EPA-AA-TEB-511-81-9
EPA Evaluation of the Petromizer System Device Under
Section 511 of the Motor Vehicle Information and
Cost Savings Act
by
Edward Anthony Barth
May, 1981
Test and Evaluation Branch
Emission Control Technology Division
Office of Mobile Source Air Pollution Control
U.S. Environmental Protection Agency
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6560-26
ENVIRONMENTAL PROTECTION AGENCY
[40 CFR Part 610]
[FRL
FUEL ECONOMY RETROFIT DEVICES
Announcement of Fuel Economy Retrofit Device Evaluation
for "PETROMIZER SYSTEM"
AGENCY: Environmental Protection Agency (EPA).
ACTION; Notice of Fuel Economy Retrofit Device Evaluation.
SUMMARY: This document announces the conclusions of the EPA evaluation
of the "PETROMIZER SYSTEM" device under provisions of Section
511 of the Motor Vehicle Information and Cost Savings Act.
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BACKGROUiro '" 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,
together 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
pollutants; and
(3) any other information which the Administrator determines to
be relevant in evaluating such device."
EPA published final regulations establishing procedures for
conducting fuel economy retrofit device evaluations on March 23, 1979
[44 i--R 17946].
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ORIGIN OF REQUEST FOR EVALUATION; On January 13, 1981, the EPA received
a request from Chandler Associates, Inc. for evaluation of a fuel saving
device termed "PETROMIZER SYSTEM". This Device is claimed "... to better
control exhaust emissions and increase the miles per gallon of automobile
engines. This device consists of two units (1) a carburetor base plate
adapter which admits additional air and swirls the air-fuel mixture and
(2) a fuel line diverter valve to regulate fuel pressure.
Availability of Evaluation Report; An evaluation has been made and the
results are described completely in a report entitled: "EPA Evaluation
of the PETROMIZER SYSTEM Device Under Section 511 of the Motor Vehicle
Information and Cost Savings Act," report number EPA-AA-TEB-511-81-9
consisting of 24 pages including all attachments.
Copies of these reports may be obtained from the National Technical
Information Center by using the above report numbers. 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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Summary of Evaluation
EPA fully considered all of the information submitted by the Device
manufacturer in the application. The evaluation of the "PETROMIZEK.
SYSTEM" device was based on that information. The Applicant submitted
the request for evaluation three times* The first and second
applications were returned - to the Applicant because to honor the
confidentiality statements contained in the application would have
precluded EPA from conducting a complete evaluation and making it
available to the public as required by the Motor Vehicle Information and
Cost Savings Act.
The Applicant submitted a third application for evaluation that contained
no confidentiality restrictions. However, the Applicant submitted no
valid test data to support the claims for increased fuel economy. The
Applicant had been advised by letter on several occasions of EPA's
requirement that Applicants submit valid test data following the proper
EPA test procedures.
Since the Applicant was unable to provide the required test data, the
Applicant requested the application be returned. The Applicant stated
they would attempt to obtain the required information at a later date and
would resubmit the more complete application at some future date. The
Applicant was advised that EPA was still required to complete the
evaluation based on the available information and publish the results.
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Therefore, based on the information provided by the Applicant, there was
'' /,* ' '
no technical basis to support any claims for a fuel economy improvement
or emissions reduction with the "PETROMIZER SYSTEM."
FOR FURTflER 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 ?. Tuerk
Acting Assistant Administrator
for Air, Noise, and Radiation
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EPA Evaluation of the PETROMIZER SYSTEM Device under Section 511 of the
Motor Vehiclfe 'Information and Cost Savings Act
The following is a summary of the information on the device as supplied
by the Applicant and the resulting EPA analysis and conclusions.
1. Marketing Identification of the Device:
PETROMIZER SYSTEM Trade Mark
2. Inventor of the Device and Patents:
A. Inventor
"A patent application is filed and is pending. The owner of the
patent rights is"
Chandler Associates, Inc.
1730 K Street, N. W., Suite 1302
Washington, D.C. 20006
B. Patent
"Until the U. S. Patent Office allows the claim made, Chandler
Associates, Inc. declines to submit this data to protect its
patent rights. The device is described in item 7 herein."
