EPA-AA-TEB-511-81-4
EPA Evaluation of the ULX-15 and ULX-15D Under Section 511
of the Motor Vehicle Information and Cost Savings Act
by
Edward Anthony Earth
May, 1981
Test and Evaluation Branch
Emission Control Technology Division
Office of Mobile Source Air Pollution Control
U.S. Environmental Protection Agency
-------
6560-26
ENVIRONMENTAL PROTECTION AGENCY
[40 CFR Part 610]
FRL " AMS
FUEL ECONOMY RETROFIT DEVICES
Announcement of Fuel Economy Retrofit Device
Evaluation for "ULX-I5 and ULX-15D"
AGENCY: Environmental Protection Agency (EPA).
ACTION; Notice of Fuel Economy Retrofit Device Evaluation.
SUMMARY; This document announces the conclusions of the EPA evaluation of
the "tJLX-15 and ULX-15D" additives under provisions of Section
511 of the Motor Vehicle Information and Cost Savings Act.
-------
BACKGROUND INFORMATION; Section 511(b)(l) and Section 511(c) of the
Motor Vehicle Information and Cost Savi igs Act (15 U.S.C. 2011(b))
requires that :
(b)(l) "Upon application of any manufacturer of a retrofit device (or
prototype thereof), upon the request of the Federal Trade Commission
pursuant to subsection (a), or upon his owp motion, the EPA Administrator
shall evaluate, in accordance with rules prescribed under subsection (d),
any retrofit device to determine whether the retrofit device increases
fuel economy, and to determine whether the presentations (if any) made
with respect to such retrofit devices are accurate."
(c) "The EPA Administrator shall publish in the Federal Register a
summary of the results of all tests conducted under this section,
together with the EPA Administrator's conclusions as to -
(1) the effect of any retrofit device on fuel economy;
(2) the effect of any such device on emissions of air pollutants; and
(3) any other information which the Administrator determines to be
relevant in evaluating such devices."
EPA published final regulations establishing procedures for
conducting fuel economy retrofit device evaluations on March 23, 1979
[44 FR 17946].
-2-
-------
ORIGIN OF REQUEST FOR EVALUATION: On January 19, 1981, the EPA received
a request from Fuelteck Corporation for evaluation of a fuel saving
device termed "ULX-15 and ULX-15D ." These Devices are fuel additives
that are claimed to improve gasoline and diesel engine combustion and
thereby increase fuel economy.
Availibility of Evaluation Report; \n evaluation has been made and the
results are described completely in a report entitled: "EPA Evaluation
of the ULX-15 and ULX-15D Under Section 511 of the Motor Vehicle
Information and Cost Savings Act," report number EPA-AA-TEB-511-81-4,
consisting of 21 pages, including all attachments.
Copies of these reports may be obtained from the National Technical
Information Service by using the above report number. Address requests to:
National Technical Information Service
U.S. Department of Commerce
Springfield, VA 22161
Phone: Federal Telecommunications Service (FTS) 737-4650
Commercial (703) 487-4650
Summary of Evaluation
EPA fully considered all of the information submitted by the Device
manufacturer in the Application. The evaluation of the "ULX-15 and
ULX-15D" additives was based on that information.
-3-
-------
Hie applicant was advised on several occasions of the requirement for
submittal of valid test data following the established EPA test
procedures. The applicant submitted no valid test data with the
application for evaluation. Analysis of the information submitted by
the Applicant did not prove that the use of "ULX-15 and ULX-15D"
would enable a vehicle operator to improve a vehicle's fuel economy.
Thus, there is no technical basis to support any claims for a fuel
economy improvement due to the usa of the "ULX-15 and ULX-15D"
additives.
FOR FURTHER INFORMATION CONTACT: Merrill W. Korth, Emission Control
Technology Division, Office of Mobile Source Air Pollution Control,
Environmental Protection Agency, 2565 Plymouth Road, Ann Arbor, Michigan
48105, (313) 668-4299.
Date Edward F. Tuerk
Acting Assistant Administrator
for Air, Noise, and Radiation
-4-
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
ANN ARBOR. MICHIGAN 48105
OFFICE OF
AIR. NOISE AND RADIATION
May 20, 1981
Mr. E. David Woycik, Jr.
