EPA-AA-TEB-511-83-8
EPA Evaluation of the Kamei Spoilers Under
Section 511 of the Motor Vehicle
Information and Cost Savings Act
by
Edward Anthony Barth
March 1983
Test and Evaluation Branch
Emission Control Technology Divison
Office of Mobile Sources
U.S. Environmental Protection Agency
-------
EPA Evaluation of the Kamei Spoilers Under Section 511 of the Motor
Vehicle Information and Cost Savings Act
The Motor .Vehicle Information and Cost Savings Act requires that EPA
evaluate fuel economy retrofit devices and publish a summary of each
evaluation in the Federal Register.
EPA evaluations are originated upon the application of any manufacturer
of a retrofit device, upon the request of the Federal Trade Commission,
or upon the motion of the EPA Administrator. These studies are designed
to determine whether the retrofit device increases fuel economy and to
determine whether the representations made with respect to the-device are
accurate. The results of such studies are set forth in a series of
reports, of which this is one.
The evaluation of the "Kamei Spoilers" was conducted upon the application
of the manufacturer. It is a plastic spoiler (or air dam) that is about
six inches high and extends the width of the vehicle. The spoiler is
installed beneath the front bumper to reduce the flow of air under the
front of the vehicle. The device is claimed to reduce the aerodynamic
drag forces retarding a vehicle and thereby improve fuel economy.
1. Title:
Application for Evaluation of Kamei Spoiler Under Section 511 of the
Motor Vehicle Information and Cost Savings Act
The information contained in Sections two through four which follow was
supplied by the applicant.
2. Identification Information;
a. Marketing Identification of the Product:
.KAMEI
b. Inventor and Patent Protection:.
(1) Mr. Karl Meier
Kamei GmbH & Co
Postfach 100539
Heinrichswinkel 2
3180 Wolfsburg II
West Germany
(2) Patent-A copy of the patent was not provided
-------
c. Applicant;
(1) Kamei USA, Inc.
300 Montowese Avenue
North Haven, Connecticut 06473
(2) Mr. Joseph J. Mongillo, President
Mr. Uwe Meier-Andrae, Vice President
Mr. Klaus Meier, Treasurer
(3) Mr. Ralph Hansen or Mr. Robert E. White are authorized to
represent Kamei USA, Inc. in communication with EPA
d. Manufacturer of the Product:
(1) Kamei USA, Inc.
300 Montowese Avenue
North Haven, Connecticut 06473
(2) Mr. Joseph J. Mongillo, President
Mr. Uwe Meier-Andrae, Vice President
Mr. Klaus Meier, Treasurer
3. Description of Product;
a. Purpose;
"Reduction of fuel consumption
Decrease of aerodynamic drag coefficient"
b. Applicability;
(1) "Vehicle application information is included in the
attached pricing schedule and catalogue." The pricing
schedule was not supplied with the application but was
provided later. The models listed in Attachment A were
extracted from this catalog.
(2) "Product may be used under all driving conditions."
c. Theory of Operation;
"The addition of a Kamei spoiler to a known vehicle produces the
following effect: controls the amount of air that is allowed to
pass under the vehicle. This process reduces the amount of drag
caused by the air. In addition, by reducing the air volume you
reduce the amount of lift caused by the air. The air is passed
over the top of the vehicle, and directed around the side, this
additional air direction causes a downward pressure, again
decreasing lift over the front axis, and controls wind
-------
buffeting, giving the auto better road adhesion, safer handling,
less horsepower needed and more M.P.G. Please see wind tunnel
reports reflecting same." The applicant provided simplified
test reports on many vehicles. Attachment A summarizes the
changes in drag and fuel consumption from these reports and
Attachment B is a sample of one of these reports. These data
are further discussed in Section 5d(2).
d. Construction and Operation;
"Kamei spoilers are manufactured of top quality high impact
A.B.S., manufacturing processing is through a computer
controlled vacuum forming machine. This process controls
uniformity from item to item. Each spoiler is designed
specifically for the vehicle, taking into consideration
reduction of drag, lift, crosswind buffeting, crankcase, disc
brake, and radiator cooling. The spoiler fits exactly to the
fenders and valance of the specific auto. The unit comes
complete with mounting instructions and fastners. Average
installation time is 15 minutes. See pictures of header
cards." The 6 by 14-inch header cards identified the spoilers
and had the installation instructions printed on the reverse
side. The applicant subsequently provided samples of these for
55 vehicles.
e. Specific Claims for the Product:
"Wind tunnel testing provides the proof that Kamei front
spoilers decrease the lift coefficient and give your car a
better aerodynamic shape. This means your car will have more
road adhesion, lower cross wind sensitivity, and greater
directional stability. Kamei spoilers also minimize the air
drag coefficient which simply means higher driving performance
with less fuel consumption and an increased maximum speed."
f. Cost And Marketing Information;
Suggested retail price varies from $63.00 to J5176.00 depending
on the application.
"The product is marketed through warehouse distributors and then
to automotive jobbers/stores who sell to the ultimate consumer"
4. Product Installation, Operation, Safety and Maintenance;
a. Installation - Instructions, Equipment, and Skills Required;
"Installation Instructions Attached" Copies of the Installation
Instructions for 55 of the models were provided. A sample of
these instructions is given in Section 5c(l).
-------
b. Operation;
"Operating instructions are not necessary for this product.
c. Effects on Vehicle Safety;
"Safety with regard to this product is not a factor."
d. Maintenance
Maintenance was not addressed in the application.
The following sections are EPA's analysis and conclusions for this device.
5. Analysis
a. Identification Information;
(1) Marketing Identification;
Kamei is the marketing name for the products of the
company. The application included information and wind
tunnel test data on several different types of aerodynamic
devices for a vehicle (front spoilers, rear spoilers,
fender flares, side skirts, hood scoops, and sun-roof
deflectors). The application was clarified to apply only
to front spoilers (see Attachments C and D).
(2) Inventor and Patent Protection;
EPA requested a copy of the patent to aid our understanding
of the device (Attachment C). The applicant responded that
there were no open patents on the product (Attachment D).
(3) Applicant;
The applicant is the U.S. subsidary of Kamei GmbH and Co.,
the parent company (Attachment H).
