EPA-AA-TEB-511-8 2-16
   EPA Evaluation of the Freedom Products Hot Tip Device  Under
Section 511 of the Motor Vehicle Information and  Cost  Savings Act
                               by

                      Edward Anthony Earth
                         September 1982
                   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  Freedom Products  Hot  Tip Device 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  "Freedom Products  Hot  Tip"  device  was  conducted
upon  the  application  of  the  marketer  of  the  device.    This  device  is
claimed to  reduce emissions and improve fuel  economy.   The  device  is  a
heated idle mixture  screw  which incorporates an air bleed.  The device is
claimed to  improve  the  preparation of  the  fuel/air mixture  and thereby
improve fuel economy and performance.

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

1.  Title;

    Application  for  Evaluation  of  the  Freedom  Products Hot  Tip  Under
    Section 511 of the Motor Vehicle Information and Cost Savings Act

2.  Identification Information;

    a.   Marketing Identification of the Product;

         Freedom Products Hot Tip

    b.   Inventor and Patent Protection;

         "See Appendix  1  - Copy of  Patent."   This patent,  provided  with
         the application,  described  an  earlier  device  and  was  submitted
         for background information  purposes  only.   Therefore,  it  is  not
         included in the attachments.

    c.   Applicant;

         (1)  Freedom Products Inc.
              P.O. Box 700
              Freedom,  CA  95019

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         (2)  Principals

              Lou and Gary Schiavon
              180 Dakota Street
              Santa Cruz, CA  95060

              Ollie and Renee Schiavon
              35 Amesti Rd.
              Watsonville, CA  95076

              Jack Passey, Jr.
              425 Hecker Pass Rd.
              Watsonville, CA  95076

         (3)  Jack  Passey,   Jr.   is  authorized  to   represent   Freedom
              Products Inc. in communication with EPA.

    d.   Manufacturer of the Product;

         (1)  Pittenger Industries
              22785 Bravo Ct.
              Salinas, CA  93908

         (2)  Principals

              C.E. Pittenger, Owner, Pittenger Industries

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

    a.   Purpo se;

         "The purpose of  the Hot Tip is to  provide  a  method of  reducing
         vehicle emissions and engine wear by effecting  a more  efficient,
         smoother running  engine.   The  Hot Tip  keeps fuel consumption  to
         a minimum, and hence conserves energy."

    b.   Theory of Operation;

         "The Hot Tip provides  a method of reducing vehicle emissions  by
         introducing a  controlled amount  of  heated  air  into  the  idling
         circuit of  the engine  carburetor.   The Hot Tip  is designed  to
         replace the carburetor  volume  control  [idle mixture]  screw,  for
         the purpose of  pre-heating  the fuel and air mixture.  Normally,
         as the  air and  fuel mixture  pass  through  the carburetor,  they
         create  a  refrigerating  action  [that]  obstructs  the   idling
         orifice,  and   the  engine   stalls.   The  Hot   Tip  de-ices  this
         orifice, which  results  in  smooth idling  performance.   The  fuel
         is more readily  vaporized,  and the  fuel mixture is more  stable.
         The total effect  is a  smooth-running engine where choking is  at
         a  minimum,  which makes  improved vaporization  and keeps  fuel
         consumption to a minimum."

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    c.    Construction and Operation;

         "See Appendix II"  Appendix II of the application was a  detailed
         description   of   the   device   construction   and   operation.
         Subsequently, a  revised version  was submitted  (Attachment  A).
         Therefore,  Appendix II no longer  applies  and it is not  included
         as an attachment.

4.  Product Installation, Operation, Safety  and  Maintenance (as  supplied
    by  Applicant);

    a.    Applicability;

         "This device applies  to all  1978  and  older  automobiles with
         carburetors which have an idle adjustment  screw, or screws,  and
         all 1979 and newer automobiles with carburetors  that do  not have
         a sealed  idle adjustment screw."

    b.    Installation - Instructions, Equipment, and  Skills Required;

         "Step 1;   Before taking  out  your carburetor's  idle  adjustment
                   screw, turn  it all  the way into  its closed position,
                   very carefully counting  the  turns  and  parts  of  turns
                   to do so.   It can then be  taken out.

         "Step 2;   Next,  screw  the  brass needle into the female  end  of
                   the Hot Tip  to approximately the  length of  the idle
                   adjustment  screw you just took from your carburetor.
                   Now  tighten  jamb  nut  firmly  to  hot  tip   barrel.
                   IMPORTANT;  Grip barrel  only on crimped  ends.

         "Step 3:   Hot Tip unit can now be installed  in carburetor,  after
                   first placing  the  coil  tension  spring you  took from
                   the idle screw onto the brass needle.  If you  find  the
                   needle is too  long,  either  stretch the tension  spring
                   or trim  the needle  at  thread end.   Turn Hot  Tip  to
                   full  closed  position,   before  backing-off  the  same
                   number of turns and  parts  of  turns counted  before  you
                   took out  the idle  screw.

         "Step 4;   Hot Tip  is  now ready  to  set.   With  engine  warmed  up
                   and at  idle with choke off,  adjust  needle  in  until
                   engine nearly dies,   then back off slowly until  engine
                   barely smoothes,  then  stop.   IMPORTANT: Do  not  reset
                   needle after energizing  without   using  pliers  as   it
                   becomes very hot.

                   NOTE;  With  two-barrel  carburetors,  which  require  two
                   Hot-Tips,  it is best to install and  set  each  Hot  Tip
                   in turn before proceeding  to the next  step.

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         "Step 5:  Hook-up must be made  through ignition circuit in  your
                   car's fuse box, so  that  heater operates only when  key
                   is on and at all the time the  engine  is  running.   Most
                   cars have a spare spade fitting in  the  fuse  box, which
                   is located under  the  dash.   If one is not  available,
                   attach a  brass spade  to the  wire  and  fit  under  the
                   metal  end  of  a  fuse.   IMPORTANT:   Before  harness
                   hook-up,  remove fuse from harness line,  remembering to
                   replace it after hook-up has  been  made."

    c.   Operation;

         "Operation is automatic with [the.]  ignition  of [the]  engine."

    d.   Effects on Vehicle  Safety;

         "None"

    e.   Maintenance;

         "None"

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

    "See Appendix III"  Appendix III is Attachment B  of this evaluation.

6.  Analysis

    a.   Identification Information;

         (1)  Marketing Identification:

              The application and supplemental  information  (Attachment C)
              described  several  different  variations   of  a  heated  idle
              mixture  screw.   After several  letters  (Attachments  D,  E,
              and  F)  and  phone  calls,   the  description  and  marketing
              status of these versions  was determined to be;

              (a)  Freedom Products Hot  Tip described  in  Appendix  II of
                   application.   This  heated needle incorporated  a  long
                   internal  air  bleed  with undercut threads  providing  a
                   short external  air  bleed.   The application  no  longer
                   applies to this model.

              (b)  The  model  identified  as  'preferred needle  B'  in  the
                   Attachment C.  This heated  needle incorporated only  a
                   long internal air bleed.  This is the version that  was
                   finally identified  as  the   only  model  to  which   the
                   application applied.

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     (c)   Preferred  needle B with a water  vapor air bleed.  The
          long  internal air bleed was to be connected to a water
          vapor  bottle   as   shown   in   Attachment   C.    The
          application did  not  cover this model.

     (d)   The   model  identified  as   'modified  needle  C'   in
          Attachment C.   This  heated  needle incorporated a short
          internal air bleed and  check valve.

          "Modified  Needle C with the check valve was  submitted
          to  California Air Resources Board.  Its purpose was  to
          prevent  the bleed back of  vapors.   The A.R.B.  denied
          us  an exemption because it  admits  particulates  from
          the   atmosphere  into  the  engine.   It  is also  more
          cumbersome  to  install  so  we  have   rejected  it."
          Attachment E.

     (e)   The   model identified  as  needle  D  in  Attachment  C.
          This  heated needle  incorporated  a short  internal air
          bleed.

          "Needle  D  with  the  short  internal  air bleed  is  the
          style  that  was  used  for  testing   to   check  the
          feasibility of  using  an air bleed.   It is not  to  be
          considered   in   future   testing    or   marketing."
          Attachment E.

     (f)   The model  identified as Freedom Products Jet Heater  in
          Attachment C.  The  application  did not apply to  this
          model.

          "Freedom   Products  Jet Heater  does  not,  as  you  have
          noted,  have an  air  bleed.   It  is the  device that  we
          have, California Air Resources  Board exemption #D109
          on  at present.  We have sold these in California.  The
          "B" needle works about 50%  better and we would like  to
          replace  the solid needle with  it which is the  reason
          for this application."  Attachment E.

(2)   Inventor and Patent Protection:

     The  patent covered the Jet Heater heated idle mixture screw
     (no   air   bleed)  and  was  provided  as  Appendix  I  of  the
     application  for  background  purposes  only  (see  Section
     6a(l)).    Appendix  II  of  the   application  was   verbally
     identified by  the  applicant as  the  new patent application
     for  the  device  being  evaluated  but  was later superseded  by
     a new patent application  (Attachment A).

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b.   Description;

     (1)   As  stated  in Section  3a,  the primary  purpose  of the  Hot
          Tip is to reduce engine wear and  vehicle emissions by using
          a  device  to  improve  the combustion  process.   This  is  in
          agreement with  the  theory  of  operation given  in  Section
          3b.  That is, the  device is claimed to  improve  the quality
          of the fuel  passing  through the  carburetor  mixture circuit
          by heating the  fuel  and introducing a controlled  amount  of
          heated air.

     (2)  The  theory  of  operation  given in  Section  3b  describes  a
          system that will heat  the small amount  of fuel  passing  the
          idle mixture  screw and  will introduce heated air  into  this
          fuel.  However,  replacing  the idle  mixture screw with  a
          heated screw  that  has  an air-bleed does  not guarantee  an
          improvement  in  emissions or  fuel  economy.   The  amount  of
          fuel and  air heated  is  relatively small compared to  the
          normal  flow  of  fuel  and  air  through  the   carburetor.
          Therefore,  any  change  in  the  mixture  circuit  may  have
          little overall  effect  on emissions  or fuel  economy  when
          driving.   Also,  a  vehicle's  induction  system  may  already
          perform efficiently and thus no change would  be  noted.

