EPA-AA-TEB-81-15
        Emissions and Fuel Economy of
         FUEL-MAX, a Retrofit Device
              F. Peter Hutchins
                John T. White
                  May,  1981
         Test and Evaluation Branch
    Emission Control Technology Division
Office of Mobile Source Air Pollution Control
       Environmental Protection Agency

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Abstract

This  report  describes  the  results of  testing the  "FUEL-MAX"  device  as
part of an evaluation  under  Section 511 of the Motor  Vehicle  Information
and Cost Savings Act.  The FUEL-MAX is  an  air-bleed  device  which  replaces
a  vehicle's  Exhaust Gas  Recirculation (EGR)  valve.  The  amount of  air
bled into  the  intake manifold is  determined  by  the vacuum signal  which
once controlled the  action  of the EGR  valve.   This  device  is claimed  to
conserve fuel.  The  primary  purpose of this  project was to evaluate  the
effect of the FUEL-MAX on exhaust emissions and fuel  economy.

Testing of  three  typical  1979 model  year passenger  cars  was conducted
during March,  1981.   The basic  test sequence  included  the Federal Test
Procedure  (FTP)  and  the Highway  Fuel  Economy  Test  (HFET).  These  tests
were performed both  before and after  installation of the FUEL-MAX.  As  a
result of  the  testing,  average  hydrocarbon and carbon monoxide emissions
decreased  somewhat  while   oxides  of  nitrogen  displayed  substantial
increases.    Fuel  economy  was  found  to   increase   approximately  three
percent on the FTP but exhibited no change over the  HFET.   The occurrence
of engine  knock  was  obvious  on  two of three  vehicles.   EPA's  Office  of
Enforcement   has   determined   that   the   FUEL-MAX  can   violate    the
anti-tampering provisions of the  Clean Air  Act.

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                                    -2-

Background

Section  511  of  the Motor Vehicle  Cost  Savings  and  Information  Act
empowers the Environmental  Protection Agency  (EPA)  to  evaluate  devices or
fuel additives  which may improve  the  fuel economy of  conventional  motor
vehicles.   The  EPA  has  developed  and instituted  a procedure  whereby an
individual  or organization  may apply for an  evaluation of the device or
fuel  additive.    This  procedure  requires  the  applicant  to   submit  a
technical  description of  the   system  in  conjunction  with  results  from
actual  testing.   Once a  complete  application is  received,  the EPA will
conduct an  engineering evaluation  and  publish the results in the  Federal
Register.  In those  cases where  the device  or additive shows  promise,  the
EPA  will  conduct  tests  as a  part of  its evaluation.   Such  testing  is
performed at EPA's Motor Vehicle Emission Laboratory in Ann Arbor.

In  February,  1980,   EPA received  an  application  from  Fuel   Injection
Development Corporation  for an evaluation  of  the  FUEL-MAX.   This device
is an  air-bleed mechanism  which replaces  the  Exhaust Gas  Recirculation
(EGR)  valve.    The  amount  of  air  bled  into  the  intake  manifold  is
determined  by the  vacuum signal which once controlled the action of  the
EGR valve.

Based  on an  evaluation  of  the test  results  submitted   to  support  the
claims  for  the  FUEL-MAX,  EPA chose to conduct confirmatory  testing.   The
basic purpose of the testing was to determine  the  effect  of  the device on
fuel  economy and  exhaust  emissions.   Secondary  purposes  included  an
evaluation of the installation instructions and driveability factors.

Test Vehicles

Three  typical 1979  production  vehicles  were   used:  a  Ford  Pinto  with  a
4-cylinder engine, an Oldsmobile Cutlass  with a 6 cylinder engine,  and  a
Mercury Zephyr  with  an  8  cylinder  engine.   All  vehicles were equipped
with  automatic   transmissions.   A  more  detailed  description of   each
vehicle is provided in Appendix A.

Test Fuel
Commercial,  unleaded  regular  fuel  was  used  in  the  testing   of   the
FUEL-MAX.  A  single batch  of  the fuel  was  purchased  and  stored at  the
EPA.  The motor octane number was 83 while the research octane  number  was
91.   The decision  to  use  a commercial  fuel was  based upon  the knock
sensitivity of  some  engines to  EGR deactivation.  The  Indolene fuel used
in  EPA  testing  has  a   higher  octane  rating  than  typical  commercial
unleaded gasoline.  Thus, use of commercial fuel was  appropriate  for this
evaluation where the possibility of increased  knock was probable.

Type of Tests

Exhaust emission  tests were conducted  according  to the  1977  Federal Test
Procedure  (FTP) described in the Federal Register  of June  28, 1977,  and
the  EPA  Highway   Fuel  Economy  Test  (HFET)  described  in  the   Federal
Register  of   September  10, 1976.   The  vehicles  were  not  tested   for
evaporative emissions.

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                                    -3-
Other  tests  were  also   conducted   as   an  additional  aspect  of  this
evaluation.   These  tests  consisted  of hot  start  LA-4 cycles.   The  LA-4
driving cycle is  the  basic FTP driving  cycle.   The results of  these hot
start LA-4 tests are generally similar to bags 2 and 3 of the FTP.

Device Installation

Installation  of  the  FUEL-MAX  on  the  test  vehicles was  performed  in
accordance   with   the   device   installation  instructions.    Following
installation, a dial  on the FUEL-MAX was set for  the size of  the  engine
as  specified  in the  instructions;  i.e., set at 1.4  for the  Pinto  (140
C1D), 2.3 for the Cutlass (231 CID), and 3.0 for the Zephyr (302 C1D).

The following problems were experienced during the installations:

1.  On the Pinto, the installation instructions call  for  the  EGR valve to
    be disconnected from the intake manifold,  but  to  be left  connected to
    the exhaust gas transfer pipe so  as  to  close the  end  of  the transfer
    pipe.   On  the  test   vehicle,  the  EGR  valve  and  the  exhaust  gas
    transfer pipe had to  be removed because  the configuration  of  the EGR
    valve was different  than that shown in  the  installation  instructions
    and an exhaust leak occurred.

2.  On the  Zephyr,  the  FUEL-MAX  caused  an  exhaust  leak at  the manifold
    where  the  EGR  valve  is normally installed.   A  sealing   plate  and
    additional  gaskets  had to  be  employed  to  prevent  this  underhood
    exhaust leak.