(4) Manufacturer:
The spoilers are manufactured in both Germany and the U.S.
In the U.S., the devices are distributed by regional firms
that represent the manufacturer. .
b. Description:
(1) As stated in Section 3a, the purpose of the Kamei Spoiler
is to reduce the aerodynamic drag on a vehicle, thus
reducing the power required from the engine and thereby
increasing fuel economy. This is in agreement with the
theory of operation and design of the device.
-------
(2) The vehicle application list that was given in the catalog
adequately described the vehicles to which each model of
the device applied. Most of these were small vehicles.
(3) The theory of operation given in Section 3c is adequate,
sound, and brief. A more detailed discussion of the
aerodynamic effects and their influence on fuel consumption
is given in Section 5d(2).
(4) The spoiler is about six inches high and extends the width
of the vehicle. The spoiler weighs about five pounds and
is made of an ABS plastic that is capped with a matte black
material for protection from ultraviolet light. The unit
is paintable without special surface preparation or may be
left unpainted (Attachment D).
(5) In Section 3e, the applicant claimed the device would
improve the fuel economy and performance of a vehicle.
These claims are in agreement with the purpose, theory of
operation, construction and potential of the device.
However, no specific numerical improvements were claimed in
this section or in the product literature provided. The
test reports which were submitted (Attachments A and B)
summarize the changes in the drag and lift forces on a
vehicle when the spoilers are installed. These wind tunnel
tests also give an estimated improvement in fuel economy
and top speed.
(6) The new pricing schedule noted in Section 3b showed a
suggested retail prices which ranged from $107.00 to
$293.00.
The cost of installation should be less than $10.00 for
those users who have the device installed by a mechanic
(fifteen minutes labor at $30.00 per hour). However, as
noted in Section 5b(l), the installation is relatively easy
and most individuals with basic mechanical skills should be
readily able to install the device.
Installation, Operation, Safety and Maintenance:
(1) Installation - Instructions, Equipment and Skills Required:
The installation instructions are short and clear and are
specific for each vehicle. The instructions for a Datsun
240Z are given below and are typical.
"1. Level and align spoiler ends to wheel wells.
"2. Using holes in spoiler as a template, drill through
sheet metal with 9/64 bit.
"3. Secure spoiler with #10 plate screws and washers."
-------
The installation of a Kamei front spoiler on a Datsun 240Z
was examined by EPA. The spoiler was attached to the
valance (front splashpan) with six screws. The spoiler has
a groove that permits it to be readily aligned with the
valance for the drilling of the six mounting holes in the
vehicle.
The installation is simple and can readily be done by
persons with average mechanical skills. It will require
the use of only a drill and screwdriver and should take no
longer than 15 minutes claimed in Section 3d. The
installation does not require the removal of the valance or
parking lights (see Attachments C and D). The necessary
mounting hardware is provided with the spoiler. According
to the applicant, it is not necessary to reposition parking
lights or turn signals since each is designed to fit
without requiring changes (see attachments C and D).
(2) Operation;
Since the spoilers reduce the front end ground clearance,
EPA asked the applicant if this reduced clearance caused
problems with curbs or parking blocks (Attachment C). The
applicant stated that the installed ground clearance ranges
between five-and-nine inches with an average of eight-
inches. Also, the spoilers are designed to spring back
after a three-inch deflection and are made of an impact
resistant ABS plastic. If bent farther, the spoiler will
snap at the mounting hole, thus preventing structural
damage to the vehicle (Attachment D). Therefore, the
vehicle should not be damaged if the spoilers are damaged
by striking a curb and the spoilers will probably not be
damaged in normal vehicle operation.
(3) Effects on Vehicle Safety;
In Section 4c, the applicant made no claims for safety due
to the device and indicated safety was not adversely
affected. However, the test data showed that the addition
of the spoiler reduced the. aerodynamic lift on the front of
the vehicle. Thus, the safety of the vehicle is improved
since the changes in handling and directional stability
caused by the lift on the vehicle are reduced. Also, the.
applicant stated in Section 3c that the device controlled
wind buffeting and reduced lift.
The brochure for the spoiler stated that "Each spoiler has
passed the coveted West German T.U.V. Safety and
Performance Certification Test."
-------
8
(4) Maintenance;
The application did not address routine maintenance. In
response to our inquiry (Attachment C), the applicant
stated that the spoilers were maintenance free. We agree
with this statement.
d. Effects on Emissions and Fuel Economy;
(1) Unregulated Emissions;
The application did not address unregulated emissions. In
response to our inquiry (Attachment C), the applicant
stated that the device should have little or no effect on
these emissions. Since the device does not change the
emission control system of a vehicle, but only changes the
engine load a small amount, the device is judged unlikley
to adversely affect unregulated emissions.
(2) Regulated Emissions and Fuel Economy;
(a) Data Requirements
The applicant did not submit test data in accordance with
the Federal Test Procedure and the Highway Fuel Economy
Test. These two test procedures are the primary ones
recognized by EPA for evaluation of fuel economy and
emissions for light duty vehicles.* The fuel consumption
data provided were estimates based on the changes in drag
that were measured in the wind tunnel.
Normally, data of this nature are acceptable only for the
preliminary evaluation of a device. Furthermore, since the
changes listed are small, validation would require a large
number of FTP and HFET tests. However, since it has been
*The requirement for test data following these procedures is stated
in the policy documents that EPA sends to each potential applicant.
EPA requires duplicate test sequences before and after installation
of the device on a minimum of two vehicles. A test sequence consists
of a cold start FTP plus a HFET or, as a simplified alternative, a
hot start LA-4 plus a HFET. Other data which have been collected in
accordance with other standardized procedures are acceptable as
supplemental data in EPA's preliminary evaluation of a device.
-------
demonstrated that a change in road load could be correlated
with a change in fuel consumption, EPA determined that, for
this device, it would be appropriate to evaluate the device
based solely on substantiating wind tunnel test data.*
(b) Data Submitted
The test data submitted by the applicant consisted of 30
test reports, each similar to Attachment B.** These
reports give the percentage change in the drag force that
was measured in the wind tunnel and the calculated
percentage change in fuel consumption, generally one to two
percent. This limited summary of the test results does not
allow a person evaluating the spoilers to perform complete
review of the data. Therefore, EPA requested additional
test details, a sample of the complete calculations for one
vehicle that was tested and a copy of the calculations that
are used to translate the measured percentage change in the
drag force to an estimated percentage change in fuel
consumption (Attachments C and D).
