EPA-AA-TEB-511-83-1
EPA Evaluation of the Malpassi Filter King Device Under
Section 511 of the Motor Vehicle Information
and Cost Savings Act
by
Stanley L. Syria
January 1983
Test and Evaluation Branch
Emission Control Technology Divison
Office of Mobile Sources
U.S. Environmental Protection Agency
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EPA Evaluation of the Malpassi Filter King 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.
In 1977, the marketer of the Malpassi Filter King submitted an
application for an EPA evaluation of the device. EPA evaluated the
device and determined that while there may be fuel economy benefits for
some vehicles, these would be offset by certain driveability and safety
problems. That conclusion was based on various tests conducted for the
marketer by American Motors Corporation (AMC).
Since that evaluation, the marketer has contended that the Agency's
conclusions were inappropriate because the device had been incorrectly
installed on Che test vehicle during a portion of the AMC tests. For
this reason, the marketer requested that EPA reconsider the facts and
reevaluate the device.
The Agency did reconsider all available information and determined that
the device may have been installed incorrectly during most, if not all of
the tests. Additionally, the test vehicle was not representative of the
current population and the test procedures followed would not likely show
the true benefits of the device. Some on-the-road test data from the
marketer and the theory of operation also suggested there may be fuel
economy benefits. For these reasons, the Agency decided to reevaluate
the device. Accordingly, the marketer submitted a new application in
February, 1982. The device, which has not changed since EPA's first
evaluation, is claimed to improve fuel- economy and engine performance.
It is classified by EPA as a fuel pressure regulator.
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 Malpassi Filter King under Section 511
of the Motor Vehicle Information and Cost Savings Act
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2. Identification Information;
a. Marketing Identification of the Product:
"This device is marketed under the name of Malpassi Filter
King. The die casting which makes up the upper half of each
unit shows the following information - Filter King - Fuel
Pressure Regulator - Patented - Made in Italy - Malpassi -
Seregno."
b. Inventor and Patent Protection;
(1) Inventor
"The inventor is Remo Malpassi, Via Montello 56, 20038
Seregno, Italy."
(2) Patent
"A copy of U.S. Patent 3695438, dated 1972, [See Attachment
A of this evaluation.] is contained in the Blue Book .
The patent was taken out by Alberto Malpassi."
c. Applicant:
(1) Name and address
Techimport Limited
119 Glen Road
Toronto, Canada M4N 2W1
(2) Principals
"The principal officers of this company are R. H.
Scrivener, President, and P.F. Coulter, Vice-President,
both of Toronto."
(3) "Tecnimport Limited will be represented by - R. H.
Scrivener, 119 Glen Road, Toronto, Ontario, Canada M4N 2W1;
telephone 416-924-2813."
The "Blue Book" was submitted with the application. It contains a
number of documents related to design and performance of the device.
Because of its size, the Blue Book has not been reproduced as an
attachment to this evaluation. Instead, appropriate excerpts have been
included. Individuals may obtain additional information on the contents
of the Blue Book by contacting EPA at the address listed after the
Conclusion Section of this report.
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d. Manufacturer of the Product:
(1) Name and address
"The device is presently manufactured by Malpassi in
Seregno, Italy.
"If sales volume became large enough, the device would be
manufactured in the U.S.A."
(2) Principals
"The principal officer and owner of Malpassi is Alberto
Malpassi."
3. Description of Product;
a. Purpose;
"The purpose of the Malpassi Filter King is to save gasoline by
improving the fuel economy of carburetor-equipped, automotive
engines."
b. Theory of Operation;
[The Malpassi Filter King is claimed to reduce and regulate fuel
pressure to the carburetor float bowl in such a way as to
eliminate the detrimental effects of fuel sloshing and pressure
pulsations which occur during conventional vehicle operation.
A more lengthy description of its theory of operation as
supplied by the applicant is found in Attachment B.]
c. Construction and Operation:
"The manner of operation of the Malpassi Filter King is fully
described-'-in the material filed with respect to U.S. Patent
3695438, which also contains a schematic diagram. [See
Attachment A.]