Manufacturer of the Device:
"The proto-type has been manufactured by Chandler Associates, Inc.,
the owner of patent rights. It is contemplated that large scale
manufacturing will be accomplished by licensing several well
established manufacturers of carburetors and/or other auto parts."
4. Manufacturing Organization Principals:
"Not Applicable."
5. Marketing Organization in U.S. making Application;
Chandler Associates, Inc.
1730 K Street, N. W., Suite 1302
Washington, D.C. 20006
Telephone (202) 785-5025
6. Applying Organization Principals:
President: Charles R. Chandler
Vice President: A. Robert Verna, Jr.
Secretary/Treasurer Arthur il. Berndtson
"Any of the three individuals named above are authorized to represent
Chandler Associates, Inc. with EPA. Mr. Chandler is the primary
contact."
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7. Description of Device:
A. Purpose of the Device (as supplied by Applicant):
"The purpose of the device is to better control exhaust emissions
and to increase the mileage per gallon of automobile engines. The
device is designed to provide a more precise measure of fuel to
the conventional carburetor, then to optimize the fuel-air ratio
at varying speeds and finally to .provide an optimum fuel-air
mixing in the intake manifold for more efficient combustion in the
cylinders."
B. Theory of Operation (as supplied by Applicant);
"The invention is a modification of any conventional automobile
(or other) gasoline engine.
"Two expedients are used, in combination, to economize the
gasoline consumption.
"On the one hand, the carburetor is spaced from the intake
manifold by an economizer plate which is provided with means to
admit a speed-dependent metered amount of air to the air-fuel
mixture passages and by a swirl plate to swirl the air-fuel
mixture.
"On the other hand, the fuel line leading to the carburetor from
the fuel pump is provided with a diverter valve which permits
excess fuel to return to the gasoline tank.
"The increased economy of fuel usage when these two expedients are
used jointly is unexpectedly and substantially larger than that
which could be attributed to the summation of the individual
effects of the two expedients, used alone.
"The carburetor economizer plate invention differs from all other
carburetor economizers because it employs a vacuum principal [sic]
(a varying venturi effect vacuum) which is contrary to
conventional knowledge about the vacuum phenomenon in carburetor
barrels. Further, the unique swirl plate produces a more perfect
fuel-air mixture in the manifold than any other device. The
resultant pressure balance when matched with the unique diverter
valve in the fuel line results in a synergistic fuel economy.
"Also of importance is the substantial reduction of excess,
undesirable exhaust gases, as a result of the more perfect
fuel-air mixture and combustion in the engine. Further, it has
been noted that the spark plugs and valves remain remarkably clean
with invention functioning."
C. Detailed Description of Construction (as supplied by Applicant).:
"For detailed description of construction see Detailed
Description, Appendix A hereto and The Drawings page 1, and
Figures 1 thru 5, extracts from patent application attachment
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'.',ť'-
(Fora NBS 1019)". Appendix A was the patent application. It was
not included as an attachment to this evaluation since (1) the
Applicant notified EPA that the Applicant was unable to supply the
required valid test data, (2) requested the Application be
withdrawn, and (3) requested that the copies of the pending patent
be returned.
8. Applicability of the Device (as supplied by Applicant);
"The device is applicable to all gasoline internal combustion engines
with conventional carburetors currently in use. The proto-type
installation is in a stock 1980 Dodge Mirada with a 318-V8, 2 barrel
carburetor engine with automatic transmission, full power accessory
package and factory air conditioning. Variations necessary for other
engines would be dependent on the configuration of the interface
between the carburetor and the intake manifold."
9. Device Installation - Tools and Expertise Required (as supplied by
Applicant);
A. "General Instructions are contained in pages Al thru A4 of
Appendix A hereto." Appendix A is not included. See comments in
Section 7C.
B. "Specific instructions are not required for individual vehicle
make/model/year/engine/etc. except possibly for a modification of
external carburetor linkages in some cases because of the
thickness of the economizer spacer plate. Preparation of
installation kits could alleviate such problems."
C. "Tools normal to any reasonably well equipped automotive shop are
adequate for the installation."
D. "Equipment normal to any reasonably well equipped automotive shop
are adequate to check the accuracy of the installation."