Vice President - Fuelteck Corporation
119 Woodbury Road
Huntington, NY 11743
Dear Mr. Woycik:
This is in response to your January 9, 1981 letter, which submitted an
application for an evaluation by EPA of .-. the "ULX-15 and ULX-15D"
additives under Section 511 of the Motor Vehicle Information and Cost
Savings Act.
The EPA evaluation of your additives have been completed. A copy of the
final report is enclosed. Also enclosed, as a courtesy to you, is a copy
of the summary which is expected to be published in the Federal
Register. This final report, entitled, "EPA Evaluation of the ULX-15 and
ULX-15D Devices Under Section 511 of the Motor Vehicle Information and
Cost Savings Act", will be made available to the public. If you have any
questions concerning this report, please contact Mr. Merrill W. Korth of
my staff at (313) 668-4299.
Sincerely,
Charles L. Gray, Director
Emission Control Technology Division
Enclosures
-------
EPA Evaluation of the ULX-15 and ULX-15D Additives under Section 511 of
the Motor Vehicle Information and Cost: Savings Act:
The following is a summary of' the information on the additives as
supplied by the Applicant, and the resulting EPA analysis and conclusions.
1. Marketing Identification of the Additives:
"Fuelteck, a public corporation, produces a gasoline combustion
improver, ULX-15, and a Diesel combustion improver ULX-15D. The
identification of the product is only through its trade names; ULX-15
and ULX-15D"
2. Inventor o.*- the Additives and Patents;
A. Inventor
James Michaels
26 Vermont Lane
Coramack, NY 11725
B. Patent
"The Patent was issued August 19, 1975 and the Serial Number for
the patent is 3,900,297. (A copy of the Patent is enclosed.)"
The patent was not provided nor made available"after subsequent
requests to the Applicant to provide it.
3. Manufacturer of the Additives:
Fuelteck Corporation
2120 Fifth Avenue
Ronkonkoma, NY 11779.
4. Manufacturing Organization Principals;
"Fuelteck Corporation is a public corporation whose officer's are the
following:
Chairman of the Board Allan Gittleson
President Stanton Rappaport
V. P. Norman R. Tengstrom
Secretary W. Robert Tucker
Treasurer W. Robert Tucker"
5. Marketing Organization in U.S. making Application:
Fuelteck Corporation
2120 Fifth Avenue
Ronkonkoma, NY 11779.
Subsequent to the original application, the applicant requested the
following address be used on all communication:
-------
-2-
Fuilteck Corporation
119 Woodbury Road
Hunting ton, NY 11743
Phone: (516) 626-1021
6. Applying Organization Principals;
"The principal officers of the organization making the application
are the same as in item #4. The person who will represent the
orgmization in communications with the EPA is E. David Woycik, Jr. -
V. -'. Operations."
7. Description of the Additive;
A. Purpose of the Additive (as supplied by Applicant);
"The objective for developing such a combustion improver was to
increase the miles per gallon received from each gallon of fuel
used. In addition, Fuelteck's combustion improver reduces the
percentage of harmful gases which are emitted from the exhaust
ports of gasoline and/or Diesel engines. The purpose for
marketing such combustion improvers is to decrease America's
dependency upon gasoline and diesel fuels and to increase the
quality of air which is emitted from the exhaust ports of such
engines."
B. Theory of Operation (as supplied by Applicant);
"Fuelteck's Combustion Improvers, ULX-15 and ULX-15D, are
composed of 85% nitro paraffins, 10% oil, and 5% catalyst. (See
Patent)" The patent was not provided.
"At elevated temperatures, the active components of the additive
are broken down and the molecules disintegrate, releasing ths
oxygen from the nitrogroups. In the first portion of the
ignition, during the first few microseconds, combination of the
fuel with the air oxygen takes place. Immediately following
this, at the elevated flame temperature, the nitro-group
disintegrates and the remaining unburned hydrocarbons in the
combustion chamber are re-ignited and burn with the liberated
oxygen from the nitrogroups. The result is a more complete
burning process culminating with increased gas mileage up to
20%."
C. Detailed Description of Construction (as supplied by Applicant);
"The Detailed Description of Construction of the combustion
improver is contained within the patent (see copy enclosed).
Also refer to Section (7B)."
The patent was not provided nor made available after subsequent
requests to the Applicant to provide it.