"Of particular note is the large area of the diaphragm which
ensures very precise control of the outlet pressure at all flow
rates and complete damping of the fuel pump generated pressure
pulsations in the fuel line. The degree of fuel filtering
provided by the large filter and its bowl is superior to that
provided by most original equipment. The flow control valve,
which is operated by the diaphragm and the spring, makes its
seal by means of a neoprene "0" ring which ensures tight closure
and long life.
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"The unit is well made of the best materials - mainly brass,
stainless steel and aluminum - and it will easily outlast the
vehicle on which it is installed."
d. Specific Claims for the Product;
"The principal claim made for the Malpassi Filter King is that
it saves gas.
"Because of the infinite variation in the performance of
automobile engines - even between identical makes and models -
and the added variable of the driving habits of individual
drivers, we do not claim a specific percentage fuel saving. We
prefer to indicate that the average improvement in fuel economy
should lie somewhere between 10 and 15 per cent. We leave it up
to the buyer to decide if he is satisfied with his improvement
in fuel economy. Therefore, if for any reason he is not
satisfied after a 30-day trial period, his money is refunded
without queston.
"A further claim is made that the use of the Malpassi Filter
King improves engine performance, i.e. that the engine will
^operate more smoothly at the lower outputs. The improvement of
performance was the original objective behind the development of
the Malpassi Filter King, but it was soon found that improved
performance equated to better fuel economy. Now, fuel savings
have become the prime benefit.
"Our basic claim may be summarized as a fuel saving of around
ten (10) percent, without penalty with respect to engine
performance or risk of engine damage or interference with the
functioning of emission control devices."
[The balance of Section 3.d addresses supporting test data and
has therefore been relocated as Attachment C.]
e. Cost And Marketing Information;
"The only sales of the Malpassi Filter King in the United States
have been related to minor marketing research studies.
"The actual cost of the Malpassi Filter King will depend upon
the marketing method selected. The likely cost to the user
would appear to lie between $49.95 and $59.95. Installation
would be extra.
"Until we have approached potential marketers, we are not sure
of t.he final marketing method."
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4. Product Application, Installation, Operation, Safety and Maintenance:
a. Application
(1) "The Malpassi Filter King is applicable to all automotive
engines which operate on gasoline and have a carburetor in
which the flow of fuel is controlled by a float/float valve
system.
"The Malpassi Filter King cannot be used with gasoline
engines having fuel injection systems or with diesel
engines.
"Only one model - No. 4 - is marketed in North America.
This model can be set to deliver fuel to the carburetor at
any pressure between 1.50 and 3.75 pounds per square inch.
As received from the factory, the units are set to give an
output pressure of 2.25 pounds per square inch, which suits
most of the cars on the road. If the owner wishes, the
unit can be "tuned", i.e., the outlet pressure modified by
turning the screw at the top, as set out in the Fitting
Instructions [See page 3 of Attachment D]. Often, tuning
increases the fuel savings by two or three percentage
points."
(2) "The operation of the Malpassi Filter King is not affected
by types of driving, weather or topographical differences.
"According to Professor Huf (Blue Book), the Malpassi
Filter King is particularly effective during travel through
high mountains and under extreme climatic conditions."
b. Installation - Instructions, Equipment, and Skills Required:
"Installation instructions are packed with each unit. A copy of
these instructions is included in the Blue Book. [See
Attachment D of this evaluation.]
"The unit comes complete with all materials required to install
it in the engine compartment of the vehicle, e.g. hoses, clamps,
mounting bracket, bolts and self-tapping screws.
"The installation of the unit requires little skill and usually
takes about half an hour. Simple tools such as a screwdriver,
pliers, a small wrench, a sheet metal drill and a tube cutter
are all that is required.
"The Malpassi Filter King is merely inserted in the fuel line,
at a convenient point, between the carburetor and the fuel
pump. The installation instructions deal, also, with special
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situations, e.g. in the case of AMC vehicles, the unit is
installed between their filter/return line assembly and the
carburetor.
"The unit can be installed as received from the factory, without
adjustment. Or, if the owner prefers, the unit can be "tuned"
to optimize fuel savings.
"The installation of the Malpassi Filter King does not require
adjustment to any part of the engine."
c. Operation:
"The installation instructions contain sections dealing with
operation and maintenance.
