EPA (Environmental Protection Agency)
       Evaluation of the P.A.S.S. KIT
       Device under Section 511 of the Motor
       Vehicle Information and Cost Savings Act
       (U.S.)  Environmental Protection Agency
       Ann Arbor, MI.
       Sep 82
L

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                                                            ' - 1 ^ 4 .4 :> 1
                                                   EPA-AA-TEB-511-82-14
         EPA Evaluation of the P.A.S.S. KIT Device Under
Section 511 of the Motor Vehicle Information and Cost Savings Act
                                by

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

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                                     TECHNICAL REPORT DATA
                             /Please rtad luttmcrioni an the rtvene helnrr completing:
 EPA-AA-TEB-31 1-8J-I-'.
              P. RECIPIENT'S ACCESSIO^NO.
           PB83     1943R1
 •; T;TL= A.NO SUBTITLE
 EPA  Evaluation of the I'. A . S . S .  KIT Device- Under Section
 511  of  the Motor Vehicle  Information and Cost Savings
 Act.
              6. PERFORMING ORGANIZATION CODE
              5. REPORT DATE
                 September  1982
 7  AUTMQRISI

      F.dward Ant lion v Barth
                                                              8. PERFORMING ORGANIZATION REPORT NO.
 9 PERFORMING ORGANIZATION NAME AND ADORESS
  United  States Environmental  Protection Agency
  Office  of Mobile Sources
  Test  and Evaluation  Branch
  Ann  Arbor, MI -',3105
                                                              10. PROGRAM ELEMENT NO.
              Hi. CONTRACT/GRANT NO.
 12. SPONSORING AGENCY NAME AND ADDRESS
                                                              i3. TYPE OF REPORT AND PERIOD COVERED;
                                                              !   Techn ica1                     '
                                                              14. SPONSORING AGENCY CODE
 15. SUPPLEMENTARY NOTES
 16. ABSTRACT

        This document announces  the  conclusions of the  F.PA  evaluation of the P.A.S.S.  KIT
   device  under the provisions of  Section 511 of the Motor  Vehicle Information and  Cost
   Savings Act.  The evaluation  of  the P.A.S.S. KIT device  was  conducted unon receiving
   an  application for evaluation by  the marketer.  The  P.A.S.S.  KIT device  is an  intake
   manifold vacuum switch  that  is  designed to disengage  the air  conditioning compressor
   during  periods o'" high  power  demand.   The device is  claimed  to eliminate the  load
   of  air  conditioning compressor  when accelerating and  thereby  improve fuel economy
   and  Performance.
        ."PA full.v considered all of  the information submitted by the  applicant.  The
   evaluation of the I'.A.S.S. KIT  device was based on that  information and the results
   of  the  EPA confirmatory testing of  a similar device.  The overall  conclusion  is  that
   '\_A.S.S.  KIT should recover part  of the emissions and fuel economv penalty incurred
   bv  using the air  conditioner  of some vehicles.
                                 KEY WORDS AND DOCUMENT ANALYSIS
                   DESCRIPTORS
                                                b.iOENTiFiERS'OPEN ENDED TERMS   c.  COSATi Field/Group
  Automob iles
  Exhaust  Emissions
  Fuel Consumption
  Tests
Air Conditioning
Fuel Economy
Gas Saving Device
 s. DISTRIBUTION STATEMENT

  Release Unlimited
19. SECURITY CLASS (This Report,
  Unclassified
21. NO. OF PAGES
      29
20. SECURITY CLASS (This page)
  Unclassified
                            22. PRICE
EPA Form 2220-1 (»-V3)

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

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

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

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

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

1.  Title:

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

2.  Identification  Information;

    a.   Marketing  Identification of the  Product:

         Model  Number - 07-06-10

    b.   Inventor and Patent Protection;

         (1)   Inventor

              Fasco Industries Inc.
              1100  Airport  Road
              Shelby,  NC  28150

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

    c.    Applicant ;

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

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

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

    d.    Manufacturer of the Product:

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

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

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

    a.    Purpose:

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

    b.    Theory of Operation;

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

    c .    Construction  and  Operation:

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

    d.    Specific  Claims  for  the  Product:

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

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

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

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

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

Product  Installation,  Operation,  Safety and  Maintenance  (as  supplied
by Applicant) :

a.   Applicabili ty :

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

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

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

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

b. •  Installation - Instructions,  Equipment, and  Skills Required:

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

c.   Operation:

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

d.   Effects on Vehicle Safety:

     "Not applicable."