-------
—3—
8. Applicability of the Additive (as supplied by Applicant):
"Fuelteck's Combustion Improver, ULX-15 (gasoline) is applicable to
all gasoline engines. The make, model, engine size and carburetion,
make/year, transmission type and ignition are not required. Since
the theory of operation is defined in Section (7B). It should be
apparent that Fuelteck's combustion improver will perform in any
gasoline engine. For example, the combustion improver will work with
a 1970 camaro, 318 hp. engine, automatic, sparkplug ignition; as well
as a 1980 Cadillac Seville, automatic, fuel-injected, electronic
ignition system.
Fuelteck's Diesel Combustion Improver, ULX-15D, works equally as well
in all Diesel engines. Whether the engine is a 1978 Mack, standard
transmission, engine size 675-237A, 225 hp, standard wheel or a
1980 Cutlass Oldsmobile Diesel, 318 hp. with fuel injection, is of no
significance. The savings in gas mileage improvement is constant no
matter what type or year of vehicle. The Diesel Combustion Improver
also reduces sulfated ash by 75%. (See Newing Laboratory report).
There is no crystallization of the Diesel Combustion Improver down to
a temperature of (minus 35° C)."
9. Additive Installation - Tools and Expertise Required (as supplied by
Applicant):
A. "Fuelteck's Gasoline Combustion Improver, ULX-15, is added
directly to the cars/truck's tank. For every 1 gallon of
gasoline that is in your tank, add (3/4) of an ounce of ULX-15.
Therefore, if you have a 20 gallon tank, you will add 15 ounces
of Fuelteck ULX-15 and then fill up. (See instructions attached
for gasoline usage.)" See Attachment A.
B. "Fuelteck's Diesel Combustion Improver, ULX-15D, is also added
directly to the cars/truck's fuel tank. For every gallon of
diesel fuel that is in your fuel tank, add one (1) ounce of
ULX-15D. Therefore, if you have a 20 gallon tank, you will add
20 ounces of Fuelteck ULX-15D, and then fill up. (See
instructions attached for diesel usage.)" See Attachment A.
10. Additive Operation (as supplied by Applicant):
"The Operation Instructions are contained in Section (9) above. A
copy of the instructions for Gasoline and Diesel engines are
attached." See Attachment A.
11. Maintenance (claimed):
"Since this application is not concerned with any external additional
devices, there is no maintenance involved with our combustion
improver. The only item which requires some sort of external
" assistance is that x/hich is needed to add the combustion improver to
the cars/truck's fuel tank as described in Section (9)."
-------
12. Effects on Vehicle Emissions (non-regulated) (claimed):
A. "After considerable testing of Fuclteck's combustion improver's,
there appears to be no substance emitted, other than those
pollutants regulated by the EPA. Not only are there no other
pollutants, but, in addition, there is a reduction of nitrous
oxides and sulfated ash. Scott Environmental Technology, Inc.
performed exhaust emission measurements for Fuelteck Corporation
on February 15, 1979. The tests were performed on a one
cylinder, two cycle, 3 hp. Briggs and Stratton engine. The
engine as tested was equipped by the Sponsor with the following
equipment: dynamometer to apply load and torque, thermocouple
to measure engine temperature and tachometer to measure RPM. A
Scott Chemiluminescense NOx analyzer, Model 125, was set up by
Scott's field engineer. The fuel used was Citgo unleaded
gasoline for the tests. The engine was run at the same
conditions for the gasoline (1st test - gasoline only) and with
the 2nd test (gasoline plus ULX-15).
"The addition of Fuelteck1 s additive to the one cylinder, two
cycle, 3 hp. Briggs and Stratton engine resulted in a decrease
in nitrogen oxides emissions (NOx) of approximately 90%. The
fuel additive not only reduced the NOx, but also reduced the
average engine operating temperature from 435°F to 365°F, a
difference of 70°F. No mechanical adjustments were made on the
engine while these tests were being performed by the Scott
engineer. For further inquiry, please see the attached Scott
Environmental Technology, Inc. report, (dated February 15,
1979.)"