          The  statements  in  Section  3b  about  carburetor   icing  are
          misleading.     Carburetor    icing   normally   occurs    at
          temperatures  near  32°F.  However,  icing is  no longer  the
          problem it was formerly.  The  icing problems were  solved  by
          a combination of fuel  and vehicle  changes.  The  refineries
          now   use   additives   to   alleviate   the   icing.     The
          manufacturers now heat the carburetor  base and inducted air.

          Also,  the  brief   description  of  the  phenomenom  by  the
          applicant, does not clearly describe how and why  icing  is a
          problem.   Icing  is  caused  by  the cooling  effect  of  the
          air-fuel mixture in  the  venturi.   This,  in turn,  causes  an
          ice build up near the throttle  blade and idle ports.   Under
          these  conditions,  the  engine  may provide sufficient  power
          for driving yet stall  when  idling.   If  icing is  a problem,
          the device may remove the ice  at  the idle  port,  however,  it
          may not remove the  ice obstructing the  throttle  blade.

     (3)  The description of  the device  provided with  the  application
          was  superseded  by  a  new description,  Attachment E.   This
          patent description  adequately  described the  device  being
          evaluated.  The  description given  of  the water  vapor  air
          bleed version adequately described  the construction of  this
          version  but   did  not  adequately  indicate  how  the  proper
          liquid   level  in   the  water   vapor  bottle   would   be
          determined.   This is critical  since the flow of  heated  air
          through the  idle mixture screw would be  strongly  influenced
          by the depth of the air inlet  tube  (item 76  of  figure 1  of
          the patent application)  below the  surface of  the  water.

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              Also, because there are several different  configurations  of
              the  idle  mixture   screws  used  in  vehicle   carburetors
              (various screw diameters and thread pitches), EPA  requested
              information  on  how  they  met this  problem (Attachment D).
              The  response  of  the  applicant*  adequately  describes   a
              practical approach that allows him to market  only  one  basic
              Hot Tip model that  is able to fit many  different  vehicles.
              However,  the  marketing  identification   of  these  various
              adapter needles was not given.

         (4)  No emission or fuel economy claims for the  device  were made
              in the  application.   Following is  the   response  to an EPA
              request (Attachment D) for specific claims:

                   "The  reduction  in emissions  and improvement in  fuel
                   economy have varied  depending  on the condition of the
                   engine  and  especially  the   carburetor.    Individual
                   driving habits  are  also  a  factor.  On cars  without
                   serious problems we have dropped emissions from 25%  to
                   75%.  Mileage increases have  been  from  very  little  to
                   20%."  This statement was  part of Attachment  E.

         (5)  No  cost  data  was   provided  with   the  application.    In
              response to EPA verbal and written requests  (Attachment D),
              the applicant stated  the  cost would  be  $59.95 plus $20.00
              for installation (Attachment C).  This was later changed  to
              $79.95  plus  $20.00  for  installation (Attachment  E).   As
              noted in Section 6c(2), because of the skills and  equipment
              required,  installation and  adjustment  must  be done  by   a
              qualified mechanic.
*  "The  application  does not  distinguish between  SAE  and  metric  screw
threads  because  the  heater  units  all  have  the  same  10-32  internal
threads.  The needles all have  the  same  threads on the  shank  that  screws
into the heater  and  is locked in place with  a  lock nut, but  the body  of
the needle that  goes into the  carburetor may have many different  sizes,
shapes and threads.   They  are identified by  the  model of the carburetor
in which they are to  be installed.   We  presently  have  needles to  cover
the more popular Carter, Ford  and  Rochester carburetors as  well as  the
most  common  Japanese  carburetors.   We  are   working  on Holley and  have
developed one main needle  at  present for it, with  additional ones  to  be
added."  See Attachment E.

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    c.   Installation, Operation, Safety and Maintenance;

         (1)  Applicability;

              The applicability  of  the  product,  as stated in  the  Section
              4a, to essentially all carbureted  gasoline powered vehicles
              with unsealed idle mixture screws is judged to be correct.

              However,  the device  applies to  few late model  vehicles.
              Beginning with  the 1979  model year,  most  GM  vehicles  have
              had sealed  idle mixture  screws.   And,  beginning with  the
              1981  model  year,  virtually all  vehicles have  had  sealed
              idle mixture screws.

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

              The installation instructions, Section 4b  were omitted  from
              the  application and  were  provided  later,  Attachment  C.
              Since  other   information  provided  indicated   that   some
              adjustment  of  the  flow   of  the   heated  bleed  air   was
              required, EPA requested   clarification  (Attachment D).   In
              response  (Attachment  E),  the  applicant  stated  that  no
              adjustment of the bleed air was required.

              Although  the  instructions  imply  that the device could  be
              installed  by  a  person   with  average  mechanical  skills,
              simple  hand   tools,  and   the  vehicle wiring   diagrams,  the
              later  statements  about the  device  installation*  show  that
              proper   installation   and  adjustment   will   need  to   be
              performed by  a  skilled  mechanic who is  familar with  the
              device and has  access to  specialized shop equipment.   The
              instructions  did  not  state how this adjustment  should  be
              done using the infrared equipment.

              The estimate  of  one  man  hour for installation is  judged to
              be reasonable.
*"I believe  the  device  should be  sold  through qualified shops  since  the
best  results  are obtained when  infrared  equipment  is used  for  adjusting
the needles.  It is not  impossible for  good mechanics to install  them by
"ear", but I don't believe the average  "back  yard"  mechanic  could  achieve
maximum benefits.  Therefore, I  prefer  to see  them  installed with  the  use
of equipment.  It is  also extremely beneficial to  check  the air cleaner,
to make sure  the carburetor  float is set correctly,  and  to check  to  see
that  the ignition system  is  in  order.   The  infra-red machine can  give an
immediate clue if the carburetor float  is not  operating  correctly." This
statement is contained in Attachment E

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                                                                            10
         (3)  Operation

              Although the device will function automatically as  claimed,
              it  may adversely  affect  vehicle  operation.   The  device
              draws appreciable power (2.5 amps, 35 watts).  Depending  on
              how  the  device is installed  in the  ignition circuit,  the
              added current may overload the wiring.  These  problems  will
              be more  acute if two  Hot Tips  are  required  (four  venturi
              and most two venturi  carburetors).

Note: Although an  additional wiring  harness is provided with the  device,
the  installation  instructions  require  the  device  to  be electrically
connected through the ignition circuit.

         (4)  Effects on Vehicle Safety;

              Based on the  description  in  the patent application  and  the
              installation  instructions,  the  device  is  judged  to  be
              capable of  being fabricated  to  be  safe  in normal  vehicle
              usage.   However,  the  additional  electrical  load  on  the
              ignition circuit may be too high for  the  wiring,  especially
              if two Hot Tips are required.

         (5)  Maintenance;

              The  applicant's  statement that  no  maintenance is  required
              is judged  to be correct.  However,  the  device,  additional
              wiring, and  added electrical  connectors  would require  the
              normal periodic  inspections  accorded  similar  components  in
              the vehicle.

    d.   Effects on Emissions and Fuel Economy;

         (1)  Unregulated Emissions;

              The  applicant submitted  no  test data  and  made  no  claims
              regarding  unregulated  emissions.  The  statements and  data
              supplied  in  Section  5 relate  to regulated emissions  and
              fuel  economy  only.   However,  since  the device  does  not
              modify the  vehicle's  combustion process  or  powertrain,  the
              device is  not expected to significantly  affect a vehicle's
              unregulated emissions.

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                                                                              11
         (2)  Regulated Emissions and Fuel Economy;

              The applicant  did  not submit  test  data in accordance  with
              the Federal  Test  Procedure and  the Highway  Fuel  Economy
              Test for the version  of  the  device  being  evaluated.*  These
              two test procedures are  the primary ones recognized  by EPA
              for evaluation of fuel economy and  emissions for  light  duty
              vehicles.**  After  numerous  telephone and written  requests
              (Attachments  F,  G,   and  H)  were  made  over  a  period  of
              several months in attempts to  coordinate  the testing of the
              Freedom Products Hot  Tip, the applicant  still had  not set
              up  a  test  program.   Because  of  the inordinate  amount  of
              time  that   had   passed  since   EPA  first   received   the
              application  it  was  finally  necessary  to   conclude   the
              evaluation  without   waiting  for  this  test  data.    The
              applicant was  so informed  with  the  invitation  to  reapply
              for an  EPA evaluation  once  he obtained  the   required  test
              data.

              As  noted   in   Section  6b(2),   EPA  is   unaware   of   any
              information that provides a  technical basis to support the
              claim for  improved  emissions or  fuel economy  for a heated
              idle mixture screw  incorporating  an air  bleed.   Therefore,
              in  the  absence  of  supporting  technical   information  or
              supporting  test  data,  EPA  concluded that  the  information
              provided did not support  the claims  for the device  and  that
              it would have  no beneficial effect  on  either emissions  or
              fuel economy.

7.  Conclusions

    EPA  fully  considered  all  of   the   information  submitted   by   the
    applicant.  The evaluation of the  Freedom Products  Hot Tip  device was
    based on that information and our engineering judgement.
*The applicant  did submit  test  data on  the Jet  Heater (Attachment  B).
This is  an  earlier version  of  the  device  that  does  not have  an  air
bleed.   This data did not  show a  statistically  significant  improvement in
either emissions or fuel economy.

**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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                                                                            12
    The  information  supplied  by  the  applicant  was  insufficient   to
    adequately substantiate either the emissions or fuel economy  benefits
    claimed for the device.

    EPA is unaware of any  data  that  demonstrates that replacing  the idle
    mixture  screw  with a  heated screw  incorporating an air  bleed will
    significantly affect the operation of the vehicle.  Thus, there is  no
    reason to believe that  the  use  of the Freedom  Products  Hot  Tip will
    benefit emissions or fuel economy.

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

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                                                                              13
Attachment A

Attachment B
Attachment C
Attachemnt D
Attachment E
At tachment F
At tachment G
Attachment H
        List of Attachments

Patent Application.  Provided as part of Attachment E.

Appendix III  of  application -  Letter of  September  4,
1981  from  Gary  Leonhardt  of Systems  Control Inc.  to
Jack  Passey of  Freedom Products  Inc.  providing  test
results of the Jet Heater.

