EPA-AA-TEB-511-81-1
EPA Evaluation of the Gas Meiser I under Section 511
of the Motor Vehicle Information and Cost Savings Act
                         by


                Edward Anthony Earth
                      May, 1981
             Test and Evaluation Branch
         Emission Control Technology Division
    Office of Mobile Source Air Pollution Control
           Environmental Protection Agency

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                                  -2-
5560-26                                                EPA-AA-TEB-511-81-1
                      ENVIRONMENTAL PROTECTION AGENCY
                             [40 CFR Part 610]
                           [FRL
                       FUEL ECONOMY  RETROFIT DEVICES
          Announcement of  Fuel Economy  Retrofit Device Evaluation




                            for "Gas Meiser I"
AGEKCY;  Environmental Protection Agency (EPA)









ACTION:  Notice of Fuel Economy Retrofit Device Evaluation-









SUMMARY: This document announces  the conclusions of  the  EPA  evaluation of




         the "Gas Meiser I" device under  provisions  of Section  511  of  the




         Motor Vehicle Information and Cost Savings Act.

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                                  —3—
BACKGROUND  INFORMATION:   Section  511(b)(l)  and  Section  511(c)  of   the




Motor  Vehicle   Information  and  Cost  Savings  Act   (15  U.S.C.  2011(b))




requires that:









(b)(l)  "Upon  application of any  manufacturer  of  a  retrofit  device  (or




prototype  thereof),  upon  the  request  of the  Federal  Trade  Commission




pursuant to subsection (a), or upon his own motion, the EPA Administrator




shall evaluate, in accordance with rules prescribed under subsection  (d),




any  retrofit device to determine  whether the  retrofit  device  increases




fuel economy and  to determine whether  the representations  (if any) made




with respect to such retrofit devices are  accurate."  .









(c)   "The  EPA  Administrator shall  publish  in the  Federal  Register a




summary of  the results of  all  tests  conducted under this  section,   to-




gether with the EPA Administrator's conclusions  as to -









         (1)  the effect of any  retrofit device  on fuel economy;









         (2)  the effect  of any such  device  on emissions  of  air  pollu-




              tants; and









         (3)  any other information which the Administrator determines  to




              be relevant in evaluating such device."









    EPA  published  final  regulations  establishing  procedures  for  con-




ducting  fuel  economy  retrofit  device  evaluations  on  March 23,  1979




[44 FR 17946].

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                                 -4-
ORIGIN OF REQUEST FOR EVALUATION:  On December 17, 1980, the EPA received




a request  from Gas Meiser  Corporation for  evaluation  of a  fuel  saving




device termed  "Gas  Meiser I".  This  Device is claimed  to "... increase




fuel economy  by pre-heating the fuel."  The Device  consists principally




of a gasoline hose wrapped around the vehicle's upper  radiator hose.









Availability of  Evaluation  Report:   An evaluation has  been  made and the




results are  described  completely in a  report  entitled:   "EPA  Evaluation




of  the Gas Meiser I under  Section  511 of  the Motor Vehicle Information




and Cost Savings Act," report number EPA-AA-TEB-511-31-1 consisting of  18




pages including all attachments.









Copies  of  this  report   may  be  obtained  from  the  National  Technical




Information Center by using the above report number.   Address  requests to:









         National Technical Information Center




         U.S. Department of Commerce




         Springfield, VA  22161




         Phone:  Federal Telephone System (FTS) 737-4650




         Commercial  703-487-4650

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                                  -5-
Suminary of Evaluation



The stated method  of operation of  the "Gas Meiser  I"  is  that  the "Gas

Meiser  I"  is  designed   to  preheat  the  fuel  and   thereby  increase  a

vehicle's fuel economy.



The Applicant submitted  no  test  data  with the application  for evalua-

tion.   Analysis  of  the  information submitted  by  the Applicant  did not

prove that use  of  the  "Gas Meiser I" would enable a  vehicle  .operator to

improve a vehicle's fuel economy.



Previous  EPA testing of  another  device  that  preheated the  fuel showed

that preheating the fuel gave no emissions or fuel economy benefits.



