EPA-AA-TEB-511-82-2
          EPA Evaluation of the Sav-A-Mile Device Under Section 511
            of the Motor Vehicle Information and  Cost  Savings Act


This document  contains  several pages which may  not  reproduce well.  Any
questions concerning the legibility of these pages should be directed to:
Merrill  W.   Korth,  Environmental  Protection  Agency,   Office  of  Mobile
Source Air Pollution Control,  Emission  Control Technology Division, 2565
Plymouth Road, Ann Arbor, MI  48105,  (313) 668-4299 or  FTS 374-8299
                                      By

                               John C.  Shelton
                                 October,  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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                                L                     EPA-AA-TEB-511-82-2




6560-26
                     ENVIRONMENTAL PROTECTION AGENCY
                            [40 CFR Part 610]
                           [FRL
                      FUEL ECONOMY RETROFIT DEVICES
         Announcement of Fuel Economy Retrofit Device Evaluation




                             for  "Sav-A-Mile"
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  "Sav-A-Mile" device under  provisions  of  Section  511 of




          the Motor Vehicle Information and Cost Savings Act.

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BACKGROUND  INFORMATION;    Section  511(b)(l)  and  Section  511(c).  of  the

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




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

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


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

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

any  retrofit  device to  determine  whether  the   retrofit device increases

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

••:iih  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  FR 17946].

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ORIGIN OF  REQUEST  FOR EVALUATION:   On May 18, 1981,  the EPA received  a




request from Energy  Managers  of America  for  evaluation of a  fuel  saving




device termed  "Sav-A-Mile".   This device  is  designed to fit  between  the




carburetor  and   the  intake  manifold.    It   is  claimed  to   increase




evaporation and  atomization  of the  fuel prior to  burning  by passing  it




through  a  heat-conductive wire  mesh  screen.   It  is also  claimed  to




function  as an  insulating block  between the  carburetor  and  the  intake




manifold.









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




•.-j:.5ults are described completely in  a report  entitled:  "EPA Evaluation




of  the   Sav-A-Mile   Device   Under  .Section  511   of   the  Motor  Vehicle




Information  and  Cost  Savings  Act,"  report   number  EPA-AA-TEB-511-82-2




consisting of 45 pages including all attachments.









Copies  of  these reports  may  be obtained  from  the  National  Technical




Information Service  by  using the above  report  numbers.   Address requests




to:









           National Technical  Information  Service




           U.S. Department  of  Commerce




           Springfield, VA  22161




           Telephones:  FTS 737-4650




           or 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  "Sav-A-Mile"

device was based on  that  information.



The  "Sav-A-Mile"  consists of  a piece of copper cloth and a flat piece of

insulating  material which  is  placed  between  the  carburetor and -intake

'manifold'of  a"  gasoline engine.  The " stated purpose 'is "to" increase  the

efficiency of the engine  and  decrease the amount of pollutants generated.



Although  the  limited amount  of  test data submitted  by  the applicant  did

suggest  some  improvement  over an unmodified induction system, the results

were  not obtained in  accordance with EPA  requirements   and  the  data  did

not  adequately quantify  the  amount of any  improvement.   In general,  EPA

has   found  that  devices  of   this   type  are  not   effective  in  reducing

emissions or  improving  fuel economy.



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

Technology  Division,   Office  of  Mobile  Source  Air Pollution  Control,

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

A8105,  313-668-4299.
 Date                                    Kathleen Bennett
                                        Assistant Administrator
                                        for Air, Noise, and  Radiation

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EPA.  Evaluation  of  the "Sav-A-Mile" Device Under  Section  511  of  the  Motor
Vehicle  Information and Cost Savings Act'

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

1.   Marketing Identification of the Device;

	^Sav-A-Mile"	   •  -;   ".-    -	-  	;-  -'-•

2.   Inventor of the Device and Patents;

     A.   Inventor
        Frank Cook
        -Rt. 4,-Box  1    -  - •
        Ft. Mill, SC  29715
    B.   Patent
        The applicant has applied for a patent  (see Attachment B)

3.  Manufacturer  of  the  Device;

    Plastic Products
    Hi Way 161
    Bessemer  City, NC  28106

4.  Manufacturing Organization Principals;

    Henry Baxter
    Plastic Products
    Hi Way 161
    Bessemer  City, NC  28106

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

    Energy Managers  of America
    11407 W.  48th Avenue
    Wheatridge, CO   80033

6.  Applying  Organization Principals:

    Ray Wickstrom -  Chairman of  the  Board
    Mike Rucker - President

7.  Description of Device:

    A.  Purpose of the Device (as supplied  by Applicant):

        "The  device designed   is   to  fit  between  the  carburetor  and
        manifold  of an  internal combustion engine  in  order  to increase
        fuel   efficiency,   engine   efficiency   and   reduce   pollution
        emissions.   The device  functions  both to reduce  evaporation  of

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        fuel  from  the  carburetor  and  the  manifold,  and  to  increase
        evaporation  and  atomization  of the  fuel  prior to  burning,  by
        passing the fuel through a heat conductive wire mesh screen."

    B.  Theory of Operation (as supplied by Applicant);

        "The  Sav-A-Mile  is comprised  of a  piece  of  cloth made out of
        copper or other  heat  conductive materials which is placed on  the
        intake manifold -of  an engine "in 'such a "manner "that the  fuel"  mix
        must  pass  through  the cloth  to  enter the manifold.   The outer
        edges of the  cloth  maintain close proximity to  the metal portion
        of the manifold  so  that  it  may readily receive  the heat  produced
        at and around the  flange of  the manifold  and conduct heat into
        the center  of the cloth, wherein the  heat - can be  transmitted to
        the fuel mixture  as it passes through the  cloth.   The  Sav-A-Mile
        further comprises -of-a flat piece  of  insulating material placed
        between  the  solid  portions of  the  carburetor to  insulate   the
        carburetor  from  the heat generated  at the manifold  to  create  a
        large  reservoir  of heat  for  use  by the  cloth.  The  insulating
        piece is so  shaped  as  to  conform  with  the  shape of the flange of
        the carburetor and  to cause no interference  to the flow of fuel
        mixture from  the carburetor into the manifold."

    C.  Detailed Description of Construction (as supplied by Applicant);

        A detailed description is provided in Attachment B.

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

    An application chart is provided in Attachment B.

9.  Costs (as supplied by Applicant):

    Not supplied.

10. Device Installation  -  Tools  and  Expertise Required  (as supplied by
    Applicant):

     Only the  Installation  Instructions were supplied  in response to  this
    paragraph  (Attachment B).

11. Device Operation  (as supplied by Applicant);

    Only the  Installation Instructions were  supplied in response  to this
    paragraph  (Attachment B).

12. Maintenance (claimed):

    "None"

13. Effects on Vehicle Emissions (non-regulated)  (claimed);

    "Data  will  be   forthcoming  upon completion  of  the  Air   Quality
    Resources Board of California test."

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                                 8

14. Effects on Vehicle Safety (claimed):

    "Does not apply"

15. Test  Results  (Regulated  Emissions and  Fuel Economy)  (submitted  by
    Applicant):

    a)  Letter from Cummins Carolinas, Inc. (Attachment B).

    b)  Custom Engineering Laboratories Tests (Attachment F).
    c') '"More data "will also  be" "forthcoming upon  completion of "the  Air
        Quality Resources Board of California test."

16. Analysis

  ~" A. " T)e script ion'of the'"Device":'	            	

       " The device is "judged to be adequately described"in Section"?;'"  ""

    B.  Applicability of the Device:

        The applicability of the device  stated  in the  application appears
        to cover, most gasoline-fueled vehicles equipped with carburetors.

    C.  Costs:
        Not supplied

    D.  Device Installation - Tools and Expertise Required;

        Only  simple  tools  and  average  mechanical   skills   should  be
        required for most installations (see Attachment B).

    E.  Device Operation;

        The   device   has   no   moving  parts.    Only   the   installation
        instructions were supplied with the application.

    F.  Device Maintenance:
        None

    G.  Effects on Vehicle Emissions (non-regulated):

        The device is unlikely to affect non-regulated emissions.

    H.  Effects on Vehicle Safety:

        If  the device  is installed  properly,  it  will  not afffect  the
        safety of the vehicle.

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 I.   Test  Results  Supplied by Applicant;

     The applicant did submit test data per the Federal Test  Procedure
     and.Highway Fuel Economy Test.  These are the  only EPA recognized
     test,  procedures*.  This requirement for test data following  these
 - -  procedures  is  stated  in the  application test  policy  documents
     that  EPA sends to potential  applicants.   The test data  submitted
     by the  applicant  are analyzed below.