E. "After installation the engine should be tuned to the vehicle
manufacturers specifications, or to the optimum timing as
indicated by an electronic diagnostic system, if available."
F. "A journeyman automobile mechanic can be expected to have the
necessary skills associated with the installation of the device."
10. Device Operation (as supplied by Applicant):
"Once the device is properly installed and adjusted no additional
variation from normal operation of the vehicle is required."
11. Maintenance (claimed);
"Once the device is properly installed and adjusted no additional
variation from normal maintenance of the vehicle is required."
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12. Effects' on Vehicle Emissions (non-regulated) (claimed):
"Since the device does not change the input of matter into the engine
and since it achieves greater efficiency of combustion, there are no
additional pollutants and the normal pollutants are substantially
reduced."
13. Effects on Vehicle Safety (claimed);
"The use of the device has no effect on the safety of the vehicle."
15. Test Results (Regulated Emissions and Fuel Economy) (submitted by
Applicant):
A. "Tests to Date: A stock 1980 Dodge Mirada, with a 318-V8 engine,
EPA rated 24 and 15 mpg, was driven 2,000 miles for break-in and
then fitted with the invention prototype and a special, metered,
one gallon gasoline tank. After precise engine tuning to factory
specifications, the best road mileage obtained before installation
was highway 19.5 mpg and city 12.0 mpg.
"With the invention installed and the engine again tuned to
factory specifications, the road mileage was increased to highway
35.0 mpg and city 16.0 mpg, increases of 79.0% and 33.3%
respectively, with no loss of power or performance."
B. "EPA Tests: During the period July 28 - August 1, 1980, Chandler
Associates, at its own expense, had dynamometer tests of the
device conducted at Automotive Testing Laboratories, Inc. at East
Liberty, Ohio. The test vehicle was a stock 1980 Dodge Mirada,
318-V8 engine, with automatic transmission, power steering, power
brakes, air conditioner, heater and AM-FM radio-tape player. The
results of the four 1975 FTP urban L-4 [LA-4] tests are as follows:
Test HC_ C [CO] NOx MPG
Without Device
1 .72 25.8 .98 13.0
2 .66 24.3 1.04 13.3
With Device
1 .43 4.1 1.48 14.5
2 .45 3.9 1.51 14.5
"It will be noted that the device brought an engine grossly
exceeding the present EPA standards, despite the full factory
emission control equipment, into conformity with the 1980 EPA
standard with a 10% increase in mileage per gallon.
"It is also considered significant that the test vehicle was
driven from the Washington Metropolitan Area to East Liberty, Ohio
(492.4 miles) over Interstate highways at 55 mph with a gasoline
consumption of 16 gallons with the device installed and 24.3
gallons on return with the device removed."
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16. Discussion
EPA corresponded extensively (see Attachments A through J) with the
Applicant in an attempt to resolve problems associated with the
application and the validity of submitted data.
The first two submittals of the application contained proprietary/
confidentiality statements that would have precluded EPA from
properly and adequately publishing the results of the evaluation.
The Applicant removed these restrictions on the third (January 9:.
1981) submittal. This application contained duplicate FTP tests on
one vehicle in both baseline and Device configurations. However,
since the vehicle was not initially at manufacturer's specifications,
the data could not be used in the EPA evaluation of the Device.
Also, EPA requires a device to be tested on a minimum of two
vehicles. The Applicant was advised of these deficiencies
(Attachment H) .
The Applicant was unable to provide the required valid test
and so informed EPA (Attachment J). EPA had previously notified the
Applicant (Attachment I) that EPA was obligated to complete the
evaluation based on the information available and publish the results.
17. Conclusions
EPA fully considered all of the information submitted by the device
manufacturer in the application. The evaluation of the "PETROMIZER
SYSTEM" device was based on that information. The Applicant
submitted the request for evaluation three times. The first and
second applications were returned to the Applicant because to honor
the confidentiality statements contained in the application would
From EPA 511 Application test policy documents:
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 CFR 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 CFR 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 Highway
Fuel Economy Data 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).
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have precluded EPA from conducting a complete evaluation and making
it available to the public as required by the Motor 7ehicle
Information and Cost Savings Act.