Thus,   there   is  no  technical  basis to support any claims  for a  fuel

economy improvement due to the use of the  "Gas  Meiser  I" device.



FOR FURTHER  INFORMATION  CONTACT:    Merrill W. Korth,   Emission Control

Technology  Division, Office of  Mobile  Source Air Pollution   Control,

Environmental Protection  Agency, 2565  Plymouth Road,  Ann Arbor,  Michigan

48105, 313-668-4299.
Date                                   Edward F.  Tuerk
                                       Acting Assistant Administrator
                                       for Air, Noise, and Radiation

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                                  -6-
Evaluation  of  the Gas Meiser  I Device under  Section 511  of  the Motor
Vehicle Information and Cost Savings Act

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

1.  Marketing Identification of the Device;

    "Gas Meiser I"

2.  Inventor of the Device and Patents:

    A.    Inventor

          William LaBombard
          1516 Oakes Street
          Marinette, Wl  54143

          William Blemke
          1516 1/2 Oakes Street
          Marinette, WI  54143

    B.    Patent
          "No Patent  - 6  feet  approved 5/16" Neoprene  Hose,  2 approved
          hose clamps, 2 wire ties

          "Mr.  Redman of  Wisconsin  Department  of  Agriculture Trade  &
          Consumer  Protection indicated  that at  most,  a  person  could
          expect  a  10% increase.   See enclosure  #1."  Enclosure  #1  is
          Attachment A,

3.  Manufacturer of the Device:
    "Pending"

4.  Manufacturing Organization Principals:

    "Pending"

5.  Marketing Organization in U.S. Making Application:

    Gas Meiser Corporation
    1516 Oakes Street
    Marinette, WI  54143

6.  Applying Organization Principals:

    William LaBombard - President and  Treasurer
    Verna LaBombard - Vice-President and Secretary
    William Blemke - Sales Manager and Representative in Communications

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                                 -7-

7.  Description of Device:

    (a)   Purpose of the Device (as supplied by Applicant):  "To  increase
          fuel economy."

    (b)   Theory of Operation (as supplied by Applicant):  "To expand  the
          atomic structure of gasoline by preheating."

    (c)   Detailed Description of Construction and Operation (as  supplied
          by Applicant);   "6 feet  approved  5/16"  Neoprene  hose,  2  ap-
          proved  hose  clamps, 2  wire ties.   Preheats  the gas  with  the
          heat from the  top  radiator  hose expanding the atomic structure
          of the gas which increases the gas mileage.  See enclosure #2."
          Enclosure #2 was the device plus the General Instructions which
          were also provided  as  Enclosure #3.  (Enclosure #3  is Attach-
          ment B of this report.)

8.  Applicability of the Device (as  supplied  by Applicant);

    "All  combustible  gas  engines  except diesel  and  air  cooled.    Gas
    Meiser I will be marketed in one size  only  and will fit all auto-
    mobiles except diesel and air cooled."

9.  Device Installation (as supplied by Applicant);

    "a.   General  Instructions  -  See Enclosure  #3";  (Enclosure  #3   is
          Attachment B.)

    "b.   All combustible engines except  diesel and  air cooled"

    "c.   Tube cutter,  screw driver"

    "d.   None"

    "e.   Reduce wrapping if vapor lock occurs"

    "f.   Minimal mechanical ability"

10. Device Operation (as supplied by Applicant):

    "See Enclosure #3"

11. Device Maintenance (as supplied  by Applicant):

    "Maintenance Free"

12. Effect on  Vehicle Emissions  (non-regulated)  (as supplied  by Appli-
    cant) :

    "No independent test results  available"

13. Effects on Vehicle Safety (as supplied by Applicant);

    "See Enclosure #4"   (Enclosure #4  is  Attachment  C).

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                                  -8-
14. Test Results  - Regulated  Emissions  and  Fuel  Economy  (submitted by
    Applicant):

    "No independent test results  available"
                               /
15. Analysis

    A.   Description of Device:

         The  Device consists  principally  of  a  gasoline  hose  wrapped
         around  the vehicle's upper radiator  hose.   The  Device is judged
         to be able to  heat the fuel to some limited  extent.