     (1) The  data  submitted by the applicant in Attachment  F  were  from
--•--     a single- -vehicle  and - consisted  of  -a--single- test -sequence
        (both FTP and HFET)  with and  without the  "Sav-A-Mile" device
        installed.    In  order   to   evaluate  repeatability  of   the
        vehicle/test  sequence,  EPA  requires  that  these  tests  be  run
        in  duplicate at  each test point.  In  addition,  EPA requires
... _.  „   that--at—least -  two vehicles -be - tested. —  The-se - requirements-
        were clearly stated  to  the applicant  in  a letter of  May  1,
.... ....  1981 (Attachment A).   -- •- 	-	
     (2)  A review of  these  data  showed that:

         (a)  HC and NOx emissions  over the  FTP  decreased  slightly

         (b)  CO emissions over the FTP decreased  substantially

         (c)  FTP fuel economy increased slightly

         (d)  HFET fuel economy increased slightly .

         However,  due  to  the weakness in  the data  noted  above,  the
         data does not confirm these  conclusions.

     (3)  No  data  from  the  California   Air   Resources  Board   were
         submitted.
 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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                                 10
    J.  Test Results Obtained by EPA;

        Due  to  weaknesses  in  the data  submitted by  the applicant,  the
        device was not tested by EPA.

18. Conclusions

    EPA fully  considered  all of  the  information submitted by  the  device
    manufacturer, in, .the application.   The evaluation of  the  "Sav-A-Mile".
    device was based  on  that information.  While thorough mixing of  fuel
    and  air  and  even distribution  of  the  mixture  will  enhance  the
    combustion process, there is  no  evidence  that  the use of  "Sav-A-Mile"
    device will result in any significant improvements  over an unmodified
    engine.. . Therefore,--based...on EPA's  experience with  similar  devices,
    there  is  no reason to  support  any  claims  for  improvements in  fuel
    economy  or exhaust  emissions  due  to  the  use  of   the  "Sav-A-Mile"
    device.

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                                 11
                           List of Attachments

Attachment A              Letter,  EPA  to  Mr.  Mike   Rucker   of   Energy
                          Managers of America, May 1, 1981.

Attachment B              511 application from Mr.  Mike Rucker  of  Energy
                          Managers of America, May 11, 1981

Attachment C              Letter,  EPA  to  Mr.  Mike   Rucker   of   Energy
                          Managers of America, June 10, 1981.

Attachemnt D              Letter,  EPA  to  Mr.  Mike   Rucker   of   Energy
                          Managers of America, July 7, 1981.

Attachment E              Letter, Mr.  Mike  Rucker  of  Energy Managers  of
                          America to EPA, July 23, 1981.

Attachment F              Letter,  EPA  to  Mr.  Mike   Rucker   of   Energy
                          Managers of America, August 13, 1981.

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                                       12
 Slay 1, 1981
 Mr. MiV.e Hucker       .
 iihergy Managero of .America
 11407 l-'esc 48th Avenue
 Wheat Kidse, CO  S0033
-Dear 
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                             13
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  be'.ween tests.   If  installation  of  the
device also involves some adjustments,  e.g.  timing,  fuel-air mixture,
choke  or idle  speed,  another test  sequence  with only  these  adjust-
ments  should  be  inserted between  the  first  and  last.  If  mileage
accumulation  is necessary in order  to  realize the  full  benefit,  the
same number of  miles that are  accumulated  before the test  runs must
also be  accumulated  before baseline runs.   In addition,  the  method of
mileage  accumulation should be  kept  constant.  Also  as  a minimum,  the
test  sequence shall  consist  of a hot-start LA-4  portion  (bags  1  and
2)  of the Federal  Test Procedure  (FTP) and  a Highway  Fuel  Economy
Test  (HFET).   The  details   of  these   tests  are   contained  in  the
enclosed packet.   Although  only a  hot-start  FTP  is  required  to min-
imize  the  costs  to you,  you  are  encouraged  to   have  the  entire
cold-start test -performed since any testing  and  evaluation  performed
by  EPA will  be  based on  the  complete  FTP, and you may  wish  to know
how a• vehicle'withr'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  instal-
lation of the device.

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

Cost  of   the  Testing  -  The  c'ost  of   the  minimum test   plan  (two
vehicles, two test  sequences  in duplicate) described above  should be
less  than $2000 per  vehicle and  less  than $4000 for  the  total  test at
any  of  the  laboratories on  the list.   It  should be  recognized that
additions  to  the  minimum test  plan (such  as mileage  accumulation,
parameter  adjustment,   or  additional testing) will  result  in  addi-
tional  costs.   In  any case,  you  will have  to  contact them  indi-
vidually to obtain their latest prices.

Outcome  of  the   Tests  - In  order   for  EPA  to  best  utilize our fac-
ilities,  confirmatory testing will  only be  performed 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 con-
sidered  encouraging.  These values  have been  chosen to assure  both of
us  that  a real  difference in  fuel economy exists,  and that we are not
seeing only the variability  in  the  results.  The  table below presents
the minimum number of cars that  need to be  tested for varying degrees
of  fuel  economy improvement,  assuming a typical amount  of variability
in  fuel  economy measurement.   For a minimum  test plan which was con-
ducted on  a  fleet of two cars,  the average  improvement  should  be at

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                                 14

    least 8%.  If.  at  least  an'8% difference  in average fuel economy  can
    be  shown,  then we  would be able  to s.iy  statistically at  the  80%
    confidence level that there  is a real improvement.

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

         Minimum Fuel Economy Improvements versus Size  of Test Fleet

         Fleet Size                   Average  Improvement Required
              2                                  8%
              3                                  7%
              4                                  6%
              5                                  5%
             10             .                     4%
             25                    '2%

Once we  receive your application, it will be  .reviewed to determine  if it
meets the requirements listed in the format.   If your application  is  not
complete, we will  ask  you to submit further  information or  data.   After
any  missing  information  has been  submitted,  your application  will  be
reconsidered, and once it meets  our requirements,  you will be advised of
our  decision  whether or  not EPA will  perform  any confirmatory  testing.
Any EPA testing will be performed at no cost  to you and  you will  be given
the opportunity to concur with our  test plan.  Once this testing is com-
plete,  an evaluation report will be written.  If  no  further testing  is
required, the report will be written solely on  the basis  of the test data
submitted and our engineering analysis.

Despite  the current  backlog and  increasing number of  inquiries regarding
fuel  economy  device evaluations, the .EPA  intends  to process your  appli-
cation  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.

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)  668-4200.  Please  contact me  if  you
have any questions  or require any further information.

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

Enclosures

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                                 May 11, 1981


  1.      Application for Evaluation of a Fuel Economy Retrofit .
         Device Under Section 511 of the Motor Vehicle Information
         and Cost Savings Act.

  2.      Trade Hame:  Sav-A-Mile

  3.      a)    "Frank Cook • "'  ':
               Rt. 4  Box 1
               Ft. Mill, SC  29715

         b)    Patent Enclosed
  4.      a)    Plastic Products
        	"•	Hi Way 161
               Bessemer City, NC  28106

         b)    Dana Corporation
               Division of Victor Products
               P. 0. Box 1333
               Chicago, IL  60690

  5.      a)    Henry Baxter
               Plastics Products'
               Hi Way 161    .
               Bessemer City, NC  28106.-

         b)    Dana Corporation •
               Division of Victor Products
               P.O. Box 1333
               Chicago, IL  60690

  6..     Energy Managers of America
         11407 W. 48th Ave
         Vfaeatridge, CO  80033

  7.      a)    Ray V/ickstrom - Chairman of the Board

               Mike Rucker - President

         b)    Mike Rucker
11407 WEST 48TH AVENUE-SUITES - WHEAT RIDGE, COLORADO 80033 • (303)420-2831

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                      1.6

a)    The device designed is to fit between the carburetor
and manifold of an internal combustion engine in order
to increase fuel efficiency, engine efficiency and reduce
pollution emissions.  The device functions both to reduce
evaporation of fuel from the carburetor by providing an
insulating block between the carburetor and the manifold,
and to increase evaporation and atomization of the fuel
prior to burning, by passing the fuel through a heat
conductive wire mesh screen. .

b)    The Sav-A-I-lile is comprised of a piece of cloth
made out of copper or other heat conductive material which
is placed on the intake manifold of an engine in such a
manner that the fuel mix must pass through the cloth to
enter the manifold.  The outer edges of the cloth maintain
close proximity to the metal portion of the manifold so
that it may readily receive the heat produced at and around
the flahg of "the"manTfbrd and "conduct the heat into the
center of the cloth, wherein the heat can be transmitted
to the fuel mixture as it passes through the cloth.
The- Sav-A-Hile further comprises of a flat piece of
insulating material placed between the solid portions of
the carburetor to insulate the carburetor from the heat
generated at the manifold and to create a large resevoir
of heat for use by the cloth.  The insulating piece is
so shaped as to conform with the shape of the flang of
the carburetor and to cause no interference to the flow
of fuel mixture from the carburetor into the manifold.