The applicant supplied additional test reports and some
test details. However, the applicant did not supply all of
the necessary requested information (Attachment H).
Therefore, our analysis and evaluation was based on the
information supplied and our review of pertinent literature
(references 1 through 33).
(c) Wind Tunnel Testing
This literature showed that wind tunnel tests are a
reliable means of evaluating drag and lift forces on a
vehicle. The testing is repeatable and small changes in
*EPA analyzed the mpg sensitivity of several hundred 1975-78 vehicles
to changes in road load horsepower. The FTP and HFET showed
respectively, a -.16% and -.33% change in mpg for each percentage
change in road load, i.e., a 3% reduction in road load causes a (-3)
x (-.33)=!% improvement in mpg for the HFET (reference 23). Also
extensive work by Volkswagen has shown that a 3% reduction in drag
would result in approximately a 1% improvement in fuel economy for
the combined FTP/HFET (reference 15).
**These reports are summarized in Attachment A. Approximately forty
other similar test reports were also supplied. These test data are
not listed since they were for rear spoilers, front and rear spoilers
together, or other aerodynamic devices.
-------
10
these forces can be readily detected. The many test
facilities have correlated well with one another in tests
conducted on specially prepared correlation vehicles. The
drag forces measured in wind tunnel tests have been
duplicated in road tests. Also, the changes in drag force
have been correlated to changes in fuel consumption for
both the FTP and HFET driving cycles.
This literature also revealed that there are many details
of the testing that need to be considered when comparing
drag test results. Among these are:
(i) There is no standard wind tunnel test
procedure.
(ii) There are production vehicle differences in
drag force of up to four percent due to
production tolerances for trim, fit, and
finish.
(iii) The data from each wind tunnel are corrected
for ground plane, blockage, and other test
facility effects. The correction factors are
different for each tunnel and the magnitude of
these corrections can be as large as the
measured change in drag forces.
(iv) Small changes in apparently similar vehicle
configurations can appreciably affect the
results. Items such as the vehicle pitch
angle, ground clearance, external accessories,
tire size, wheel covers, radiator size, and
air-conditioned or non air-conditioned are
important to hold constant in comparing wind
tunnel results.
The literature contains several reports and articles on
front spoilers. This information shows that even small
changes, some barely noticeable, in the design of a spoiler
can greatly affect the drag force. Conversely, some rather
noticeable changes may not appreciably alter the drag. A
device such as a spoiler must have the proper height, and
location to achieve optimum benefits. Small changes in the
height and location can appreciably reduce the benefit .or
cause adverse effects. Each spoiler needs to be tested on
the specific vehicle for which it is designed. Thus, there
is no reason to expect an untested spoiler to reduce drag
and improve fuel economy because it is also possible the
opposite effect could occur.
-------
11
(d) Comments on Wind Tunnel Testing
The coefficient of drag, Cd, is the number popularized in
wind tunnel testing. However, the effect on fuel economy
is due to the drag force which is the product of the drag
coefficient, frontal area, and dynamic pressure. This
pressure is a function of vehicle speed and atmospheric
density. Therefore, a more meaningful comparison between
vehicles is to compare the product of frontal area and drag
coefficient.
The literature supplied by the applicant states that the
spoilers are wind tunnel tested on all vehicles for which
they are designed. This in fact was not always the case.
The basic shape used for one spoiler model may be used for
several vehicle models of one manufacturer and even for the
vehicles of other manufacturers. Not all of these
configurations have been tested. Therefore, because of the
sensitivity of aerodynamic devices to size, location, and
overall vehicle shape, there is no reason to believe that
one basic design will have the same effect on several
vehicles.
(e) Vehicle Design
The final consideration on the potential effectiveness of a
spoiler is the operating variables.
(i) The device will only improve fuel economy if
it is able to reduce drag. A vehicle with
poor aerodynamics, and thus high drag forces
may benefit more from the device than one
which is already aerodynamically sleek.
(ii) The vehicle manufacturers are now giving
greater attention to reducing vehicle drag.
Changes made to the front of a vehicle to
improve the aerodynamics will limit the
effectiveness of an aftermarket spoiler.
(f) Operating Variables
The effectiveness of a spoiler will depend on both the
percentage reduction in the aerodynamic drag force and
vehicle speed. At speeds above 35 mph, drag is the largest
retarding force.* Since drag is directly proportional to
the square of speed, it becomes an even larger percentage
of the retarding forces as speed increases. Therefore, a
spoiler will have a greater effect at highway speeds than
at urban speeds.
*These retarding forces are engine and drivetrain friction, rolling
resistance and aerodynamic drag.
-------
12
(g) Cost Effectiveness
The improvements in fuel economy due to the spoilers were
small, typically one or two percent. For a vehicle
initially achieving 30 mpg, and gasoline selling at $1.40 a
gallon, it would take over 125,000 miles to recover the
cost of a $100 spoiler if a two percent improvement were
achieved.
(h) Effect on Emissions
The small reduction in engine load, due to the reduced drag
forces, should have minimal effect on regulated emissions.
6. Conclusions
EPA fully considered all of the information submitted by the
applicant. The evaluation of the Kamei Spoilers was based on that
information and our engineering judgment. The overall conclusion is
that the Kamei Spoilers have the potential to improve the fuel
economy of some vehicles.
The amount of this fuel economy benefit depends on several factors.
The most important is the percentage reduction in the drag force due
to the spoiler. Vehicles for which the device is well matched will
likely experience an improvement in fuel economy. The second
important factor is the type of driving cycle. The device will be
more effective in highway driving than urban driving. Since a
typical improvement in fuel economy would be one or two percent, it
is unlikely the cost of the unit would be offset by fuel savings
during the life of the vehicle.
This reduction in engine load due to the spoilers (and small increase
in fuel economy) should have a minimal impact on emissions.
Installation is quick and simple and could be accomplished by most
owners.