    B.   Applicability  of the Device;

         The applicability  of  the device, as stated in  Section  8,   "All
         combustible gas engines except diesel  and air  cooled" is judged
         to be valid.

    C.   Device  Installation ~ Tools and  Expertise Required:   were iden-
         tified  in Section 9

         (1)  The general instructions  provided are judged to be adequate
              for the physical installation of the  device.

         (2)  The  claim that  the instructions  are  applicable to   "all
              combustible  engines  except diesel  and  air  cooled"  (Sec-
              tion  8.),   i.e.   no  vehicle   specific  instructions  are
              required, is judged to be correct.

         (3)  The tools identified in Section 9.c. are  judged to be  ade-
              quate for installation of the Device.

         (4)  The  statement  that no  special  equipment  is  required  for
              installation checkout is  judged  to be correct.

         (5)  The Device is judged to not require adjustments nor require
              vehicle   adjustments.  If  vapor  lock  problems  are  encoun-
              tered,  the  Applicant   suggests  reducing  the  number of
              wrappings of  the "Gas Meiser  I" around  the engine's upper
              radiator  hose.  This is judged  to be able to alleviate any
              vapor lock problems induced  by the device.

    D.   Device  Operation:

         The Applicant  refers to the  installation instructions for Device
         Operating instructions.   The  only post  installation  instructions
         contained therein relate to vapor lock.  This is  deemed adequate.

    F.   Device  Maintenance:

         Applicant claims the Device  is "Maintenance Free" in Section 11.
         This is true  in the  general usage of the  term maintenance,  the

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                              —9—


     added Device fuel  fittings  and  fuel line installed in the vehi-
     cle,  would  require  the  normal  periodic   inspection  accorded
     similar components in the vehicle.

G*   Effect on Vehicle Emissions (non-regulated):

     The  Applicant  submitted  no  test  data,  Section  12.   However,
     since the Device does not appreciably modify the vehicle's emis-
     sion  control system  or  powertrain,  it  appears  reasonable  to
     assume that  the  Device would not  significantly affect  a vehi-
     cle's non-regulated emissions.

H.   Effect on Vehicle Safety;

     The Applicant's enclosure on safety  is  a letter from his attor-
     ney  to  an automotive association  (see  Attachment  C).   In  this
     letter the claims for safety appear to be based  on  three points:

     (1)  the fuel is  not heated above  the  temperature of the auto-
          mobile coolant.

     (2)  the fuel is not pressurized or vaporized.

     (3)  no problems have been encountered in the unspecified number
          of installations made.

     When  properly  installed,  it  appears unlikely  that  the  Device
     would adversely affect  vehicle  safety in normal usage  and  that
     the Applicant's  claim is justified.

     However, if vapor  lock  is  encountered,  the Applicant's solution
     of  reducing  the  wrappings  on  the  radiator  hose  will  require
     disconnecting the fuel line.  If this was done on  a hot,  stalled
     vehicle, fuel would be spilled  in the  hot  engine compartment.
     To minimize this hazard,  the  Applicant  should specify that  this
     procedure be only performed after the engine  has  cooled.

     Also, in event  of an accident,  the  vehicle's fuel system would
     be more  vulnerable due  to the  added length  of  the  fuel  line
     wrapped around the upper radiator hose.

I.   Test Results Supplied by Applicant;

     Applicant  did  not  submit  any  test data  per the Federal  Test
     Procedure or Highway Fuel Economy Test.  These are  the only  EPA

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                                    -10-


         recognized test  procedures^-'-).   This  requirement  for  the  test
         data following  these procedures  is  stated  in  the  Application
         format  and  two  subsequent  letters  EPA sent  to  the  applicant
         (Attachments  D,  E,  and F).  Therefore,  there was  no  technical
         basis to  support the Applicant's claim of increased fuel economy.