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    e.    Maintenance;

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

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

    a.    Unregulated Emissions:

         "Not applicable."

    b.    Regulated Emissions and Fuel Economy:

         "Not applicable."

6.   Analysis

    a.    Desc ription:

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

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

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

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

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

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

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

b.   Installation, Operation,  Safety and  Maintenance:

     (1)  Applicability:

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

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

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

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

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

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

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

          (3)  Operation;

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

          (4)  Effects on Vehicle Safety:

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

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         (5)  Maintenance;

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

         Effects on Emissions and Fuel Economy;

         (1)  Unregulated Emissions:

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

         (2)  Regulated Emissions and Fuel  Economy;

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

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

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

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         reduction  In  vehicle emissions and fuel  consumption.**  However.;>:
         although   the   P.A.S.S.   KIT  and  Pass  Master   operate  in  an';,'
         identical  manner,  their A/C on/off  set points are  significantly
         different.  EPA has  no information available  to  evaluate whethe!r;
         one  device would  function  better than  the  other.  Thus,  EPA is.
         unable  to quantify  the  fuel  economy benefits  for the  P.A.S.SX
         KIT  based  on  the testing  of the  Pass  Master.                    ;; :-
                                                                           I •'.
         Potential  Effectiveness  of  an  Air Conditioning Cutoff  Device:

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

         (1)  Usage                                                     ':.!••'"

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

              (b)   The   device  functions   only  when   the  A/C   system  isr,
                    turned on.  The Device  is  then supposed to  negate parti'
                    of  the fuel economy penalty  incurred by using  the air '
                    conditioner.    This   important   characteristic  of  their •
                    device is  called  the   "buy-back".   This  is   the  amount...
                    of  the  fuel  economy  penalty due  to the A/C chat  is''''.
                    saved by the device.                                    ;'.,

         (2)  Effect of  air conditioning  design                           ";.,"'•
                                                                          "I ' i
              There are  several types  of  air  conditioning systems  found .
              on  American  cars.   While most  systems incorporate  similar'•'•;'•
              major   components    (compressor,    condenser,    evaporator, ,/'
              receiver-dryer,   and  expansion  valve),   the   method   of;  .
              controlling   the  interior   temperature  of   the   vehicle' j;
              varies.  The  effect  of the   "P.A.S.S. KIT" compressor  cutout,
              switch will depend on  the  type of  system installed in  the',:'.  ,;
              vehicle and to  what  position the A/C control  unit is set.   • Ji,','1!
                                                                          i,, • -lii
              Present  air conditioning  systems  sense  an  evaporator  coil ;i ;.'!(
              parameter  such  as  refrigerant  pressure  or  temperature  or , i !|:
              outlet air temperature  and  use  this  parameter  to  control ' |||i!
              the amount  of refrigerant to the evaporator  coil.   The        ,{ ' <|;
                                                                              i
**The fuel  economy  gains with the  "Pass  Master" device,  varied  from 0  to •'•  i
4%  depending  on-  the   vehicle  and  test  conditions.   These  tests were ,
designed to  give  the  device  the  best  opportunity  to  display the  maximum
benefit in  that  they  were conducted with  the A/C  set  to maximum  cooling
and  the  windows open.   Given the  similarity of  the  devices,  it  is  our
engineering  judgment that  such  tests  reasonably quantify the maximum fuel
economy benefit of either  the Pass Master or  the P.A.S.S. KIT devices.     ','"'