B. Sulfated Ash Report
"Newing Laboratories, Inc. of Islip, NY conducted sulfated ash
content tests for Fuelteck, Inc., dated May 22, 1980. The
results were the following:
"The amount of sulfated ash content in regular gasoline
fuel was decreased 75% from .002% sulfated ash to .0005%
sulfate ash after using Fuelteck1s ULX-15. In diesel fuel,
the amount was decreased 35% from .017% to .011% with
diesel fuel plus Fuelteck's ULX-15D. (See Newing
Laboratories for further results.)"
C. Reduction of Hydrocarbons (HC) and Carbon Monoxide (CO):
"In all 3 Pratt tests, from the readings of the EPA test meter,
it was determirted that the contents of the Hydrocarbons (HC) and
carbon monoxide (CO) in the engine emissions were reduced.
"The reduction of Hydrocarbons (HC) in the engine emissions
ranged from a minimum of 30.5% to a maximum of 34.4%. The
average was computed to be a 32.5% reduction in hydrocarbons.
-------
-5-
"The reduction of carbon monoxide ranged from a minimum of 17.4%
reduction to a maximum of 18% reduction. The average was
computed to be 17.7%."
13. Effects on Vehicle Safety (claimed):
"Fuelteck's ULX-15 is non-corrosive to ferrous metals. Cold rolled
steel strips in contact with ULX-15 for 72 hours at room temperature
failed to show any weight loss. Polyethylene is compatible with
ULX-15. When mixed in the proper proportions in fuel, there is no
effect on those surfaces which are compatable with the fuels.
"There is no effect of ULX-15 on viscosity of the lubricants, when
added as recommended.
"In conclusion,, Fuelteck's ULX-15 and ULX-15D has no corrosive
effects upon the engine components when used as recommended. (See
Bernard Newman, Ph D., report for further information)."
14. Test Results (Regulated Emissions and Fuel Economy) (claimed) :
"Please see the enclosed emissions and fuel economy reports from
Pratt Institute, Scott Laboratories, and Newing Laboratories. These
reports have been thoroughly explained in Section 12 of this
application."
15. Analysis
A. Description of the Additive:
(1) The primary purpose of the Additives is claimed to be
improved fuel economy.
(2) The theory of operation, given in Section 7B, is that the
additive causes the unburned hydrocarbons in the combustion
chamber to be completely burned. Since a properly tuned .
vehicle engine emits little unburned hydrocarbons, it is
highly questionable that a 20% fuel economy benefit could
be achieved solely by use of the.Additive.
Also, since the applicant did not provide either a patent
or a chemical description of the Additive, EPA is unable to
judge if the Additive actually does behave in theory as
claimed in Section 7B.
B. Applicability of the Additive;
The applicability of the Additives, as stated in the
application, "ULX-15" for all gasoline engines, and "ULX-15D"
for all diesel engines, are judged to be correct.
-------
-6-
C. Additive Installation - Tools and Expertise Required:
The installation instructions contained in Section 9 and in
Attachment A are judged to be adequate for the physical addition
of the Additive to the fuel by most vehicle operators. The only
operator caution is to add the Additive to a partially filled
tank, so that complete mixing can occur during fill-ups.
D. Additive Operation;
No specific instructions were provided for operation of a
vehicle with the Additive, and none were judged to be required.
E. Additive Maintenance:
The Additives are judged to require no maintenance, just
periodic addition to the fuel as stated.
F. Effects on Vehicle Emissions (non-regulated) ;
Since the Applicant failed to provide a detailed description of
the Additives, EPA is unable to judge whether or not the
Additive would adversly affect non-regulated emissions.
The Applicant references testing performed by Scott
Environmental Technology, Inc., Newing Laboratories, and Pratt
Institute, as evidence that the Additive causes no harmful
non-regulated emission effects. These data do not support the
Applicant's claim of a negative effect on non-regulated
emissions.
(1) The Scott Environmental Technology, Inc. testing consisted
of constant speed tests of a single cylinder, two cycle, 3
horsepower engine. These results cannot be extrapolated
nor inferred to directionally indicate what might be
achieved on a multi-cylinder, four cycle automotive engine,
during the EPA cold/hot start transient vehicle tests.
(2) The Newing Laboratories report consisted of the test
results for a standard ASTM test for fuel and oil ash
content. Again, the results cannot be extrapolated or
inferred to directionally indicate the Additive effect
during transient cycle vehicle testing.