    J.    EPA Testing of  a Fuel Preheater:

         EPA  tested   a   fuel  preheaterv^)  which  used  water  from  the
         engine block to  heat the fuel in  a copper tube and  shell  heat
         exchanger.  This device  could be  expected  to add more  heat  to
         the fuel  than "Gas  Meiser  I"  because  the copper  tube  and shell
         design is a more efficient heat transfer mechanism than the "Gas
         Meiser I" neoprene hose wrapped around the  upper radiator hose.
         Also it  would  have  acted  sooner  because  the engine  would not
         first have to raise the engine coolant to the thermostat setting
         for the hot coolant to flow through the upper radiator hose.

         This fuel preheater did not improve vehicle fuel economy.  Since
         the "Gas Meiser  I"  could  be expected  to receive  less  heat  from
         the  coolant,  in the absence  of  valid  test  data  there is  no
         reason to expect  the "Gas Meiser I"  to  improve  vehicle  fuel
         economy nor justification for EPA  to test  the Device to further
         investigate the claim for fuel  economy.

16. Conclusion:

    The Applicant  submitted  no test data that proved that the "Gas Meiser
    1"  would improve vehicle fuel economy.

    EPA previously tested a similar device which  failed to  show a  fuel
    economy  benefit.   Therefore,   it  is  unlikely  that  testing of  the
    device would have  shown  a fuel economy benefit.
         From EPA 511 Application Format:
         Test Results (Regulated Emissions and  Fuel Economy):
         Provide all" test  information which is available on the effects
         of the device on vehicle emissions  and fuel economy.

         The Federal  Test  Procedure  (40 CRF  Part 86)  is the  only test
         which is recognized by  the  U.S.  Environmental Protection Agency
         for  the evaluation  of  vehicle  emissions.   The   Federal  Test
         Procedure and  the Highway Fuel Economy  Test (40 CRF  Part 600)
         are the only tests which are normally recognized by the U.S. EPA
         for  evaluating vehicle  fuel  economy.  Data  which   have  been
         collected in accordance  with other  standardized  fuel economy
         measuring procedures (e.g. Society of Automotive Engineers) are
         acceptable  as  supplemental  data to  the Federal  Test  Procedure
         and the Highway Fuel Economy Data and will be used, if provided,
         in the preliminary evaluation of the  device.   Data are required
         from the test vehicle(s) in both baseline (all parameters set to
         manufacturer's  specifications) and modified  forms  (with device
         installed) .
(^Evaluation of the Fuel Xpander,  EPA-AA-TAEB-80-2

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ROGERS  &  HERTEL  -
     > 3 _•• S O t_' T M MILL D T R E E, 1
     MERRILL, WISCONSIN
     May 6, 1930
                                      'M
                                  TELEPHONE 7/5/5.7*5-550'
    Attachment"A
TOMAMAWK O r f" I C C

•> O SO". 3SO
7 NOPfTM lOfAMJ?** AVENUE
TOMAMAW*. WISCO.%Si'< ?.•• *B7
 • tLtn^ONE 7IJV/-*5> Mf.J
        7"5/S.T«% - It J'-*O

 MOBILE TELEPHONES
 JAMES T. MOOCRS .
 "5/3&0 HOD

 MARRr n. HE^TCt.
      Mr. William Blemke
      P. O. Box  §4
      Bryant, WI   54418

      RS:  Gas Preheater

      Dear Bill:

      I believe  that I have some answers to the questions that you raised regarding  the
      development and marketing of your gas preheater.

      As far  as  I have been able to determine, there is no State Agency that would test
      your product  before marketing can start.

      However, I did talk with a. Mr. Tom Redman at the Wisconsin Department of Agriculture
      and Trade, Consumer Protection Division, 801 W. Badger Road, Madison, WI 53702,
      (608) 266-7222, regarding the proposed advertising and marketing of your product.

      He is forwarding to us a law which went into effect on April 30, regulating the
      advertising and marketing of devices intended to increase or improve fuel mileage
      in automobiles and  motor vehicles, which is enclosed.