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                                                                10
method  of  controlling  the  refrigerant varies.  'The cool ing 
 Several  vehicle manufacturers  have  incorporated  both  types
 of  control  on  vehicles.   When the  A/C switch  is on  "Max
 Cool",  the  compressor runs continuously.  When at  Normal, .or;
 "FE"  (Fuel  Economy)  settings,  the  compressor cycles.
                                                        1  '"!  «
 The  P.A.S.S. KIT device will  work best on  systems  designed
 to operate  in a "Continuous" mode.  During  the  acceleration
 modes,  the  compressor will  be  cut out by the  T .A.S.S.' KIT
 device.    Since   the  compressor  will  run  enough   during
 nonacceleration  modes  to  control  evaporator   temperature,
 the  reduced engine  load in  acceleration may result in  some
 fuel economy  savings  (buy-back).                          f.
                                                          i.'
 On "Cycling"  type systems,  the  P.A.S.S.  KIT may or may  not
 have   an   effect.    If   the  car   accelerates   while
 compressor  is not engaged,  the P.A.S.S.  KIT will  have
 effect.   If  the  compressor  is engaged,  the  P.A.S.S.
 will  disengage  the   compressor  and  allow   the   engine
 accelerate  the  vehicle with  a  reduced load  on  the engin*
 Upon  completion of  the acceleration,  the  compressor wi|
 run  to restore  the   evaporative  pressure/temperature.
 fuel  saving will  be caused  by making  the  compressor   rS
 during  a  more  efficient   operating  mode   (crui.se  versj
 acceleration).   Due   to  the  intermittent  cycling  and   q,
delayed  compressor   operation,   less   fuel  economy
 (buy-back)  is expected on  this  type  of system.

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

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

          (3)  Operating Variables

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

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

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

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

              (d)  The  type  of  driving  cycle  used  will  influence  the-
                   effectiveness  of  the device.   The  system will be more
                   effective   in  urban    driving   with   its    increased
                   acceleration  modes  operation  than  in  highway   steady
                   state driving.

              (e)  The  effectiveness  will  also  depend on  the  penalty  in
                   comfort  the  operator is  willing  to  accept.   Usually, a
                   vehicle  is in  a  heavy  acceleration mode  for only 5  to
                   30 seconds.   Since the  evaporator  fan  remains  on and
                   there is  stored  cooling,  only a slight  change  in air
                   conditioning   comfort    would    be   noted.    However,
                   prolonged  steep  grades  or heavy  loads may  cause the
                   device   to cut out excessively  and  thereby  noticeably
                   reduce   the cooling.   This   also  will  tend to  occur  as
                   the  device  is adjusted  to maximiz,  the fuel economy
                   buy-back  by  adjusting   the  P.A.S.S.  KIT to  activate
                   sooner.
8.  Conclusions

    EPA  fully  considered  all  of   the   information   submitted  by  the
    applicant.  The  evaluation of  the  P.A.S.S. KIT  device was  based  .on
    that information and the results  of  the  EPA confirmatory  testing of a
    similar device.   The  overall  conclusion  is  that  P.A.S.S.  KIT should
    recover part  of  the emissions  and  fuel  economy  penalty  incurred  by
    using the  air  conditioner of some vehicles.

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                                                                             12
    The amount  of  this fuel  economy  benefit depends  on  several factors.
    The  most  important  factor  is  the  amour.t  that  the  vehicle  ,air
    conditioner  is  used.    Drive.-rs  in  warm  climates  who  frequently :use
    their air  conditioner would  experience  che  greatest  change  in  fuel
    economy  when driving  in  situations  that   frequently  activate  ' the
    device.   The second important factor  is  the suitability of the device
    to  the  manifold  vacuum  characteristics  of  the  particular  vehicle.
    The improvement  in  fuel economy with  the  air conditioner on can  range
    up  to  a   few  percent  depending  on  the   vehicle  and  the  specific
    adjustments  the   user  performs  to  match  the  P.A.S.S.  KIT   to his
    vehicle.   Another  factor  affecting  the  performance  is  the  type of
    vehicle  air  conditioning  unit   to   which  the  "P.A.S.S.  KIT" .is
  .  applied.   Systems  which  operate  continuously should  realize  a larger
    benefit  than those which cycle.    The final  factor  is  the  type ,of
    driving.   The "P.A.S.S.  KIT"  system is expected  to  show the greatest
    improvement in urban stop-and-go driving.