Letter of January  4,  1982  from Jack Passey  of  Freedom
Products  Inc.  to  EPA  responding  to  EPA  telephone
request  for   claims   for   device,  cost,   drawings,
installation   instructions,   and   missing   page   of
application.

Letter of  January 19,  1982  from  EPA  to  Jack  Passey,
Jr.  of  Freedom  Products  Inc.  requesting  additional
information  about  the  device  and  clarification  of
previously submitted information.

Letter of  February 19, 1982 from  Jack  Passey, Jr.  of
Freedom  Products  Inc.  responding  to EPA request  of
January  19,  1982  and  providing  copy  of  new  patent
application.

Letter of  March  9, 1982 from  EPA to Mr.  Jack  Passey,
Jr.  of  Freedom  Products   Inc.  confirming  telephone
conversation  of   February  24,   1982  and  providing  a
suggested test plan.

Letter of April  12,  1982 from EPA  to Mr.  Jack  Passey,
Jr.  of Freedom  Products  Inc.   requesting  information
and current status of test  program of applicant.

Letter of  May 27,  1982 from EPA  to Mr.  Jack  Passey,
Jr. of Freedom Products Inc. setting  deadline  for  test
results for the Hot Tip.

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                                                        14
              Docket No.  CT-500
HEATED AIR BLEED IDLE NEEDLE
         John R. Passey, Jr.
         Citizen of the United States
         425 Hecker Pass Rd.
         Watsonville
         County of Santa Cruz
         State of California 95076

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     BACKGROUND OF THE  INVENTION

               Field  of  the  Invention

               This invention  relates to gas and liquid

     contact  apparatus  and more particularly to a heated,

 5   air bleed idle jet  needle for an internal combustion

     engine carburetor.

               Description of  Prior Art

               Whitmore  et al  3,215,417, November 2,  1965,

     discloses a carburetor  idle  valve heater wherein the

10   inner end of a tubular  metal housing is connected to

     a solid  idle needle valve and the housing contains an

     electric heating coil for the valve.   A battery  connection

     is made  to a plug in the  outer end of the housing.

               Kinunell 2,576,401,  November 27, 1951 discloses

15   an electric carburetor  heater wherein fuel enters an

     outer container  and passes through an enclosed percolatiii'--
    i
     container.  Energization  of  the starter motor circuit

     causes a resistor in the  percolating container to boil

     fuel therein and eject  the fuel through sidewall

20   orifices of a closed end  tube and thence into the main

     jet of the carburetor.  A 'resistance wire is wound around

     the tube and the resistance  coil remains energized after

     the engine is started until  the temperature of the

     incoming fuel rises high  enough to open a thermostat

25   switch.  A heat  insulating shield surrounds the  coil.

               Kwartz 2,723,339,   November 8,  1955, discloses

     a fuel activator for carburetors wherein gasoline from

     the carburetor bowl flows down  into an  electrically

     heated cup-shaped receptacle  and then flows up through

30   a tube into a fixed, main fuel  discharge jet for the

     carburetor throat or mixing  chamber.

                             -2-

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                                                                           16
               Eskew 2,846,989, August 12, 1958, discloses a


     carburetor de-icer wherein the carburetor needle valve


     has a bore that is connected to one end of a tube by a


     coupling nut incorporating a sealing ferrule.  The other


 5   end of the tube admits heated air to an air heater box


     mounted on the exhaust manifold of the engine.


               Schlichtling 3,077,341, February 12, 1963,

     discloses an air bleed idle needle valve wherein an air


     bleed inlet check valve is opened by high vacuum with the


10   throttle closed to lean the idle mixture.  Another air


    .inlet port is opened by a thermostatic valve during hot

     weather.


               Probst 3,557,763, January 26, 1971, discloses a


     system for inducting the vapor of a water-methanol soluticr.

15   into a port provided in the inlet manifold of an internal
    «
     combustion engine, the port being for the connection of

     accessories.  The vapor is drawn from a liquid vapor trap


     vessel having a metered air inlet tube.


               Rock 3,865,907, February 11, 1975, discloses a


20   system for bleeding air into the idle needle valve during


     normal operation and for injecting air and water vapor


     from a water reservoir vapor trap through the idle needle

     valve curing acceleration by a spring advanced, vacuum

     retracted piston.


25             Kirmss, Jr. 3,275,922, April 8, 1975, discloses

     a vapor injection system for channeling an octane increas-

     ing vapor from a liquid reservoir through a passage in the

     idle adjustment screw.  The air inlet to the reservoir


     is .-r.etered by a needle valve.

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                                                                        17
     SUMMARY OF THE INVENTION



               The heated, air bleed needle valve assembly of



     the present invention is an improvement in heated idle



     •needle valves of the type disclosed in the aforesaid



 5   Whitmore et al patent 3,215,417.



               An object of the present invention is to reduce



     exhaust emissions of pollutants such as carbon monoxide,



     hydro-carbons, etc. from an internal combustion engine



     and to decrease engine fuel consumption.   These objects



10   are accomplished by the installation of a heated idle



     needle valve which can be fitted to original equipment



     carburetors without modification of the carburetor and



     which can be adjusted after installation.  Another object



     is to provide such a device which incorporates an air



15   bleed passage and yet complies with both  Federal and Stats



    •emission standards or regulations relative to the escape



     of gasoline vapors from the carburetor to the atmosphere.



               Experiments and engine testing with a conanerci
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                                                                           18
    element and both elements are conductively connected  to the


    idle  needle valve for the carburetor.   The needle valve


    serves as an electrical ground for one end of the heating


    coil.   The vehicle battery is connected to an insulated


 5  plug  on the other end of the coil.  A circuit is completed


    through the coil and the coil heats the needle valve  both


    directly and by heat conduction from the surrounding


    metal housing.   The needle valve conducts a heat to the


    adjacent zone of the carburetor throat structure.


10             Raw gasoline, normally aspirated for idling


    when  the throttle is substantially closed, is vaporized


    by  the heated needle, valve,  thereby reducing pollutant


    emissions.   Heating the needle va-lve and the adjacent •


    carburetor body by conduction facilitates engine starting,


15  particularly at low ambient temperatures.


               It is contemplated that pollutant emissions
    «

    and fuel consumption could be further reduced by admitting


    a correctly metered flow of air through a metering or


    air bleed jet formed in the aforesaid heated idle  needle


20  valve.   Experiments were conducted by boring an air bleed


    passage of selected diameter axially through the needle


    valve,  which passage communicated with the atmosphere


    and with the carburetor throat at the  idle jet port therein.


    When  such an air bleed passage is provided in a heated


25  needle valve and when the passage is of the proper size


    for the engine, not only are emissions further reduced,


    but the total percent reduction in emissions exceeds  the


    reduction which could be expected from the simultaneous


    employment of needle heating and of air bleed techniques.


30  These results were displayed by various comparative centre?.


                            -5-
. I

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                                                                          19
     tests of heated only, air bleed only, and heated air bleed .



     idle needles, using a full size commercial  "Sun" engine



     analyzer.



               Although the addition of an air bleed passage



  5   to a heated idle needle valve, such as the needle valve of



     the aforesaid Whitmore et al patent, reduces pollutant



     admissions to an unexpected degree, the provision of an



     air bleed passage that is open to the atmosphere, could



     permit the escape of a very small volume of gasoline vapor



 10   when the engine is not running.  In some •jurisdictions,



     even this small fuel vapor escape could preclude official



     approval and certification of the device.  Such fuel vapor



     escape could be prevented by connecting a liquid vapor



     trap to the air bleed inlet of an idle needle valve.



 15   However, the connection of a liquid vapor trap to an



    • air bleed version of the VJhitmore et al assembly does not



     provide an acceptable device.



               Because of the interference, protrusion, overhar-r,



     etc., of carburetor and engine elements in the vicinity or



 20   the idle jet needle, the most accessible portion of a



     heated air-bleed needle assembly for selective connection



     of an air bleed inlet to a vapor trap is the outermost



     end portion of the assembly.  This requires that the air



     inlet passage be provided in the outer plug that closes



25   the outer end of the tubular housing, which plug must



     also be connected to the battery circuit.  In the pre-



     ferred assembly the outer plug is insulated from the



     tubular metallic housing to avoid short circuiting of the



     wire heating coil element through the housing and the



30   grounded needle valve.  The insulation extends along



                            -6-

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                                                                       I  20
      the  inner  wall  of  the housing to preclude electrical




      contact  of the  resistance wire core with the housing.   The



      insulation must withstand the heat from the wire coil  and



      the  preferred installation is formed as a braided  fabric



 5    sleeve of  fiberglass filaments or fibers.



                When  bleed air is drawn through the outer plug



      of a heated air bleed needle valve assembly having



      insulation of the  character described, minute particles oi;



      glass fiber can be detached from the fibers forming the



10    insulation sleeve.  The air bleed passage in the needle



      valve is a small diameter metering passage, e.g. 0.020"-



      0.030",  and unless dislodged insulation particles  are



      drawn completely through the passage, that passage will



      become plugged  by  insulation particles after a relatively



15    short period of operation.  This is particularly true



      when the air bleed inlet of the assembly is connected
     4


      (as  by a rubber hose) to the air or vapor chamber  of a



      water vapor trap.  Water vapor drawn through the-needle



      valve assembly  housing will wet dislodged insulation



20    particles, thereby causing the particles to form a



      paste-like mass which collects in the needle valve air



      bleed passage and  soon obstructs or plugs it.



                In the heated, air-bleed needle.valve assembly



      of the present  invention, plugging of the needle valve



25    air  bleed  passage  by insulation particles or the like  is



      prevented  by a  small diameter, air conducting shield



      tube connected  between the outer, air inlet plug and



      an inner plug that connects to the threaded air bleed



      needle valve.   Thus, even if particles of insulation are



30    dislodged  within the tubular housing, they cannot  be



                            -7-

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                                                                        21
     drawn  into  the  air bleed passage in the needle valve.

     Preferably,  the shield tube is a thin walled metal tube

     having one  end  secured in one of the end plugs of the

     needle valve assembly by a light press fit.  In order  to

 5   insure that the electric heater coil provides the sole

     electrical  connection between the outer and inner plugs

     of the assembly, the other end of the shield tube is

     electrically insulated from its associated plug.  In the

     preferred embodiment of the invention, the aforesaid

10   shield tube  insulation is provided by fitting one end  of

     the shield  tube with a sleeve of insulating material whic.1;;

     isolates the shield tube from the wall of the bore or

     socket formed in the associated plug for receiving the

     insulated end of the shield tube.