(3) The Pratt Institute testing consisted of constant speed
tests of twa single cylinder, four cycle, 3.5 horsepower
engines (one gasoline and one diesel). Again, these
results cannot be extrapolated nor inferred to
directionally indicate what might be achieved on a
multi-cylinder, automotive engine during the EPA cold/hot
start transient vehicle tests.
-------
G. Effects on Vehicle Safety;
The Additive is normally intended to be added to- the vehicle's
fuel tank by the operator during refueling. Since the Applicant
provided no information, warnings, cautions, or packaging
information to the user, EPA is unable to judge the safety of
the Additive to the user..
Based on the' information provided, EPA is unable to judge if the
Additive is compatible with vehicle fuel systems.
H. Test Results Supplied by Applicant;
Applicant did not submit any test data per the Federal Test
Procedure of Highway Fuel Economy Test. These are the only EPA
recognized test procedures.^' This requirement for test
data, following these procedures, is stated in the application
test policy documents and in two subsequent letters EPA sent to
the applicant. (Attachments C, D, and E) The test data
submitted by the Applicant are listed below and evaluated.
(1) The Applicant submitted test data for testing performed by
Scott Environmental Technology, Inc., Newing Laboratories,
and Pratt Institute as evidence of the beneficial effects
of "ULX-15 and ULX-15D". These data do not support vehicle
fuel economy or emission benefits for the reasons cited in
paragraphs 16 F (1), (2), and (3).
(2) The Applicant submitted testimonials from a variety of
satisfied customers. These testimonials are summarized in
Attachment B.
(1) From EPA 511 Application Test Policy documents:
Test Results (Regulated Emissions and Fuel Economy):
Provide all test information which is available on the effects
of the device on vehicle emissions and fuel economy.
The Federal Test Procedure (40 CFR Part 86) is the only test
which is recognized by the U.S. Environmental Protection Agency
for the evaluation of vehicle emissions. The Federal Test
Procedure and the Highway Fuel Economy Test (40 CFR Part 600)
are the only tests which are normally recognized by the U.S.
Environmental Protection Agency for evaluating fuel economy.
Data which have been collected in accordance with other
standardized fuel, economy measuring procedures (e.g. Society of
Automotive Engineers) are acceptable as supplemental data to the
Federal Test Procedure and Highway Fuel Economy Data will be
used, if provided, in the preliminary evaluation of the device.
Data are required from the test vehicle(s) in both baseline (all
parameters set to manufacturer's specifications) and modified
forms (with device installed).
-------
-8-
Although the users undoubtedly felt they had achieved real
benefits through the use of the Additive, these rlata
represent a relatively uncontrollable test of the Additive
and cannot be used to validate the claims for the Additives
given in the application and in Attachment A.
16. Conclusions
EPA fully considered all of the information submitted by the Additive
manufacturer in the Application. The evaluation of the "ULX-15 and
ULX-15D" additives was based on that information.
The applicant was advised on several occasions of the requirement for
submittal of valid test data following the established EPA test
procedures. The applicant submitted no valid test data with the
application for evaluation. Analysis of the information submitted by
the Applicant did not prove that the use of the "ULX-15 and ULX-15D"
would enable a vehicle operator to improve a vehicle's fuel economy.
Thus, there is no technical basis to support any claims for a fuel
economy improvement due to the use of the "ULX-15 and ULX-15D"
additives.
-------
-9-
List of Attachments
Attachment A ULX-15 and ULX-15D instructions
Attachment B Summary of Fuelteck testimonials provided with
511 application
Attachment C EPA letter to Fuelteck, dated November 7, 1980
Attachment D EPA letter to Fuelteck, dated February 25, 1981
Attachment E EPA letter to Fuelteck, dated February !6, 1981
-------
ULX-.15 and ULX-15D COMBUJTIQK IHPUOVEftS
These products are mixtures of organic compounds developed
to improve the combustion properties of hydrocarbon fuels.
ULX-15 is intended for use in Gasoline and Gasohol while ULX-15D
is intended for use in Diesel Fuel and Home Heading Oil. There
,\
is no evidence of damage, such as corrosion or other chemical
or physical attack, to any engine or its components or to any
heating system due to the vise of these products.