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

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

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                                                                            13
Attachment A
Attachment B
Attachment C
Attachemnt D
        List of Attachments

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

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

Letter  of  December 22, 1981  from  Jay Kuiper of  Cartel
Products   to   EPA   acknowledging   receipt   of   511
evaluation information.                           j"

Letter  of  January 28,  1982  from ,  EPA  to Jay Kuiper 'of
Cartel    Products    acknowledging    receipt    of ':  511
application    for    P.A.S.S.    KIT    and    requesting
clarification and  additional  information.         '
Attachment E
Letter  of April  13,  1982  from  Jay  Kuiper  of  Cartel
Products  to  EPA discussing  proposed  changes  to  the
P.A.S.S.  KIT device.
Attachment F
Letter  of  April  19,  1982  from EPA  to Jay  Kuiper of
Cartel  Products  requesting  copy  of  proposed   changes
for P.A.S.S. KIT.
Attachment G
Attachment H
Attachment I
Letter  of  April  27,  1982  from Jay  Kuiper  of  Cartel
Products   to   EPA   providing   modified   installation
instructions for P.A.S.S. KIT.

Letter  of  May  18,  1982  from  Charles  Vandenberg  of
Cartel  Products  to  EPA discussing  P.A.S.S.  KIT sample
variability   and    providing   additional    proposed
installation instructions and device applicability.';,
                                                  i'1
Letter of June  10,  1982  from  EPA to Charles  Vandetiberg
of   Cartel   Products   stating   application   was ..!,• now
complete but that,  since  no testing was  performed,;  no
specific  percentage  improvements   could  be  cited  in
this evaluation.

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                        r~«onii
VACUUM MOSI TO CAOBUIAIOH
            (If COXHIC1O*
        VACUUM >«OSI TO
               P.A.S.S.      KIT
                                                                                      ATTACHMENT A
               INSTALLATION INSTRUCTIONS

    1  Select • mounting location In the engine compartment to allow the leads Irom
      the P.A S S KIT io retch ihe A/C compressor electrical ie»dH>. *nd th« rubtw
      hose supplied to  reach (h« carburetor vacuum line
    2. Locate a suitable  existing mounting Dolt or drill a 1/8" hole and mount the unit
      with the sheet metal screw provided.               '             __
    3 Cut one ol th* wires connected to the A/C compressor clutch. Strip about  3/8"
      ol insulation from the ends  Attach to Ihe P A S S K17 'eaUs with ih.; wire nuls
      provided Push Ihe wire terminals over the terminals o. the base of  Ihe P.A.S.S.
      KIT
    * Locale the "Mamtofd vtcuum" line.  The "manifold vacuvi.m" source  will be near
      the case ol the carhuretor  bolow iho throttle platen) Chi- 13 tho Tame vacuum
      source that 13 connected 10 Ihe distributor vacuum advance mechanism.  *  •
      Note:                      '                 j
      — DO NO? connect Io  the jundary vacuum pump    ''.!
      — DO NOT use the vacuum hose connecied to thv char.coai Mier M nas a con-
         stant vacuum)                               ''.     '"'"'-•
      — Some cars may require trial and error io Mnd Ihe correct vacuum source
      -especially (hose  with  luel m|octton               .:
      If you cannot loc.ite Ihe vacuum source, ash a mechanic
    5 IF YOUR CAR HAS A  PURSER VACUUM LINE cut the'vac^um nose near Its
      source inseM Ihc appropriate TEE provided, and attacn Io me P.A.S.S.'KIT
      with the rubber hose provided
      IF YOUR CAR HAS A METAL VACUUM LINE Cut the line with a tubing culteror
      hacVsaw Do not use side cullers as they will close th«.'.end ol !he  tubing  Cot
      two 1" pieces from (he ruober hose provided. Slide one onto eacn end o> th»
      metal tubing. Insert the Tee. and push Ihe rubber hos» over the nipple on tha
      Tee and the P A S S KIT                       '
    6 You have now complelrd (he installation of your PASS  Kir Thu  unit  has
      been preset at Ihe factory, however, it is ad|ustable IO swiicaoff »arit*f or later
      as follows
      1. Remove blae* protective cap
      2 To have compressor clu.lc.h cut out earlier, turn screw riocbwns one/terith
        turn at a time,
      3 To have compressor clutch cut out later, turn screw counter  clocX-wise
         one/lenth turn  at a dmo                         :            •     ;
      4 Replace blacK protective cap (The biacx protective cap must oe replacod.)
                                           WARNING: Do nol connect to auxiliary vncuum pump.
                                  SWITCH  SPECIFICATIONS
                           S^ilcn Vacuum