Vehicle Test Configurations

Baseline testing was  performed  after  each vehicle was  set to  the  vehicle
manufacturer's tune-up specifications.  The  second  test configuration was
with  the   FUEL-MAX   installed   in   accordance  with   the   installation
instructions.  A  third  configuration was employed  in testing  the  Pinto.
In  this  configuration  (along  with  the  FUEL-MAX),  the  ignition  was
retarded by  5°  from  specifications.   This  was  done to correct  the heavy
knock which had been exhibited in the road evaluation.

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                                    -4-
Test Results

The vehicles were  tested  during March of 1981.   All  tests were performed
by  EPA at its Motor  Vehicle Emission Laboratory  in  Ann  Arbor.   Table 1
summarizes  the  results of  this testing.   Emission levels are  listed in
grams/mile while fuel  economy is shown in miles  per  gallon.   The results
of the individual  tests on  each vehicle  are presented in Appendices B, C,
and D.
                                   Table  1
                           Summary of Test Results
FTP
Vehicle
Ford
Pinto

Oldsmobile
Cutlass

Mercury
Zephyr

Overall
Fleet

Configuration
Baseline
FUEL-MAX
Average Change
Baseline
FUEL-MAX
Average Change
Baseline
FUEL-MAX
Average Change
Baseline
FUEL-MAX
Average Change
HC
2.08
1.58
-24%
1.89
1.46
-23%
2.47
2.08
-16%
2.15
1.71
-20%
CO
26.0
18.6
-28%
21.0
19.4
-8.0%
25.5
14.2
-44%
24.2
17.4
-28%
NOx
1.35
6.03
+350%
1.55
7.44
+380%
0.67
7.17
+970%
1.19
6.88
+480%
MPG
21.
22.
+4.
18.
18.
+1.
15.
15.
+3.
17.
18.
+3.
5
4
2%
2
5
6%
2
7
3%
9
5
4%
HC
.76
.61
-20%
.40
.23
-43%
.89
.83
-7.0%
.68
.56
-18%
HFET
CO
5.2
2.8
-46%
4.7
1.6
-66%
2.7
1.2
-5.6%
4.2
1.8
-57%
NOx
2.38
6.83
+190%
1.56
8.72
+460%
1.17
9.03
+670%
1.70
8.19
+380%
MPG
29.
29.
+1.
26.
26.
-0-
22.
22.
-0.
25.
25.
+0.
0
3
0%
4
4

9
8
4%
8
9
4%
The Pinto exhibited heavy  knock during the road evaluation.   In  this case,
the basic timing was retarded 5° and  the  vehicle  was  retested.  The results
are shown in Table 2 below:

                                   Table  2
            Summary of  Test Results on Pinto with Retarded  Timing
Vehicle    Configuration  HC
Ford
Pinto
Baseline
FUEL-MAX
FUEL-MAX (-5°) 1.20
Average Change -42%
(from baseline)

HC
2.08
1.58
1.20
-42%


CO
26.0
18.6
18.3
-30%
FTP
NOx
1.35
6.03
4.46
+230%
HFET
MPG
21.
22.
22.
+3.
5
4
2
3%
H£
.76
.61
.50
-34%
C0_
5.2
2.8
2.0
-62%
NOx
2.38
6.83
5.24
+120%
MPG
29.0
29.3
29.8
+2.8%

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                                    -5-

On-Road Evaluations and Observations

Pinto;   With  FUEL-MAX installed,  the  vehicle exhibited  the  following
         knock characteristics;
             a)  Cold engine, light acceleration - moderate knock
             b)  Heavy knock  on  light accelerations or  while  maintaining
                 speed on a minor grade
             c)  Under wide-open  throttle  accelerations  to 55  mph,  knock
                 did not occur
             d)  Idle quality was poor (rough) with a warmed-up engine

             Ignition  timing  retard  of  approximately  5°  removed  the
             knock.  Vehicle acceleration performance deteriorated.

Cutlass; With  FUEL-MAX,  this  vehicle  exhibited  stumble  and  hesitation
         attributable to a lean air/fuel mixture.   Knock (trace)  occurred
         under  heavy  accelerations,  moderate  accelerations   and  light
         accelerations.  Intermittent, light knock occurred under highway
         cruise conditions with FUEL-MAX.

Zephyr;  This  vehicle  exhibited  occasional  occurrences  of  trace  knock.
         When cold, the vehicle exhibited stumble at 20 mph.

Conclusions
As a result of EPA  testing  of  FUEL-MAX on three 1979  passenger  cars,  the
following conclusions were drawn:

1.       The installation instructions and the material  packaged  with  the
         device were not adequate in all cases.

2.       Use  of   the  FUEL-MAX  resulted  in  a  decrease  in  hydrocarbon
         emissions.   The average decrease was 20% for  the  FTP  and 18%  for
         the HFET.

3.       Carbon monoxide  emissions were  also  reduced;  28%  over  the  FTP
         and 57% over the HFET.

4.       NOx  emissions increased  substantially;  480%  over the  FTP  and
         380% over the HFET.

5.       Use of the FUEL-MAX resulted in  a three percent increase in fuel
         economy on the FTP but essentially no change on the HFET.

6.       During the  road  evaluations,  FUEL-MAX  caused heavy knock  on  one
         car, and light knock  in another.  Knock was  rarely noted  on  the
         third car.

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                                    -6-
7.       Installation of  the FUEL-MAX  device  is  considered  "tampering1
         under the provisions of the Clean Air Act*.
*"EPA tests  showed  that the use  of  this device,  on  the vehicles  tested
caused emissions to  exceed  applicable standards.  Thus, the  installation
of  this  device  by   a  person in  the  business  of  servicing,  repairing,
selling,  leasing, or trading motor  vehicles,  fleet operators, or new car
dealers will be considered in violation  of Section 203(a)(3)  of  the  Clean
Air Act, the  Federal prohibition  against tampering with emission control
systems.   That  is,  there is currently  no  reasonable  basis for  believing
that  the  installation or use  of  this  device will not adversely  affect
emission performance.   This  determination does  not  preclude  the  use  of
the FUEL-MAX device  on  a different  vehicle or vehicles  than  those  tested
by EPA if Federal Test Procedure  tests  performed on such vehicles clearly
establish that  emission performance  of  those  particular vehicles  is  not
adversely affected.