FURTHER INFORMATION CONTACT: Merrill W. Korth, Emission Control
TechnologyDivision,Officeof Mobile Sources, Environmental Protection
Agency, 2565 Plymouth Road, Ann Arbor, MI 48105, (313) 668-4299.
-------
13
BIBLIOGRAPHY
1. Gross, Donald S. and William S. Sekscienski, "Some Problems
Concerning Wind Tunnel Testing of Automotive Vehicles", SAE Paper
660385
2. Beauvais, F.N. , S.C. Tignor, and T.R. Turner, "Problems of Ground
Simulation in Automotive Aerodynamics", SAE Paper 680121
3. White, R.G.S., "A Method of Estimating Automobile Drag
Coefficients", SAE Paper 680189
4. Ludvigsen, Karl E., "The Time Tunnel - An Historical Survey of
Automotive Aerodynamics", SAE Paper 700035
5. Goetz, Hans, "The Influence of Wind Tunnel Tests on Body Design,
Ventilation, and Surface Deposits of Sedans and Sports Cars", SAE
Paper 710212
6. Ohtani, Kenichi, Michio Takei, and Hikota Sakamoto, "Nissan
Full-Scale Wind Tunnel - Its Application to Passenger Car
Design", SAE Paper 720100
7. Hucho, W.-H, L.J. Janssen, and G. Schwarz, "The Wind Tunnel's Ground
Plane Boundary Layer - Its Interference with the Flow Underneath
Cars", SAE Paper 750066
8. Marte, Jack E., Robert W. Weaver, Donald W. Kurtz, and Bain Dayman,
Jr., "A Study of Aerodynamic Drag", NTIS Report No. PB-251 710
9. Hucho, W.-H., L.J. Janssen, and J.J. Emmelmann, "The Optimization of
Body Details - A Method for Reducing the Aerodynamic Drag of Road
Vehicles", SAE Paper 760185
10. Morelli, A., L. Fioravanti, A. Cogotti, "The Body Shape of Minimum
Drag," SAE Paper 760186
11. Carr, G.W., "Reducing Fuel Consumption by Means of Aerodynamic
'Add-On' Devices", SAE Paper 760187
12. Olson, M.E., "Aerodynamic Effects of Front End Design on Automobile
Engine Cooling Systems", SAE Paper 760188
13. Doberenz, Marvin E. and Bruce P. Selberg, "A Parametric Invesigation
of the Validity of 1/25 Scale Automobile Aerodynamic Testing", SAE
Paper 760189
14. Schenkel, Franz K., "The Origins of Drag and Lift Reductions on
Automobiles with Front and Rear Spoilers", SAE Paper 770389
-------
14
15. Janssen, L.J., and H.-J. Emmelmann, "Aerodynamic Improvements - A
Great Potential for Better Fuel Economy", SAE Paper 780265
16. Muto, .Shinri, and Tomo-o Ishikara, "The J.A.R.I. Full-Scale Wind
Tunnel", SAE Paper 780336
17. Bruce, D.L., "Determination of Automobile Aerodynamic
Characteristics, Low Speed Wind Tunnel Tests," Lockheed-Georgia
Co., for Environmental Sciences Research Laboratory, U.S.
Environmental Protection Agency, June 1978
18. Needley, Lloyd, "An Effective Aerodynamic Program in the Design of a
New Car", SAE Paper 790724
19. Cogotti, A., R. Buchheim, A. Garrone, A. Kuhn, "Comparison Tests
Between Some Full-Scale European Automotive Wind
Tunnels-Pininfarina Reference Car", SAE Paper 800139
20. Buchheim, R., R. Unger, G.W. Carr, A. Cogotti, A. Garrone, A. Kuhn,
L. I. Nilsson, "Comparison Tests Between Major European Automotive
Wind Tunnels", SAE Paper 800140
21. Yoshiyuki, Kazuhiko, Tatsuo Maeda, Michitoshi Takagi, and Mootoo
Yanagawa, "Datsun 280ZX - Integration of Aerodynamics and
Appearance", SAE Paper 800141
22. Hogue, Jeffery R., "Aerodynamics of Six Passenger Vehicles Obtained
from Full Scale Wind Tunnel Tests", SAE Paper 800142
23. Murrell, Dillard, "Passenger Car Fuel Economy: EPA and Road", EPA
460/3-80-010
24. Buchheim, R., K.-R. Deutenbach, and H.- J. Luckoff, "Necessity and
Premises for Reducing the Aerodynamic Drag of Future Passenger
Cars", SAE Paper 810185
25. Morelli, A., P. Nuccio, and A. Visconti, "Automobile Aerodynamics
Drag on the Road Compared with Wind Tunnel Tests", SAE Paper 810186
26. Costelli, A., A. Garrone, A. Visconti, R. Buchheim, A. Cogotti, and
A. Kuhn, "FIAT Research Center Reference Car: Correlation Tests
Between Four Full-Scale European Wind Tunnels and Road", SAE Paper
810187
27. Szigethy, Neil M., "Aerodynamics: Slippery Cars and Slippery
Numbers", Automotive Industries, December 1981, pp. 87-89
28. Simanaitis, Dennis, "Seeking Light at the End of the Tunnel, My Cx
is Lower Than Yours; or Is It?", Road and Track, August 1982, pp.
32-35
-------
15
29. Tremulis, Alex, "Tunneling Through the Ages, A Stylist Unearths Some
Gems of Aero History," Road and Track. August 1982, pp. 36-39
30. Del Coats, "Aero Estimation, Self Taught", Road and Track,
August 1982, pp. 48-50
31. Simanaitis, Dennis, "Our Day in the Tunnel", Dam the Wind, Full
Speed Ahead", Road and Track, August 1982, pp. 48-50
32. Roberts, Glenn F., and Axel B. Rose, "Detecting Small Differences in
Fuel Economy: Air Conditioning Versus open Windows", SAE Paper
820075
33. "Automotive Wind Tunnel Design, Test Results and Correlations",
SAE SP-515
-------
16
List of Attachments
Attachment A Kamei Front Spoilers - Availability and Summary of the Drag
and Fuel Economy Effects.
Attachment B Wind Tunnel Test Report.
Attachment C Letter of March 23, 1982 from EPA to Joseph Mongillo of
Kamei USA, Inc. requesting information missing from
application, clarification, and additional information.