      What we have  to avoid/ of course, is making a misleading or unsubstantiated claim
      about the  increase  that a customer could expect by buying and using your product.

      Mr. Redman indicated to me" that the University scientists they have talked with
      have indicated that at most, a person could expect only a 10 per cent" increase -'--r:
      by the  use of any gas .preheater or vaporizer in the gas line as yours is set-up.   -J _

      They talk  about this- as the maximum, theoretical efficiency increase.. ;'•?..         ';/"" J
                                                                          : -^ScL^V  - .•:??''&₯'—&?•••
                                                                          '' -• ^fe^'.-  f;^j^3p£-
                            '^swi*^
                                                                           ,	 . ...     ...

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                             GAS MEISER I

                Read Instructions Before Installation


1. Cut fuel line approximately 6" from carburetor WITH TUBE CUTTER.

2. Connect 1 end of hose to line from carburetor and secure with
   clamp.

3. Begin wrapping fuel line hose around radiator hose.  Be sure
   fuel line hose is wrapped tightly to receive top performance
   from GAS MEISER I.

4. After wrapping fuel line hose approximately 4 to 6 times,
   depending on engine size, connect other end of hose to fuel
   line from fuel pump and secure with clamp.

5. After fuel line hose is connected on both ends,  use plastic
   wire ties to secure GAS MEISER I  to radiator hose.

6. Before starting engine, make sure gas filter and air cleaner
   are clean.                                                    .

7. Start engine to make sure all lines are connected properly.

8. If vapor lock should occur, reduce wrappings on" radiator hose.



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                                                                       Attachment
                                      -13-
LINCOLN HO'.'-.L
P O. ilO*  4 \f\
**O SOUTH MILL r*rMEtT
MEHHILL. WISCOMSIN E'

TELEPMOM: 7is/53e s^oi
                                                 rO"AHAW>-. Office
                                                 „ „ „„, ,„.,
                                                                   JAMCS T POOtRS
                                                                   »is -ase-uoo
      LAWYERS

September  15,  1980
      JAMES T. ftOOCFfS / HARRY R. HEUTEU /JAMES T. RUNYON
                     HENRY R.3CHUL7Z
Mr. Gary L. Antoniewicz                                            •           ,
Staff Counsel                                                         ' "
Wisconsin Automobile  & Truck Dealters Assoc.                .                 ..
25 W. Main Street
P.O.  Box 5345                                         ."•-..:.; •:':'', - .
Madison. Wis.   53705           '                              ^ •' :    . ,  V  .   -.

Re:  William Blemke -. Gas-Meiser Gas Preheater                        :  .

Dear Gary:

I have your letter  of September  12, 1980, and expected that sooner  or
later my correspondence  would cross your desk when 1 learned that the
Wisconsin Automobile  & Truck Dealers Association was involved.

I make no claims to having any engineering skills or expertise, but 1
would like to take  just  a couple minutes of your time to explain the
principles involved in Mr. Blemke's "Gas Preheater".

Mr. Blemke has  developed two models; the first model uses a right angle
plumbing joint  and  the gas line  runs through a copper tubing surrounded   —.-.-•
by hot water from  the automobile or truck's cooling system.         "._ .'    """.".""

The gasoline under  no circumstances is heated above the temperature that
the coolant obtains during normal engine operation of approximately 190*'.'
to 200°.  ... -...    ..  ,     -•.-••••   .;•  . /;. ....  .,,;••;;.:"   .:	••'   • -'.- • .'^--'.-i^v--- -•

Mr. Blemke's second model involves using six feet of black neofrene
gas line tubing which is wrapped directly around the hot water hose that
runs from the engine  block to the radiator.

Once again, the gas in the black neofrene tube is not heated above  the
temperature- of  the  coolant in the automobile approximately 190° to  200°.

Both models of  Mr.  Blemke's gas  preheater have been installed on a  number
of automobiles  and  trucks and to date there have been no problems with  fires,
explosions, or  vapor  lock that is associated with gas preheaters that use
the engine heat from  the manifold, which raises the gasoline considerably
above a safe temperature.