"The only maintenance required is the annual changing of the
corrugated paper filter in the aluminum bowl attached to the
underside of the unit."
d. Effects on Vehicle Safety:
"The reports of the testing of the Malpassi Filter King by the
Air Resources Board of California confirm that the operation of
the unit does not change the air/ fuel ratio of the mixture
delivered by the carburetor to the engine. Therefore, there is
no risk, even at the lowest possible setting, of "lean burn" and
engine damage. Nor is there any danger to the occupants of the
vehicle.
"The unit is always in use and we have had few reports of any
malfunctions. Occasionally, an owner will lose the adjusting
screws but the engine will continue to function.
"As the Blue Book records, the Malpassi Filter King is standard
factory equipment on a number of vehicles. Some of these have
very expensive engines, so that it would be unlikely the
manufacturers would use the unit if there was the slightest
chance of damage or fall-off in performance."
e. Maintenance:
"The only maintenance required is the annual changing of the
fuel filter which is contained in the aluminum bowl attached to
the underside of the unit.
"The use of the Malpassi Filter King does not effect the normal
maintenance of the engine. However, because minor flooding is
much reduced by its use, the interior of the engine remains
relatively free of carbon and spark plugs remain clean over long
periods."
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5. Effects on Emissions and Fuel Economy;
a. Unregulated Emissions;
"The Malpassi Filter King was thoroughly tested by the Air
Resources Board of California and cleared for sale in that
State. The ARB testing and their 1981 re-evaluation of the unit
are covered in detail in the Blue Book. [See Attachments E-l
through E-3.] In general terms, the ARB concluded that the
Malpassi Filter King did not cause additional contaminents to be
released to the air and that it did not interfere with the
functioning of automotive emission control devices".
b. Regulated Emissions and Fuel Economy;
"The fuel economy effects of the Malpassi Filter King have been
dealt with in 3.d. Specific Claims. [The supporting test
information in Section 3.d has been relocated to Attachment C
for the readers convenience.]
"The various reports of the Air Resources Board of California
have been reproduced in full in the Blue Book." [See
Attachments E-l through E-3.]
6. Testing by EPA;
EPA did not conduct confirmatory testing of the device for this
evaluation because the test data submitted by the applicant did not
adequately support the claims made for the device.
7. Analysis
a. Identification Information:
Marketing Identification: EPA's only concern with the marketing
identification is that the model number apparently is not marked
on the device. The Agency believes it should be located on the
device even though only one of several models is currently
marketed in North America (according to Section 4.a.(l) of the
application).
b. Description;
(1) The primary purpose of the device, as stated by the
applicant, is to "save gasoline by improving the fuel
economy of carburetor-equipped, automotive engines". Based
upon the description and theory of operation of the device,
.the Agency finds no problem with the statement.
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(2) The theory of operation given in Section 3.b. of the
application was judged to be adequate. It appears the
device is intended to control the fuel pressure and thereby
prevent overfilling of the carburetor float bowl and
consequential overenrichment of the air-fuel mixture.
(3) The description of the device given in U.S. Patent 3695438
was judged to be adequate. Additionally, the device
appears to be constructed of appropriate materials, i.e.,
brass, stainless steel, and aluminum. Because a sample was
not examined, the Agency could not judge the quality of
manufacturing associated with the device.
(4) The device is claimed to improve fuel economy and
performance of carbureted engines. The applicant claims
that on the average, fuel economy will improve by 10 to 15
percent. The applicant supports this claim by stating that
if the buyer is not satisfied with the device after a 30
day trial period, the buyer's money will be refunded
without question. Despite the guarantee made, the
applicant did not submit adequate data to substantiate such
claims. Thus, without additional information and test
results, EPA cannot determine if the claims are reasonable.
(5) The cost of the device, as given by the applicant, is
between $50 and $60. EPA estimates that installation time.
would be from 30 to 60 minutes and assuming a shop rate of
$20 per hour, the installation cost would be an additional
$10 to $20. Thus, total cost would be between $60 and
$80. Assuming a 10% improvement in fuel economy with costs
of $70 per device and $1.40 per gallon of fuel, a vehicle
averaging 20 MPG would have to be driven about 11,000 miles
to recover the cost.