Heither product presents a toxicological or an explosive hazard,
Benefits to be expected through the use of these combustion.
improvers in either gasoline or Diesel Engines are as follows:
DECREASE IN FUEL CONSUMPTION
REDUCED EMISSIONS OF HC, CO, AND NO
JC
EASIER STARTING
IMPROVED COMBUSTION OF FUEL CONTAINING MOISTURE
REDUCED MAINTENANCE TIME
in Gasoline Engines:
QUICK THROTTLE RESPONSE
REDUCED "HESITATION"
FASTER ACCELERATION
SOMEWHAT LOWER HEAD TEMPERATURE
-------
Additionally, in Diesel Engines:
SMOOTHER RUNNING
REDUCED NOISE
LOWER SULFATED ASH DEPOSITS
BREAK-UP OF SOLIDS IN FUEL
These products should not be added to a full fuel tank unless
some provision is made for thorough mixing. It is recommended
that the proper amount of additive be added to a partially filled
tank. This can then be mixed by the addition of more fuel so that
the final concentration of combustion improver in gasoline does not
exceed 3/4 ounce per gallon and for diesel fuel and home heating
oil does not exceed one ounce per gallon.
For optimal performance, it is not advisable to exceed the
recommended concentration of combustion improver. Excessive amounts
do not improve performance and could result in poorer performance
while lowering cost efficiency.
When adding to a previously treated fuel, treat only for
the amount of fuel to be added.
-------
2120 Fifth Avenue, Ronkonkoma. NY 11779 (516)585-5885
Enclosed in this folder are testimonials and test data
relating to Fuelteck's combustion improvers, ULX.-15 and
ULX-15D, as follows.
1. Testimonials from:
A. Nassau County. New York, indicating an 1Q% in-
crease in miles per gallon.
B. Metropolitan News Company, an 85 truck fleet, has
been using our product for one year and reports a decrease in
fuel consumption of 16%. They also attest to a reduction in
deposit build-up on spark plugs, easier starting in cold weather
and quicker acceleration.
C. A&P Food Stores of Garden City, New York, conducted
a diesel test on a 1978 Mack Truck. The result was a 27% increase
in miles per gallon.
D. Mina Fuel Oil Co.. Corona, N.Y. , reports a 15 to. 20%
savings in fuel consumption with much easier starting in cold
weather.
E. Puritan Fuel Oil Co.. has indicated increased miles
per gallon from using Fuelteck's ULX-15D. Also, they report
cleaner injectors, easier starting in cold weather and, there-
fore, less maintenance,
2. Test Reports as follows:
A. Pratt Institute concluded that the average reduction
in fuel consumption using gasoline was 25%.- Additionally, the
average reduction in fuel consumption for diesel fuel was 2Q%.
The average reduction of hydrocarbon (H.C.) in the engine emis-
sions was 32.5%. Similarly, the average reduction in carbon mon-
oxide (C.O.) was computed to be 17.7%.
B. Scott Environmental Laboratory conducted a nitrogen
oxide emission test and found that by using Fuelteck combustion
improver there was a reduction of nitrogen oxide (N.O.) of approx-
imately 90%. It also lowered the engine temperature 70° Fahrenheit.
C, Newing laboratories conducted a sulfated ash test and
concluded that Fuelteck's combustion improver reduces the sulfated
ash by 75%. ... .
3. Photographs showing how clean Fuelteck burns compared to
competitor's products. -
-------
Kovo.-ber 7, 193C
Mr.
2120 5th Avenue
Ror.konkoina, 1ft" 11779
Bear Jir. Uoycik:
Per your telephone request please find enclosed copies of. the EFA Test Policy,
the Federal Regulations pertaining to a fuel econcry device, and the
Application Fomat for uce v^ith Fuel Econo;r.y Retrofit device Evaluation uncier
Soction 511 of the Motor Vehicle Inforrration and Cost Savings Act.
1 ht>:>e that this infomation will be of value to you.
Sincerely,-
Ilorrill »'. Korth, Device Evaluation Coordinator
Test and Evaluation Branch
Enclosures
ECTDr'TEB :Korth :cd: 2565Plyn:outhRd.: 11/07/80
-------
i-1. L. Davici woycik, Jr.
y-j.?it£ci; Corporation
ibury Re.
, tJY 11743
ti.^ar ilr. Vcycik:
A prelinir.ary evaluation .o£ your applicatior. has 'oten perforiued. i'liis
evaluation shows the following:
1. last ti*.^. patent for the device was referenced but net. enclose-:?
with tae application.