c)    Detailed description of the invention.  V7ith
reference to the drawings, a standard double throat
carburetor has been employed for the description, although
the device is suitable for use upon carburetors with any
number of throats.  The device; includes a flat sheet of
insulating material (11).  the insulating material (11)
should be heat resistant, of good strength, impact
resistant and able to withstand the pressure of being
tightly bound between the carburetor (15) and the manifold
(16), more particularly between the manifold flange (20)
and the carburetor flange (19). ..Grade C phenolic with
cnavas base in laminated sheets has proven to be a
satisfactory material for the insulating material although
equivalent materials may be employed.  The thickness of
the insulating materail- (11) should be large enough to
provide adequate insulation for the carburetor (15) but
the thickness is limited in practice by the mechanical
consideration of being able to fit the device into existing
engine compartments,  A thickness of 3/8 inches has been
found to be the optimal size although higher thicknesses
should produce better results where their use is possible.
The insulating material (11) is of the same shape as the
flange (19) of the carburetor'(15)with which it is in
contact including centrally located passageways aligned
with the throats (10) of the carburetor (15) to allow

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 the  insulating material  (11)  is  interposed betv/een all
 contact points of the  carburetor (15) and manifold (16) .
 to insure adequate insulation of the carburetor  (15) and to
 prevent heat  dissipation from the manifold (16).
       Between the insulating  material (11) and the flange
 (20)  of the manifold  (16)  is  placed a sheet of mesh cloth
 (12)  composed of copper  or other heat conducting material.
 The  optimal material  for the  mesh cloth  (12) has been     • .
 found to be square mesh  wire  cloth made  of pure copper.
 The  optimal demensions of the cloth (12) have been found
 to be 40 meshes per lineal inch,  with a  wire diameter of
 .010 inches,  an opening  width of 0.150 inches providing 36
 percent of open area.  Equivalent materials may be used
 that are highly conductive, heat resistant, resistant of .-
 corrosion, and that have the  proper ratio of open area.
 to area of contact in  order to maximize  fuel atomization
 •and  vaporization while minimizing interference- to flov/  	
 of fuel into.the manifold (16).   The outside edges of.
 the  mesh cloth (12) are  so shaped to align with the contact
 portions of the carburetor (15)  and the  manifold (16) and
 the  cloth (12) is so  placed as to cause  all fuel mixture
 flowing from  the carburetor (15)  to the  manifold, (16) to
 pass through  the cloth (12).
       Betv/een the flange of the  carburetor (19) and the
 insulating material (11),  betv/een the insulating material
 (11)  and the  cloth (12), and  betv/een the cloth (12) and
 the  manifold  flange (20) are  placed gaskets (13) made of
 asbestos or other material as are commonly used in.the
 field to insure a tight  and leakproof seal betv/een the
 components.   All the  components'^are provided with openings  •
 (17)  aligned  with the  openings of the carburetor (21) and
.the  mainfold  (22) through which  bolts (18) or equivalent
 connecting devices may pass.   The components are drawn
 tightly together according to the specifications for the
 engine being  used.
       When in place and  the engine is running, the invention
 provides for  insulation  for the  carburetor (15) by means of
 the  insulating material  (11)  from the heat generated in.
 the  area of the manifold (15).  The mesh cloth (12),
 whose outer edges are  in close proximity to the manifold
 (16)  and the  heat normally generated there, conducts the
 heat into the center  of  the mesh cloth (12) where it nay be
 transmitted to the fuel  mixture  just prior to the mixture
 entering the  manifold (16) causing the mixture to be more
 completely atomized and. vaporized.  The  steady flov/ of fuel
 through the center of the cloth  (12) rapidly removes
 the  heat creating a large thermodynamic  differential between
 the  center and outer  edges of the cloth  (12), thus
 encouraging the steady flov/ of heat toward the area of
 contact betv/een the cloth (12) and the fuel.
       V/hile the preferred embodiment of  the invention is
 described herein, it  is  to be understood that the
 invention is  not limited to the  precise  sonstruction herein

-------
                             18
10.

11.

12.

13.


14.

15.
modifications coming within the scope of the invention
as defined in the appended claims.  As previously dis-
cussed, the device can be adapted to any type of carburetor
merely by insuring that all throats of the carburetor are
matched by passageways in the insulating material.
      What I claim is:
      1.  A device to be mounted between a carburetor
and an intake mainfold of an internal combustion engine
to prevent premature fuel evaporation and improve fuel
atomization and vaporization comprising:
      a)  means for insulating said carburetor, from heat
transmitted from said manifold, and;
      b)  means for simultaneously passively intro- ..
ducing said heat into said fuel and stomizing said fuel
by impact.
      2.  A device to be mounted between a carburetor
and an''intake manifold of an internal combustion engine
to prevent premature fuel evaporation and improve fuel
atomization and vaporization comprising:
      a)  a flat sheet of heat resistant insulating material
having passageways equal in size and aligned with the
throats of said carburetor, said insulating material being
attached.to the flange of said carburetor by tight and
leakproof means, and;
      b)  a flat piece of meshed, heat conducting material
mounted transversely to the flow of said with one side
attached to said insulating material by tight and leakproof
means and one side attached to the flange of said manifold
by tight and leakproof means.
      3.  The device in Claim 2 wherein the said insulating
materail- is somprised of grad C .phenolic.
      4.  The device in Claim 2 wherein the said meshed
material is- somprised of wire cloth made of copper.

See attached APPLICATION CHART

See attached INSTRUCTION SHEETS FOR EM4002-U and EI14004-U'

See attached Instruction sheets

None

Data will be forthcoming upon completion of the Air
Quality Resources Board of California's test.

DOES NOT APPLY

See attached letter from Cummings Carolina.  More data
will also be forthcoming upon completion of the Air
Quality Resources Board of California's test.

-------
                                     n69 WEST OAKLAND AVENUE
                                             SUITE C
                                 .  BOCK HILL SOUTH CAROLINA 29730

                                 January  14,  1WO

        IN THE UNUED SlA'iES PAlEN'i AND URADEM/IlK OFFICE
                       -7roJ?»s"c-7>  «
In re Application of:             ' &/3~j>

Frank Cook                O>^-proup: R.Unit 342
                               \6^S  ''
Serial No. 06/051,982            	•>

Filed: June 25, 1979

For:  Fuel Efficiency Device


TO:   1HE-COMMISSIONER OF PA'iENiS &  iRADEMARKS

Sir:

        Since 1 have  received no correspondence concerning the above
referenced patent since its filing,  I  was concerned that perhaps an
office response had been lost  in the  mail.   I would  appreciate it if
you could inform me  of the present  status of this Application.

                                 Respectfully  submitted,
                                  W. Ry
                                  Registration  No. 28860
WRH/gw
 Action on the abo?e  identified application is  to be ^xpected
 .. ..

-------
                          20
  V.b'B WEST OAKLAND AVENUE
          SUITE C

ROCK HILL SOUTH CAROLINA 29730


June 21,  1979
In the  United States Patent
& Trademark Office
Washington, D.C. 20231

To: The  Commissioner of Patents and Trademarks

Sir:  Transmitted herewith for filing is the patent application
of Inventor: Frank  Cook.
            •
         Enclosed are:

         1   sheet of drawings
         9   pages of specifications
         2   pages of oath and power of attorney
         check  in the amount of $75.00 to cover filing fee

                                 Respectfully submitted,


                               ••/*/
                                 W.  Ryan Hovis
                                 Registration No: 28,860

WRH/gw

Enclosures

-------
                           21



                   FUEL EFFICIENCY DEVICE



               ABSTRACT OF THE DISCLOSURE



        A  device  designed to fit between the' carburetor and



manifold of internal combustion engines in  order to increase



fuel efficiency, engine efficiency, and reduce pollutant  emissions.



The device  functions both to reduce evaporation of fuel from  the



carburetor by providing  an insulating  block between the carbure-



tor and the manifold and to  increase vaporization and  atomization



Of the  fuel prior to burning  by  passing the fuel through a  heat



conducting  wire mesh screen.



             BACKGROUND OF  THE INVENTION



        There are two principle causes for  the failure of present



day internal combustion  engines to completely  burn the fuel intro-



duced  into  the engine.   First   a considerable quantity  of fuel is lost



through evaporation as the  fuel is  introduced into  the warm car-



buretor.  Second,  there tends to be  incomplete burning of the fuel



due to the  failure of the fuel to be completely  atomized and vaporized.



        The complete burning of the  fuel is handled in the prese.it



invention by interposing  a wire mesh cloth between the carburetor



and the intake manifold  in such a  manne^  that  the fuel mixture must



pass through the cloth to enter the manifold.  The  impact of the fuel



mixture against the cloth serves to more completely atomize the fuel



droplets.   In addition, the  cloth is made of a  highly conductive



material which transmits engine and manifold  heat  to the  fuel mixture



                               1

-------
                        22
as it stHkcs the cloth thus  evaporating the droplets into  vapor.




The  heat  supply to the cloth is increased by  means of the insul-




ating material  discussed below.  After passing through the cloth the  fuel




is thus in a gas,  rather than a liquid  state, and will be  burned



more efficiently.




        The problem  of fuel evaporation  from the carburetor  is




remedied  by placing a layer of insulating material  between the cloth



and the solid portions  of the carburetor.   The carburetor is thus




insulated  from  engine heat,  remains  cooler,  and causes less fuel




evaporation.  Moreover, the insulation helps  prevent heat dissipation



from the  manifold and thus  creates a larger  reservoir of heat  to



be used by the mesh cloth.
                                 •.