                           ConiiCU  Sli»er. Mea«7 Duly

                           Elrcl"Cjl • Aulomolix Clulcn Load
                         m Mptal

                   S«l Poml On • 8" Vtcuum
                          'Oil  4" Vacuum

                   •Ad|uilaolr From J.5" Vacuum Io 5" Vacuum
                             COMPLETE   *  READY TO INSTALL
£4RT£L  PRODUCTS DIV.
VANDENBERG CORPQH
encounter moderate  dirt;
 EPA NOTE:   The  installer  may encounter moderate  iTicuy in  locating  the,(proper vacuum
 line.   Vacuum port elevation/location is not  always  indicative  of the  type 'of  vacuum  signal.
 Also, some Fords  have dual advance  (two vacuum lines).

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                                                                Attachment B          15

                 UNITED  STATES ENVIRONMENTAL PROTECTION AGENCY

\ ^Vi/^Z  <                        ANN ARBOR. MICHIGAN  48105


         December 14, 1981                                                   OFFICE OF
                                                                      AIR. NOISE AND RADIATION


         Mr. Jay Kuiper
         Carter Products Division
         Vandenberg Corporation
         3757 Lake Drive
         Grand Rapids, MI  49506

         Dear Mr.. Kuiper:
                                                                               4  .
         •This is in  response  to  your  recent  inquiry regarding an EPA eva luation,,r r
         your, Pass  Kit  device.   The Environmental  Protection  Agency  is charged  by
         Congressional  mandate  to  evaluate   fuel   economy  and  emission  control
         devices.  While  the  EPA does  not  actually  "approve" such devices,  it does
         conduct evaluations  for the  purpose  of  increasing the common knowledge, in
         the  area.   For  this  reason,  the outcome  of any  testing  by  EPA  becomes
         public  information.   It is this information which  may  be  cited, although
         no claims can  be made  that any EPA  findings constitute  "approval"  of , tht
         device or system.

         Enclosed with this letter  is a  packet of materials  which you will  need  to
         apply  for  an  EPA  evaluation  of  your  device.   This  packet  consists  of
         1) an  application  format,  2)  a  document  entitled  "EPA  Retrofit and
         Emission Control Device  Evaluation Test  Policy",  3) "Basic  Test flans and
         Testing Sequences",  and ••'<) a copy of the  applicable  Federal Regulations.
         In  all  of  these documents  the  term "device"  includes fuel  additives.
         Motor vehicle  oils,  lubricants and  oil  additives  do  not  fall  under the
         provisions  of  Section   511  of the  Motor  Vehicle   Information and Cost
         Savings Act.   However,  EPA  is prepared  to work  with manufacturers  of
         thes'e products,  using  the  same procedures  and  protocols  defined  in the
         enclosed documents.
             i
         In or,.der  for  the EPA  to conduct  an evaluation of  your device, we  must
         have an  application.   Once  you  have  reviewed  all  the  documents in  the
         packet,  you  should  prepare  an  application   in  accordance   with   the
         guideJines of the application format.  A  critical  part  of  the  application
         is th<: substantiating test  data.   The required test results will have ;to
         be  obtained  at  a  laboratory of  your  choice.    Such   testing  would |be
        'conducted at your  expense.   A list  of laboratories, which  are known 'to
         have the  equipment  and  personnel  to  perform  acceptable tests, has  been
         included  in  the  enclosed  packet.   The   laboratory   list   is  revised
         periodically,  so  be certain that  the list  you  are  using  is  current.
         Please allow EPA to comment on your  test  plan  before beginning  testing at
         an  independent   laboratory.   If  you  desire,  we  can  assist in   the
         development  of a satisfactory test plan.                                '«
                                                                                * * •
         There  are,  however, several aspects  concerning  testing  at  an outside
         laboratory which I would like to  bring to your  attention at this time:

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

 The  tests  are  conducted  in a  "back-to-back." manner,  once  with  the
 vehicle in  baseline  condition, and  again with  the  device  installed
.with  no  vehicle  adjustments  between tests.    If  installation of  the
 device  also involves some adjustments,  e.g. timing,  fuel-air mixture,
 choke  or  idle  speed,  another  test  sequence  with only  these adjust-
 ments   should  be  inserted   between the   first and  last.  If  mileage
 accumulation is  necessary  in order  to  realize the full  benefit,  the
 same  number of miles  that  are accumulated before the test  runs, must
 also  be accumulated before  baseline  runs.  In addition,  the  method of
 mileage accumulation  should be kept constant.   Also,  as a  miniaua,
 the  test sequence  shall  consist  of  a hot-start  LA-4 portion  (bags 1
 and 2)  of the Federal Test  Procedure (FT?) and a Highway Fuel Ecooaay
|Test   (HFF.T).    The details  of  these   tests  are  contained  in  the
 enclosed  packet.   Although only  a  hot-start  FTP  is  required  to
 minimize the  costs to  you, you  are encouraged  to  have  the -entire
 cold-start  test  performed,  since any confirmatory  testing and evalua-
:tion  performed  by EPA will  be  based  on  the complete FTP, and  you  nay
 wish  to  know  how a  vehicle  with  your  device  performs  over 'this
^official test.   As a  final  requirement, the  personnel of the outside
 laboratory  you  select  should  perform   every element  of  your test
 plan.   This includes  preparation  of the  test vehicle,  adjustment of
 parameters,  and  installation of the device.

 Submission  of  Data - We require that all test data obtained  from  the
 outside laboratories in support  of your  application  be submitted to
 us.   This includes any  results you have  which were  declared  void or
 invalid by  the  laboratory.   We also ask  that you notify us of  the
 laboratory  you  have chosen, when  testing is  scheduled to begin, what
 tests you  have  decided to conduct,  allow us  to maintain contact with
 the laboratory  during the course  of the  testing,  and allow  the test
'laboratory  to directly answer any questions  at  any  tine  about  the
 test program.                                                    '•' •
i\                                      •   .                       ii;
'Cost  of  the  Testing  - The  cost  of  the minimum  test  plan, .(two
s|ehicles,  two  test sequences in duplicate) described  above  should  be
[less than $3000 per vehicle  and less than $6000 for the  total  test at
ary of  the laboratories  on  the list.   It should  be  recognized that
additions  to the  minimum test  plan  (such as mileage  accumulation,
 parameter  adjustment,  or  additional  testing) will  result  in  addi-
 tional  costs.   In  any  case,  you will  have to contact  them  individ-
ually to obtain their  latest  prices.