2. Testing was not pertormed on vohicies in . occotMacce v
-------
i-V'ruary 26, 19cil
K.r. L. Bavitl Uoyeik, Jr.
Fitelteck Carpcratior
119 '.Joodburg' Road
rIY 1174i
;":car Mr. Uoycil::
T!'«J r.tivirar^t-ntal Protection Agency is charged by Concessional mandate to
evaluate fuel economy and emission control devices. l.'hile the EPA does not
actually "approve" such devices, it does conduct evaluations £or the purpose
of increasing the cotr.non knowledge in the area. Tor this reason* the outcome
of any testing by EPA becomes public information. It is this info motion
v!:ich may be cited although no claims can be Trade that any C?A findings
constitute: "approval" of" the device or oyster:.
f.nclosed with this letter is a packet of ciatorialii which you will need to
apply for an Kl'A. evaluation of your device. This packet consists of 1) an
application format, 2} a document entitled "C?A retrofit an.rf Muiission Control
!;cvica Cvalisation Test Policy" and 3) .1 copy of the applicable -Fed oral
': emulations.
In order for the EPA to conduct an evaluation of your device, we nust have an
application. Once you have reviewed all the documents IP the packet, you
should prepare an application In accordance with the guidelines of tlu>
/implication for:r*it. A critical part of the application is the substantiating
t;:st data. The required test results will have to i-e attained at a laboratory
of your choice. Such testing would he conducted at your expense* A lij;t of
laboratories vhich are know, to have the equiprent and personnel to ferfom
acceptable testy has beer, included in the enclose:! packet. If you desire, we
can assist iu the develop fen't of a satisfactory test plan.
Or.ce i;e receivt: your application, it vjJ.ll he rfrviewu to rteter:':iite if it. meets
thfc requircr.ents listed in the forr-iat. If £;ot you will he advised of our
decision whether or not EPA will perfom any confirmatory testing. Any EPA
ter.tinp- vrf.ll be perforn:ed at no cost to you, and you will be given the
j-.;:ortunity to concur with our test plan. Gnce this testing is complete, an
cvalatien report will be vrittea solely on the basis of the test data
r.tibr'itted and our engineer inr, analysis.
-------
Ti'cru aro, ho--,wtr, sovoral --^icts concerninc; tenting ;vt c«:; oi:t.sl«
l.r.t;:>racory which I would 3 i>:o to brin;.; to your nttcv.itioh .it this tir^u:
Tout requirements - Altr.ou'/;> differ ront tyres of de-vices r-Ay
require ;. irore conplex tear plan, thft F:inir'U':i v.i require involves; tv;o
vehicles and tvo test stuuci-.c^s run in duplicate. The vehicles should be
selected from those listed in Tahlo 1; if possible. Each vehicle it; to
be- set to iraiuu ncturer'r. tune-un specifications for the baseline testa,
Viui tests are conducted in a "back-to-back11 runner, once with- the vehicle
lo . baseline condition and again with the device installed with no vehicle
adjustments batween tests. If installation of the device also involves
fiene adjustments, e.g. tining, fuel -air mixture, choV.e or tdla speed,.
.mother test sequence with only these adjustments should be inserted
between i he first and last. Also as a triniaun, the tent sequence shall.
consist of a hot-start LA-4 portion (bags 1 and 2) of the Federal Test
Procedure: (FT?) and a Highway Fuel Economy Test (IrFCT). The details of
these tests are contained in th« enclosed pacl:et. Although only «
hot-start FT? is required to ciininize' the coats to you, you arti
encouraged to have tha entire cold-start test performed since any te«;tiuf.
and evaluation performed hy EPA will be-, based OP. the complete FTP onii you
r'-rjy t/lBh to know hov a vehicle vith your device performs over this
official' teat. As s. final requirement, tha personnel of the outnidp
laboratory you select should perform, every decent of your test pl.in.
Thit; include.'; preparation of tl'.e tcr-t vehicle, adj«stneat uf pariinwters
.v.id installation of the device.
;-ji:L>uission of Data - '.;« require "that all test ilata obtniued fron the
outside laboratories in support of your application be cubiritted to us.