        Several inventions have attempted to  achieve energy saving




and pollution prevention results  by  placing devices  between the car-




buretor and  intake manifold.  The patent to  Larson No.  3,449,098




teaches the use of a foraminus material to increase atomization and




mixing.   It does not,  however,  employ the use of a heat conductive




material to increase evaporation  nor  does it  involve insulation  of the




carburetor in combination with the  foraminus material.  The patent

                                          *

to Goldman No. 2,657,123 teaches  the use of wire,  screen in con-




junction with rotating  propellers.  Again, the invention does not




provide for heating the mixture  nor for insulating the carburetor.

-------
                           23
The patent to Burwinkle ct  al No.  3,459,162 teaches the use of
foraminus plates,  rather than mesh,  and  provides  for  heating the
mixture by passing engine exhaust through passageways in  the  plates.
The patent to Ramey No. 2,701,557 again teaches  the  use  of screen
or mesh between the carburetor and the manifold for atomization but
does not employ heating for evaporation nor does it  employ insulation
of the  carburetor.   The patent to  Henderson No. 3,088,447, designed
to decrease pollutants, employs heating of the fuel mixture but teaches
heating by means  of electrical  resistance or recycling of the exhaust.
        The  patent to Chandler No. 2,085,574 teaches insulation  of
the carburetor, but not by  means  employed herein and not in  com-
bination with the mesh cloth  designed to heat the fuel mixture.   The
patent  to  Balfe No. 2,072,862 teaches insulation of the carburetor by
means different from  those employed herein and not in combination
with the mesh cloth designed to heat the  fuel mixture.
        The advantage of the present invention over those  enumerated
above  is that the  present invention ccrrbines  the beneficial  effects of
insulation of the carburetor with the beneficial effects  of passage
of the  fuel mixture  through the  mesh cloth in order  to atomize the
fuel,  and further  to heat and vaporize the fuel by  heat conduction.
Furthermore  the present invention  operates in a purely passive
manner requiring no outside  heating or other devices and can  be  simply
                             3

-------
                           24                                       -V



and easily installed between the carburetor  and intake manifold



without alteration to the manifold,  the carburetor,   or other parts



of the engine.




                   SUMMARY  OF THE INVENTION



         The present invention pertains to a device to be placed



between  the  carburetor and intake  manifold  of  an internal combustion



engine with the purpose of increasing the efficiency of fuel usage



of the engine and decreasing the amount  of  air pollutants generated



by the engine.  Th2 invention is comprised  of  a  piece  of  cloth



made out of copper or other heat conducting materials which is




placed on the intake manifold  of the  engine  in such a  manner that




the fuel  mixture must  pass through the cloth to enter the manifold.



The outer  edges of the cloth maintain close proximity to the metal



portions  of the  manifold  so that it  may readily receive the heat pro-



duced at and around the  flange of the manifold  and conduct the  heat



into the  center  of the cloth, wherein the  heat can be transmitted ro



the fuel  mixture as it  passes  through the  cloth.  The  invention further



comprises  a flat piece of insulating material placed between the



solid  portions of the carburetor to  insulate the  carburetor from  the



heat  generated at the  manifold and  to create -a  larger  reservoir  of



heat  for  use by the cloth.  The insulating piece is  so shaped as to



conform  to the  shape  of the flange  of the  carburetor and to cause  no



                             4

-------
                                                                  •1.
                       25
interference to the flow  of fuel mixture from the carburetor into

the manifold.

                  BRIEF DESCRIPTIONS OF THE DRAWINGS

        One embodiment of the invention will be described below

with reference to  the accompanying drawings in which:

        Figure 1  shows an exploded perspective view of th; device

as it would be placed  between the carburetor and the manifold.

        Figure 2  shows a cross-sectional  side  view  of the device

along the  line  2.-2 of Figure 1 as the device is in place  between

the carburetor and the manifold.

           DETAILED DESCRIPTION OF THE  INVENTION

        With  reference  to the drawings, a  standard double throat      «

carburetor has been employed for'the  description,  although the  device

is suitable for use upon carburetors with any number of throats.   The

device includes a  flat  sheet of insulating material 11.  The  insulating

material  11 should be heat resistant, of good strength,  impact resistant,

and  able to withstand the pressure of being tightly bound between the

carburetor 15  and the manifold 16, more particularly between the mani-

fold flange 20  and the carburetor flange 19.  Grade  C phenolic  with

canvas base  in laminated sheets has prpven to be a  satisfactory material

for the insulating  material although equivalent  materials  may be employe

The thickness  of the insulating material 11 should be large enough  to

                             5

-------
                          26
provide adequate insulation fo  the carburetor 15 but the thickness

is limited in practice by the mechanical considerations of being able

to fit the device into existing engine  compartments.   A  thickness of

3/8 inches has  been  found to be the optimal size although higher

thicknesses  should produce better  results whsre their use is  possible.

The  insulating  material  11  is of ths same shape as  th::  flange  19 of

th:: carburetor 15 with which it is in contact including centrally

located passageways  aligned  with  the throats 10 of the carburetor 15

to allow the  free  passage of the fuel mixture.   In other words, ths

insulating material 11 is interposed between all contact  points of the

carburetor 15  and manifold  16. to  insure adequate  insulation of  th?

carburetor 15  and to prevent  heat dissipation from the manifold 16.

         Between the  insulating material 11  and the flange  20  of the

manifold 16  is placed a shset of mesh  cloth 12  composed  of  copper

or other heat conducting material.  The optimal material  for the mesh

cloth 12 has been found to be square mesh wire cloth made of pure
                       i
copper.   The optimal dimensions  of the cloth 12 have been found  to be

40 meshes per lineal inch,  with a wire diameter of  .010  inches, an

opening width of 0.150 inches providing 36 percent of open area.

Equivalent materials may be used that  are highly  conductive, hsat

resistant, resistant to corrosion,  and that  have the  proper ratio of

open  area to area of contact in order to maximize fuel  atomization  and

                              6

-------
                           27
vaporization  while minimizing interference to flow of fuel  into the

manifold 16.  The outside edges  of the mesh cloth 12 are so shaped

as to align with the contact portions  of the carburetor 15  and the

manifold 16 and the cloth 12 is so placed as to  cause all  fuel mixture

flowing from the carburetor 15 to the manifold 16 to pass through the

cloth 12.

        Between  the flange of the carburetor 19 and the insulating

material 11, between  the insulating material  11  and the  cloth 12,  and

between the cloth 12 and the manifold flange  20  are placed gaskets 13

made of asbestos or other material as are commonly used in the

field to insure a tiglh and leakproof  seal between  the components.

.All the components are  proviujd  with openings  17 aligned  with the

openings of the carburetor 21 and the manifold  22 through which bolts 18

or equivalent connecting devices  may pass.   The components are

drawn tightly together according  to the specifications for the engine

being used.

        When in place anJ tha engine is  running,  the invention provides

for insulation for thj  carburetor  15 by means of the insulating -material 11

from the  heat generated  in the area  of the? manifold 16.  The mesh

cloth 12,  whose outer edges  are  in close proximity to the manifold  16  -

and  the heat normally generated  there, conducts  the  heat, into the  center

of the mesh  cloth 12 where it  may be transmitted to the fuel mixture

                             7

-------
                          29    .
just prior  to. the mixture  entering the manifold 16 causing the mixture

to be more completely atomized  and  vaporized.   The  steady  flow

of fuel through  the center of the cloth 12 rapidly removes the h-at

creating  a large thernodynamic differential between  the  center  and

outer edges  of the cloth 12,  «hus encouraging the steady flow of heat

toward the area of contact between the cloth  12  and  rlr  fuel.

         While the preferred  embodiment of the invention is  described

herein,  it  is to be understood that the  invention is  not limited to  the

precise construction  herein disclosed and ths right  is  reserved to all

changes  and  modifications coming within the scope of  the invention

as defined  in the appended claims.  As previously discussed,  the

device can be adapted to any type of carburetor merely  by insuring

that  all  throats of the carburetor are matched by passageways in
                                                                    f •
the insulating material.    '

         What I  claim is:

         1.   A  device to be  mounted  between  a carburetor and an

intake manifold  of an internal combustion engine to prevent premature

fuel  evaporation and  improve fuel atomization and vaporization com-

prising:

         (a) means  for insulating  said carburetor  from heat trans-

mitted from  said manifold, and;

         (k) means  for simultaneously passively introducing said  heat

into  said fuel and atomizing said  fuel by impact.

                             8

-------
                           29.
        2.   A device to  be mounted between  a carburetor anJ an
intake  manifold  of an internal  combustion engine to prevent premature
fuel  evaporation and  improve fuel  atomization  and  vaporization com-
prising:
        (a) a flat sheet of haat  resistant insulating material having
passageways equal  in size  and ali jned with the throats of said car-
buretor, said insulating material being attached to the flange of said
carburetor by tight and leakproof  means, and;
        (b) a flat piece of meshed,  heat conducting material  mounted

transversely to  the flow  of said fuel with one  side attached to said
insulating material by  tight and  leakproof means and  one side  attached
to the  flange  of said  manifold  by tight and  leakproof means.
        3.   Th2 device in Claim  2 wherein the said  insulating material
is comprised of grade C phenolic.
        4.   The device is Claim  2 wherein th= said  meshed  material
is comprised of wire cloth made of copper.