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                                    -7-




                                   Appendix A




                            Test Vehicle Descriptions
Make/Model




Model Year




Type




Vehicle I.D.




Initial Odometer




Engine Type




    Configuration




    Displacement




    Fuel Metering




    Fuel Requirement




Transmission




Tires




Inertia Weight




Actual HP @50 mph




Emission Control Systems
Ford Pinto Oldsmobile Cutlass
1979
2 door
9T11Y186165
23540
Spark Ignition
In-line 4
140 C1D
2V Carburetor
Unleaded
Automatic
B78-13
3000
10.3
EGR
Catalyst
1979
2 door
3R47A9M523280
34880
Spark Ignition
V6
231 CID
2V Carburetor
Unleaded
Automatic
P195/75R14
4000
12.0
EGR
Catalyst
Mercury Zephyr
1979
2 door
9E35F621630
31760
Spark Ignition
V8
302 CID
2V Carburetor
Unleaded
Automatic
CR78-14
3500
11.2
EGR
Air Pump
Catalyst

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                                    -8-
                                 Appendix B

                   Test Results - Ford Pinto, 140 CID, 4 Cylinder
Test    Test                   Federal Test Procedure     Highway Fuel Economy Test
Date.    #   Configuration	HC    CO    NOx   MFC    HC   CO   NOx   MPG	

3-3-81  5560  Baseline          2.09  26.1  1.37  21.44
3-3-81  5561  Baseline                                   0.74  5.0  2.35  28.87
3-4-81  5562  Baseline          2.06  26.0  1.33  21.56
3-4-81  5563  Baseline                                   0.77  5.3  2.40  29.19

3-5-81  5564  FUEL-MAX          1.66  20.2  5.84  22.06
3-5-81  5565  FUEL-MAX                                   0.64  3.2  6.57  29.17
               \
3-6-81  5566  FUEL-MAX          1.50  17.0  6.22  22.71
3-6-81  5567  FUEL-MAX                                   0.58  2.3  7.08  29.42

3-25-81 5568  Fuel Max (-5°)*   1.00  18.8  4.36  21.97
3-25-81 5569  Fuel Max (-5°)                             0.49  1.9  4.93  29.80
3-26-81 5570  Fuel Max (-5°)    1.41  17.8  4.56  22.48
3-26-81 5571  Fuel Max (-5°)                             0.51  2.1  5.56  29.90

*For  this  series of  tests,  the device  remained in  place  but  the  basic
timing was retarded 5° to correct a heavy knock condition.

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                                    -9-
                                     Appendix C
                   Test Results - Oldsmobile Cutlass, 231CID, V-6

Test    Test                   Federal Test Procedure     Highway Fuel Economy Test
Date.    #   Configuration    HC	CO    NOx    MPG    HC   CO    NOx   MPG
3-4-81  6845  Baseline
3-4-81  6848  Baseline
3-5-81  6849  Baseline
3-5-81  6850  Baseline
3-6-81  6851  Baseline
3-6-81  6852  Baseline
1.95  22.3  1.56  18.16
1.82  20.3  1.52  18.37
1.90  20.5  1.57  18.16
                         0.55  7.1  1.52  26.17
                         0.43  5.0  1.44  26.61
                         0.36  4.2  1.58  26.34
3-10-81 6853  FUEL-MAX
3-10-81 6854  FUEL-MAX
3-11-81 6855  FUEL-MAX
3-11-81 6856  FUEL-MAX
1.40  18.9  7.44  18.43
1.51  20.0  7.45  18.62
                         0.22  1.4  8.57  26.32
                         0.24  1.6  8.76  26.53
3-19-81 8359  Baseline
3-19-81 8361  Baseline
3-19-81 6858  FUEL-MAX
                         0.40  4.6  1.61  26.43
                         0.25  2.6  1.63  26.40
                         0.23  1.9  8.82  26.42
                            HOT START LA-4
3-19-81 8358  Baseline
3-19-81 8360  Baseline
3-19-81 6857  FUEL-MAX
3-19-81 6859  FUEL-MAX
1.14  13.4  1.50  19.25
1.32  15.1  1.54  19.54
1.24  16.5  7.90  19.71
1.37  15.6  7.73  13.06*
*Fuel economy void - error in CO- readings.

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                                   -10-


                                     Appendix D
                     Test Results - Mercury Zephyr, 302CID, V-8

Test    Test                   Federal Test Procedure     Highway Fuel Economy Test
Date.    //   Configuration     HC	CO    NOx   MPG    HC   CO   NOx   MPG	
3-3-81  6771  Baseline
3-3-81  6772  Baseline
3-4-81  6773  Baseline
3-4-81  6774  Baseline
3-5-81  6775  Baseline
3-5-81  6776  Baseline
2.42  25.2  0.66  15.10
2.42  24.1  0.69  15.25
2.46  23.2  0.71  15.23
                         0.94  1.4  1.34  23.08
                         0.86  3.8  1.07  22.58
                         0.86  2.8  1.11  23.09
3-10-81 8094  FUEL-MAX
3-10-81 8095  FUEL-MAX
3-11-81 8125  FUEL-MAX
3-11-81 8126  FUEL-MAX
2.05  14.3  7.20  15.72
2.12  14.2  7.14  15.72
                         0.81  1.2  9.31  22.77
                         0.85  1.1  8.75  22.80
3-18-81 8302  Baseline
2.58  29.5  0.61  15.04

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                    123
                                       Attachment H

                                       EPA-AA-TEB-81-15
        Emissions and Fuel Economy of
         FUEL-MAX, a Retrofit Device
              F. Peter Hutchins
                John T. White
                  May, 1981
         Test and Evaluation Branch
    Emission Control Technology Division
Office of Mobile Source Air Pollution Control
       Environmental Protection Agency

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                                  124
Abstract

This  report  describes  the  results of  testing the  "FUEL-MAX"  device  as
part of an evaluation  under Section 511 of the Motor Vehicle  Information
and Cost Savings Act.  The  FUEL-MAX is an  air-bleed  device which  replaces
a  vehicle's  Exhaust Gas  Recirculation (EGR)  valve.  The amount of  air
bled into  the  intake manifold  is  determined  by the vacuum signal  which
once controlled  the  action  of the EGR valve.  This  device  is claimed  to
conserve fuel.   The  primary purpose of this project was to evaluate  the
effect of the FUEL-MAX on exhaust emissions and fuel  economy.