The Applicant submitted a third application for evaluation that
contained no confidentiality restrictions. However, the Applicant
submitted no valid test data to support the claims for increased fuel
economy. The Applicant was advised by letter on several occasions
(Attachments C, E, and H) of EPA's requirement that Applicants submit
valid test data following the proper EPA test procedures.(D
Since the Applicant was unable to provide the required test data, the
Applicant requested the application be returned. The Applicant
stated they would attempt to obtain the required information at a
later date and would resubmit the more complete application at some
future date. The Applicant was advised that EPA was still required
to complete the evaluation based on the available information and
publish the results.
Therefore, based on the information provided by the Applicant, there
was no technical basis to support any claims for a fuel economy
improvement or emissions reduction with the "PETROMIZER SYSTEM."
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Attachment A
Attachment B
Attachment C
AttacHe^nt D
Attachment E
Attachment F
Attachment G
Attachment H
Attachment I
Attachment J
List of Attachments
Copy of September 2, 1980 letter from Chandler
Associates, Inc. to EPA submitting confidential
511 Application.
Copy of November 17, 1980 letter from EPA to
Chandler Associates, Inc. advising Applicant
that application is being reviewed.
Copy of November 28, 1980 letter from EPA to
Chandler Associates, Inc. returning the
application since it contained proprietary
information which would have been required to
be published in the official evaluation.
Copy of December 8, 1980 letter from Chandler
Associates, Inc. to EPA resubmitting
application and permitting EPA to include
description of device and theory of operation
in published evaluation.
Copy of December 23, 1980 letter from EPA to
Chandler Associates, Inc. returning the second
application since it still contained
cofidential information. Letter also notified
Applicant EPA had completed an initial review
and that EPA would require additional
data/information to further process the
application.
Copy of January 9, 1981 letter from Chandler
Associates, Inc. to EPA again resubmitting
application. This application contained no
proprietary or confidential information.
Copy of February 12, 1981 letter from Chandler
Associates, Inc. to EPA advising EPA of status
of Chandler testing.
Copy of February 25, 1981 letter from EPA to
Chandler Associates, Inc. notifying Application
of data deficiencies and providing EPA test
policy for Applicants.
Copy of April 3, 1981 letter from EPA to
Chandler Associates, Inc. notifying Applicant
of data deficiencies and of requirement for EPA
to complete evaluation.
Copy of April 13, 1981 letter from Chandler
Associates, Inc. notifying EPA that Applicant
was currently unable to provide required data,
intended to resubmit in future, and requested
return of original application.
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Ť.LLacnmen.L n.
CHANDLER ASSOCIATES, INC.
1730 K Street, N.W.. Suite 1302
Washington. D.C. 20006
Telephone: 202-785-5025
CONFIDENTIAL September 2, 1980
(until attachment is c
removed)
Mr. Peter Hutchins
Emission Control Technology Division
U.S. Environmental .Protection Agency
2565 Plymouth Road
Ann Arbor, Michigan 48105
Dear Mr. Hutchins:
Following up on your recommendation in the recent
telephone conversation you had with Art Berndtson, I am for-
warding our application for evaluation of the new fuel
economizer and emissions control device developed by Chandler
Associates, Inc.
By way of background, we purchased the 1980 Dodge
Mirada, referred to in the application, because we knew it was
a poor fuel and emissions performer. After extensive road
testing we became convinced that our device really did work
on the road. We are aware that EPA has been criticised for
indicating mpg ratings for automobiles which were rarely
achieved by owners on the road. We submit that our device
does indeed perform well on the road, particularly on inter-
state highway driving. After our road testing experience, we
talked at length personally with Bruce Everling in the EPA
Washington office. Bruce recommended that we contract with an
independent laboratory and conduct two EPA 1975 FTP urban tests
with the device and two tests without the device. We conducted
these tests at the Automotive Testing Laboratories, Inc. in
East Liberty, Ohio and the test results are referred to in the
application. As a result of these tests, Bruce Everling then
recommended to Art Berndtson that he get in touch with you.
So here we are!