-------
 STATE OF SOUTH CAROLINA)
 COUNTY OF YORK            )
         As  the below named inventor, bc-ing duly sw;>rnt  I ik-|x»sc
 and  say that:
         My  residence,  post  office address and citizenship are stated
 bolow  nsxt to my  name; that
         I verily believe I  am  the original, first  and sole inventor
 of th- invention entitled: Fuel  Efficiency Device described and  clrimed
 in the attached  specifications;  that
         1 do njt know and do  not believe the  same  was ever known
 or usoJ in tin; United States  of America before my  invention'thereof,
 or patented or described in any printed publication in any country
 before my invention thereof for more than one year  prior  to this
 application,  that the same  was not in public use  or  on sale in  the
 United States of America, more than  one year  prior  to  this application,
 that  the invention has not been patented or made  the subject of an
 inventor's  certificate  issued before the date of this  application  in  any
 country foreign  to  the United States of America on an application  filed
 by me or my legal representative or  assigns  more  than twelve  months
 prior to this application, that I acknowledge-my duty ro disclose in-
 formation of which I am aware which is  material  to the examination of
 this  application,  and that no  application for patent or inventor's certificate
on this invention has been  filed in any country foreign to the United
States  of America prior to  thio application by  me  or my legal  represent-

-------
arivcs or  assigns.



        I hereby appoint  the  following  attorney to prosecute this



application and to transact ail business in the Patent anJ Trademark



Office connected therewith:  W.  Ryan Hovis,  Registration No. 28,860.



Address  all telephone  calls to W.  Ryan Hovis at telephone  number



803-324-1122.



        Address all correspondence to W. Ryan Hovis,  1169 W.



Oakland Avenue, Suite C, Rock Hill,  South Carolina  29730.   .



Full name of  sole inventor: Frank Cook



'Inventor's  Signature:	



Date:	



Residence:
Citizenship:
Post Office  Address:
Sworn to  and  subscribed before me this 	 day of



1979.
                              Notary Public for South Carolina



                              My Commission  Expires:	

-------
32

-------
                Cummins
                Carolines
                Inc.
33
      Emco Corp.
      Fort Mill,  S.C.
                                         January 15, 1980
      Gentlemen;

           We dyno  tested  the  1979 Concord DL Vehicle without the use of a
      gas saving device and with it.  We find that the 'Save' a mile1
      carburetor plate increased milage by a 6 miles per gallon average on
      our chassi dyno.
           During the test the carbon and hydro carbons dropped from
      C0%2£ HC5 to  C03>4%  HC2  1/2.
3700 NORTH INTERSTATE 85 • P. O. BOX 26603  • CHARLOTTE. N. C. 28213 • 704/596-7690

-------
                               3'4
                     \AVl
7LE
             INSTALLATION INSTRUCTIONS
 CAFiejRETOR  BASE
   CASKET
  EM4002S-F-G
      PART  NO: EM4002-U
     2 EMCO
       INTERNATJONAL
       CORPORATION
    Use SAV-A-MELE
   and wear a smile
Ift-ii;?! *'h P.O. BOX 613, FORT MILL.
       SOUTH CAROLINA 29715

-------
                                       35
                        INSTALLATION INSTRUCTIONS

                                   FOR

                                SAV-A-MILE

 (Pi)  1.  Retime air cleaner and attaching hoses.
     2.  Disconnect fuel line and vacuum hoses to carburetor, making sure
         you know where vacuum  lines are to be reconnected.
     3.  Remove carburetor attaching bolts or stud nuts.
     4.  Remove carburetor, making sure to clean mating surfaces on
         intake manifold and carburetor.

NOTE;  On engine equipped with  BGR plate, between intake and carburetor,
       the BGR plate should be  removed and old gaskets cleaned from
       surfaces of both intake  and EGR plate.


 (B)  1.  Mew place laminated gasket and screen assembly on models having
         BGR plate between BGR  plate and intake manifold. On all other
         models, the gasket-screen assembly should be placed directly
         on the intake manifold.
     2.  Now place one gasket on top surface of BGR plate, then place
         spacer block and another gasket on top of block.
     3.  Replace carburetor.

NOTE;  On seme models, it will  be necessary to back out existing studs
       about a quarter-inch;. On scene GM models, longer bolts (supplied
       in kits for those models) will be necessary.


 (C)  1.  After carburetor has been installed and secured, be careful
         to re-install all vacuum hoses properly. Also be sure to  '
         torque down bolts and  stud nuts to recommended pressure.
     2.  Crank engine, check for vacuum leaks and smoothness of idle.
     3.  Replace air cleaner and attaching vacuum lines and hoses.
     4.  At this time, a road test should be made to insure proper
         running of the vehicle.

NOTE: After a  few hours of running, recheck the torque on the stud
      nuts or  bolts to ensure the carburetor is seated properly to
      prevent  any vacuum leaks.


     PRIOR TESTING HAS PROVEN BEST RESULTS WERE ATTAINED AT SPEEDS
     NXW EXCEEDING THE NATIONAL HIGHWAY SPEED LIMIT. DRIVE 55 mph
     STAY ALIVE, AND LET SAV-A-MILE SAVE FOR YOU.

     Thank you for buying SAV-A-MILE and tell a friend

        (See reverse side for installation diagram)

-------
 ^
     rbfft: P.O. BOX 613, FORT MILL,
           SOUTH CAROLINA 29715
                                                                                                          36
                                                                         EM1001-U
                        EM4004-U
                        EM4004-UC
                                     TERMS AND POLICIES
Ordering—When ordering, use part number only.
Shipping—All orders will be shipped by UPS or other common carrier unless otherwise specified.
Special Application—Contact EMCO International Corp.
Invoices—Invoices will be mailed the same date products are shipped to distributors. All deliveries will be made C.O.D.
Returns—Written or verbal permission must be obtained from EMCO International before returning any merchandise for credit. All returns must be
        prepaid.
Claims—All claims for loss or damage must be made to Carrier.
Prices—All orders are subject to state and federal taxes where applicable. All prices are subject to change without notice.
Defective Merchandise—Full credit or replacement will be given for any unit returned defective, with the exception of the following:
                    (1)-No aerosols must be used following installation of the Save-A-Mile unit.
                    (2)-Any screen damage.
                     'The Sav-A-Mile unit is warranted for the life of the installation as there are no products used in its construction that will
                     wear out.
EMCO International reserves the right to make changes in  its Sav-A-Mile unit at any time to improve the product.
This warranty limits any implied warranty, and no other person, company, or organization is authorized to assume for
EMCO International any other liability in connection  with the sale of the Sav-A-Mile unit.
(Some states do not allow limitations on how long an implied warranty lasts. This limited warranty gives you specific
legal rights, and you may also have other rights which vary from state to state. If you need assistance, contact your
state's Consumer Affairs Office.)

         EMCO  INTERNATIONAL CORP.  WARRANTY
           EMCO International warrants that all  of its products are free from defects in material workmanship. All EMCO
           products are subject to the conditions established in this policy.
           1. EMCO warrants that when Sav-A-Mile units are property installed in their correct application they will be free from
              defect.
           2. Due to the variety of modifications made on all engines that may affect performance economy for engine life,
              EMCO's obligation  under this warranty is limited to the repair or replacement of the Sav-A-Mile Unit.
           This warranty begins on the date of purchase by the consumer. This warranty will be void on any Sav-A-Mile unit that
           shows evidence of misapplication, improper installation, abuse, lack of proper maintenance, negligence, or alteration
           from their original design.