Testing of  three  typical  1979 model  year passenger cars  was conducted
during March,  1981.   The basic test  sequence included  the  Federal Test
Procedure (FTP)  and  the Highway  Fuel  Economy Test  (HFET).   These  tests
were performed both  before  and  after installation  of the FUEL-MAX.  As  a
result of the  testing,  average  hydrocarbon and carbon monoxide emissions
decreased  somewhat  while   oxides   of  nitrogen  displayed  substantial
increases.    Fuel  economy  was  found   to   increase   approximately  three
percent on the FTP but exhibited no change over the  HFET.  The occurrence
of engine knock  was  obvious on two of three vehicles.   EPA's  Office  of
Enforcement    has  determined   that   the   FUEL-MAX   can   violate    the
anti-tampering provisions of the Clean  Air  Act.

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                                  125
 Background

 Section  511  of  the  Motor  Vehicle  Cost  Savings  and  Information  Act
 empowers the  Environmental  Protection  Agency  (EPA)  to  evaluate  devices or
 fuel  additives  which may improve  the  fuel economy of  conventional  motor
 vehicles.   The  EPA  has  developed and instituted  a procedure  whereby an
 individual  or organization  may apply  for an  evaluation of the  device or
 fuel  additive.   This  procedure  requires  the  applicant  to  submit  a
 technical  description of  the  system  in  conjunction  with  results  from
 actual  testing.   Once a  complete application is  received,  the EPA  will
 conduct an  engineering  evaluation and  publish the results in  the  Federal
 Register.   In those  cases where  the  device  or additive shows  promise,  the
 EPA  will  conduct  tests  as  a part  of its evaluation.   Such  testing  is
 performed at  EPA's Motor Vehicle Emission Laboratory in Ann Arbor.

 In  February,  1980,   EPA received  an application  from  Fuel  Injection
 Development  Corporation  for an evaluation  of  the  FUEL-MAX.  This device
 is  an air-bleed mechanism  which replaces  the  Exhaust Gas  Recirculation
 (EGR)  valve.   The  amount   of  air  bled  into  the  intake  manifold  is
 determined  by the  vacuum signal which once controlled the action of  the
 EGR valve.

 Based  on  an  evaluation of  the  test  results  submitted  to  support  the
 claims for  the  FUEL-MAX,  EPA chose  to conduct confirmatory testing.   The
 basic purpose of the testing was  to  determine  the effect  of the device on
 fuel  economy and  exhaust   emissions.   Secondary  purposes "included  an
 evaluation of the installation instructions and driveability factors.

 Test Vehicles

 Three  typical 1979  production vehicles  were  used:  a  Ford  Pinto  with  a
 4-cylinder engine,  an Oldsmobile  Cutlass with a 6 cylinder engine, and  a
Mercury Zephyr  with an  8  cylinder  engine.   All  vehicles were equipped
 with  automatic  transmissions.   A  more  detailed  description of   each
 vehicle is provided in Appendix A.

Test Fuel
Commercial,  unleaded  regular  fuel  was  used  in  the   testing   of   the
FUEL-MAX.  A single batch of  the fuel  was  purchased and  stored at  the
EPA.  The motor octane number was 83 while the research octane number  was
91.   The decision  to  use a commercial  fuel was  based  upon  the knock
sensitivity  of  some  engines  to  EGR deactivation.   The Indolene fuel used
in  EPA  testing  has a  higher  octane  rating  than  typical  commercial
unleaded gasoline.  Thus, use of commercial fuel was appropriate  for this
evaluation where the possibility of increased  knock was probable.

Type of Tests

Exhaust emission tests were  conducted  according  to the 1977 Federal Test
Procedure (FTP) described in the Federal Register  of  June  28,  1977,  and
the  EPA  Highway   Fuel   Economy  Test  (HFET)  described   in the   Federal
Register  of   September   10,  1976.   The  vehicles  were   not  tested   for
evaporative emissions.

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                                  126
Other  tests  were   also   conducted   as   an  additional   aspect  of  this
evaluation.   These  tests  consisted  of hot start  LA-4 cycles.   The  LA-4
driving  cycle  is the basic FTP driving  cycle.   The  results of  these  hot
start LA-4 tests are generally similar to bags 2 and 3 of the FTP.

Device Installation

Installation  of  the  FUEL-MAX  on  the  test  vehicles was  performed  in
accordance   with  the   device   installation  instructions.    Following
installation, a  dial on the FUEL-MAX was set for  the size of  the  engine
as  specified  in the instructions;  i.e., set at 1.4  for the  Pinto  (140
CID), 2.3 for the Cutlass (231 CID), and 3.0 for the  Zephyr (302 CID).

The following problems were experienced during the  installations:

1.  On the Pinto, the  installation instructions call  for  the  EGR valve  to
    be disconnected  from the intake manifold, but to  be  left  connected  to
    the exhaust gas  transfer pipe so  as  to  close the  end of  the transfer
    pipe.   On  the   test  vehicle,  the  EGR  valve  and  the  exhaust   gas
    transfer pipe had  to  be removed because the configuration  of the  EGR
    valve was different  than that shown in the  installation  instructions
    and an exhaust leak occurred.

2.  On the  Zephyr,  the FUEL-MAX  caused  an exhaust  leak at  the manifold
    where  the EGR  valve  is normally  installed.    A sealing   plate  and ,
    additional  gaskets had to  be   employed  to  prevent  this  underhood
    exhaust leak.

Vehicle Test Configurations

Baseline testing was performed after  each vehicle  was set to  the vehicle
manufacturer's tune-up specifications.  The second test  configuration  was
with  the   FUEL-MAX   installed  in   accordance   with   the   installation
instructions.   A third configuration was employed in testing  the  Pinto.
In  this  configuration  (along with  the  FUEL-MAX), the   ignition   was
retarded by 5°  from  specifications.   This was done  to correct  the heavy
knock which had been exhibited in  the road evaluation.