7'sis includes any results you have uhich were declared void or ievalic! by
the lalxjratory. V:e also ask that you notify us of the ' Inboratcry you
hovi: chosen » vihcn testinj: is schedules." to ««*.-•; In, w};at tests you hcvo
decided to conduct, allow us to rxiintaia contact ' vdth the l«ibor.ztory
•d;:rin-i the Cv~)urut* • of the test la?-;, nn-;! allow the tr.-c-t laboratory to
directly answer any questions at any tire about the tost program.
Cost cf the Testing — The cost of the r-dniriun test plan (two vehicles,
two tcsit sequences in duplicate) ciancribed above should be less than
02000 per vehicle and lose- than S40CO for the total teat at or.y or the:
laboratories on the list. You will have to contact then individually to
obtain their latest prices.
Outcome of the Testr. - Although it is impossible to accurately \>r edict
t'-.e over -a 11 worth of & device from a snail amount of testing, we have
established sorse- guidelines which will helj> you eetarriine whether the
r.e'jt fs'sults- with your device should be considered encoi;r««ing» These
values-- have been chosen, to assure both of ut; tbat n real difference in
fuel economy exists ar.d that we are not seeing only the variability irv
tho results. The tab'le belcw presents the r.ininain rwviber of cars that
jieo'i to be tented for varying decrees of fuel ecouony irtn
i:«;t;uninsj a typical anount of variability in fuel economy .T.
For a rainicurt test plait which vas conducted on a fleet, of tx.-o carts, thu
-------
fcVttrr.j-.s :--^rovet:ienr uhwuld b»j -it l«.-.--ist H.''.. if .uc li_-::£.t. ;•.!: i'T: diirt'cjrorseo
in aver«;:o fuel econony can bo r.:.iov;ri, then we; t:yulci be able to ;:ay
stisticcl Iv ;>t the SO?' confide-rnif li.-vcl tlv:t tn..-re Is a rc^al inprove— ent.
Sir.lliirly, -,;a would er.r-cct ?. r-inAuur-. of 5" iiuprovorer.t for a fleet of 5
vehicles. Test results which di.sp];:y a si^nif Icoxit iiiero<«fi<:: in emission
levels should fce reason for concern .
Mini. -•!:•?. Fuel F.conor,:y Inprovert»iit.s versus Size cf T»>at Fleet
Flcur. Size Avcrap.c Innrovot~ant_ S?eg»jlred
2 3^ '
3 /A
' A 6S
5 5^
10 «:; •
25 2>r
Once we receive your application, it wi.ll be reviewed to determine if it reets
the requirement s listed In the forwat. If your application is not coraplete,
v« v?Ill aok you to subinit further inf orr'.ation or data. After any nissin£
±riforr,ation has been submitted, your sp plication will he' reconsidered end once
it r--o«ts our requirements, you will he advised cf cur decision v>h ether or not
i:?A will perform:- any couf irrstory testing. Any F."JA testing «vill be perfor>Ts«nlo.t«, on evaluation raport will bo
vritters. If no further testing in rwnn'rcd, the ror-ort vl.ll ^>£- written nalcly
on the. basis oC the test :y.editious u r;ann&r OB possible. l.'a nave estaMis!?ec! a poal of twelve x/eeks
frow the receipt of a complete opplicatioti to the annouRceserit of our report.
Tht: attainraent of this objective requires very precise- scheduling and \re are
dispendini; en t-u: applicant to respond ^ronptly to any questions? or to subtiit
a:-y requestcsj data. Failure to respond in o tiraaly r-rmner will unduly delny
tho process. In the extrer/.e case, \;c r.ay consider lack- of response e»s a
i/itl:draw«l of the application.
I hope the information above- and that contained in t;-.e enclosed doctssents oil i
jid you in the preparation of an 'acceptable application for un K?A evaluation
o}' your device. I will hfc your contact with I-TA riurin-; this process and any
.'•libsacjueBt E?A evaluation. My address is EPA, Motor Vehicle Ec-idslon
La'r.oracory , 2565 Plymoutli Ho ad , Ann Arbor, Hichi^an, 4S105. Th«.- telephone
ni'.nbc-.r is (313) 66-5—4200. Please ccntact ma if you have ar.y questions or
rt?c;i'.ire any furthf.'r inf orr-ation.
.c..ii set-, rely,
••'.orrill U. Korth
novice- Evaluation Coordinator
Tfcfvt and Evaluation Branch
------- |