-------
                                                                       APPLICATION  CHART
Year
Model
Bbl.    Mfg.  Our No.
            AMERICAN'MOTORS
     8 Cylinder
1963       196                1   M
1960-70     196.232. Eng. PiP      2   C
1960-79     196.199.232.258 Eng  I   H
     1 Cylinder
190079     250.287.290.304.327.
          343.401            4   C.ll
          360 Eng.            2   C.H

                    BUICK
     6 Cylinder
1962-63     198,215Eng.         1   fl
196465     225. 250 Eng.         1   R
196667     198.225 Eng.        ' 1   R
1908-79     250 Eng.            1   R
     8 Cylinder
1962-63     le Sabre            2   R
1964-67     300.340 Eng.         2   C. R
1966       340 Eng.*-AT (CalH)    2   R
1966-73     3SO. 400. 425. 430.
          (455) Eng.           4   C. R
1968-79     350 Eng.            2   R
                          EM1001-U
                          EMI002U
                          EM1001.U
                          EM4004-U
                          EM4002-U
                          EMI001-U
                          EMI001-U
                          EMI002-U
                          EMIOOI U

                          EM20Q2-U
                          EM2002 U
                          EM2002-U

                          EM4004-U
                          EM2002-U
1967-79    All
     4 Cylinder
1972-74
                  CADILLAC
                             4   C.R  EM4004-U
                    CAPRI
                             2   H
                                     EM4002-U
 CHEVROLET (Camaro, Chevclle, Chevy II
           /Nova, Corvette, Vega)
     6 Cylinder
 1963-79    194.230.250 Eng.      t   C.R
 1964-67    327 Eng.             4   H
 196569    307.327.396.427 Eng.  4   H
 1966-68    263.327 Era.         2   R
 1966-69    302. 392 Hi Perl Eng     4   H
 1967-69    427Eng.(400-435hp|    2   H
 1968-79    327.350.396.400.402.
          427.454 Eng.         4   C.R
 1968-71    307 Eno.             2   R
 1969-71    327.350. 396. 400 Eng.  2   R
 1972-79    307Eng.             2   R
 1970-79    350. 396. 402. 454 Eng.  4   II
 1972      350.400 Eng.         2   R
 1973-79    350.400Eng.         2   R
 1969-71    7-28                4   H
                           EMIOOI-U
                           EM4000-U
                           EM4000-U
                           EM2002-U
                           EM4000-U
                           EM4002-U

                           EM4004-U
                           EM2002-U
                           EM2002-U
                           EM2002-U
                           EM4000-U
                           EM2002-U
                           EM2002U
                           EM4000-U
              COMET/MONTEGO
      6 Cylinder
 1969-79     250Eng.
     . 8 Cylinder
                   1   C.M  EM1001-U
 1969-79
 1963-71

 1972-79
 1972-79
302 Eng.             2

         COUGAR
260.289.302.351.390
Erg.                2
302 Eng'.             2
351.390 Eng.         2
             CHEVROLET TRUCK
                                 M   EM4002-U
            EM4002-U'
            EM4002-U
            EM4002-U
      4 & 6 Cylinder
 1963-79    194.230.250.292 Eng.
      8 Cylinder
                   1   C.R.  EM100I-U
0 Mf
1960-67
1966-79
1967-79
1968
1968-79
1068-79
196970
265.283.
348. 350.
356 Eng.
396 Eng.
307 Eng.
427 Eng.
350. 396.
322. 327 Eng.
366 Eng.
. 402 Eng.
2
2
4
2
4
C.R.
R
H
H
R
H .
C.R
EM2002-U
EM2002-U
EM4000-U
EM4002-U
EM1002-U
EM4000-U
EM4004-U
                                                      Year
                            1960-79

                            1967-71
                            1967-72
                            1972-79
                                                      Model
                        Bbl.   Mfg.   Our Ho.
                                                     Year
           Model
                                          Bbl.    Mlg.   Our No.
                                                                                                                                                                Year      Model
                                                                                                                                                                               Bbl.    f.
CHRYSLER & IMPERIAL
360. 361. 383. 400Eng. 2   C.H.
                      S.B
383 Eng.            4   C.H
440 Eng.            4
400 Eng.            4
                                            1973-79    410 Eng.
                               C.H

                               r
                               (TO)
                                    EM2002-U
                                    EM4000-U
                                    EM4000-U

                                    EM4004-U

                                    EM4004-U
            DODGE PASSENGER
     6 Cylinder
1960-79    195.225 Eng.         1  C
1960-79    225 Eng.            1  H
     8 Cylinder
196079    273.318 Eng.         2  C.R
1960-79    360. 361. 383.400 Eng.  2  C.H.
                               S.B
1968-71    350.383 Eng.         4  C.H
1971-72    400 Eng.            4  H. C
1972-79    3-10,360.400 Eng.     4  C

1973-79    440 Eng.
                                                                           (TQ)
EM1001-U
EM1001-U

EM1002-U

EM2002-U
EM4000-U
EM4000-U

EM4004-UC

EM4004-UC
                                                           DODGE TRUCK
                                                 6 Cylinder
                                            1961-79    196. 225 Eng.
                                                 8 Cylinder
                                            1960-79    273.318.361 Eng.     2  C. S
                                            1960-79    361 Option. 383.400    2  C.H
                                            1960-79    413 Eng.            2  S
                                            1960-79    413 Eng.            4  C.H
                                            1960-79    413 Eng.            2  H
                                            1972-79    360.400.440 Eng.     4  C
                                                                           |TO)   EM4004-UC
                                                                                   1   C.H  EMIOOt-U
                                                                  EM1002-U
                                                                  EM2002-U
                                                                  EM2002-U
                                                                  EM4000-U
                                                                  EM2002-U
                                          FAIRLANE/TORINQ
6 Cylinder
1969 250 Eng. 1
1969-79 250Eng. 1
H
C.M
EMIOOI U
EM100I-U
8 Cylinder
1962-71
1972-79
1970-71

260. 289. 302. 351 Eng. 2
351.390. 400 Eng. 2
302. 351CEng. 2
FALCON
M
M
F

EM4002-U
EM4002-U
EM4002-U

8 Cylinder
1963-70
260. 289, 302 Eng. 2
H. M
EM4002-U
             FORD PASSENGER
     6 Cylinder
1965-69    240Eng.(Exc.w/S.T.
          68-69)              1  H    EM1001-U
1965-79    240 Eng.            t  C.M EM1001-U
     8 Cylinder
1963-72    260.289.302.351.
          351C. 351W. 390. 400.
          429 Eng.            2  H. M EM4002-U
1965-79    352.390,428.427.429
          Eng.               4  H.M EM4000-U
                            4  R    EM4000-U

                                    EM4002-U
                                    EM4002-U
                                    EM4000-U
                                       Eng.               <
                             1970       429 Eng.            I
                             1973-79    35IC. 351.390.400.429
                                       En}.               2   M
                             1972-79    302 Eng.            2   M
                             1974-79    w'C(Cililonry)       4   C
                                                            6 Cylinder
                                                       1974-79    200 Eng.
                                                           FORD BRONCO
                                                                         i   c
                                                            8 Cylinder
                                                       1966-79    289.302 Eng.         2   M.H
                                                                                 EMI001-U

                                                                                 EM4002-U
                                                                                                                      EM4002-U
                                                                                                                      EM4002-U

                                                                                                                      EM4002-U
                                                                                                                      EM4002-U

                                                                                                                      EM4000-U
                FORD TRUCK
     6 Cylinder
1964-69    240.262.300Eng.     1   H    EM1001-U
1964-79    240.250.262.300Eng. t   C.M  EMI001-U
     8 Cylinder
1960-79    292. 302. 330. 332. 352.
          360.361.390Eng.     2   M
1960-69    292.302 Eng.        2   H
1962-79    330.332.353.360.361.
          390Eng.            2   H
1968-71    302Eng.            2   H
1970-75    360.390.401.477.534
          Eng.               4   H


                GMC TRUCK
     4&6Cylinder
1960-63    351. 401. 478 Eng.
1961-69    30SC.D&EEng.
1964-70    230.250. 292 Eng.
1965-69    351.351C.351E£ng.   2
1970       305C.351CEng.w/CCS 2.
1972-79    230.250.292 Eng.
     8 Cylinder
1968-79    327.350. 396. 400. 455
          Eng.
1968-73    307Eng.
1969       366.427Eng.
1969-73    350Eng.
1971-79    350.366. 427Eng.
1973-79    GMC Motor Home
1972       350Eng.
1974-79    350 Eng.

                 IHCTRUCK
1966       B0282. BG241 Eng.
1966       V239Eng.
1966.69-79 RD450Eng.
1966-79    V266.V304.V345.V501

1968       V304.BG220.265Eng.  1
1966-79    V549Eng.
1968-79    RD406Eng.
1969-71    V304Eng.
1969-79    196.232, 358 Eng.
1969-79    V392Eng.
1969-79    RD50I Eng.
1970      V549.V220.VF200Eng.  4
1970-71    V402.V461.478Eng.
1972-79    V478Eng
1972-79    V40I Eng.

                 JEEP CORP.
1962-65    230Eng.
1964-79    225.226. 230, 232.258

1966.67.71 22l 304 Eng.
1968.70.71 350 Eng.