                                                                             ....:• •; .;.-.':J.Tn. :••'}
                                                                             -Z:'- '•.'-.' = • L'.-N- -V-'- * "f.

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Kr. Gary L. Antoniewicz
Page 2
Ti\f. greatest results with Mr. Blemke's gas preheater are realized  during the
winter months, when gasoline in thr gas tank is normally at  20°  to 25" below.   _..-.
zero, depending upon the ambient air temperature and instead of  entering the    ..
carbeurator at 20° to 25° below zero would enter it at  180°  to 190° Fahrenheit,
which results in increased and. easier vap< • i.zation and  better gas  mileage.

Neither model of Mr. Blemke's gas preheater alteru r.he  chemistry of the vehicle's
etavaissions.                                                      -:•......   .-",'_
                                    .                                 .- ' v:   • ' •• Y * '•'.
We have been working with State and Federal agencies regarding Mr. Blemke's ..'?,.
invention  and 1 share your concerns regarding  the product's  liability issue,•% -'
but  I reiterate, to date there have been  no problems with  either model and  .•'.-•-, .'
none of  the  State  and Federal agencies .that we have contacted seem concerned
about the  safety of the product.      .                             •"'-.'';''  :""V'.

Once again,  1 want to  reiterate  that  Mr.  Blemke's device  does no-t pressurize     "
or vaporize  the  gasoline.   By  the way,  Mr. Blemke's advertisings/and experience
with the gas mileage'  improvement  are  much more reasonable  and in line than  the
crazy advertising  schemes probably  seen lately.

Mr.  Blemke's  customers  have  been  experiencing  a  3 to A  mile  per  gallon increase
and  not  the  100  to 500X seen advertised by others.                           .  .

Mr.  Blemke has advertised a  10%  to  30%  increase  in mileage based of course on
the  vehicle  and  the previous-mileage  experience  of  the  driver.
 Yours truly,
 James T.  Runyon  ...
 Attorney  for William Blerake  and Gas-Meiser, Inc.
                                                                                    , .f .„



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                                                   Attachment D
                            ,. .-15-
July 7, 1S>30
Rogars £r liercel Lawyers
Lincoln. Llouse
P. 0. 30x 393
Merrill, Wl 54452

Dear Hr. Kuayoa:
     * 'in re^e to
oa procre, <"**?'
                                 -*
                                                                    i-:-
                                               (Test Policy, Retrofit
                                                  . the
 laforiaatioQ

 It should be M»d ttat                                            .



             Eot EPA wattos P^« to oat^tlag.
 ,!«. th. -portion you


       d
                                                          ", h»a no
                     w^s-rto ••ai3cus\S"»acerlal-- ^ Wkaanshlp;, ^ E?A;.

       ..r^^^l^Sv^^Sl^sSs^K^:
           •fflodifieB cha fuel Ueli^.y 8/sCua oz           interest froTa
                                 :io«. (>-
                                 itei-^el
  'foiTthSir" recomaendislona ou ttUs'"subject. y7~-  :,:~ -.-:;.;;; •• ^^.TTX^.;.;;'.^.:^.;>:

   « youuave any additiouul ^a.io.s, pl-sa 'f^ft^ to coutact ne f or ^
   assiscauca.
                                                 *B»    -         '
   Sincerely,


   P.. Peter Uutclilns* Project 5-lanajjer.                                      :
   lest aad Evaluaclou Sraacix                                        .     .

   Enclosures                                              -... - .       "-'V'-V-'-V
         .  .              •     .    .    .              ••  .   --s^--; ^.^SiiPi
                                                          • - si-'f •*•'•>. '• • - -'•'•'•'."J'^Vifei*"
                                                          •••.-.~; •..-'•"-:. .""yy-v-/yg^g
                                     '  . •    •       •      _^i:^i-i^.-.--'"--—"frH^rr^r
                            __„•_	    --—		 •-  -• :"    ^v.^v.':-. .:':i^2J*^
            	,			"                 •     •     .     - -. . ..ii »v,-»*'tv.-- ^..- . -*.•*.*'-3(t*vT»,«rrvS:

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                                        -16-

                                                                     Attachment E
                                                                                   .
December 4, 1960                                                             ;.'.. .;/;.
1-lr.  v/illiam Slemke                                                           •    "- r','Vfr*^''
151''1-  Oaues Street                                                                 '-"'-\''7;?~^i.
"arir.etta, !,;!  54143                                                     •      '     ^S^

Dear Mr.  lilerake:                       •                                  'X-    '      ••- Y^Y"'^

This letter  is in response to  your inquiry  of November 26,  1930 re$arding  an ':'---:  •'-'':
T-TA  evaluation  of Gas  Meiser.  The Environmental  Protection  Agency is charged  ':   -;\>
by   Congressional  irandate  to  evaluate  fuel  economy  and  esisaion  control
devices.    While  the  EPA does  not  actually  "approve"  such  devices,  it does . _ ..  V  ,
conduct evalaatiofis  for  the purpose of increasing the ccnnon knowledge  in  the .-.-•
area.  For  this  reason,  tbe  outcoine  of any  testing  by  U?A becomes  public
information.   It  is  this infom'.ation which ir>ay  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 nateriala  which  you  will  need  to
apply  for an  EPA evaluation of  your  device.  This packet consists  of 1)  an    :
application  foroat,  2)  a docLnr.ent  entitled "EPA  P.etrofit and Emission Control
Device Evaluation Test Policy"  and 3) a copy  of the applicable Federal Regula—
tlors.	-  -..'-.                   '.'''-'' "•'-:•--';•••  --"   .     . '" -;.  .'•-".-/;..'.;	':' . /. ..':-,'.:...-_ -..;.
 In order  for the EPA to conduct  an evaluation  of your device;,  we r?.ust-'have an
 application.   Once  you  have  reviewed  all the docuoar.ts  in  the  packet,  you  .
 should"'prepare  an   application  iu  accordance  vrith.  the  «yidelin€-sr..oi" . the'-'-• "--
 application.: forii.-at. . -.- If- yoii •ho.yo- not  yait.'rCon'cluc-tVd tlio.-tests.  u-e... rfcnuicej.'.-vc-.';—.. .-..
 covi -:r>sr.j.s-t  iu ;the •-lioc'i.o'n'.cbt -of .^ a :s?i tin factory "..tes.'t-'.ji.larj*  .".-"_.-:-.,-.'.^v.v.^-_'»"-"-""~ ~^':.'~:~\-
 Gticc .'-fi receive' ybiir application,: it will be  reviewed to -ieteninr;. if  It ir«etG
 r he.,  recu.ir.cp.e_nt.•>. -1 i s.t e-J ^.-in,;. the i.IoTjpa t. . .'If -_-i so y ..-..yo«__"_ vi 1"1'.', be' - r.^i v i 3_fi
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                                     -17-
If your  application is not  complete,'we  vili ask you to subniit further  infor-
mation or  data.   This request  rain with the device installed with no vehicle
     adjustments  between tests.   If installation of  the  device also involves
     eoine  adjustments,  e.g. tiering,  fuel-air p.ixture, ': choke or   idle  speed,
     another  test  sequence  with only  these  adjustments should  be inserted
     between  the  first  and  last.   Also as  a ninitruK,  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  Tnininize  the  costs  to  you,   you  are
     encouraged to have the entire cold-start test. performed since  any  testing
     and- evaluation .performed by EPA will be based cm .the complete  FTP and . you
     nay  wish  to know how  a   xt>hicle  with  your  device performs over this
     official   test.  As a  final  requirement,  the personnel of   the outside
     laboiMtory you  select  should  perfons  f.very  eleine.nt  of  your' test plan.
     T'ni.s  includes preparation cf the  test  vehicle,  adjustment of parar:eter.^
     r.nd installation of  the 
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                                     -18-
     We would  expect a  p.i^iitiura of  5£ inprove^ant for  a  fleet of  5  vehicles"
     (see. table  below).   Test results vhich rJisplay a significant increase in
     cp.icsicm  levels  nay be. reason  for EPA  to require rrore  extensive testing
     or to deny further  evaluation.                                       .   -
     Submission  of Data  - Ve  require that all  test data  obtained  frota .
     outside  laboratories  in support of your  application be submitted  to. us.'-r-
     This includes any results  you have vhich  vere declared  void or invalid by
     the  laboratory.   V-'e  aioo  ask  that  you  notify  us  of the  laboratory .you "*
     hova  chosen, when  testing  is  scheduled  to  begixi, what  tests  you have
     decided  to  conduct,  allots  us to  raintain contact  with  the  laboratory ^
     during  the  course  of  the  testing,   and allc'-r  the test  laboratory  to
     directly answer any questions at  any  tirr.e about  ths test  prograia.         •'