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

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

         Minimum Fuel Economy  Improvements versus Size of Test Fleet

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

Once we receive your application,  it wi.ll be  reviewed  to  determine if  it
meet.s. the  requirements  listed in  the format.  Please  do  not  submit con-
fidential,  trade secret,  or  proprietary information  as EPA  cannot assure
that'.]'1 srch  information can   be  protected  in all  situations..    If  your
application  is  not complete,  we will ask  you to submit  further  informa-
tion or data.   After any missing  information has  been  submitted,  your
application  will be  reconsidered,  and once  it meets  our requirements; you
will'.'jjbe advised of our decision whether or not EPA will  perform  any'con-
firmatory testing.   Any EPA  testing  will  be  performed  av  no  cost  t'd you
and ypu will be  given the opportunity to concur with our  test  plan.  lOnce
this ^testing is complete,  an  evaluation  report  will be  written.   If  no
further testing is  required,  the  report  will  be written  solely  oil!', the
basis( of the test data submitted and  our engineering  analysis.         |l
    '^                   •                                            'i'i
EPA intends  to   process your  application  in  as  expeditious  a manner  as
possible.   We have  established a goal of twelve weeks from  the receipt of
a complete application to  the  announcement  of  our report.   The attainment
of this objective  requires  very precise scheduling,  and we  are  depending
on the   applicant to  respond  promptly to any  questions,  or to submit any
requested  data.  Failure to  respond  in  a  timely manner will unduly delay
the process.  In the  extreme  case, we may  consider  lack of  response: as a
withdrawal of the application.

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

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

Enclosures

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                                                      ATTACHMENT C    19
PRODUCTS DIV.
       December 22, 1981
       UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
       Ann Arbor, MI  48105

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

       Dear Sir,

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

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

       Have a joyous holiday season.

       Sincerely,
       cc
    <                VANDENBERG CORPORATION               :
3133-MADlSCN AVE . S E. GRAND PAPIDS. MICHIGAN 495O3 * PHONE (616) 243-O15/
   ."<;•

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^tolr                                                         ATTACHMENT D       20

 .^  Xj    UNITED STATES ENVIRONMENTAL PROTECTION AGENCY   '
^fzrt-l •-
     •y • .'                  ANN ARBOR. MICHIGAN  48105                   .'      '
                                                               OFFICE OF
                                                        AIR AND WASTE MANAGEMENT
    January 28, 1982
    Mr.  Jay Kuiper, Vice President
    Cartels Product Division
    Vandenberg Corporation
    3133 Madison, SE
    Grand Rapids, MI  49508
    Dear Mr. Kuiper:                                                   :' " "

    We received -your  letter  of January 13,  1982  in which you appliedjfor  an
    EPA evaluation of the P.A.S.S. KIT, a fuel economy retrofit device.'i  ''   •

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

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

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

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                                                                        21
V/e will  need your response  to  the preceding items  to  properly evaluate
your device.   In  order  to process applications  efficiently,  we establish
a  schedule  for  each one.   1 ask  that you  respond to  this  letter  by
February 20  and  plan to complete your testing by March 20.   If you have
any questions  or  require  further information, please contact me at (313)
660—4299 -

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

Enclosures

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 PRODUCTS DJV.                                   ATTACHMENT  E
       April  13,  1982
       United  States  Environmental
       Protection  Agency
       Ann Arbor,  Michigan  48105

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

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

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

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

       Looking forward to working with you.

       Sincerely,                                                 Y
                    VANDENBERG CORPORATION               ;'
3133 MADISON AVE SE GRAND RAPIDS. MICHIGAN 495O8  » PHONE (616) 243.O457
       i                                          '                i?;
  .    j;

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                                                      Attachment F

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

Dear Mr. Kuiper:

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

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

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

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 PRODUCTS DJV.
                                                    ATTACHMENT G   24
     April  27, 1982
     United States Environmental
     Protection Agency
     Ann Arbor, Michigan  48105

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

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

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

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

     In the E.P.A.  evaluation 'of the "Pass Master Vehicle Air Conditioner
     Cut -  Off Device" you state that the largest drawback with the
     "Pass  Master"  device is that  it is not optimized forear.h type of
     vehicle.   We hope that our proposed changes in items 2  and 6 inithe
     installation instructions  will giva the installer an opportunity
     to "fine  tune" the device  so  that it will  operate correctly  for.jeach
     vehicle.                                                      ''
                                                                  ' i •
                                                                  I i
     With the  changes  we have  submitted, I would hope that you can  '•>.
     release a report  similar  to the report prepared for the "Pass  Master".
                                                                   i
     Thank  you for  your suggestions and encouragement.              •'•;

     Sincerely,                                              .       \
     JK/rt
               /
                    VANDEN8ERG CORPORATION                 !
3133 MADISON AVE..S.E GRAND RAPIDS. MICHIGAN 495O8 • PHONE (616) 243-Q457

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                                                                         25
                         P.A.S.S. KIT


Additional Proposed  Installation Instructions.