Chandler Associates is a small group with limited
resources. We do not have the financial resources to conduct
the more extensive tests on multiple vehicles etc. referred to
in the EPA policy documents. We have applied for evaluation
of the device under the Department of Energy/National Bureau
of Standards program and we have requested a $100,000 grant
for the broad testing program of the type EPA desires. Our
DOE application is in the paper shuffling mill at NBS and it
could be a couple of months before we hear anything from them.
With EPA interest indicated perhaps the DOE action could be
expedited, but this is conjecture.
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September 2, 1980
Mr. Peter Hutchins
Emiss.i.OTi Control Technology Division
Page 2
Your general counsel's office here in Washington
has assured us that if our papers containing proprietary
information are properly marked the confidentiality will be
observed by EPA. Accordingly, we have marked our application
pages as being exempt from Freedom Of Information requests
and of a proprietary confidential nature.
We are prepared to cooperate with EPA in any way
we can without surrendering our proprietary interest in the
device.
Very truly yours,
Charles R. Chandler
President
Chandler Associates, Inc.
CRC:elj
Enclosure
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UN
Attachmenc
TED STATES ENVIRONMENTAL PROTECTION AGENCY
ANN ARBOR. MICHIGAN 48105
OFFICE OF
AIR. NOISE AND RADIATION
November 17, 1980
tfr. Charles R. Chandler
Chandler Associates, Inc.
1730 "K" Street, N.W. , Suite 1302
Washington, D.C. 20006
Dear Mr. Chandler:
This is to advise you that your application for evaluation of the Petromizer
device under Section 511 of the Energy Policy and Conservation Act has been
forwarded to the EPA Engineering. Evaluation Group, where it will be analyzed
according to the requirements of the regulation. They will review the
material submitted with your application and determine if EPA testing is
warranted.
We will contact you if further information is needed with respect to your
application.
r
Sincerely, .-*'
Merrill W. Korth, Device Evaluation Coordinator
Test and Evaluation Branch
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JJcveaibor 23, 1930
Mr.. CharleaV-BŁ,
Chandler Associates, Inc.
1730 K Street, D.W., Suite 1302
Washington, DC 20006
Dear Itr. Chandler:
I have been informed by the EPA Engineering Evaluation Group that the
information and data contained in your application for evaluation of
"Fetronizer" under Section 511 of The Motor Vehicle Information and Cost
Savings Act are regarded, by your firrr, as proprietary. The EPA is required
by Section 511 to publish a report detailing the results of any device
evaluation and naka this report available to the general public upon request.
Included in that report, per Section 511 directives, are a detailed
description of the theory of operation of the device and the U.S. Patent
documentation.
Since your firm has not as yet received a Patent Certificate, it is
understandable that your firm would vish to protect its invention. However,
due to the requirements of Section 511 this Agency can not adequately
safeguard the subraitted inf omation. Therefore, I am returning your
application in good faith and assure you that duplicates of your submission
have not been r.ade.
If you are still interested in having your device evaluated by this Agency,
there are two alternatives "which can be incr.ediately identified:
"Rcaubmit your 511 Application, as is, vi'thout the need for
confidentiality with the expectation that a Patent Certificate will be
received prior to EPA publication of its evaluation results.
.Wait until a Patent Certificate has been received and rssubnit your 511
Application without the need for confidentiality.
Please advise this office of your decision so that our files may be updated.
I apologize for the delay your firm has incurred. If I can be of any
casistanca ir. your decision making process, please feel free to contact my
office (313-663-4299).
S-j
rt
:/ Sincerely,
-j
'-!
Merrill W. Korth, EPA Device Evaluation Coordinator
Test and Evaluation Branch
Enclosure
,.. T? u TJ..Ť-,.!, v
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CHANDLER ASSOCIATES, INC.
1730 K Street, N.W.. Suite 1302
Washington. D.C. 20006
Telephone: 202-785-5025
December 8, 1980
Mr. Merrill W. Korth
EPA Device Evaluation Coordinator
Test and Evaluation Branch
Ann Arbor, Michigan 48105
RE: Petromizer - Fuel
economy system
Dear Mr. Korth:
In response to your letter of November 28, we
have opted to re-submit our 511 application, as is,
with the understanding that upon completion of the
evaluation that EPA is required to publish the evalua-
tion results including a description of the device and
the theory of operation.