Attachment D Letter of May 5, 1982 from Joseph Mongillo of Kamei USA,
Inc. to EPA responding to EPA request.
Attachment E Letter of May 17, 1982 from Joseph Mongillo of Kamei USA,
Inc. to EPA responding to phoned and written requests by
EPA for information.
Attachemnt F Letter of July 9, 1982 from Joseph Mongillo of Kamei USA,
Inc. to EPA providing wind tunnel data.
Attachment G Letter of October 4, 1982 from EPA to Joseph Mongillo of
Kamei USA, Inc. discussing information supplied by Kamei.
Attachment H Letter of October 18, 1982 from Joseph Mongillo of Kamei
USA, Inc. to EPA discussing test results submitted by Kamei.
-------
17
Attachment A
Vehicle
Audi
BMW
Cheverolet
Datsun
Dodge
Ford
Honda
Kamei Front Spoilers
Availability and Summary of Drag and Fuel Economy Effects
Model, Year
Fox, all
4000, 8/78-80 Sedan only
Coupe and 5+5
2002, all
320i, thru 1979
320i, 1980-81
528, 530i, all
Chevette, 1974-81
Camaro, 1974-77
Camaro, 1978-81
240Z, 260Z, up to 6/74
210, 1978-79
510, 1979
Maxima, 1981
310 GX, 1980
210, 1980
200SX, 1979-81
280ZX
260Z, after 6/74, 280Z
210, pre-1978
510, 1980
Colt, 1980 up
Omni, 4 door only
Front
Spoiler Test*
Part No. Vehicle
4 4231
4 4233
4 4234
4 4220
4 4221
4 4222
4 4600
4 4223
4 4540
4 4541
4 4542
4 4281
4 4282
4 4284
4 4516
4 4517
4 4518
4 4519
4 4520
4 4521
4 4522
4 4523
4 4545
4 4215
Escort 4 4255
Fiesta, all 4 4256
Mustang/Capri, 1979-81 4 4257
Escort/Lynx, 1980-81 4 4258
Mercury Capri II, thru 1978 4 4260
Civic, 1980 4 4273
1500, Civic, 1979 4 4274
Civic model 1200, only 4 4275
Accord, thru 1978 4 4276
Accord, 1979 up 4 4277
Percent**
Test Percent Change
Report Change Fuel
No. Drag Consumption
Audi 80, Type 82 23
Audi 80, Type 80 68
BMW 2002 2 dr.
BMW 3 series
BMW 3 series
BMW 3 series
BMW 5 Series
Simca Horizon 22
Escort 60
-5%
-5%
-1%
9%
6%
26
39
58
65
42
-5%
-3%
-2%
-2.3%
-2%
-1.7%
-1.1%
- .7%
- .8%
- .8%
-2.2%
- .4%
79 4dr Accord
-1%
- .4%
-------
18
Kamei Front Spoilers
Availability and Summary of Drag and Fuel Economy Effects (cont.)
Vehicle Model, Year
Mazda RX7, all thru 1980
323 GLC, 1979-80
626, 1979-81
GLC, 1981
Mercedes DB W123
Benz DB S123
Opel Ascona
Manta
Kadett
Kadett
Plymouth Horizon, 4 door only
Champ, 1980 up
Renault Le Car, all to 1979
15/17 Gordini
Subaru all to 1979
1980-81
Toyota S-R5, 1976-79, Sport Coupe
Celica, pre 1976
Celica, 1980-81
Corolla Sedan, 1980-81
Corolla, 1975-79Sedan/Wagon
Tercel, 1980
Corolla S-R5, Sport Coupe
Supra, 1979-81
Celica, 1976-77 only
Tercel, 1981
Celica, 1978-79
Volkswagen Super Settle, all
Custom Settle
Scirocco, all thru 1981
Dasher, 1979-81
Rabbit, w/o ducts, all +
P/U truck
Front
Spoiler Test*
Part No. Vehicle
Percent**
Test Percent Change
Report Change Fuel
No. Drag Consumption
4 4500
4 4501
4 4502
4 4503
4 4555
4 4555
4 4241
4 4243
4 4244
4 4246
4 4215
4 4535
4 4265
4 4271
4 4510
4 4511
4 4524
4 4525
4 4526
4 4527
4 4528
4 4529
4 4531
4 4532
4 4533
4 4534
4 4283
4 4210
4 4211
4 4225
4 4226
4 4232
4 4235
RX7
4dr Sedan
Wagon
Ascona
Manta
Kadett-C
Kadett-D
Simca Horizon
Renault 5
Celica Coupe
Super Settle
Scirocco
Scirocco
Passat
Rabbit
45
134
30
33
13
61
22
50
7
36
10
156
53
38
-1% - .3%
-2.8% -1.0%
-6.5%
-2% - .6%
-4% -1.4%
-6% - -2%
-4% -1.4%
-6% -2.2%
-8% -2 . 9%
-1% - .5%
-4% -1.5%
-3% -1.1%
-3.3% -1.2%
-7% -2.6%
-4% -1.3%
-------
19
Kamei Front Spoilers
Availability and Summary of Drag and Fuel Economy Effects (cont.)
Front
Spoiler
Vehicle Model, Year
Rabbit, w/ducts, all +
P/U truck
Rabbit, New Style,
twin ducts
Jetta, all
Test*
Part No.
4 4236
i*
4 4610
4 4250
4 4237
4 4570
Test
Report
Vehicle
Golf Cabriolet
Golf Sedan
Golf Sedan
Polo
Golf Sedan
Jetta
Percent**
Percent Change
Change Fuel
No. Drag Consumption
1
2
125
55
54
79
-3%
-4%
-3.3%
-1%
-5%
-2.4%
-1.1%
-1.4%
-1.1%
- .5%
-1.7%
*The tests were performed on the vehicles of the same configuration. The
differences in names between the applicable model vehicle and the test vehicle was
because usually a European version of a vehicle was tested, i.e., VW Golf is the
same as a VW Rabbit.
**Percent change in fuel consumption was not actually measured but was calculated
using VW's emperical equations to relate the measured change in drag to the change
in fuel consumption.