15             The heated air bleed idle needle valve assembly

     of the present  invention is a universal device in that
    •
     a single basic  heated housing unit can selectively

     mount  any one of an assortment of needle valves, custom

     designed for a  selected carburetor.  There are two basic

20   variations  in the specifications of various needle valve;-.

     the adjustment  thread diameter pitch and the optimum

     diameter of  the air bleed passage.   In accordance with

     the present  invention, an assortment of different

     individual needle valves is provided to meet different

25   specifications  but the outer end of each needle valve

     is formed with  a single standardized thread, e.g.  a 10/32

     thread.  The inner plug of the assembly body is counter-

     bored  and tapped to form a complementary,  internally

     threaded socket.  Thus, any selected needle valve of the

30   assortment  can  be screwed to the outer plug of the assemb.U'.

     The selected needle valve is secured by a  locknut.

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                                                                           22
      BRIEF DESCRIPTION OF THE DRAWINGS




                Figure 1 shows an installation of a heated air



      bleed needle valve assembly connected to a liquid vapor



      trap, with parts in section.



 5              Figure 2 is an enlarged section of the preferred



      needle valve assembly in the installation of Figure 1.



              .  Figure 3 is a greatly enlarged fragmentary sectiv:



      of  the carburetor end portion of the needle valve asseir-bly.



                Figure 4 is an enlarged partial perspective of



10    the insulated end of the shield tube.



                Figure 5 is a section like that of Figure 2 showi:



      a modified form of shield tube installation.



                Figure 6 is a section like that of Figure 2



      showing a  modified form of shield tube.



15      '        Figures 7 and 8 are views of modified threaded



    . idle needles.                                    :



      DESCRIPTION OF THE PREFERRED EMBODIMENT



                Figure 1 shows a preferred idle needle valve



      assembly of the present invention fitted to an internal



20    combustion engine carburetor and connected to an air



      bleed vapor trap.



                The down draft carburetor C is bolted to the



      intake manifold M of an internal combustion engine in the



      usual manner.  Installed on the carburetor is a heated



25    air bleed  idle needle valve assembly V of the present



      invention.   The air bleed inlet of the needle V (to be



      described  in detail presently)  is connected by a flexible



      hose H tc  a liquid vapor trap T for preventing release



      of  gasoline vapors within the carburetor to the atmosphere.



                             -9-

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                                                                          23
                        CARBURETOR




               The  body 10  of the carburetor C is  flanged at  12



     for attachment to a flange on the intake manifold M in the.



     usual manner.   The carburetor has the usual air inlet



 5   venturi  14  in  a fuel mixture delivery throat  16.  A main



     jet 18 supplies fuel to  the venturi 14 from the carburetor



     bowl 20  in  a manner well known in the art.  During operatic:..-..



     the flow of the mixture  of fuel and air through the carbura".:^



     to an inlet port 22 in the inlet manifold is  controlled  by



10   a throttle  butterfly valve 24, in the usual manner.



               The  idle jet portion of the carburetor includes



     an idle  jet orifice 28 opening into the throat  16 from an



     idle chamber 30 formed in a thickened carburetor body



     portion  32.  The chamber 30 receives idling fuel from a



15   passage  34  formed in the carburetor wall, which passage



    . connects to a  fuel delivery tube 36 extending into the



     carburetor  bowl 20 in  a  conventional manner.



           GENEPAL  DESCRIPTION OF NEEDLE VALVE ASSEMBLY



               Referring to Figures 1 and 2,'the major elements



20   of the needle  valve assembly V include a tubular metal



     housing  40  connected directly to an inner plug  42, which



     plug mounts the outer  end portion of an air bleed idle



     needle N.   The body of needle N is threaded at  44 and



     screwed  into a complementarily threaded bore  46  in the



25   carburetor  wall portion  32.   The inner end 50 of the



     needle N is conical to provide for manual adjustment of  th&



     effective size of the  idle jet orifice 28 in  the usual



     manner.   A  coil spring 51 maintains the  adjustment.  The



     needle N is formed with  an air bleed passage  ?, to be



30   described in detail presently.



                            -10-

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               In order to thoroughly vaporize the  fuel drawn
     out of the idle jet orifice 28 during engine operation,
     the needle N is electrically heated by an electric resists.-.i;«
     coil heating element E.  The heating coil extends between
 5   the inner plug 42 and an outer plug S2 secured in the
     housing 40 and insulated therefrom by a sleeve S.  The outs:-:
     plug 52- has an air bleed passage formed therein, as will
     be described in detail presently.
               Heating current is supplied to the resistance
10   heating element E from the live terminal of the vehicle
     battery B (Fig. 1) via a line 54 controlled by a switch
     56, which switch may operate in conjunction with the
     engine ignition switch (not shown).  The line  54 has a
     connector clip 58 that connects to a nipple 60 (see Fig-
15   ure 2) projecting from the outer plug 52.  When the switci".
    ,56 is closed, the circuit is completed from the live post--.:
     battery B, through the line 54, the outer plug 52, the
     heating element E, the inner plug 42, the needle N, the
     wall 32 of the carburetor C and ground.
20             In order to prevent plugging of an air bleed
     passage P in the needle N and in accordance with the
     present invention, a shield tube ST extends between the
     inner and outer plugs 42,52 and isolates air bleed vapor
     passing through the needle valve assembly V from the
25   interior of the tubular housing 40  and the insulating
     sleeve S.  The importance of the shield tube ST during
     vapor trap operation will be explained in detail sub-
     sequently.
                       VAPOR TRAP
30             In some jurisdictions the small volume of fuel
                            -11-                       '
                                                                           24

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                                                                        25
     vapor that might escape from the air bleed passage P in


     the idle needle N, through the needle valve assembly V


     and to the atmosphere, represents an unacceptable emission.,


     In these jurisdictions, a liquid vapor trap T is installed


 5   and is connected by the hose H to the needle valve


     assembly V.


               The nipple 60 projecting from the outer plug 52 .:..>:


     the needle valve assembly is formed to provide a terminal


     hose nipple structure 62 (see Figure 2)  for receiving one


10   end of the hose H leading from the vapor trap T.-


               The vapor trap T permits bleeding of the


     atmospheric air into the carburetor idle jet during engine


     operation while trapping any fuel vapor that might other-


     wise be emitted from the air bleed passage when the


15   engine is not running.  The vapor trap includes a water


     reservoir, preferably in the form of a plastic container
    %                              •

     or bottle 70 (Figure 1).  The bottle 70  has a threaded


     filler neck 71 that receives a closure cap 72.  The cap


     is apertured at 74 for air tight connection to the


20   associated end of the hose H in any suitable manner, such


     as by a'friction fit, bonding,  cementing,  etc.  The


     bottle 70 is partially filled with water W, leaving an


     upper air chamber 75.


               In order to admit atmospheric  air" into the air


25   chamber 75 in response to the partial  vacuum developed in


     the carburetor 16 during engine operation,  an air inlet


     tube 76 is provided.   The upper end of this tube makes


     an air tight connection to a fitting 77  secured to the


     bottle 70 and the lower end of the tube  extends to the


30   bottom of the bottle.

                            -12-

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                                                                         26
10
15
          When the engine is running and the hose. H is



connected to the needle valve assembly hose nipple 62, al._



and water vapor are drawn from the air chamber 75 of the-



bottle 70 through the hose H.  These gases flow through



the needle valve assembly V and into the carburetor



throat 16.





          When the engine is running and the hose H is



connected to the needle valve assembly hose nipple 62,



air and water vapor are drawn from the air chamber 75 oc



the bottle 70 through the hose H.  These gases flow thrc<.u;h



the needle valve assembly V and into the carburetor th.r.-?.;•.



16.  The resultant pressure drop in the air chamber 75



causes atmospheric air to flow as make-up air into the



air inlet tube 76 and to bubble up through the body of



water W in the reservoir.  This action maintains the



gas pressure in chamber 75 at substantially atmospheric



pressure and provides a source of air for the chamber V:i



during engine operation.  However, any fuel vapors that



find their way back from the carburetor throat 16 to the
                            -13-

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                                                                          27
     chamber  75  ar<=  trapped in the bottle  70 by the body of



     water W  and will not be forced out  of the tube 76 to the



     atmosphere.



               Under circumstances wherein escape of fuel



 5   vapors to the atmosphere from the air bleed needle valve



     assembly V  is not objectionable, no water trap T need



     be provided and no hose H is  connected to the hose nippla



     62 of the needle valve 70.



              NEEDLE' VALVE ASSEMBLY DETAILS



10             Referring to Figures 2 and  3, the needle N is



     threadedly  attached to the inner plug 42 of the assembly



     V, in order that a specific needle  may be selected from



     an assortment of needles designed for various, carburetors



     and engines.  As mentioned, the outer threaded portion



15   44 of the needle mates with the internal threads 46



    , formed at the carburetor idle chamber 30.  The diameter           i



     and pitch of the outer threads 44 may vary from needle



     to needle,  depending on the carburetor, but all needles



     have outer  end  attachment threads 80  of the same pitch



20   and diameter.   The inner plug 42 is counterbored and



     internally  threaded at 82 to  receive  the needle attach-



     ment threads 80 and the needle is  maintained in assembled!



     condition with  the plug 42  by a locknut 84.



               As mentioned, the needle  valve N is provided wi-s.-:.