Application, Installation, Operation, Safety and Maintenance;
(1) Applicability:
The stated applicability of the product appears to be
appropriate.
(2) Installation - Instructions, Equipment and Skills Required;
The installation instructions (Attachment D) submitted by
the applicant were judged to be quite thorough.
Additionally, the applicant's statement that the
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10
Installation requires little skill and only simple tools
was also judged to be accurate. Overall, based on the
design of the device and the adequacy of the installation
instructions, EPA does not expect purchasers to experience
difficulty when installing the device.
(3) Operation:
EPA agrees that the device can function properly and will
not require any controlling action by the driver.
(4) Effects on Vehicle Safety;
Since the device is to be installed in the fuel line, there
are some fire hazards associated with its installation and
use. With proper installation, check-out and periodic
inspections, there should be no unusual danger. On the
other hand, the Agency is concerned about potential
driveability problems during hard accelerations and high
temperature conditions. Since the device is intended to
significantly reduce fuel pressure, it may aggravate the
tendency for vapor lock. This, in turn, will affect engine
performance (e.g., hesitation, stalling, etc.).
The reader should note that the Agency's conclusions given
in the final report during its first evaluation of the
Malpassi Filter King in 1977 were that the "device did not
benefit the nation because of driveability and safety
problems associated with it". This conclusion was reached
after learning that the device had caused driveability
problems during hot weather testing of the device by
American Motors Corporation (AMC). Subsequent to the
release of the Agency's final report, the applicant
presented enough information to cause the Agency to decide
the device may have been installed incorrectly during part
or all of the AMC testing . For this reason, the Agency
decided the driveability problems noted during the AMC
tests were perhaps unjustly attributed to the device. The
applicant was notified (Attachment F) that during EPA's
reevaluation of the device, the Agency would not base its
conclusions on the AMC test results and that it intended to
evaluate the driveability characteristics associated with
the device. EPA also suggested in the same letter that an
installation instructions state that for those vehicles having an
in-line filter/return line assembly, the device must be installed between
the assembly and the carburetor. It appears that during the AMC testing
program, the device was installed between the assembly and the fuel
pump. Consequently, fuel pressure was overly reduced.
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11
independent test facility evaluate driveability under "hot
soak" conditions at temperatures above 90°F. However, the
applicant did not submit the required test data. For this
reason, EPA does not have data showing whether or not there
is a safety related problem associated with the device.
Because of the design of the device (and not because of
AMC's test results), the Agency is concerned about the
safety aspects of the device.
(5) Maintenance;
The applicant states the only maintenance required is the
annual changing of the fuel filter which is contained
within the device. The applicant also states the spark
plugs remain clean over a longer period of time. EPA
judges that replacement of the fuel filter is not likely to
be a difficult task to perform. With respect to the spark
plugs remaining clean, EPA judges that should the device
indeed be capable of lowering emissions and improving fuel
economy, then it seems plausible that the combustion
chamber (and spark plugs) should remain clean longer.
However, the applicant did not provide any test data or any
other evidence to substantiate that statement ajid
therefore, EPA cannot support that claim.
d. Effects on Emissions and Fuel Economy;
(1) Unregulated Emissions;
The applicant states that the device had been tested by the
Air Resources Board of California (ARE) and that the test
data was contained within the Blue Book. That data
(Attachments E-l through E-3) showed that ARB tested the
device with respect to regulated, not unregulated
emissions. EPA notified, the applicant of this fact and
requested that he submit information for unregulated
pollutants (Attachment F). The applicant did not respond
to the Agency's request.
Although appropriate information was not submitted, it is
EPA's engineering judgement that based on the design of the
device, the Malpassi Filter King is unlikely to adversely
affect unregulated pollutants.
(2) Regulated Emissions and Fuel Economy;
The applicant did submit test data (see Attachments C and
E-l through E-3) to support the claims made for the
device. EPA evaluated the data and noted several problems
associated with it. These concerns were expressed to the
applicant in two letters (Attachments F and G) and are
summarized as follows:
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12
(a) AMC Test Data
1_. Testing was performed on a chassis
dynamometer. This stationary operation is
unlikely to reveal the full potential of the
device due to the relatively small amount of
fuel bowl sloshing during the test.