                   LINCOLN
1960-62    430 Eng.
1963-72    430.460.472 Eng.
1973-79    460 Eng.
2
2
|
2
2.
t
4
2
4
2
4
4
2
2
it/
K
i
4
2
2
1
4
2
2
1
4
4
4
2
4
4
in
IP.
2
1
2
2
4
4
4
S
s
C.R
S
S
C.R
C.R
R
H
R
H
R
R
R
H
H
H
H
H
H
'H
C
H
H
H
H
H
H
H
H
R
R
R
C
C.M
C.U
EM1002-U
EM1002-U
EMI001-U
EM2002-U
EM2002-U
EM1001-U
EM4004-U
EMI002-U
EM4000-U
EM2002-U
EM4000-U
EM4004-U
EM2002-U
EM2002-U
EMIOOt-U
EM4000-U
EM4002-U
EM4002-U
EMIOOt-U
EM4000-U
EM4002-U
EM4002-U
EM100I-U
EM4000-U
EM4000-U
EM4000-U
EM4002-U
EM4000-U
EM4000-U
EM2002-U
EM1001-U
EM4002-U
IM2002-U
EM4002-U
EM4000-U
EM4600-U
                                                                                                                   MAVERICK
                                                           6 Cylinder
                                                      1971-79     250Eng.
                                                      1073-79     250 Eng.
                                                           8 Cylinder
                                                      1971-79     302 Eng.
                                                                                                                                 C
                                                                                                                                 M.C
                                                                                                                       EMIOOt-U
                                                                                                                       EM100I-U
                                                                                                               2  M    EM4002-U
                                                                                       MERCURY
                                                                     1960-71    292.351.352.390.400.
                                                                               429 Eng.             2   C.
                                                                     1960-62    352 Eng.             2   H
                                                                     1961-79    352.390.410.428.429
                                                                               Eng.                4   H.
                                                                     1971-79    351.400.429 Eng.      2   M
                                                                     1970-79    351.390.400.429 Eng.  2   H
                                                                     1970      429 Eng             4   R
                                                                     1971-79    429,460 Eng.         4   M
                                                                                                               6 Cylnder
                                                                                                          1969-79     250 Eng.
                                                                                                                                                                        MUSTANG
                                                                                                                                                                   i  c
                                                                                                               8 Cylinder
                                                                                                          1965-71     351.400.429 Eng      2  M
                                                                                                          1965-79     260.289.302 Eng.     2  M
                                                                                                          1966       289Eng.            4  M
                                                                                                          1969       302 Eng.(Boss)       4  H
                                                                                                          1970-79     429CobriEng.        4  R
                                                                                                          1970       302 Eng.            2  H
                                                                                                          1970       351CEng.           2  H
                                                                                                          1972       302.351WEng.     .  2  H
                                                                                                          1972       351CVspclbore       2  H
                                                                                                          1972-79     351.404.429 Eng      2  V

                                                                                                                          MUSTANG II

                                                                                                                                      2  H

                                                                                                                          OLDSMOBILE
                                                                                                               6 Cylinder
                                                                                                          1964-79     225,250 Eng.         I  C
                                                                                                          1963-73     330. 350. 394. 400. 425.
                                                                                                                    455Eng.            2  C
                                                                                                          1966-79     330.350. 490. 425. 455
                                                                                                                    Eng.               4  C
                                                                                                          1972       350 Eng.            2  R
                                                                                                          1974-79     350 Eng.            2  R
                                                                                                                                            4 Cylinder
                                                                                                                                       1974-79
                                                                                                                                                            PINTO
                                                                                                                4 Cylinder
                                                                                                           1971-79                       2  f

                                                                                                                PLYMOUTH (Barracuda,
                                                                                                                6 Cylinder
                                                                                                           1960-79    225 Eng.             1   C
                                                                                                           1970-79    225 Eng.             1   H
                                                                                                                6 Cylnder
                                                                                                           1962-79    273.316Eng.         2  C
                                                                                                           1963-79    360.36t.383.400Eng  2  C
                                                                                                           1966-79    273.350.383 Eng.     4  C
                                                                                                           1967-79    413.426.440 Eng.     4  C
                                                                                                           1971      318Eng.             2  R
                                                                                                           1972-79    340.360.400 Eng.     4  C
                                                                                                           1973-79    440 Eng.             4  C

                                                                                                                  PONTIAC (Firebird, Ten
                                                                                                                6 Cylinder
                                                                                                           1964-79     215.230.250 Eng.
                                                                                                                                                                                             1  C
                                                           8 Cylinder
                                                      1963-73    326.350.389.400.455
                                                                Eng.               2  C
                                                      1966-79    350.400.428.455 Eng. 4  C
                                                      1969       350 Eng.
                                                                (Tempest-Firebird)      2  H
                                                      1971       307Eng.            2  R
                                                      1972       307 Eng.            2  R
                                                      1972       350 Eng.            2  R
                                                      1974-79    350 Eng.            2  R

                                                                     THUNDERBIRD
                                                                312Eno.            4  H
                                                                                                                                                                 1957-60
                                                                                                                                                                 1981-72    990.428.429.460
                                                                                                                                                                 1970-79    429CobrUeiEng.
                                                                                                                                                                                   4  r

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                                        38'
May 14,  1981
Ilr. :'LLke tucker
iin^r^y ilana^ars of America
il'iO? Waet <43tU Avenuo
Vacdt iUJ^e, ^°  "0033

Oaar :-lr. iluckeir:

I as  sorr/  ttiau a list  of irKiopcndeiit  laboratories was  not  iiicludeu  in
our ;Lry 1, 1931 mailing to you.

TtKi laboratory  iis!: is enclosed s*ith this  lectar.

Sincerely,
Marrill W. Korth
uavics Evaluation Coordinator
Test, and Evaluation Lranch

Enclosure

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  \        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                          ANN ARBOR. MICHIGAN  48105                         39
June 10, 1981                                                   AIR. NOISE AND RADIATION
Mike Rucker
Energy Managers of America
11407 W. 48th Avenue
Wheatridge, CO  80033
Dear Mr. Rucker:

We have reviewed your recent  application  for  an evaluation of the "Sav-A-
Mile"  fuel  economy retrofit  device.   Following are two comments  on your
application:

    1.  -There  is  reference  made to  tests  being  run by  California  Air
         Resources Board  but  there is no mention of the  test  plan.   Any
         testing performed in support  of  an application for an EPA evalu-
         ation  should be  based on a test plan approved by EPA.   This is
         to ensure that the test  plan  will  adequately  evaluate the device
         and that the results will be acceptable to us.

    2.   The  test  results  from  Cummins  Carolines, Inc.  are  inadequate
         from  an evaluation  standpoint.   It  does  not appear that  the
         tests  were  conducted in accordance in the current  Federal  Test
         Procedure as  described  to  you  in my letter  of  May 1.  In  any
         case,  complete  test  data from each  test should  be  supplied  and
         they should include all "before and after" tests run.

We hope these comments are helpful to  you in conducting  a  test  program to
evaluate  Sav-A-Mile.   We  are looking forward to  reviewing  the  results
from  the  testing being performed  at the  California Air Resources Board.
We are  also expecting your test  plan for an  evaluation at  a  laboratory
which we have recognized.  We are prepared to help you  develop this plan.

In order to process applications  for EPA  evaluations more  efficiently, we
have  established a  schedule  for  each.   On this basis,  I  ask that  you
respond to  this  letter by June 30 and to  plan on submitting  test  results
from  an EPA recognized  laboratory by July 13.   Please contact me if  you
have any questions.

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

-------
         UNITED STATES ENVIRONMENTAL PROTECTION /-G-ENCY
                                                                            40
                        ft.NN ARBOiA. '-I! r.H'GAN  ifi'.Oi-
                                                                    OITF ::E OF
July 7, 1981                                                  Ai.?. NCIEE AND RAOiATSON
Mr. Mike Rucker
Energy Managers of America
11407 West 48th Avenue
Wheatridge, CO  80033

Dear Mr. Rucker:

In my  letter to  you of June  10, 1981,  I explained  the  requirement  for
testing  of  "Sav-A-Mile" by  an  independent  laboratorary  recognized  by
EPA.   I also asked  for the  submittal of  a  tent  plan  at  that  time.   I
requested  that  you  respond to  my letter  by  June 30, 1981.   We  have  not
received your response.   Since  you have not supplied EPA with appropriate
test  data  for  "Sav-A-Mile",  we  have  insufficient  data to  support your
claim for  its fuel economy benefit.

Under the  provisions of  Section  511  of  the Motor Vehicle Information  and
Cost Savings Act,  EPA is required to-  evaluate  your additive on the  basis
of available information and  publish the results of our evaluation  in  the
Federal Register.

We have begun to  prepare  our  report.   Please  contact  me  immediately if
you  do not  understand  this  course  of  action.   My telephone  number is
(313) 668-4299.