25   an air bleed passage P.  This passage is formed by dril-



     ling an  axial bore 86 through the valve body and into



     the conical end 50.   A radial bore  88 intersects the



     inner end of the axial bore 86.  The  diameters of one



     or both  of  the  air bleed bores 86,88  are selected to



30   minimize both fuel consumption and  exhaust gas pollutant



                             -14-

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                                                                            28
15
     emissions.  The latter may be measured by analyzer tests
     during engine operation.
               The tubular housing 40  is  preferably formed
     from a metal having a good coefficient of heat conduction
 5   such as aluminum or an aluminum alloy.  As best seen
     in Figure 3, the inner plug  42 is connected to the
     sleeve 40 by a crimping operation.   The plug has a shallow
     groove 90 into which is crimped a bead 92 by deforming
     the wall of housing 40, with a conventional crimping
10   tool.  The resultant metal to metal  joint facilitates
     conduction of heat absorbed by the housing 40 directly
     to the needle N and henca onto the.wall portion 32 of
     the carburetor.
               In order to mount the inner end of the heater
     element coil E, the inner plug 42 has a reduced diameter
    tthimble 94 formed with a flared out  surface 96 (Fig. 3).
     The inner end convolutions of the heater coil E are
     forced over the flared surface 96 of thimble 34 to make
     a snug electrical connection with the inner plug 42.
     This connection is made before the houcing 40 and is
     slapped over and secured to the plug 42, as described
     above.
                As  seen  in  Figure  2,  the outer plug  52 also
     has  a  flared  projecting  thimble  98 that snugly receives th.::
     outer  end convolutions  of  the  heater coil E  in the manner
     described in  connection  with Figure 3.
                In  accordance  with the  preferred embodiment  of
     the  present  invention,  a metal  shield tube ST  extends
     between  the  end  plugs 42,52  for conducting bleed air through
30   the  assembly  V.   As  seen in  Figure 2,  the outer plug 52
                             -15-
20
25

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                                                                         29
     has an axial bore 100 that receives the outer end of

     the shield tube ST with a light press fit.

               In order that the resistance coil element E

     will provide the sole electrical connection between the

 5   plugs 42,52, even though the shield tube ST is formed of

     metal, the inner end of the shield tube is electrically

     insulated from the inner plug 42.  This insulation is

     provided by a short insulating sleeve 102 (Figures 3

     and 4) that is slipped over the inner end of the shield

10   tube in a pre-assembly operation and which snugly

     embraces the shield tube.  The thimble 94 of the end

     plug 42 is eounterbored at 104 (Figure 3) to freely

     receive the insulating sleeve 102 during assembly.  The

     inner end face of the insulated portion of the shield

15   tube ST makes no contact with other parts and hence the

    « shield tube does not provide an electrical short for the
                i
     resistance coil element E.

               In assembling the needle valve assembly V, one

     end of the heater coil E is forced over one of the plug

20   thimbles and the insulation sleeve 102. on the shield tuba

     ST is inserted in the counterbore 104 (Figure 3)  in the .

     thimble 94 of the inner plug 42.   The other end of the

     wire coil E is now forced over the outer plug thimble

     T.  The outer insulation sleeve S is next slipped over

25   and along the outer plug 52 until its inner end abuts

     the inner plug 42.   The tubular metal housing 40 is

     slipped over the insulating sleeve S and the underlying

     outer plug 52, until the inner end of the housing

     surrounds the inner plug 42, as shown in the drawings.

30   The previously mentioned crimping operation to form

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                                                                           30
     the  crimp  that  secures the housing 40 directly to the




     inner plug 42 can now be performed.



                As seen in Figure 2, the outer plug 52. is



     formed with a shallow groove 106 like the groove 90



 5   formed in  the inner plug, but the outer insulating



     sleeve S Surrounds the groove 106.  Thus, when the



     tubular housing 40 is crimped at 108 by the crimping



     tool, the  outer plug 52 is secured in the tubular housing



     40 with a  length of the insulating sleeve S trapped



10   between the plug and the housing.  The resultant insula-



     tion of the outer plug 52 from the housing 40, the



     insulation of the shield tube ST from the inner plug



     42 and the disposition of the insulating sleeve S around



     the  wire coil E all insure that the coil E will provida



15   the  sole electrical connection between the outer- plug



     52 and the inner plug 42 which mounts the electrically



     grounded needle valve N.



                Before the assembled valve V is fitted to a



     carburetor, a sturdy tubular outer fabric sleeve 110 is



20   snugly fitted over the tubular metal housing 40.  The-



     outer sleeve 106 facilitates manual rotation of the



     assembly V for  adjustment of the needle N in the carburetc:-



   . wall, particularly when the heater coil E is energized



     and  the tubular metal housing 40.has been heated.



25              After the needle N has been threaded into the



     carburetor with the spring 51 surrounding the needle, tha



     electrical connector 58 is slipped over the connector



     nipple 60  and if a vapor trap assembly T is to be



     employed,  one end of the hose H is slipped over the



30   hose nipple 62.



                            -17-

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                                                                           31
                        EXAMPLES



               By way of the specific examples, the diameter of



     the axial bore 86 or of the radial bore 88 forming the



     air bleed passages in the needle N, will be approximately



 5   0.56 mm (0.020 inches) for a typical four cylinder engine



     of about 2 1/2 liter displacement.  The corresponding.



     diameters will be approximately 0.76 mm (0.030 inches)



     for an eight cylinder, five liter  (305 cu. in.) engine.



     The shield tube ST has an external diameter of about



10   2.38 mm (3/32 inches) and a bore of about 1.59 mm



     (1/16 inches).  The heater coil E is formed of nichrome



     wire of about 22 gauge or 0.635 mm (0.025 inches)



     diameter and has a resistance of about 4 ohms at



     21°C (70°F)  for 12 volts D.C. operation.



15             The insulating sleeves S and 102 are woven



    ,as tubes from fiberglass fibers, the tubes being com-



     mercially available under the trade name of Varflex,



     manufactured by the Varflex Company of Rome, N.Y..



               The needle N, the end plugs 42,52, the housing



20   40 and the tube ST are formed of aluminum or of an alumiii..:.



     alloy for good electrical and heat conduction.



                        OPERATION



               When a needle valve assembly V of the present



     invention is originally installed, the original idle



25   needle valve is replaced by a needle N of the present



     invention.  This involves selecting and mounting a



     matching thread needle N on the inner.plug 42.  The



     selected needle N should have an air bleed passage P



     diameter suitable for the displacement of the engine,



30   typical examples having been given previously.  The



                            -18-

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                                                                           32
      connector wire lead 54 is hooked up to the vehicle  wiring



      system as indicated in Figure 1.  If required by  local



      regulations, a vapor trap assembly T including bottle 70



      are  mounted near the engine and the hose H is forced over



'5    the  hose nipple 62.



                The assembly V is adjusted with the engine ruari.Lc;:.;



      and  with the heater coil E energized and at temperature-



      Optimum, adjustment is obtained by the use of an engine



      exhaust gas analyzer and a tachometer, such as the  analyzers



10    manufactured by the Sun Electrical Corporation of Chicago,.




      IL.



                With the throttle closed, the basic criteria for



      optimum adjustment are maximum engine speed without engirra



      "rolling" and without fuel starvation and stalling.   If



15    an engine analyzer is available, other criteria are the



      minimizing of emissions such as CO,NX and hydrocarbon



      gases.   As previously mentioned, it has been found  by



      analyzing the results of operational tests employing- the



      heated air bleed needle valve assembly of the present



20    invention and an exhaust gas analyzer, that the reduction.



      in emissions attained by simultaneously employing both



      the  needle heating technique and the air bleed passage



      technique is greater than the reduction in emissions



      attainable by the separate use of either technique.   More



25    significantly, if the emission reductions attainable



      individually by the two techniques separately are



      combined to provide a statistically correct theoretical



      combination reduction figure (the product of the



      individual figures), the aforesaid operational tests



30    have shown that the emission reduction attained by



                            -19-                     ;

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                                                                         33
      applicant's double action needle assembly exceeds the



      reduction that would be theoretically provided if the



      aforesaid two techniques  (heating and air bleed) were



      simultaneously employed.



 5            ,  If the water trap T is fitted, the gas drawn



      through the needle assembly V will contain water vapor.



      When no. shield tube ST is provided, this gas dislodges



      particles from the insulating sleeve S.  Any tendency



      of these dislodged particles to plug the air bleed



10    passages P in the needle N is aggravated when the gas



      contains water vapor.  The water vapor facilitates



      agglomeration of dislodged particles into a sort of



      paste, with the resultant plugging of the air bleed



      passage P.



15              By isolating the mixture of air and water



      vapor flowing through the needle valve assembly from the



      insulating sleeve S, the shield tube ST prevents the afore--



      said entrainment of insulation member particles in the



      gases drawn through the air bleed passage P.  Thus,



20    the heated air bleed needle assembly V of the present



      invention will operate indefinitely without plugging,



      even though a liquid vapor trap T is employed.  This



      result is not attainable if the shield tube ST is



      omitted.  In fact, even if the needle valve assembly



25    V is employed without the liquid vapor trap unit T,



      so that atmospheric air is drawn directly into the



      bore 100 in the shield tube, the shield tube ST



      insures that no particles of insulation material can



      accumulate in the needle air bleed passage P, even



30    under hiyhly humid atmospheric conditions.



                             -20-

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                                                                         34
                      MODIFIED FORMS


                Figure 5  is a longitudinal section  like  that  of


     Figure  2  showing a  modified form of the invention.  Since
                                           »

     the only  difference between the forms of Figure  5  and thah


 5   previously described relates to the assembly  of  the shiel-;A


     tube, the reference numerals employed for the elements  of


     the embodiment  of Figures 1-4 are applied without  change


     to the  corresponding elements in the embodiment  of Figure


     5.  However, where  elements in the embodiment of Figure


10   5 have  been modified, the subscript "a" has been applied


     to corresponding reference characters.


                In the needle valve assembly Va of  Figure 5


     a metal shield  tube STa is provided which serves the Sam*;


     function  as the shield tube ST of the preferred  embodi-


15   ment, but in Fig. 5 the shield tube is insulated from


     the rear  plug instead of from the front plug,  as :in
    4

     Figure  2.   In the embodiment of Figure 5 the  bore  104a


     in the  front plug 42a has a diameter that receives the


     shield  tube STa with a light press fit.  The  bore  lOOa


20   in the  thimble  98a  of the rear plug 52a has a diameter


     large enough to freely receive an insulating  sleeve 102a


     that snugly embraces the rear end of the shield  tube


     STa.  Except for the physical transposition of the


     insulating sleeve from one end to the other end  of the


25   shield  tube, the asssembly steps and the mode of opera-


     tion of the embodiment of Figure 5 is like that  described


     in connection with  the preferred embodiment of Figures


     1-4.


                Figure 6  shows a similar modified form of the


30   present invention wherein the shield tube is  formed of


                            -21-

-------
                                                                      ;   35
     a nonconducting, heat resistant material.  In the heated



     air bleed needle valve assembly Vb of Figure 6, as in tha



     case of Figure 5, the elements of the assembly which are



     modified are given the same reference characters as those



 5   previously applied but with the subscript "b" applied



     thereto.