-------
ATTACHMENT B
20
TECHNISCHE ENTWCKLJUNG
TECHNICAL RESEARCH
WOLFSBURG
TESTREPORT
WINDKANAL
WIND TUNNEL
BERCHT NR. 4
REPORT NO.: ....?..
DATUM/ DATE: l.Q . 7.,. 7.9..
a. si/^0%
DIPL-ING. R. WIEBELS
VERSUCHSFAHRZEUG/TEST CAR:
. Hg.ncla.. Accord...'. 7.9.. Stuf enheck/notcabc
155 R 13
FRONTSPOILER/FRONT SPOILER
KAMEI Typ ...4...4277
GEPRUFT IN/TESTED IN: ...W.Qlf simrg
DATUM / DATE: 24 .04...1979
VERBESSERUNGEN DURCH SPOILER / IMPROVEMENTS BY SPOILER:
MINUS 1 %
PLUS 2 %
MINUS ..?./..4...%
1. VERRINGERUNG DES LUFTWIDERSTANDSBElWERTES .. Cyy"
DECREASE IN AERODYNAMIC DRAG COEFFICIENT ..CD":
2. HOHERE GESCHWINDIGKEIT ENTSPRECHEND GEWINN AN LEISTUNG.N
HIGHER TOP SPEED ADEQUATE TO INCREASE IN PERFORMANCE ..?"'
3. VERRINGERUNG DES KRAFTSTOFFVERBRAUCHS. ^B" BEMSCHTER BETRIEB
REDUCTION OF FUEL CONSUMPTION .JPC1: COMBINED DRIVING CONDITIONS:
4. VERRINGERUNG DES AUFTRIEBSBEIWERTES AN DER VORDERACHSE ,.CAV"
DECREASE IN LIFT COEFFICIENT ON FRONT AXLECLP"
MINUS 1?....%
AUFTRIEB/LIFT
YORN / FRONT
HINTEN/ REAR
SYMBOL
__
500-
25
50
75
100
-------
ATTACHMENT C 21
\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
? ' ANN ARBOR. MICHIGAN 48105
/
March 23, 1982 OFF.CE OF
AIR. NOISE AND RADIATION
Mr. Joseph J. Mongillo, President
Kamei USA, Inc.
300 Montowese Avenue
North Haven, CT 06473
Dear Mr. Mongillo:
We received your letter of February 25, 1982 in which you applied for an
EPA evaluation of the KAMEI Spoilers as a fuel economy retrofit device.
Our sample application format documents consists of three pages that
divide the application into five sections. Your application directly
addressed only sections 1 through 4d. I presume you did not have page 3
which covers maintenance, unregulated emissions, regulated emissions, and
fuel economy. Enclosed is a complete copy of our application format.
Our Engineering Evaluation Group has made a preliminary review of your
application and .has identified several areas that require additional
information prior to further processing. Our comments below address each
section individually.
1. Section No. 2b. - Please provide a copy of the patent in English.
2. Section No. 3c. - What are typical weights of the front spoil-
ers? Rear spoilers? Fender flares? Side skirts?
3. Section No. 3c. - Are the devices available in color or must
they be painted as a part of the installation?
4. Sections No. 3e. and 4a(l) - This section provided only a range
of costs but stated that a pricing schedule was attached to your
application. However, none was received.
5. Section No. 4a(l) - For which vehicles is the universal rear
spoiler, part no. 44410, applicable? For which vehicles is the
universal rear spoiler, part no. 44420, applicable?
6. Section No. 4b. - Your application stated that a copy of the
installation instructions was attached, however none was
received. Please provide a copy of t,he installation instruc-
tions for both front and rear spoilers.
7. Section No. 4b. - Is removal of a vehicle's front splash pan
required to install the front spoiler on any vehicles? Please
identify any vehicles.
-------
22
8. Section No. 4b. - Is it necessary to reposition parking lights
or turn signal lights on any vehicles to install the front
spoiler? Please identify any such vehicles.
9. Section No. 4c. - What is the installed ground clearance of tha
front spoiler? Are there any problems with ground clearance due
to curbs or parking blocks?
10. Section No. 4e. - Maintenance was not addressed, I presume this
was because you did not receive a full copy of the application
document. I assume no maintenance is required. Is this correct?
11. Section No. 5a. - Unregulated emissions was also not addressed.
I presume that you expect no effect on unregulated emissions.
Is this correct?
12. Section No. 5b. - Regulated emissions and fuel economy also was
not directly addressed although the enclosed test reports did
provide results of some wind tunnel testing. There are several
areas that need additional clarification or information.
a. The 29 test reports you provided are numbered 1 through
53. Report numbers 3, 11-19, 23, 24, 25, 29, 30, 31, 33,
34, 35, 37, 47, 49, 51, and 52 (24 reports) were not
included. Please provide a copy of these missing reports
as well as any which have been conducted more recently.
b. The information brochures you provided notes that the
spoilers are wind tunnel tested on all vehicles for which
they are designed. The test data you provided covered only
approximately one-third of the vehicles for which you sell
spoilers. Please provide the test data for all vehicles
and part numbers not deleted on the enclosed part number
listing.
c. The universal rear spoilers appear to apply to several
vehicles. Please provide the test reports for those
universal models identified in paragraph 6 not previously
provided (Reports 5, 6, 32, 40, 41, 43, and 44 were
provided with the application).
d. Please describe the wind tunnel testing with respect to:
(1) Replication of tests.
(2) Wind speeds.
(3) How lift is calculated.
(4) How drag is calculated.
(5) Sample calculation for a test report showing test data
for both baseline and spoiler configurations.
(6) Any data showing correlation of wind tunnel drag
results with chassis dynamometer fuel economy and road
fuel economy.
-------
23
e. You stated on page 2 of your Information letter of October
16, 1979 that "We determine fuel economy according to
Volkswagen-Research Division investigations for EPA
COMBINED CITY AND HIGHWAY DRIVING".
Please provide a copy of the applicable document(s) and
note any specific changes or simplifications that .are
incorporated for your use.
f. HaVe you done any fuel economy measurements under control-
led test conditions to determine the fuel economy benefits
of your spoilers? Please briefly describe any testing and
provide fuel economy results on each vehicle.
