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                       ANN ARBOR. MICHIGAN 48105
June 10, 1982                                                      OFFICE OF
                                                             AIR. NOISE AND RADIATION
Mr. Charles Vandenberg
Cartel Products Division
Vandenberg Corporation
3133 Madison, SE
Grand Rapids, MI  49508

Dear Mr. Vandenberg:

We received  your  letter of May  18.   It appears you have  adequately ad-
dressed our  comments on the  P.A.S.S. KIT  Installation  instructions and
vehicle applicability.  Since you did not mention testing, it appears you
do not  plan  to test the P.A.S.S. KIT using a  test  plan  approved by EPA.
Therefore, we  are  preparing the evaluation of  your device based  on the
information now available to us.

If you  do decide  to test at  an independent  laboratory, please  send us
your test plan by  June  30th  so  that we  have the opportunity to review it
to preclude  the risk of  an oversight  that might  invalidate  your whole
effort.   We  recognize that  such testing is expensive and  want to ensure
that any testing you undertake will meet our needs.  Also  let  us know at
that time which laboratory you  have  selected and the scheduled dates for
testing.  Please plan to have the test  program completed by August 15 so
that our evaluation can still be completed  in a timely manner.

Although we will be able to complete  our evaluation without you providing
any test results,  it will not include any percentage values which you can
use in  your  literature  or advertising.   Our position on this  matter was
expressed to you  in our  meeting on  May  5.   If you have  any questions
about our requirements,  please contact me at (313) 668-4299.

Sincerely,
Merrill W. Korth, Device Evaluation Coordinator
Test and Evaluation Branch

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