Sincerely,
Charles R. Chandler
President
CRC/meb
Encl: 511 application
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A L c decline u L
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
ANN ARBOR. MICHIGAN 48105
OFFICE OF
December 23, 1980 AIR. NOISE AND RADIATION
Mr. Charles R. Chandler
Chandler Associates, Inc.
1730 K Street, N.W., Suite 1302
Washington, DC 20006
Dear Mr. Chandler:
Your application for an EPA evaluation of the Petromizer device is labeled as
confidential and we returned it to you on 11/28/80 explaining that we can not
protect confidential ioformation. After you talked to the EPA Office of
General Council you returned the application to EPA with the misunderstanding
that EPA can protect it on a confidential basis.
After receiving the Petromizer application the second time I called
Mr. Bochenek with the EPA Office of General Council who informed me that I can
not guarantee Chandler Associates, Inc. that EPA will be able to protect
confidential material in all Freedom of Information Act situations. As a
result I must return your application a second time and suggest the same two
alternatives listed in my letter of November 28, 1980.
Resubmit your 511 Application, as is, without the need for
confidentially with the expectation that a Patent Certificate will
be received prior to EPA publication of its evaluation results.
. Wait until a Patent Certificate has been received and resubmit your
511 Application without the need for confidential.
We do not plan to take further action on your application until the
confidential problem is resolved.
In the meantime the EPA Engineering Evaluation- Group has completed an initial
review of your application and has found that the following additional
information/data are required in order to process your application further:
What was the actual test vehicle mileage at the time of the ATL,
Inc. testing?
Please provide a detailed description of the test program conducted
at ATL, Inc. .to include all vehicle maintenance, engine design
parameter settings (air-fuel ratio, initial ignition time, etc.),
dynamometer settings (inertia and power absorber), ambient
temperature, etc.
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CHANDLER ASSOCIATES, INC.
1730 K Street, N.W.. Suite 1302 Attachment F
Washington, D.C. 20006
Telephone: 202-785-5025
January 9, 1981
Dr. Merrill Korth
EPA Device Evaluation Coordinator
Test and Evaluation Branch
Ann Arbor, Michigan 48105
Dear Dr. Korth:
Thank you for your letter of December 23. I'm
sorry about the apparent confusion concerning the
protection of the proprietary information. We are
aware that EPA cannot protect proprietary information
in all situations. Suffice to say that the correspondence
on this subject presently in the file is not without
value should a future determination be required. Our
application is resubmitted herewith in an unclassified
form - that is in original form with the "confidential"
designation removed.
We appreciate the preliminary review made by
Engineering Evaluation Group and submit the additional
information and data requested in Enclosure A.
Chandler Associates is a new company with modest
resources, which has limited our capacity to do laboratory
dynamometer tests. We believe it is in the public
interest to conduct further evaluation testing of this
new system and wish to cooperated fully with your staff.
We can offer to send the Dodge Mirada test vehicle or
the 1978 Chevrolet Caprice to your laboratory for further
testing, or alternatively, build a prototype system for
installation on test vehicles on which you may already
have test data. We would also be pleased to make avail-
able Mr. A. Robert Verna, who built the present prototypes
and was present at the ATL rests. Mr. Verna is completely
knowledgeable on the system and results to date.
Please let us know how we may be of further help
in this matter.
Sincerely yours.
Charles R. Chandler
President
CRC/meb
Ends. (2)
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Has .the device been installed on any other vehicles to determine if
air cleaner-to-hood clearance is acceptable?
Exactly how is the appropriate amount of "excess fuel" to be
returned to the fuel tank determined for each engine application?
What is fuel diverter valve's effect on driveability and safety?
Please provide installation instructions representative of those to
be supplied to the ultimate consumer for each engine application (to
include any carburetor linkage and modifications, engine design
parameter adjustments, etc.).
Were any tests performed on the 1980 Dodge Mirada according to the
EPA Highway Fuel Economy Test Procedure at ATL, Inc.? If so, please
provide those data.
Please provide test data to support the claim of a synergistic fuel
economy effect with use of your invention.