Despite  the  current  backlog. and  increasing number of inquiries regarding fuel
econ.o-.ay  device  evaluations,  the  EPA intends to process  your application in as
expeditious  a iranner as possible.   We have established  a goal of twelve veeks
fron  tlm receipt of  a complete application to tha announcetMut  of our raport.
Tho attainment  of this objective requires very precise scheduling  and we are
depending OR the applicant  to  respond promptly to any  questions or to submit
any requested data.   Failure to  respond  in a  tirr.ely  isar.per v/ill unduly delay
the  process.   In the  extreme  case,  we  r.ay  consider lack of  response  as a
vithdrawl of  the application.

L '"ope the information abova 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 Ei'A  during this process and any
subsequent   EPA   evaluation.   My  address  is  EPA,   Motor  Vehicle  Enission
Lo.borr.'tory,  2555  Plyiroutli  Road ,  Ann  Arbor,  Michigan,  4S105.   The  telephone
r.v.nber  is ,(313)   663-4200.  . Please contact TTC if  you have  any questions or
'         any  further  information.       .                    • '       " -         "
Merrill I/.  Knrth,     ;
•.Sevice Evaluation;Coordinator  ...    ;----•..-
'£r-i3sion Gonirol Technology L'ivision  -  •'.•:;
ECTD:TEB:Korth:cd:X259:2565PlymouthRd:12/4/80
                                                                                   rV '-t -
                                                                                    ~r,-:C

                                                                 -jrfe^^^S^^-^f^i^^v^**155^^

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(
                                                     f             Attachment-F
                                     -w-            V                      - -  -
         UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                        ANN ARBOR. MICHIGAN 48105
        o  100,                                                    OFFICE OF
January 8, 1981                          .                    AIR. NOISE AND RADIATION
Mr. William Bletnke
1516 Oakes Street
Marinette, WI  54143

Dear Mr. Blemke:

EPA has  received your  application  for evaluation of  Gas Meiser  I  under
Section 511 of the Motor Vehicle Information and Cost Savings  Act.

EPA has  reviewed your application.  However,  no  test  data was  submitted
with your application.  If you decide to obtain data from a private  labo-
ratory as  described in my letter  to  you on December 4, 1980, we  will  be
happy to  work with you  in designing  a test plan.   The EPA policy  docu-
ments that you  received  require  only  hot start data but it may be to  the
advantage of your device i£ it is tested on a cold start basis.

The Gas Meiser  I is a fuel preheater that routes  fuel  through a  flexible
fuel line  that  is wrapped around the  upper  radiator hose.  EPA  recently
tested a  fuel preheater called  FuelXpander  which showed no fuel  economy
benefits.   (A  copy of  this  report  which  was  sent  to  your   attorney,"
Mr. Jamas T. Runyon,  on  July 7, 1980.)   Therefore,  in  the  absence  of
valid new  data  showing a benefit for your device, there  is no  basis  for
EPA conducting confirmatory tests of the Gas Meiser I,

EPA will continue to  process  your  application  On the basis of the avail-
able information.

Enclosed  for  your information is a copy  of the EPA report detailing  the
FuelXpander test  results.  Please contact  me   (phone  (313)  668-4299)  if
you have any questions or require any  further information,

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

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