I realize that you may not be able to immediately supply all of the
information requested. However, in order that we may efficiently assist
you, I ask that you provide as much of this information as possible in
your reply and note when the remainder will be available.
This information will be necessary to further process your request for
evaluation. In order for us to conduct our evaluations efficiently, we
have established a schedule for each. I ask that you respond to this
letter by April 24. If you have any questions or require further infor-
mation, please contact me.
Sincerely,
Merrill W. Korth
Device Evaluation Coordinator
Test and Evaluation Branch
Enclosures (3)
-------
ATTACHMENT D
24
AUTO EXTRAS
P.O. 426 300 Montowese Ave. North Haven, CT. 06473
"Phone: (203) 777-6675 Telex 96-6468 "Kamei USA"
May 5, 1982
Mr. Merrill W. Korth
Environmental Protection Agency
Device Evaluation Coordinator
Tests Evaluation Branch
Motor Vehicle Admissions Lab
2565 Plymouth Road
Ann Arbor, Michigan 48105
Dear Merrill,
With respect to our conversation of May 3, 1982 and your
letter dated March 23, 1982. First I would like to thank
you for clarifying many points in question. I will re-
spond to each item of your letter.
Item I Section 2B
To the best of my knowledge there are no open patents on
the spoilers we are discussing.
Item II Section 3C
The average weight of our spoilers are approximately four
and a half to five pounds.
Item III Section 3C
The spoilers come in a matte black A.B.S. capped material
that is paintable without special preparation.
Item IV Section 3E & 4A
The average retail price of our front spoiler is approxi-
mately $ 100.00. We will forward a price schedule of same,
please note that the retail price is suggested and no one
pays full retail this is understood.
Item V Section 4A
We should forget about the rear spoiler application for now
this will be a separate project by it self.
Item VI Section 4B
We will supply header cards with instructions.
Worldheadquarters Wiesbaden/Germany Plants at Wolfsburg, Wittlich/Germany NorthHaven, Connecticut
-------
25
Mr. Merrill W. Korth -2- May 5, 1982
Item VII Section 4B
It is not necessary to remove the valance or other sheet
metal from the vehicle to install a spoiler, however if
the valance has been damaged many people remove it and
replace the damaged valance with a spoiler this is not
applicable on all vehicles.
Item VIII
No. Our spoilers are designed with consideration for
parking lights, etc.
Item IX Section 4C
The average ground clearance of our spoiler is 8 inches
there is no problem with curbs unless the vehicle has
been lower, however some ground clearance will run from
5 inches to 9 inches a 5 inch ground clearance spoiler
will hit a six inch curb however so will the undercarriage
of the vehicle. Our spoilers are designed to be not sen-
sitive after a three to four inch deflection they will
snap at the side mounting hole. This will eliminate any
structural damage.
Item X Section 4E
The A.B.S. material we use is U.V. stabalized by capped
material and leaves the spoiler maintenance free.
Item XI Section 5A
There should be little or no effect on emissions, however
considering the fact that the addition of a proper spoiler
will reduce fuel consumption and allow the vehicle to
travel with less resistance using less horsepower. One
might conclude less erni.ssions. .
Item XII Section 5B
A. Many of the new spoilers have not yet been put through
the wind tunnel, also some spoilers have been modified
and not yet retested, although all are designed to. meet
positive wind tunnel results. If necessary we will
leave out these spoilers yet to be tested, and submit
them when we have the test results.
B. We will supply the latest test reports on the additional
spoilers tested since our last report.
C. We will hold off on the rear spoiler as previously stated,
unless you feel it will be beneficial at this time.
-------
26
Mr. Merrill W. Korth -3- May 5, 1982
D. Item 1-6 Please see enclosed wind tunnel test report
explanation.
Merrill again I fully appreciate your time, consideration
and help on this program.
If we at Kamei can be of further assistance, please do not
hesitate to call us at (800) 243-1792.
Sincerely,
71?
Jose'ph J. Mongillo
President
JJM/nra
-------
ATTACHMENT D
27
AUTO EXTRAS
P.O. 426 300 Montowese Ave. North Haven, CT. 06473
Phone: (203) 777-6676 Telex 96-6468 "Kamei USA"
May 17, 1982
Mr. Tony Earth
Environmental Protection Agency
Device Evaluation Coordinator
Motor Vehicle Admissions Lab
2565 Plymouth Road
Ann Arbor, Michigan 48105
Dear Mr. Barth,
With respect to our recent conversation and request
for additional information. Enclosed please find
some additional and new wind tunnel test reports.
Also enclosed please find a list of our original
spoilers indicating what other spoilers are made
from the basic unit and a brief note of the reason
why we change the part numbers.
In the meantime I have requested the information on
item "E" and "F" of page three from Mr. Merrill W.
Korth's letter dated March 23, 1982. As soon as I
receive this information from Germany I will forward
it care of your attention.
Thank you again for your help and consideration in
this matter.
Respectfully,
KAMEI AUTO EXTRAS, INC,
Joseph J. Mongillo
-President
JJM/nra
cc: Merrill W. Korth
Worldheadquarters Wiesbaden/Germany Plants at Wolfsburg, Wittlich/Germany North Haven, Connecticut
-------
ATTACHMENT E
28
RJlnc
AUTO EXTRAS
P.O. 426 300 Montowese Ave. North Haven, CT. 06473
Phone: (203) 777-6676 Telex 96-6468 "Kamei USA"
July 9, 1982
Mr. Merrill W. Korth
Environmental Protection Agency
Test Evaluation Branch
2565 Plymouth Road
Ann Arbor, Michigan 48105
Dear Merrill,
With respect to our conversation of this afternoon
I am enclosing some additional wind tunnel testing
reports and procedures, as I mentioned the test re-
ports are in German and I can only hope you will
be able to evaluate the results.
When we receive the additional information that
addresses Item "E" of your letter dated March 23,
1982, I will forward it in care of your attention.
Thank you again for your time and patience on this
project.