               In the form of Figure 6 the shield tube STb is



     formed of a nonconducting, heat resistant material such a::



     glass, sintered aluminum oxide or a heat resistant



10   thermosetting resin.  Neither end of the shield tube STb



     need be insulated from its associated end plug, so that



     the bores 104b in the front plug 42b and lOOb in the



     rear plug 52b receive the associated ends of the shield



     tube directly without need for an insulating sleeve, as



15   before.  The shield tube STb of Figure 6 has a nice



     sliding fit in the bores 104b,100b and end stop shoulders



     are provided for axially locating the shield, tube.  The



     general principals of assembly and mode of operation of



     the form of the invention shown in Figure 6 are like thos.:



20   previously described.



                    NEEDLE ASSORTMENT



               The needle N (Figs.  1-3)  has mounting threads



     80 of a standard diameter and pitch, eg 10/32.   The



     carburetor threads 44 have a larger diameter and a finer



25   pitch, eg 1/4"/36.



               Figures 7 and 8 show two additional examples



     of assorted needles which are constructed to fit the



     carburetor for a given engine but each of which can be



     mounted on a single master needle valve assembly V,



30   Va or Vb in accordance with the present invention.

-------
                                                                           36
     The needle Na  of  Figure 7 is  like the needle N previously



     described except  that the diameter and pitch of threads



     44a that are received by the  body of the carburetor C  are



     identical with the diameter and pitch of the standard



 5   mounting threads  80 that mount the needle in the inner



     plug.   In other words, the needle Na of Figure 7 is



     uniformly threaded along its  length.  In the embodiment



     illustrated the mounting threads 80 are size 10/32 for



     all needles.



10             The  needle Mb of Figure 8 has threads of uniform.



     basic diameter along its length but in this needle the



     carburetor threads 44b are of a finer pitch (eg 10/40)



     than are the standard needle mounting threads 80 (10/32),



     previously described.



15             Having  completed a  detailed description of



    tseveral embodiments of my invention so that those skilled



     in the  art may practice the same, it can be seen that  I



     have disclosed heated air-bleed needle valve assemblies



     which improve  fuel economy, reduce exhaust emissions,



20   can be  selectively connected  to a- liquid fuel vapor



     trap, which will  operate indefinitely without plugging



     of the  air bleed  passage running through the jet needle,



     and which can  be  fitted with  any one of an assortment



     of threaded needle valves.



25    CET:lw
                            -23-

-------
                                                                    37
           I claim:






           1.  An adjustable  idle needle valve assembly



for controlling the aspiration of idling fuel into the



throat of  an internal combustion engine carburetor at a



zone downstream of the throttle valve, said assembly



comprising a threaded metal  needle valve, an elongate



tubular metal housing, inner metallic plug means for



said tubular housing connected to _the outer end of



said needle valve, outer metallic plug means for said



housing, means for insulating one of said plug means



from the housing, a tubular  electric insulating sleeve



within said housing, a helical heating coil of resistance



wire within said insulating  sleeve connected between



said outer and inner plug means, and means for providing



an electrical connection to  said outer plug means for



energizing said coil;   the  improvement wherein said



needle valve has an air bleed passage extending axially



from its outer end to a transverse passage at its inner



end, an axial air passage in said inner plug means



communicating with said needle valve passage, an air



inlet passage in said outer  plug means, a small diameter



air conducting shield tube extending between said outer



and inner  plug means and communicating with the air



passages therein, said coil  of resistance wire providing



the sole electrical connection between said outer and



inner plug means, and an air line connection on said



outer plug means for selectively connecting said plug



means to an air inlet vapor  trap.

-------
                                                                     38
          2.  The  needle valve assembly of claim  1;



wherein said  shield  tube is formed of  metal and means



for electri.ca.lly insulating one end of said shield tube



from one of said plug  means.





          3.  The  needle valve assembly of claim  2;



wherein the other  end  of said  shield tube  is mounted



directly to the other  of plug  means.






          4.  The  needle valve assembly of claim  2;



wherein the air passage  in  said one plug means has a



portion that  is larger in diameter than the diameter of



said one end  of the  shield  tube,  said  shield tube



insulating means comprising an insulating  sleeve



surrounding said one end of the shield tube and disposed



in said larger diameter  portion of the inner plug means



passage.





          5.  The  needle valve assembly of claim  4; where-



said shield tube insulating sleeve is  a fiber glass



fabric.





          6.  The  needle valve assembly of claim  4 ;



wherein said  shield  tube is mounted directly in the



air passage of said  outer plug means with  a light



press fit.






          7.  The  needle valve assembly of claim  1;



comprising a  liquid  reservoir  air  inlet vapor trap and



air conduit means  detachably connected between said



vapor trap and the air line connection on  said outer



plug means.

-------
                                                                    39
           8.  The needle valve assembly of claim 7;



wherein  said electrical connection means comprises a



connector  clip detachably connected to said outer



plug means between said air line connection and said



housing.






           9.  The needle valve assembly of claim 1?



wherein  the inner portion of said inner plug means is



formed with a threaded socket communicating with the



air passage in said inner plug means, the outer end



of said  needle valve being externally threaded and



screwed  into said socket for facilitating attachment of



any one  of an assortment of needle valves to said



inner plug means and a locknut for the external threads



on the outer end of said needle valve.






           10.  An adjustable idle needle valve assembly



for the  carburetor of an internal combustion engine,



said assembly being of the type having 'a threaded needle-



valve with an air bleed passage therethrough, an electric:



heater unit comprising a tubular housing, inner plug



means for  connecting the inner end of said housing to



the outer  end of said needle valve, electric terminal



plug means for the outer end of the housing, means for



insulating one of said plug means from the housing,



a helical  electric heating coil within said housing



connected  between said plug means for heating said



needle valve, an electric insulation sleeve surrounding



said coil, an air bleed passage through each of said



plug means and a hose nipple on said electric terminal



plug means; the improvement comprising a small diameter



metallic air conducting shield tube, means for mounting



said shield tube between said plug means and in com—

-------
                                                                     40
electrically insulating said shield tube from one of



said plug means to prevent shorting out of said heating



coil by said shield tube and means for selectively



connecting the hose nipple on said electric terminal



plug means to a vapor trap.






          11.  The assembly of claim 10; wherein said



shield tube insulating means comprises an insulating



sleeve disposed between an end of the shield tube and



the associated plug means.
GET:Iw

-------
                                                                      41
     ABSTRACT OF THE DISCLOSURE



               An adjustable idle needle valve assembly



     for an internal combustion engine carburetor .includes



     an air bleed threaded needle valve mounted on a plug



 5   for a tubular metal housing, an insulating fiberglass



     sleeve in the housing and an electric needle valve heat--:



     coil within the insulating sleeve.  The heater coil



     extends between the needle valve mounting plug and an



     outer air inlet plug for the tubular metal housing.



10   An air-conducting shield tube extends between the



     plugs for isolating the flow of bleed air from the



     insulating sleeve, particularly when the outer plug



     is connected to a liquid vapor trap."

-------
                                                        42
                           — I.
7O

-------
44
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              100
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                       N             4Za   Xl04a       w    lOZa   '\00a

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-------
                                           ii
                          ENVIRONMENTAL ENGINEERING
                                     DIVISION
  Attachment B

A
In reply refer to:
413-81-213
Project #7801-019
September 4, 1981
Mr. Jack Passey
Freedom Products, Inc.
P.O. Box 700
Freedom, CA  95019

Subject:  Test Results of Jet Heater

Dear Mr. Passey:

     Systems Control, Inc. (SCI) performed emissions and fuel economy tests in
accordance with procedures specified by the Environmental Protection Agency.
The tests performed were duplicate LA-4 driving cycles and an SH cycle for
each of three different configurations.  The LA-4 driving cycle is the cold
transient and cold stabilized portion of the Federal Test Procedure (FTP).
The SH cycle consists of a 3-minute cruise at 50 mph followed by identical
back-to-back Highway Fuel Economy Tests (HFET).

     The three vehicle configurations were as follows:
  T.
     Test 1)   Baseline with vehicle adjusted to factory specs.

     Test 2)   Vehicle with "Jet Heaters" installed and adjusted to Freedom
               Products Recommendations.

     Test 3)   Vehicle with stock idle mixture screws installed and idle
               mixture adjusted to give smoothest idle with highest manifold
               vacuum.

     The LA-4 driving cycle includes accelerations, decelerations, idles, and
cruises.  The maximum speed driving is approximately 55 mph and the average
speed is approximately 25 mph.   The driving cycle is performed on a chassis
dynamometer and represents typjical driving.  Emission data repeatability is
usually ±20 percent.  Fuel economy repeatability is usually ±5 percent.

     Tests were performed on a 1978 Chevrolet Monte Carlo with a 305 cu. in.
V-8 engine, automatic transmission, air conditioning and with 63,000 miles
accumulated.  All three tests were performed using a 3,500 pound inertia and
10.7 road horsepower.
     KfSTCMS COHTCOL, WC • 421 CAST CEBBITOS AVENUE Q ANAHEIM, CA 92805 • C71O 356-5450

-------
                                                                             45
Mr. Jack Passey
September 4, 1981
Page 2 of 3
     The results of the tests are as follows:


                                     EMISSIONS (GRAMS/MILE)    FUEL ECONOMY
                                     HC    CO     N0x    COT"   LA-4   HFET

Test 1 - Vehicle Factory Specs     0.655   7.5   0.782  569.9  15.21  21.05

Test 2 - With "Jet Heaters"        0.660  11.58  0.728  571.8  15.06  20.98

Percent of Change                  0.7    54.4   -6.9     0.3  -0.9   -0.3
Test 3 - Veh. Adj. to Best Idle    1.748  39.72  0.778  555.6  14.23  21.03
Test 2 - With "Jet Heaters"        0.660  11.58  0.728  571.8  15.06  20.98

Percent of Change          •       -62.2   -70.8  -6.4     2.9   5.8   -0.2


Percent Change =
     In addition to the driving cycles, another idle test was performed mea-
suring emissions with the infrared analyzer.  Two measurements were taken.
One with the vehicle in Test 2 configuration.  The other was with the vehicle
in Test 3 configuration.  The results are as follows:


                        IDLE RPM IN DRIVE    CO %      HC  PPM    VACUUM
                                            EO   TP    EO   TP

With Stock Idle Jets           500         3.4  2.6   230  230     16.4"

With "Jet Heaters"             500         1.4  .75   180  160     16.2"

EO = Engine Out (Ahead of Catalytic Converter)
TP = Tail Pipe (After Catalytic Converter)


     The results show that compared to a vehicle that is adjusted to factory
specifications the "Jet Heaters" increases the CO emissions with no signifi-
cant change in either urban or Highway Fuel Economy.