New Instruction .$2:

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


New Instruction #6:

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

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

                                                                iir
     The above described fine adjustment is easily accomplished if
you !can hear or "feel" your A/C disengage.  If not - we suggest!
that you temporarily run a wire from the P.A.S.S. KIT switch into
the passenger compartment.  Connect to a 12 volt bulb or circuit:.1
testier and run wire  back to the A/C clutch lead.  Uhen bulb is  .'
"Ij.t, A/C clutch is engaged.  When bulb is off, A/C clutch is   ;.;,:.
disengaged.
    • When adjustment is completed, remove wire and indicator light
from passenger compartment and connect electrical leads permanently
as described in instruction #3.                                ;;• •
                                                               M

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 ^A^-.-*                                                    ATTACHMENT H     26
CARTEL PRODUCTS DIV.
              May 18, 1982
              United States Environmental      .                                    ^N
              Protection Agency                            '
              Ann Arbor, Michigan  48105
              Attn:  Merrill W. Korth                                    ;  .
                     Device Evaluation Coordinator                   .     :
                     Test and Evaluation Branch                           •
              Dear Merril 1:                                               '
                                                                         i
              In'response to your discovery of the  variation in the       !
              upper (on) set point of our P.A.S.S.  KIT vacuum switches,
              we have bench  tested the switches on  hand and found that
              approximately 12% of those tested exceeded 9" Hg..  We subse-
              quently discovered that the latest shipment of these switches
              supplied by our vendor were manufactured to a tolerance of
              7-10". Hg instead of our requirement of 8"±1" Hg.

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

              I have enclosed a revised copy of the "Addition'.1  Proposed
              Installation Instructions", and copy  for the exterior of the
              package regarding vehicles to which the kit does not apply.

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

              Thank you very much foryour help Merrill and Tony, we       f.
              look forward to hearing from you.                           )
              Charles Vandenber

              CV/rt

              Enclosures

              cc:  Tony Barth
                             VANDENBERG CORPORATION              '}.
         3133 MADISON AVE.. S.E. GRANDPAPIDS. MICHIGAN 495O8 • PHONE (616)243-0457

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                                                                     27
                        P.A.S.S.  KIT


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


New Instruction #2:

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


New Instruction #6:

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

   1.  Remove black protective cap.

   2.  To have compressor clutch  cut out earlier,  turn screw
       clockwise one/tenth turn at a time.

   3.  To have compressor,- clutch  cut out latsr,  turn  screw
       counter clockwise one/tenth turn at a time.
   ,4.  Replace black protective cap.  (The black protective cap
       must be replaced.)                                   ',''.
   ;  The above described fine adjustment is  easily accotnpl istfed if
you can hear or "feel" your A/C disengage.   If  not, we suggest
that you temporarily run a wire from the P.A.S.S.  KIT switch (into
the passenger compartment.  Connect to a 12  volt buHb or circuit
tester and run wire back to the A/C clutch lead.   When bulb i!s
lit, A/C clutch is engaged.  When bulb is off,  A/C clutch is.''
disengaged.      t                                            \

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

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                                                                    28
                        P.A.S.S.  KIT

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


        1982  Ford Escort with automatic transmission

        1982.  Mercury Lynx with automatic  transmission

        1982  Cadillac, all  models.

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

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                                                      Attachment  I
                                                                             29
        UNITED STATES ENVIRONMENTAL PROTECTION  AGENCY
                        ANN ARBOR. MICHIGAN  48105
June 10, 1982                                                      , OFFICE OF
                                                             AIR. NOISE AND RADIATION
Mr. Charles Vandenberg
Cartel Products Division
Vandenberg Corporation
3133 Madison, SE
Grand Rapids, MI  49508

Dear Mr. Vandenberg:

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

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

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

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

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