Your cooperation in this matter and rapid response are appreciated. I look
forward to receipt of the requested information/data so that we can continue
processing your application for evaluation on a non confidential basis. If
you require any further information or assistance, please feel free to contact
my office (313) 668-4299.
Sincerely,
Merrill W. Korth, Device Evaluation Coordinator
Test and Evaluation Branch
cc: F. P. Hutchins
R. N. Burgeson
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Accacnmenc
CHANDLER ASSOCIATES, INC.
1730 K Street. N.W.. Suite 1302
Washington. D.C. 200O6
Telephone: 202-785-5025
February 12, 1981
Dr. Merrill W. Korth
EPA Device Evaluation Coordinator
Test and Evaluation Branch
Ann Arbor, Michigan 48105
RE: Petromizer Gasoline
Economy Device
Dear Dr . Korth :
In our letter of January 9, 1981 we indicated we
were installing the new device on a 1978 Chevrolet Caprice
with a 305, 8 cylinder engine. This is to advise that we
have made the installation and tuned the engine to factory
specifications with encouraging results.
We are not yet prepared to submit mileage statistics
because we have no yet complied sufficient accurate data.
However, we were pleased to note that on the Sun computer
analyzer, with probe inserted in the exhaust pipe, we
obtained readings of CO-0.53, HC-0.06. The odometer
mileage was and the original catalytic converter crystals
had not been changed.
The latest tune-up on the 1980 Mirada; with the
device installed, on the Sun analyzer, at 24,740 miles
with the original catalytic converter crystals showed
CO-0.0 and HC 0.03-0.06. These Mirada readings were
obtained despite the fact that the dealer could not
adjust the engine to comply with the EPA standards while
the device had been removed and only the catalytic
converter was operating.
The foregoing information is forwarded to assist in
the preliminary evaluation of our application.
Sincerely yours,
Charles R. Chandler
President
CRC/meb
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Attachment H
UNITED STATED ENVIRONMENTAL PROTECTION AGENCY
\ V
/sINARBOR. MICHIGAN 4B10',
OFFICE OK
AIR. NOISE AND RADIATION
February 25, 19S1
Mr. Charles Chandler
Chandler Associates, Inc.
1730 K. Street, N.W. , Suite 1302
Washington, D.C. 20006
Dear Mr. Chandler:
The EPA has performed a preliminary evaluation of the Petromizer using
the information provided. Our findings to date are that:
1. The vehicle tested was not at manufacturer specifications when
tested in baseline; (high HC and CO and low NOx on FTP and very
high idle CO levels).
2. Tests on a single vehicle are insufficient basis for EPA confir~
raatory testing.
Enclosed are copies of documents which specify the testing which is
necessary for support of confirmatory testing by the EPA. As you will
see, we require a minimum of two test vehicles with duplicate tests
before and after the device is installed. This is a total of eight hot
start tests.
As you may have several questions oh the procedures etc, please feel free
to contact me after you have read the enclosed documents.
Sincerely,
Merrill W. Korth, Device Evaluation Coordinator
Test and Evaluation Branch
Enclosures
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Accacnmenc
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
(J
5? ANN ARBOR. MICHIGAN 48105
OFFICE OF
AIR. NOISE AND RADIATION
April 3, 1981
Mr. Charles Chandler
Chandler Associates, Inc.
1730 K Street, N.W. - Suite 1302
Washington, DC 20006
Dear Mr. Chandler:
Since you have not supplied EPA with complete independent laboratory data
for the "Petromizer" , we have insufficient data to support a fuel economy
claim for the device. As explained in my letters to you on 2/25/81, and
2/26/81, we cannot jusify the expenditure of Government funds for EPA
testing of a device which has not shown positive results when tested by a
recognized independent laboratory.
Under the provisions of Section 511 of the Motor Vehicle Information and
Cost Savings Act, EPA is now required to prepare a report on your device
and publish notice in the Federal Register that we have completed our
evaluation. We are presently preparing such documents that will be pub-
lished, if we have not received sufficient independent laboratory data by
5/11/81.
Please contact me immediately if you do not understand this course of
action.
Sincerely,
Merrill W. Korth
Device Evaluation Coordinator
Test and Evaluation Branch
cc: P. Hutchins
T. Earth
511 File (Petromizer)
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