     However, compared to a vehicle that is adjusted out of specification but
to "Best Idle," the "Jet Heater" significantly reduces both HC and CO emis-

-------
                                                                            46
Mr. Jack Passey
September 4, 1981
Page 3 of 3
     If you have any questions please feel free to call me or Dick Carlson at
(714) 956-5450.  We are returning the "Jet Heaters" separately.

                                        Sincerely yours,

                                        SYSTEMS CONTROL, INC.
                                        Environmental Engineering Division
                                        Gary Leonhardt
                                        Project Engineer
GL/jp

cc:  R. Carlson
     F. Labun
     P. Meyer
     T. Thurman
     Contracts

-------
         FREEDOM PRODUCTS IMC.
                                       c
                                       47
                  P.O. BOX 700
                FREEDOM, CA 95019
                 408-722-40&3-
i\s. &-
                                     / lf/2.
/vXsv
      xM

                                               .
                                •


-------
                                                      48
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    iFE-DOM.  (TAU
                                                   «=**
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V4E-A"iei>
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-------
**°ST'"*                                                                Attachment D
           UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
       i
       '                   ANN ARBOR. MICHIGAN 48105
                                                               OFFICE OF
 January 19, 1982                                       AIR AND WASTE MANAGEMENT
 Mr. Jack Passey Jr.
 425 Hecker Pass Rd.
 Watsonville, CA  95076

 Dear Mr. Passey:

 On December  8,  1981,  we received your  letter  dated November 24,  1981  in
 which  you  applied  for  an  EPA  evaluation  of  the  "Freedom Products  Hot
 Tip",  an emissions/fuel economy device.  We  notified you  on December  10
 that  page  3  of the  application  was  missing.   We  received  page  3  on
 January 7,  1982.

 Our  Engineering  Evaluation Group  has made a  preliminary review  of  your
 application.  Based on this review, our phone  call  to you on December 10,
 and  the information provided  in your letter of  January 4, we have  iden-
 tified several areas  that  require additional clarification prior  to  fur-
 ther  processing  of  your  application.   Our  comments  below address  the
 individual sections of your application.

 1.  Section No. 2 - Marketing Identification

     Several  different  variations  of  this device  (heated  idle  mixture
     screw)  were described.   They are:

     a.   Freedom Products  Hot Tip of  your application.   It  incorporates
          both a long internal and a short external air bleed.

     b.   Preferred  needle  B of  your  January 4 letter.   It incorporates a
          long internal air bleed.

     c.   Preferred  needle  B  of  your  January 4  letter with vapor bleed.
          It incorporates a long internal air bleed through a vapor bottle.

     d.   Modified  needle C of your January 4  letter.   It incorporates a
          short internal air bleed with a check value.

     e.   Needle  D   of  your January  4  letter.   It  incorporates  a  short
          internal air bleed.

     f.   Freedom Products   Jet  Heater  of  your   January  4,  letter.   It
          apparently has no air bleed.

     From the correspondence  and  our  telephone  conversations,  it is  not
     clear  exactly   to which  variation  your application  applies.   Please
     specify  which   device  or devices are  covered by  your  application.
     Also your  application  does  not distinguish between  units? with SAE  or
     metric screw threads.   Other  literature suggests  that both  are avail-
     able.  Do  you  market  SAE and metric versions?   If  so, how  are  they
     identified?  Hot*  many  different models of  your  product are required
     to cover the range of  applications?

-------
                                                                            50

2.  Section 3 - Identification -f Inventor/Patent Protection.

    In our discussion of December  10,  you stated that Appendix 1 -  (copy
    of the  patent)  referred to  an earlier device  and  was submitted  for
    background information  purposes only.   Is  this correct?  This  patent
    appears to describe the Jet Heater.  Is this correct?

    In our  discussion  of   December  10,  you  stated  that  Appendix  II  -
    (Description of Unit) was  also a  copy  of  the new patent  application
    and that this was the device being  submitted  for  evaluation.  Is  this
    correct?

3.  Section 8 - Description of Device

    The description of the  unit  (Appendix II) is  presumed  to apply  to  the
    device indicated in Section 2  of the  Application.  This appears  to be
    what I have identified  in item 1 above  as a.  Freedom Products Hot  Tip
    incorporating long  internal and short  external air  bleed.   Is  this
    correct?

4.  Section 9 - Applicability

    You stated  that  the device  can  be used on essentially all  vehicles
    with unsealed idle mixture  screws.  Many vehicles manufactured  during
    the past several years  have  had features to discourage tampering  with
    the idle mixture.  Your non-air bleed units apparently incorporated  a
    limiter function  to prevent tampering.  Does  the  device  applied  for
    have a similar anti-tampering feature?  If  yes, please  describe.

5.  Section 10 - Installation Instructions

    The installation  instructions provided in  the  application  and  your
    letter  of  January  4  appear to  apply  only on a  non-air  bleed  idle
    mixture screw heater -  the Freedom Products  Jet  Heater -  and not  to
    the device applied  for  which this  application was  submitted.  Is  this
    correct?   These  instructions  appear  incomplete  for  any   of  the  air
    bleed  devices  noted  in item  1 of  this  letter.    Is this  correct?
    Please provide detailed installation and adjustment instructions  for
    the device which you identify in item 1 above  as  the device for  which
    you are requesting an evaluation.

6.  Section 12 - Maintenance

    You state  that  the  device requires no  maintenance.  However  Appendix
    II, pages  7 and  8, indicate  that maintenance  is  required.    Please
    explain.

7.  Section 15 - Test Results

    The test results  appear to be for device  identified  in Item 1  above
    as Needle D.  Is this correct?

8.  What are the specific emission and  fuel economy claims to be made  for
    your device?

-------
                                                                             51
9.  How  will the  device be  marketed.   You  stated  on  December  10  that
    marketing was  to be  done  principally through tune-up shops.  Hox
-------
                                                          ATTACHMENT E
        FREEDOM  PRODUCTS INC.
                        P.O. BOX 700
                    FREEDOM, CA  95019
                 \3ET-HEATERA

                       408-7QQ  1003
Febraury 19, 1982            728*4728
Mr.  Merrill W. Korth
U.-:.  Environmental  Protection Agency
Anr.  Arbor, Michigan   48105

Dear Mr. Korth:

   •  In  response to your letter of January 19,. 1982,  I will answer
each question in the order they are presented.  I am  also enclosing
a copy of the patent which has been submitted to the  United States
patent office.

1.   Section No. 2 - Marketing Identification

    a,b,c   The Freedom Products Hot Tips B incorporates the
          .'long internal and short external air bleed tube as
           per the enclosed patent application.  This is the device
           we want to have tested and want to market.  The long
           internal  air bleed heats the air better then the short
           air bleed,but its main purpose is to enable us to filter
           out particulates and to prevent the bleed back of vapor
           after the engine is stopped by use of the vapor bottle
           or filter bottle as it may also be called.  In states
           such as California, I believe the filter  bottle would
           be a necessity.  If other states that don't have a
           pollution problem would permit it the device car also
           be used without the bottle.

    d. Modified Needle C with the check valve was submitted to 0
      California Air Resources Board.  It's purpose  was to prevent
      the bleed back of vapors.   The A.R.B. denied us an exemption
      because it admits particulates from the atmosphere into the
      engine.  It is also more cumbersome to install so we have
      rejected it.

    e. Needle D with  the short internal air bleed is  the style that
      was used for testing to check the feasibility  of using an
      air bleed.   It is not to be considered in future testing or
      marketing.

    f. Freedom Products Jet Heater does not, as you have rioted, have
      an air bleed.   It is the device that we have,  California
      Air Resources  Board exemption #0109 on at present.  We have
      sold these in  California.   The "B" needle works about 50%
      better and we  would like to replace the solid  needle with
      it which is  the reason for this application.

-------
The  application does not distinquish between SAE and metric screw
threads:: because the heater units all have the same 10-32 internal
threads.  The needles all have the same threads on the shank that
screws into the heater and is locked in place with a lock nut, but
the-body-of the needle that goes'into-the-carburetor may have'many
different sizes, shapes and threads.  They are identified by the
model of the carburetor in which they are to be installed.  We
presently have needles ta cover the more popular Carter, Ford and;
Rochester carburetors as well as the. most common. Japanese carburetors.,
We are working on Hoiley and' have developed- one main needle at
present for it, with additional ones, to be added.

£_  Sections. 3- Identification of Inventor/Patent Protection

    Appendix I is the Jet Heater or the needle in "f" above.
    Appendix II is a Copy of a patent application involving the
    air bleed, but the enclosed new patent aoolication is to take
    it's place and is the device being submitted, for evaluation.

3.  Section 8- Description of Device
                                                                          53
    Yes, the Freedom Products Hot tip is the one identified in
    item I as "a" but with the description as in the new Appendix
    II as mentioned above.
4.  Section 9- Applicability

    The device can be made tamper proof by drilling a small
    hole near the needle end: and1 running a wire through
    the hole1 and installing a, lead seal between the two
    heaters.  On single application a  Stamped
    part as illustrated here is installed under
    a carburetor flange mounting nut and wired  to the heater.

5.  Section 10- Installation Instrustions

    The installation instructions for the solid needle and the
    Hot Tip with air bleed are virtually the same.  The Hot Tip
    usually has to be backed out a little more, because of the  air
    bleed, to get a smooth idle.  The addition of the vapor or
    filter bottle would require a simple diagram showing a vacuum
    line from the heater end to the bottle.  The bottle is mounted
    on any available space under the hood with a bracket held on
    by sheet metal screws.

6.  Section 12-Maintenance

    The only maintenance that is required is the same as for any
    carburetor in that continued usage causes carbon build up in
    the idle circuit.  If it gets plugged up as with a stock idle
    screw it may haveto be removed for a regular carburetor cleaning
    job.   The electrical part has 100% Safety margin against
    burn out and we have never had a failure so far.