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                                  127
 Test  Results

 The vehicles  x*ere tested during March  of  1981.   All tests were  performed
 by  EPA at  its  Motor Vehicle Emission  Laboratory in Ann  Arbor.   Table  1
 summarizes  the results  of  this testing.   Emission levels  are listed  in
 grams/mile  while  fuel economy is shown  in  miles  per gallon.   The  results
 of the  individual tests  on  each vehicle are presented in Appendices B,  C,
 and D.
                                   Table 1
                           Summary of Test Results
                                    FTP
                             HFET
Vehicle    Configuration  HC
CO
Ford       Baseline       2.08  26.0
Pinto      FUEL-MAX       1.58  18.6
           Average Change -24%  -28%
NOx

1.35
6.03
+350%
MPG
HC
CO
NOx
MPG
             21.5   .76   5.2
             22.4   .61   2.8
             +4.2%  -20%  -46%
Oldsmobile Baseline       1.89  21.0  1.55   18.2    .40   4.7
Cutlass    FUEL-MAX       1.46  19.4  7.44   18.5    .23   1.6
           Average Change -23%  -8.0% +380%  +1.6%   -43%  -66%
                   2.38   29.0
                   6.83   29.3
                   +190%  +1.0%

                   1.56   26.4
                   8.72   26.4
                   +460%  -0-
Mercury    Baseline       2.47  25.5  0.67
Zephyr     FUEL-MAX       2.08  14.2  7.17
           Average Change -16%  -44%  +970%

Overall    Baseline       2.15  24.2  1.19
Fleet      FUEL-MAX       1.71  17.4  6.88
           Average Change -20%  -28%  +480%
             15.2   .89   2.7   1.17   22.9
             15.7   .83   1.2   9.03   22.8
             +3.3%  -7.0% -5.6% +670%  -0.4%
             17.9
             18.5
             +3.4%
              .68   4.2
              .56   1.8
              -18%  -57%
                   1.70   25.8
                   8.19   25.9
                   +380%  +0.4%
The Pinto exhibited  heavy  knock during the road evaluation.   In this case,
the basic timing was retarded  5° and  the  vehicle  was retested.  The results
are shown in Table 2 below:
                                   Table 2
            Summary of Test  Results on Pinto  with Retarded  Timing
                                    FTP
                             HFET
Vehicle    Configuration  HC_    CO    NOx    MPG    H£    CO    NOx    MPG

Ford       Baseline       2.08  26.0  1.35   21.5   .76   5.2   2.38   29.0
Pinto      FUEL-MAX       1.58  18.6  6.03   22.4   .61   2.8   6.83   29.3
           FUEL-MAX (-5°) 1.20  18.3  4.46   22.2   .50   2.0   5.24   29.8
           Average Change -42%  -30%  +230%  +3.3%  -34%  -62%  +120%  +2.8%
           (from baseline)

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                                     128
On-Road Evaluations and Observations

Pinto:   With  FUEL-MAX  installed,  the  vehicle  exhibited  the  following
         knock characteristics;
             a)  Cold engine, light acceleration - moderate knock
             b)  Heavy knock on light accelerations  or  while maintaining
                 speed on a minor grade
             c)  Under wide-open  throttle accelerations  to 55  mph,  knock
                 did not occur
             d)  Idle quality was poor (rough) with a warmed-up engine

             Ignition  timing  retard  of  approximately  5°  removed  the
             knock.  Vehicle acceleration performance deteriorated.

Cutlass; With  FUEL-MAX,   this  vehicle  exhibited  stumble  and  hesitation
         attributable to a lean air/fuel  mixture.   Knock (trace) occurred
         under  heavy  accelerations,  moderate  accelerations  and  light
         accelerations.  Intermittant, light knock occurred under highway
         cruise conditions with FUEL-MAX.

Zephyr;  This  vehicle  exhibited  occasional  occurrences  of   trace  knock.
         When cold, the vehicle exhibited stumble at 20 mph.

Conclusions

As a result of EPA testing of  FUEL-MAX on three 1979  passenger cars,  the.
following conclusions were drawn:

1.       The installation instructions and the material  packaged with  the
         device were not adequate  in all cases.

2.       Use  of   the   FUEL-MAX  resulted  in  a  decrease  in  hydrocarbon
         emissions.  The average decrease was 20%  for  the FTP and 18%  for
         the HFET.

3.  .     Carbon monoxide  emissions  were  also  reduced;  28% over the  FTP
         and 57% over the HFET.

4.       NOx emissions  increased  substantially;  480% over   the  FTP  and
         380% over the  HFET.

5.       Use of the FUEL-MAX resulted in a three percent increase  in fuel
         economy on the FTP but essentially no change on  the HFET.

6.       During the road evaluations,  FUEL-MAX  caused heavy  knock on  one
         car,  and light knock in  another.   Knock was rarely noted on  the
         third car.

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                                  129
7.       Installation of  the FUEL-MAX  device is  considered  "tampering"
         under the provisions of the Clean Air Act*.
*"EPA tests  showed  that the use of  this device, on  the  vehicles tested
caused emissions to exceed  applicable  standards.   Thus,  the installation
of  this  device  by  a  person in  the  business  of  servicing,  repairing,
selling,  leasing, or  trading motor  vehicles,  fleet  operators,  or new car
dealers will be considered in violation of Section 203(a)(3) of the Clean
Air Act, the  Federal  prohibition against tampering  with  emission control
systems.   That  is,  there  is currently no  reasonable  basis for believing
that  the  installation or use  of  this device  will not  adversely affect
emission performance.   This determination does  not  preclude the  use of
the FUEL-MAX device on  a  different  vehicle or  vehicles than those tested
by EPA if Federal Test Procedure tests performed on such vehicles clearly
establish that  emission performance  of those particular vehicles  is not
adversely affected.

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                                      130
                                   Appendix A

                            Test Vehicle Descriptions
Make/Model

Model Year

Type

Vehicle l.D.