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

-------
''  'p^A fV'    "•	N/l_JL_TV_A
 ^^^l '£NEBGY MANAGERS 01 AMERICA
                                                                      41

                                      July  23,  I'-.'01

      I-!r.  Ilerrili \1.  Xorth
      Device Evaluation Coordinator
      Test  and Evaluation Branch
      United States Environmental Protection  Agency
      Ann  Arbor, MI  43105

      Dear Merrill;
           Concerning your letter of July 7.  Due  to  some conflicts,
      we have been going in- too many directions at once  in our company
      and  I.was  forced to go to our office  in Hawaii  and was unable
      to answer your letter of June 10th.   Please  find enclosed
     .the  test data we have received from Custom Engineering Performance
      o.nd  Emmission Laboratory.  Our tests  there will be .continuing
      concerning a fuel consumption test and  concerning  testing of
      other vehicles.  I hope you will  accept this preliminary data.
      The  laboratory in California is having  a  hard  time finding a
      4 cylinder engine which will comply with.  California specifications,
      I will be  sending you other information as soon as I receive it.
                                      Sincerely yours,
                                      Ilichael  Hucl:er
                                      President
      Enclosure        A/CT£:  /Jo
                           lOi 4<
    11407 WEST 48TH AVENUE - SUITE B • WHEAT RIDGE, COLORADO 80033 • (303)420-2831

-------
                                                  i.--a                 .
                                       )iUi
-------
                                 °  '            • •   - • -     -; '••- ?/ 7
                                tub2 Osvi  t^iai^cichii-iib              43
           Performance  and  Emissions Laboratories
                                     -Idle HC from I50ppa to 90ppo
             The test vehicle uas then scheduled for testa  with the device.
             The results of these tests are shown on attachment I.  The  emission
        results for hydrocarbons  (HC), carbon monoxide(CO),  carbon dioxide(00^),
        and oxides of nitrogen, corrected for huaidity(No  ) are reported
                                                     wCC
        in gracs per mile (g/mi).  Fuel Economy  reported as miles per  gallon
         'M?G) is calculated using the carbon atom balance method as per
        CEl 4-0.
             The test results were obtained using the described test vehicle
        and no inference should be made as to how other types of vehicles
        cay perform under similar conditions, A continuation of this
        program is scheduled which will involve  a 4-cyl engine as soon
        as the vehicle has been procured.
                                             K.L. Downing, General laager
                                             Custoa En gin se ring
         ;.C./Billy  Closson
7091-A BeloravR AVR                ^714^ R91-S704                Garden Grove. Ca. 92641

-------
                              i 3 3 fT "s* ?"». H '•')  7" ?• ? f> ? > ' y*
                                  )I
          Performance  and Emissions Laboratories
                              Attachaent I

                           1979 Ford FIDO pick-up
                           302 C.I.D. u/ auto trans.
                           V.I.N.  F10GREC6669
                           Inertia Wt. 40001bs.
                           Odometer 51338
      75 FTP
•>
Baseline
W/ Device

1
1
HC

.38
.2
CO

7.
.2-

17
68
.CO
627.
619.
2
59
47

1
1
^x
.76
.73
F.
13.
U.
17

n
»
1
»

9

           % Difference
-63%
                   -1.7%
      HWFST
Baseline
W/ Device
.58
.6
.12
.1
465.64
449. S3
2.223
1.99
13.975
19.6
           % Difference
    -17^   -3.45    -10.5%
7091-A Belgrave Ave.
(714)891-5704
                   Garden Grove. Ca. 92G41

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                                                                                .45
            Performance  and Emissions Laboratories
                                    TESTING AGREEMENT

CE SALES ORDER S                                     DATE
    Agreement made this day  between  Custom Engineering Performance and Emissions	
Laboratories, hereinafter called  CF  and   /-'A- .'•'£ r*V'   /^~s"A'-£ ^r jT /<•".':. *\ ' '   ^ '•
	hereinafter called the "CLIENT".

1.   Tests       CE agrees under  the terms and conditions set forth herein  to perform
                 the following  testing program:

                 Miscellaneous  preparatory efforts -- including consultation time,
                 tune-up procedures, etc. — to enable definition of the extent. •_•:
                 testing to  be  done; followed by testing according to stipulated
                 dyno-CVS procedures, at the appropriate charges by prior mutual
                 agreement as specified in attachment (s) to this testing acreerer.t.

1.1  Time        The tests will be conducted, consistent with CE's prior comni—.ents,
                 as soon as  possible after this Testing Agreement is cor.plsted by
                 both CE and CLIENT.

2.   Charges     Service of  CE  personnel and equipment will be billed per atvar.-iCici
                 schedule.  Charges  will be based on each hour or fraction  thereof.
                 Services to be rendered are shown on the attachment to this ij: ••_•-
                 ment.

3.   r°rl£liJ-?_PJH  CE and CLIENT  incorporate the condition below into this nqre--- •••r-.t.

     CI.1K;;T agrees that no attempt at recovery of payment is to be bsr.ed on .'^ny
'jondit-i ons of the test vehicle  which would not characterize the Certified or stock
configuration which such vehicle  -represents unless such condition is specifically
provided for in this Agreement.   Any characteristic of the test vehicle which is
incompatible with the FTP (40 CFR 85) or the standard testing facility and  equipment
which CZ uses in the implementation  of the test procedures, or any result of such  a
characteristic which occurs  during the test sequences, will not justify recovery of
3.1  CE will furnish to the  CLIENT at  the expiration of this Agreement, three copies
     of ,-= written roport of  the test results.  A con-.puter printout analysis will  be
     considered the same as  a  written  report.  Additional reports or documentation
     will be provided for additional cost to be mutually agreed upon in advance.

3.2  CE agrees to hold the results of  these tests in confidence and to use its best
     effort to.assure that they are not divulged to any other party without authori-
     zation from the CLIENT  in writing.  CE makes no representations, nor assumes
     responsibility for any  results or information other than as they appear in the
     complete written report referred  to above.
7r,ni A D«I«,-,V,O AWO                 I7-\A\ R91-5704                 Garden Grove. Ca. 92641

-------
                                          46


3.3   C LIE N'T agrees not  to  use  the  CE  name  or  cxcc-rpts  from  the  report in connection
      vith any advertising  or  sales promotional  purposes  without specific prior
      approval of CE  in  writing.

3.4   CE agrees to use its  best effort to maintain  the  security  of  CLIENT'S device
      while in the possession of  CE and to  hold  in  confidence  confidential information
      disclosed to CE in writing-in order to facilitate performance of the tests.

3.5   It is agreed and understood that CE is acting as  an independent contractor in the
      performance of  any and all  work  hereunder  and shall be solely liable and responsible
      for the payment- of all legal  claims made by its employees  or  agents on account of
      any damages to  property or  persons arising out of or in  connection with the  per-
      formance of this Agreement.

3.6   In the event of  cancellation or alteration  of  this schedule by CLIENT, CE n: servos
      the right to assess a charge  to  recover  any losses  or  costs resulting fron. such
      cancellation or alteration.   The total charge shall not  exceed twenty percent (20%)
      of the estimated project  cost. ...          . .

4-    Pay-rent  CLIENT agrees to the following  method of payment:

               /  /  Cash in advance - Certified Check  £	___vir.c'   _       	.

                     Net upon, receipt  of invoice -  P.O. §	
5.    Special Conditions Testing  Special conditions and terras  to  this spe^i.:--  .:   ti-:~
                       .  .         Agreement are included in Attachment (2)  Lr  ^._ ..'•. -c:.L.*.

              ./7  Not Applicable

                    Applicable
6.    AUT-iCRIZATION  In witness thereof the parties hereto  set  their  hands:

      Client  /'/ •.?/•- £ /"    Si" ~'XK X'  '•/ ;^ A  .'^ /•.' ^~   SJ ''• •* '" "  ^

      Address

      City/Statf
                            ^^
        Da t e

        ?h or, e/Ar encode
      CUSTOM Ef.'GiriEEr.ING
      Performance and Eir.issions Laboratories
                       t
                          S' •                *
                   * •   ^ '     / '
        Signature   ''   -^ ,•
                 _           .
        Title ^ -i. -r^ T-+T /

        Bate    ,/.' '<:     v

-------
                       ANN ARSOR. MICHIGAN  -48105
August 13, 1981
47
                                                             OFFICE OF
                                                     AIR AMD WASTE MANAGEV1EN1
Mr. Michael Rucker, President
Energy Managers of America
11407 West 48th Avenue - Suite B
Wheat Ridge, CO  80033 ~
Dear Mr. Rucker:

I  have 'received  your  letter  dated  July  23,  1981.   Unfortunately,  it
appears  that  you are  having Sav-A-Mile tested  before submitting  a  test
plan to  us for comment  and approval.   As  I  emphasized  in my  letter  of
June 10,  any  testing performed  in support  of an  application for  an EPA
evaluation  should  be based  on  a  test  plan approved  by  us.   This is  to
ensure- -that  the... test—plan .will  adequately  evaluate  the_ device.   For
example,  in the  data supplied in  your  letter,  it  appeared that  only one
test sequence was  performed with and  without  your  device.   Because  of
test and  vehicle variability,  we1 insist on  duplicate test  sequences  at
each test point.  Also, data  supplied to us should be  complete,  e.g., bag
by bag analysis, and not  just the  final test results.  This  allows us  to
perform a more thorough evaluation. .

I must must inform you that Custom Engineering  is no  longer on  our  list
of recognized laboratories.  They have  not yet submitted  an application
in response to our new  requirements.   I am enclosing a current  list  of
recognized  facilities for your use in the future.

In  order  to  process  these  applications   in  a timely  manner,  we  have
established a schedule  for each.  Although  we are  now behind  schedule
with your  device, I  will  grant  you an extension until August 24  for  sub-
mission of  a  test plan to me.   By  September 15,  I  will expect the results
of testing  at a recognized  laboratory.   Please  contact me if  you have any
questions.  My telephone number is (313) 668-4299.

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

cc:  511 File  "Sav-A-Mile"

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