Respectfully,
KAMEI AUTO EXTRAS,
Jcfseph J. Mongillo
President
JJM/nra
Worldheadquarters Wiesbaden/Germany Plants at Wolfsburg, Wittlich/Germany North Havea Connecticut
-------
ATTACHMENT F1
29
NITED STATES ENVIRONMENTAL D=?OTECT!ON AGENCY
MIC.-iGA1. 48;C:
October 4,. 1982
AI.'T.'NC:SE ANS RACiATICN
Mr. Joseph J. Mongillo, President
Kamei USA, Inc.
300 Montowese Avenue
North Haven, CT 06473
Dear Mr. Mongillo:
In response to your application of March 5, we have begun to finalize our
evaluation of Kamei Spoilers. The purpose of this letter is to outline
the positive and negative aspects of our analysis and to document our
understanding of some of the pertinent supplemental information you have
provided .
Although the information provided in your application supports a gener-
ally favorable conclusion about the effectiveness of your spoilers, there
are several negative factors. Our comments in these areas stem princi-
pally from the fact that the information provided is insufficient to
allow an impartial reviewer to verify the benefits you claim. These
deficiencies may have been resolved favorably if you had supplied the
supplemental information we requested. Our comments below highlight the
positive and negative aspects of your product that will be presented in
our evaluation:
Positive Factors
1. Although the changes were small, the limited data showed an
improvement in fuel economy.
2. The installation is quick and simple.
3. The spoilers are available for, and have been tested on, many
vehicles.
Negative Factors
1. The methodology for translating a change in drag in the wind
tunnel to a change in fuel economy was not described.
2 . The correlation between fuel economy in the wind tunnel and on
the road was not explained.
3. The test speeds and method of extrapolating results were not
given.
-------
30
4. The results infer that a change in drag coefficient is the sole
effect. Actually, for there to be a reduction in aerodynamic
drag, there must be a reduction in the product of drag coeffi-
cient and frontal area. The frontal area could increase due to
the spoiler.
5. The device was tested principally on small sedans. The benefits
for small station wagons and larger cars is unknown.
6. Some basic designs are applicable to several vehicles but yet
tested only on one. Because of the sensitivity of aerodynamic
devices to size, location, and overall vehicle shape, we have no
reason to believe that one model will have the same effect on
all vehicles it will fit.
Initially, there were also other negative factors. Some of these were
satisfactorily resolved by the supplemental information you provided.
Others were resolved by our own efforts. However, the negative factors
listed above relate specifically to your spoilers and the actual testing
conducted. Thus, we were unable to independently satisfactorily resolve
these questions by searching the published literature.
The supplemental information that you provided in your letter of May 17,
1982 contained several listings of spoilers that were grouped according
to basic configuration. Because it appeared that several of these
groupings were in error, we reviewed the list with you on June 16 and
made the necessary corrections. Enclosed is a copy of the groupings as
we now understand them.
We are now in the process of finalizing the evaluation of your spoilers.
If you have any comments or are now able to supply the information which
we requested previously. Please contact me by October 20.
Sincerely,
Merrill W. Korth
Device Evaluation Coordinator
Test and Evaluation Branch
Enclosure
-------
31
Original
Spoiler No. Vehicle
44210
44223
44225
44260
44233
44235
44257
44271
44274
44281
44283
44500
44511
VW Super Beetle
BMW 528, 530i
VW Sirocco
thru 1981
Ford Capri
thru 1978
Audi 4000
Sedan thru 1982
VW Rabbit
Ford Mustang/
Capri 1979-82
Renault 15/17
Gordini
Honda 1500
Civic 1979
Datsun 240 Z,
260 Z to 6/74
Toyota Celica
1978-79
Mazda RX-7
thru 1980
Subaru
1980-81
Spoiler Mfg.
From Original
Spoiler Tooling
44211
44217
44273
44282
44284
44523
44519
44546
44510
44522
44535
44545
44536
44516
44527
44534
44529
44533
44502
4452.4
44532
44503
44537
44504
44528
44501
44531
Vehicle
VW Custom Beetle
BMW 528E
Honda Civic 1980-82
Datsun 210 1978-79
Datsun 510 1979
Datsun 510 1980
Datsun 200 SX, 1979-81
AMC Spirit, Concord
AMX, 1979-80
Subaru to 1979
Datsun 210 pre-1978
Plymouth Champ 1980 up
Dodge Colt 1980 up
Toyota Starlet 1981-82
Datsun Maxima
Toyota Corolla Sedan
1980-81
Toyota Tercel 1981-82
Toyota Tercel 1980
Toyota Celica 1976-77
Mazda 626 1979-81
Toyota SR5 1977-79
Toyota Supra 1979-81
Mazda GLC 1981-82
Toyota 1/2 ton pickup
1982
Mazda RX-7 1981-82
Toyota Corolla 1975-79
Sedan/Wagon
Mazda 323 GLC 1979-80
Toyota Corolla SR5
Coupe 1980 up
-------
32
44560 Audi 5000
44570 VW Jetta
44275 Honda Civic 1200
44255 Ford Escort
44261
9
44540
44548
44258
Ford Mustang 1974-78
Chevrolet Chevette
Pontiac T-1000
Ford Escort/Mercury
Capri 1980-81
-------
ATTACHMENT G f^ 33
El IMC.
auto extras
300 Montowese Ave. 'P.O. Box426 North Haven. CT06473
Tel.: (203) 777-6676 Telex 96-6468 "Kamei USA"
October 18, 1982
Mr. Merrill W. Korth
Device Evaluation Coordinator
Test and Evaluation Branch
Environmental Protection Agency
Motor Vehicle Admissions Lab
2565 Plymouth Road
Ann Arbor, Michigan 48105
Dear Mr. Korth,
In response to your letter dated October 4, 1982, and our
subsequent conversation of October 14, 1982. I am now in
receipt of some additional information from our parent
company, Kamei GmbH & Co KG. This information explains
how our aerodynamic engineers determine drag, lift, speed
and fuel economy.
I ar sincerely hopeful this new information will aid in
your evaluation of our product.
Should you determine that additional information is nec-
essary please contact myself and I will provide same..
Thanking you again for your time and consideration in
this matter.
Respectfully,
KAMEI AUTO EXTRAS, INC.,
*x-
jseph J. Mongillo
President
JJM/nra
Enclosures
Worldheadquarters Wiesbaden/Germany Plants at Wolfsburg. Wittlich/Germany North Haven. Connecticut
------- |