Initial Odometer

Engine Type

    Configuration

    Displacement

    Fuel Metering

    Fuel Requirement

Transmission

Tires

Inertia Weight

Actual HP @50 mph

Emission Control Systems
Ford Pinto

   1979

  2 door

9T11Y186165

   23540

Spark Ignition

 In-line 4

 140 C1D

2V Carburetor

   Unleaded

 Automatic

  B78-13

   3000

   10.3

    EGR
 Catalyst
Oldsmobile Cutlass

       1979

      2 door

  3R47A9M523280

   34880

  Spark Ignition

        V6

      231 CID :

   2V Carburetor

   Unleaded

     Automatic

    P195/75R14

       4000

       12.0

    EGR
     Catalyst
Mercury Zephyr

     1979

    2 door

  9E35F621630

   31760

Spark Ignition

      V8

    302 CID

 2V Carburetor

   Unleaded

   Automatic

    CR78-14

      3500

     11.2

    EGR
   Air Pump
   Catalyst

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                                      131
                                 Appendix B

                   Test Results - Ford Pinto, 140 CID, 4. Cylinder
Test    Test                   Federal Test Procedure     Highway Fuel Economy Test
Date.    #   Configuration	HC    CO    NOx   MFC    HC   CO   NQx   MPG	

3-3-81  5560  Baseline          2.09  26.1  1.37  21.44
3-3-81  5561  Baseline                                   0.74  5.0  2.35  28.87
3-4-81  5562  Baseline          2.06  26.0  1.33  21.56
3-4-81  5563  Baseline                                   0.77  5.3  2.40  29.19

3-5-81  5564  FUEL-MAX          1.66  20.2  5.84  22.06
3-5-81  5565  FUEL-MAX                                   0.64  3.2  6.57  29.17
3-6-81  5566  FUEL-MAX          1.50  17.0  6.22  22.71
3-6-81  5567  FUEL-MAX                                   0.58  2.3  7.08  29.42

3-25-815568  Fuel Max (-5°)*   1.00  18.8  4.36  21.97
3-25-815569  Fuel Max (-5°)                        .     0.49  1.9  4.93  29.80
3-26-81 5570  Fuel Max (-5°)    1.41  17.8  4.56  22.48
3-26-81 5571  Fuel Max (-5°)                             0.51  2.1  5.56  29.90
               /
*For this  series of  tests,  the device  remained  in  place  but the  basic
timing was retarded 5° to correct a heavy knock condition.

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                                     132
                                     Appendix C
                   Test Results - Oldsmobile Cutlass, 231CID, V-6

Test    Test                   Federal Test Procedure     Highway Fuel Economy Test
Date.    //   Configuration    HC	CO    NOx    MPG    HC   CO    NOx   MPG
3-4-81  6845  Baseline
3-4-81  6848  Baseline
3-5-81  6849  Baseline
3-5-81  6850  Baseline
3-6-81  6851  Baseline
3-6-81  6852  Baseline
1.95  22.3  1.56  18.16
1.82  20.3  1.52  18.37
1.90  20.5  1.57  18.16
                         0.55  7.1  1.52  26.17
                         0.43  5.0  1.44  26.61
                         0.36  4.2  1.58  26.34
3-10-81 6853  FUEL-MAX
3-10-81 6854  FUEL-MAX
3-11-81 6855  FUEL-MAX
3-11-81 6856  FUEL-MAX
1.40  18.9  7.44  18.43
1.51  20.0  7.45  18.62
                         0.22  1.4  8.57  26.32
                         0.24  1.6  8.76  26.53
3-19-81 8359  Baseline
3-19-81 8361  Baseline
3-19-81 6858  FUEL-MAX
                         0.40  4.6  1.61  26.43
                         0.25  2.6  1.63  26.40
                         0.23  1.9  8.82  26.42
                            HOT START LA-4
3-19-81 8358  Baseline
3-19-81 8360  Baseline
3-19-81 6857  FUEL-MAX
3-19-81 6859  FUEL-MAX
1.14  13.4  1.50  19.25
1.32  15.1  1.54  19.54
1.24  16.5  7.90  19.71
1.37  15.6  7.73  13.06*
*Fuel economy void - error in CO^ readings.

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                                  133
                                     Appendix D
                     Test Results - Mercury Zephyr, 302CID, V-8

Test    Test                   Federal Test Procedure     Highway Fuel Economy Test
Date.    //   Configuration     HC      CO	NOx   MPG    HC   CO   NOx   MPG
3-3-81  6771  Baseline
3-3-81  6772  Baseline
3-4-81  6773  Baseline
3-4-81  6774  Baseline
3-5-81  6775  Baseline
3-5-81  6776  Baseline
2.42  25.2  0.66  15.10
2.42  24.1  0.69  15.25
2.46  23.2  0.71  15.23
                         0.94  1.4  1.34  23.08
                         0.86  3.8  1.07  22.58
                         0.86  2.8  1.11  23.09
3-10-81 8094  FUEL-MAX
3-10-81 8095  FUEL-MAX
3-11-81 8125  FUEL-MAX
3-11-81 8126  FUEL-MAX
2.05  14.3  7.20  15.72
2.12  14.2  7.14  15.72
                         0.81  1.2  9.31  22.77
                         0.85  1.1  8.75  22.80
3-18-81 8302  Baseline
2.58  29.5  0.61  15.04

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                             Attachment
  Award Winning Automotive Engineers
SMSH  GAS CONSUMPTION
   Tests prove
   Savings up to
   12!/2 mpg (cityi
   Up to 33% mpg
   (highway)
                  /'
                  ;-%,
                  l«Cik^
   DEVELOPED BY
   THE INVENTORS
   OF THE YEAR 1979
    **A

American
Society of
Inventors
V-
           ."•!-'fu-£U
           I ^ ci-"*i-£i'—• I
           1 "|s oca E
                      9
   What is Fuel Max? Pollution control systems, used on care built
   since 1973 to help meet Federal emissions control standards, drive down
   gas mileage and performance. Fuel Max' is a precision engineered
   device that enables a car owner to change the air/fuel ratio and eliminate
   the negative effects of exhaust gas recirculation. Fuel Max can add
   up to l2Vt%" more mpg in city driving, up to 33%" more on the highway.
   When Fuel Max was tested on 50 randomly selected 73 to 79 cars
   and trucks,-gas savings averaged a dramatic 10V2%! Fuel Max also.saves
   gas and improves performance on 1980 models, but to a lesser degree.

   HOW does Fuel Max WOrk? Tho pollution control system
   on 73—'80 automobiles works by roclrculating exhaust gas back
   Into the engine by means of an EGR (Exhaust Gas Recirculatlng) Valve.
   This reduces the exhaust emissions but also decreases the car's
   smoothness, acceleration and response. It causes more gas to be
   burned. Fuel Max Is a precision built vacuum operated valve that uses
   the existing EGR system but allows MORE AIR Into the engine     •'.
   intake and eliminates recirculation 'of exhaust gas. More air In the
   combustible mixture means a leaner mix—you use less gas, get better
   performance, and lower total overall emissions.