-------
                                                                             54
   7.   Section  15- Test  Results

       Yes,  the test was  conducted using needle D.

   8.   The  reduction in  emmisions and  improvement  in  fuel economy
       have  varied depending on  the  condition of the  engine and
       especially the  carburetor.  Individual driving habits are also
       a  factor.  On cars without serious problems we have dropped
       emissions from  25% to 75%.  Mileage  increases  have been from
       very little to  20%.

   9.   The marketing of  the device is  the most difficult problem to
       solve. I have interviewed promoters,brokers, wholesalers,
       retailers and have been approached by two large corporations
       interested in an  out right purchase..  I believe the device
       should be sold  through qualified shops since the best results
       are obtained when  infra-red equipment is used  for adjusting
       the needles. It is not impossible for good mechanics to install
       them  by  "ear"',  but I don't believe the average "back yard" mechanic
       could achieve maximum benefits.  Therefore  I prefer to see them
       installed with  the use of equipment.  It is also extremely
       beneficial to check the air cleaner, to make sure the carburetor
       float is set correctly and to check  to see that the ignition
       system is in order.  The  infra-red machine can give an immediate
       clue  is  the carburetor float  is not  operating  correctly.

   10.  A  wiring harness  is included  with each set and includes a
       9  amp fuse and  holder.

   11.  The price, of the  Hot Tip  Heater may  be adjusted to $79.95 as
       it is more costly  to manufacture.  The installation should
       cost  the same if  no vapor bottle is  used and some shops may
       possibly want $25.00 if the bottle is used.  The $20.00
       installation  is  an average cost.  Some heaters, as on a
       Courier, can be installed in  half the time and should not
       cost  as  much.

       Thank you for the  opportunity to answer these  questions.  I
   will look foward to hearing from  you after you have looked over
   the  information.
   Sincerely,
   Jack  Passey Jr.
   President of
   Freedom  Products
425

             Ca 95076

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 cf
I
                                                                   Attachment F
To        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY            55
 UJ
^                       ANN ARSOR. MICHIGAN  48105
f

  March 9, 1982
                                                                    OFFICE OF
                                                              AIR. NOISE AND RADIATION


  Mr. Jack Passey, Jr.
  425 Hecker Pass Road
  Watsonville, CA  95076

  Dear Mr. Passey:

  The  purpose  of  this  letter  is  to  confirm  the  items  discussed in  your
  letter  of February  19 and  clarified  in  our  telephone  conversation  of
  February 24.  We are  also providing you with a suggested test  plan which
  you  can use at an independent laboratory to evaluate the "Hot Tip".

  Following is a summary of what we understand from recent communications:

       1.  Appendix I to your  application of November 24, 1981 described an
           earlier device.   It was submitted  for information  only and  does
           not apply directly  to your application.

       2.  Appendix  II  of   your   application  described  a  model  with  an
           unshielded long  internal air  bleed with  undercut  threads  provid-
           ing an external  air bleed.  The application no longer  applies to
           this model.

       3.  The copy of  the  patent  enclosed with your  letter  of February 19
           describes  the device   to  which your  application  applies.   It
           incorporates a shielded,  heated,  long  internal air bleed.  This
           model can be used with  or without a vapor bottle.

       4.  The air bleed of the needle is preset.  There is  no clamping of
           an attached  bleed hose either to  check out,  install,  or  adjust
           the air flow through the  bleed.  The  only adjustment is  by the
           turning of the threaded needle in the carburetor  body.

       5.  The  application  currently  covers  the  model  without  the  vapor
           bleed.  You were  unsure  as  to whether  the  application  should
           also  cover the  vapor   bleed  version.   Please inform  me  if  the
           vapor bleed model is to be included in the application.

       6.  The installation instructions in your  application apply  to the
           device now described as having no vapor bleed.

       7.  If you  decide  the vapor bleed  model  should be included in  your
           application,  please provide  the installation and  operating in-
           structions for  it.  Be sure  to include instructions about  re-
           filling the reservoir.

       8.  For the vapor  bleed model, you were  unsure of the water  level.
           What  is  the height  in  inches of the water level   in  the  bottle
           above the submerged end of the air inlet tube?


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                                                                           56
     9.  The electrical load of  a  single needle is still  the 2 1/2  amps
         quoted in your letter  of January 4.

     10. From a standpoint of  electrical loads on the vehicle,  there are
         no problems associated  with  hooking  up two needles to  the  igni-
         tion switch.

     11. The test data  submitted with your application was for  the  model
         D  (of  your January  4  letter)  which had  a   short  external  air
         bleed.  The application does  not apply to  this model.

We now  believe  we have sufficient  information so  that we  can assist you
in developing  a  test  plan for  your   use  at  an independent  laboratory.
Enclosed is a family of general  test  plans which can  be used  in evaluat-
ing your device.  It appears that  test plan code A (no parameter  adjust-
ments  and  no mileage  accumulation required) using test  sequence code  4
(claims for  device  on city and  highway, device does  affect cold  start)
would  be  the most  appropriate Test  Plan/Test  Sequence  to  use.  On  the
other hand, Test  Sequence code  1 (claims for device on city and highway,
and device does not affect cold  start) would also be acceptable  to  us and
would cost less.

For test plan A,  the baseline  test  is  conducted  with the vehicle adjusted
to manufacturer's specifications,  not "best  idle".   Since you  previously
indicated that you felt best idle  should be the  baseline,, you may  wish to
add parameter adjustment  tests  by  using test plan code B.  However,  this
will increase the number  of tests  on  each  vehicle  and  add  to the  cost of
the testing.

Your letter of February 19 indicated  you expect  the fuel economy benefits
to vary between  0%  and 20% based on your  road test experience.   If  a
similar  level  of  vehicle-to-vehicle   variability  is   encountered  in  the
laboratory tests, you will need  to test a number of vehicles.   For  exam-
ple,   if the  average fuel  economy improvement  achieved in  testing  the
device is less than 5%, you will need  to test  more  than  three  vehicles to
verify the fuel economy improvement.

In order to  minimize the  potential costs, you  may  wish  to test vehicles
sequentially rather  than  as a  group.   On this basis,   you could  initially
test two or  three vehicles.  If  the test results are   not conclusive,  you
could  schedule another  complete  test  sequence  on additional vehicles, one
at a time.

Also, please note that the number  of  individual  tests  required by  a  given
Test Plan  and Test  Sequence  refers  to  the number of valid  tests  on  a
vehicle that is in proper tune  when tested.

Since  I would  expect the  results  to  differ  between your basic  model and
the one with the  vapor  bleed,  it will be necessary to test each configu-
ration  separately.   To minimize the  test  requirements,  the same  vehicle
fleet could be used for both configurations and  it would not  be  necessary
to rerun  a second set  of baseline tests.  The  tests  on the vapor  bleed
model could immediately follow tests on the basic model.


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                                                                           57
I  am prepared  to assist  you further  in  the  development of  your  test
plan.  Please  inform  me of your  progress by March 22.   If  you have any
questions or require further information, please contact  me.

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

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                                                                         ATTACHMENT G
      Jff
       \    UNITED STATES ENVIRONMENTAL  PROTECTION AGENCY             58

^^•s$£>-/                   ANN ARBOR. MICHIGAN 48105
 %. ^

                                                                       OFFICE OF
                                                                 AIR, NOISE AND RADIATION


    April 12,  1982
    Mr. Jack Passey,  Jr.
    425 Hecker Pass Road
    Watsonville,  CA   95076

    Dear Mr. Passey:

    Since  I haven't  heard  from you recently,  I am writing  to determine the
    status  of your test  program on the "Hot Tip".  In your telephone  response
    to my  letter of  March  9,  you stated that  you  intended  to negotiate with
    other  independent  laboratories.   You  also  promised  to  supply  several
    pieces  of information that we still have not received.

    In my  letter I suggested  that Test Plan  A, using Test  Sequence  1  or 4,
    appeared to  be the most appropriate  test  plan.  I also  commented on the
    idle adjustments.  Please  provide  a copy  of the test plan you expect to
    use and tell me which laboratory you have  chosen  and when the testing is
    scheduled.

    Again,  I am  prepared to assist you in  the  development  of your test plan.
    Please  let me know of  your progress  by April 23.  If you have any ques-
    tions or require  further information, please contact  me.

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

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                                                                           ATTACHMENT H

                                                                                     59
f  £\  To        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
        r                       ANN ARBOR.  MICHIGAN  48105


         May 27, 1982                                                       OFFICE OF
                                                                      AIR. NOISE AND RADIATION


         Mr. Jack Passey, Jr.
         425 Hecker Pass Road
         Watsonville, CA  95076

         Dear Mr. Passey:

         We still lack  appropriate  test  data to support your  claims  for your "Hot
         Tip".   As  I  explained  in our earlier letters and telephone conversations,
         we are  obligated  to publish  our  evaluation in the Federal  Register.  We
         cannot  delay that  action indefinitely  and have begun  to prepare our eval-
         uation.  Therefore,  I must  ask you again  to  provide  the  information we
         need or we will have to complete  our  evaluation and  publish our conclu-
         sions with the information at hand.

         We have yet to see  your plan  for the te«t program  you are  planning to
         undertake.  As we  explained, if we do not  have  the  opportunity to  review
         your plan,  you run  the risk of an oversight  that might  invalidate your
         whole  effort.   We recognize  that  such testing  is  expensive  and  want to
         ensure  that your testing will meet  our needs.

         Because of the inordinate amount  of time that has passed  since we  first
         received your  application and the  difficulties encountered in getting the
         information  for us to  analyze,  we are faced with the  need  to establish a
         deadline.   That  deadline is July  2.   At  that  time,  we will conclude our
         evaluation,  with  or without  the  requested information.  We  believe that
         that date  allows  enough time for our review of your  plan and the conduct
         of the  program at  an independent  laboratory.  As we  stated previously, at
         least  two  or three  vehicles  should be  tested.   If the data from the  inde-
         pendent laboratory indicate a meaningful fuel  economy or emissions  bene-
         fit, EPA may perform confirmatory  tests.

         Please  let us know when you  send us the  test plan  what  laboratory you
         have selected  and  the  scheduled dates for  your  testing.   If you have any
         questions  about  our requirements,  please contact me  immediately at  (313)
         668-4299.

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

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