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

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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

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    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

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         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).

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    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.

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(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."

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     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."

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     (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.

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          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.

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                                                                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.

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          (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.

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                                                                              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.

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                              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

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                                                                              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

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                                                                             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.

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                                                                                         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%

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                                                                                       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.

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                                                       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 AXLE„CLP"
                                                         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.

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                                                                         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.

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                                                                              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)

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                                                        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

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                                                         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

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                                                          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

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                                                             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.

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                                                                             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

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                                                                             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

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                                                                          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

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                                                 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

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