   Fuel Max is easy to install.  Easy-to-ioiiow instructions
   included—simpler than changing your car's sparkplugs.
   No carburetor adjustment necessary!
   Federal EfW regulations permit vehicle owner to Install Fuel Max on own
   fehicle.
                               Only $29,95 postpaid right to
                               your door. Fuel Max soon pays for itself
                               with the gas savings you get!      .
                               Exclusive only through this offer.

                               Order tOday. Start saving gas
                               and getting better performance from
                               your car.
                              'Patent pending
                              '•Results ol tests using E.KA. protMttuns on e W? Chevy wtti
                               a 305 cuDic inch V-S engine.                •
                             r
    WARRANTY
    Fuel Max is warranted against
    delects in materials and work-
    manship for one year from date of
    purchase.
                               OGI Group Ltd.
                               114 East 32 Street
                               New York. New York 10016
                               Please send mo
                                        I
                      FUEL MAX @ S2U.95 ppd, 1
                               Name _
                               Address
                               City	
                   -State	Zip
         Enclosed is my check or money order for $	 I
            Visa & Mastercharge card holders dial   I
            toll tree #800-228-2028     '       |
         Satisfaction Guaranteed or Money Refunded |

-------
                                               135
                                                                      Attachment  J
13.  Wilt I Really Save Gas by Driving 55 MPH
    instead of 60 or 65?
Yes. The  most efficient driving speed is usually
between 30 and 40 miles per hour. For each 10
mph speed increase,there is a  fuel economy
penalty of about 10 percent. At speeds above 65
mph, the  penalty is even greater.

14.  Does the Air Conditioner Reduce Fuel
    Economy?
Yes. The  air  conditioner uses engine power,
which causes a decrease in fuel economy of a few
percent.

15.  Why Do Some Cars Run after They Are
    Turned Off?
After-Run, or  so-called dieseling, is aggravated
by an excessively fast idle speed. Engines should
be tuned when warmed up to idle atthe minimum
speed which gives a smooth idle. (Check auto-
matic  transmission cars in "drive".)  If cold idling
is a problem, the automatic choke may be set to
stay on longer. (Automatic choke also boosts idle
speed.)

16.  Is There  Really a Fuel Shortage?
Yes and  No. There is no shortage of energy
resources, but there is a very real  shortage of
cheap energy. We have become accustomed to
buying gasoline for 50$ per gallon, which is less
than we pay for  beer,  milk, soft  drinks, or even
distilled water.
17.  What Kind of Tires Give the Best Gas
     Mileage?
Radial tires have less rolling resistance than bias-
ply tires, and give a fuel economy improvement of
a few percent. Higher tire pressures can also add
a few percent to fuel economy, but safety is more
important.  Stick  to the manufacturer's recom-
mened tire pressures.

18.  Do Special Oils Really Work?
Some of the synthetic oil products and "slippery"
oils can make a small improvement in fuel econo-
my by reducing engine friction.

19.  Is It Legal for Me  to Change My Car's
     Emission  Control System?
If you are  not a  Professional Mechanic, Dealer
Representative, or Fleet Operator, the Federal
EPA Laws do not apply to you. Some individual
states are  considering legislation  which might
apply. Check your owns state's legislation if you
are not  sure.

    20.  Can Fuel-Max Damage an  Engine?
No. Fuel-Max can actually prolong the life of an
engine  by eliminating the  corrosive  effect  of
exhaust gas recirculation.
          FUEL-MAX INDUSTRIES
               P. O. Box 726
             Bellmawr, NJ 08031
 FUEL-MAX — GASOLINE CONSERVATION
         FOR CARS AND TRUCKS
Fuel-Max has been designed forthe motorist who
wants to improve his vehicle's fuel economy. The
Fuel-Max installation has shown an average im-
provement in fuel economy better than ten per-
cent. For those serious about conserving fuel, an
additional ten to twenty percent may be saved by
careful attention to driving habits.

Driving Habits can make the difference between
15 MPG and 25 MPG on the same car. Careful use
of your car's power can save more fuel than any
other technique.

Most of the gasoline your car uses is consumed
during accelerations. The harder you accelerate,
the more fuel is wasted. It is for this reason that
highway driving gives better economy than city
driving.

While only about 10 horsepower are needed to
maintain  your car at  55  miles per hour on the
highway, you can use all of your engine's horse-
power to accelerate. The economical driver uses
the minimum horsepower required for any driv-
ing situation. A good way to retrain yourself for
economical driving habits is to pretend there is a
glass of water on the dashboard, and drive in such
a way as to avoid getting wet.

REMEMBER THESE GAS-SAVING TIPS -
   AVOID PROLONGED IDLING
   DON'T CARRY AROUND UNNECESSARY
    WEIGHT
   ACCELERATE GRADUALLY, DRIVE
    SMOOTHLY
   FOLLOW THE  SPEED  LIMITS -
    HIGHER SPEEDS WASTE FUEL

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                                               136
            FUEL ECONOMY —
        QUESTIONS AND ANSWERS
To help you understand some of the technical
aspects, we have listed answers to the 20 most
frequently asked questions about fuel economy.

1.  What is EGR? (Exhaust Gas Recirculation)
Exhaust Gas  Recirculation  is used on all cars
built after 1973. The EGR Valve is controlled by a
vacuum signal that comes from the carburetor
whenever the  throttle is in  the cruising  range.
Most cars  also have a temperature-controlled
vacuum switch in the control line to keep the EGR
Valve from  opening when the engine is cold.

EGR  allows some  of the exhaust gas to bleed
back into  the  engine  intake, which helps  to
control one of the emissions, Oxides of Nitrogen.
When the  EGR system  is  disconnected, fuel
economy improves a few percent, performance is
improved noticeably, Oxides of Nitrogen emis-
sions increase, and the engine may knock or ping
more than before.

Fuel-Max uses the  controls and passages of the
EGR system for another purpose.

2.  How does the Fuel-Max work?
Fuel-Max makes use of an engine's existing EGR
system,  but bleeds air into the engine instead  of
exhaust gas. The Fuel-Max improves fuel econ-
omy and performance, and  causes a change  in
the balance of  the three regulated exhaust emis-
sions. In general, Hydrocarbon and Carbon Mon-
oxide emissions go  down, and Oxides of Nitrogen
emissions go up. The total of the three emissions
usually goes down.

Fuel-Max causes the engine to run on a leaner air-
fuel mixture, only when the engine is warmed up.
Fuel-Max does not operate  at idle,  or on wide-
open throttle  accelerations.  For this reason a
better fuel economy improvement  should  be
expected in highway  driving than urban driving.
3.  What is Engine Knock or Ping?
Knock is the sound made by a small "explosion"
in the combustion chamber, when the fuel and air
burn  abruptly  instead of  smoothly. Heavy and
prolonged knocking  can  cause damage to the
engine.  There are two remedies for excessive
knock: 1. Switch to a higher octane fuel.
       2. Retard the  ignition timing, which will
         also  cause the  fuel economy to de-
         crease.

4.  Should I Change the Ignition Timing?
To  get  the  maximum  fuel economy, ignition
timing should  be advanced as far as the engine
will tolerate without knocking. (Usually not more
than  8 degrees beyond factory specifications.)
Advanced timing will usually cause theemissions
to increase.
5.   What is Octane? Octane is a measure of a
fuel's resistance to knock. For example, an en-
gine which knocks on 86 octane fuel might not
knock on 90 octane fuel.

6.   What is Unleaded Gasoline?
Before 1975,- almost all  gasoline  contained a
Lead-Compound additive. Lead increases the
octane of the gasoline, but may not be used in
catalyst-equipped vehicles. The lead is deposited
on the inside of the catalytic converter and spoils
the catalyst.

7.  Why does Unleaded cost more than Regular?
If lead is not used to boost a fuel's octane, the fuel
must go through additional refining to raise its
octane. The extra refining uses energy, so un-
leaded fuel costs  more  to  manufacture than
leaded fuel of the same octane.

8.  What is Air-Fuel Ratio?
The mixture  of fuel and air supplied  by the
carburetor or fuel injection system must be carfe-
fully set to the right ratio. Most vehicles operate in
the range of 15to 18 Air-Fuel Ratio. (15poundsof
air for each pound of fuel.)

The most efficient mixture is the leanest (highest
air-fuel ratio) that the engine will tolerate without
rough running or hesitation. There is no external
adjustment on the  carburetor for air-fuel ratio,
except the idle mixture.
9.   How Should I Adjust the Idle Mixture?
Turn the mixture screw (or screws) to the leanest
setting (clockwise is leaner) that gives a smooth
idle. Some cars have plastic limiter caps on the
idle screws to restrict the range of adjustment.

10.   Will a Lean Mixture "Burn Valves"?
No. All modern cars operate at air-fuel ratios
greater than 15. The air-fuel ratio which gives the
highest combustion temperature is 14.7. Temp-
eratures drop as the mixture gets richer or leaner
than 14.7.

Before 1970, many vehicles used mixtures richer
than 14.7, and leaning  the mixture could raise
combustion temperatures, and "bum valves".

11.   Will it help to  remove the Catalytic
     Converter?
No. The catalytic converter has no direct effect on
fuel economy. Its removal would not produce any
change except increased exhaust emissions.

12.   How Should I Measure Gas Mileage?
Anyone can measure fuel economy by keeping a
record of each fuel purchase. Start by noting the
odometer reading when the tank is full. Then note
the number of  miles on the odometer and the
gallons purchased  every time you buy fuel. After
using  several tankfuls  of fuel, divide  the total
miles travelled  by the  total  gallons used. The
result  will be the  miles per gallon. Be sure to
average several tankfuls of fuel, to get accurate
measurements over a long period.

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                                                         Attachment
           UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                          ANN ARBOR. MICHIGAN  48105
                                                                      OFFICE OF
                                                                AIR. NOISE AND RADIATION
November  7,  1980
Mr. Michael D. Leshner, Chief Engineer
FIDCO  Fuel  Injection Development Corporation
110 Harding Avenue
Bellmaur, NJ  08030

Dear Mr. Leshner:

During our  analysis  of  your  firm's  application  for  evaluation  of  the
"Fuel-Max"  fuel  economy retrofit device under Section 511 of the Motor Vehicle
Information and Cost  Savings  Act  we have found  deficiencies  in the data you
enclosed .with your application.

First, the appendices to one of  the Scott reports were not included with the
application.    We   requested  a  complete  copy  of  the  report   from  Scott
Environmental Technology, Inc. but  they will not  release the information to us
without prior authorization  from the sponsoring company.  Please forward to us
Appendices  A, B,  and  C  for Scott  Report  #1827 01  0979,  "Technical Report on
Evaluation  of a  Fuel Economy Device".

Second, in   the  test  reports  provided  with  your  firm's  application,  the
baseline  data were collected by the testing  laboratory on vehicles in an "as
received"  condition.   The independent laboratory can not verify the status of
the  engine  design parameter  settings.   Please  provide  detailed  information
regarding  the engine  design parameter  settings  (ignition timing,   idle speed,
 idle   mixture,  etc.)  for  each  vehicle   used  for  the  baseline  and device
installed  testing  supporting your firm's application for evaluation.

Thank   you  very  much  for  your  help  on  this  problem.  Your  cooperation will
facilitate  the  evaluation process.

Sincerely,


rtVjuvoLu.  to \
-------
                                            .  ••r fc T
                                            Attachment L
   Fuel y Injection Development Corporation
                                       29 December 1980
Mr. Merrill W. Korth
U.S. Environmental Protection Agency
Ann Arbor, Michigan 48105

Dear Mr. Korth,

I have enclosed a complete copy of Scott Environmental
Technology Report #182? 01 0979.  The copy which was originally
sent with our Section 511 Application did not Include the
appendices.  These appendices were not available to our
company until today.  The company which sponsored the test
program was not willing to share the appendices without
compensation, and we had to negotiate a special agreement
for th^-ir release.

Second, we did some checking on the engine design parameter
settings for the test vehicles.  All of the vehicles were
leased by the sponsoring company for their employees.
The vehicles were all-delivered new by factory dealerships,
and were not adjusted after initial new-car preparation.
Since these calibrations were not measured, we can only assume
they were all set to factory specifications.

I apologize for the delay in forwarding this information.
Please let me know if I can help you to expedite this evaluation.
                                        Sincerely,
                                        Michael D. Leshner
                                        Chief Engineer
    110 Harding Avenue  • Bellmawr, N.J. 08030  • 609/931-3168

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