2_. The fuel line system on the AMC vehicle
tested was not representative of the
population of in-use vehicles.
3. Only one vehicle was tested and an
inadequate number of complete tests were
performed. Therefore, statistically sound
results were not possible.
4^ Some test results were obtained using models
of the device other than that covered by the
current application for evaluation.
5_. The device appears to have been installed
incorrectly on the test vehicle during some
or all of the tests.
(b) ARB Test Data
The ARB test data consisted of steady-state tests
performed on one vehicle. Although the tests were
adequate for ARB purposes, they did not entirely
satisfy EPA's test requirements. That is, because of
the absence of fuel bowl "sloshing" during
steady-state testing, the ARB data did not show the
capability of the device in controlling instances of
overenrichment. Therefore, fuel economy benefits
attributable to the device could not be accurately
determined.
With respect to exhaust emissions, it is EPA's
engineering judgement that based on its design, the
device should not have an adverse effect on either
emission levels or on emission control systems
regardless of fuel bowl "sloshing". For this reason,
even though there was an absence of "sloshing" during
ARB's testing, that data was judged to be adequate in
showing the effect of this device on emissions. That
data showed the device did not significantly change
the emission levels for either hydrocarbons, carbon
monoxide, or nitrogen oxides.
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13
(c) Independently Conducted On-Road Tests
Of the 47 test results submitted, most were inadequate
because of one or more of the following reasons:
1. Unrepresentative vehicles.
2. Insufficient number of vehicles tested.
3. Replicate testing not performed.
4. Inadequate control of test variables.
5. Back-to-back testing not performed.
Although most of the test results were not adequate,
there were a few that were satisfactory enough to
suggest that there may be fuel economy benefits
associated with the device and that additional testing
should be conducted to confirm whether the benefits
were real. EPA assisted the applicant in developing a
test plan which would provide well controlled on-road
data.
The applicant was requested repeatedly (Attachments F,
G, and H) to provide the additional test data
required, however, he failed to do so. The applicant
notified the Agency he was arranging to have the
device tested in Michigan by Bendix Corporation but
had encountered a number of delays in working out the
testing arrangements. Despite the delays, the
applicant indicated he still intended to obtain the
required data. The applicant had been given ample
time (more than eight months) to submit the required
test data but by this time, winter had arrived. Its
adverse and unstable conditions are not conducive to
on-road testing. Rather than delay the evaluation
awaiting better weather, the Agency notified the
applicant (Attachment I) that it was completing its
evaluation of the device using all available
information. He was extended the invitation to
reapply for another EPA evaluation as soon as he
obtained adequately controlled test data which
substantiated his claims. Subsequently, the applicant
notified EPA that Bendix Corporation would not be
testing his device and that he was instead working out
testing arrangaements with Southwest Research
Institute (SwRI) in San Antonio, Texas. He further
stated the testing might possibly be finished by
Christmas or shortly thereafter (another 1 1/2 to 2
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14
8. Conclusions
month delay). The Agency notified the applicant that
it would proceed with its final evaluation report and
any data submitted prior to its release would be
considered and may be incorporated in the report. By
March 1, the report was ready for release and data had
not yet been submitted by the applicant. The Agency
tried contacting the applicant in a final effort to
determine if test data was about to be submitted.
However, thus far the Agency has not been able to
reach him. The Agency also checked with SwRI to see
if testing had been performed. SwRI stated the
applicant was sent a proposed test plan in mid-January
but that he had not responded. Thus, with no data
immediately forthcoming, the Agency decided to release
its report.
EPA fully considered all of the information submitted by the
applicant. The evaluation of the Malpassi Filter King device was
based on that information and EPA's engineering judgement. While it
is probably true that some fuel can be wasted as a result of
overenrichment due to sloshing and late closing of the float valve,
there is no evidence that such losses are significant or that this
device can minimize them. Thus, there is no technical basis for EPA
to support the claims made for the device or to perform confirmatory
testing. Moreover, there remains some concern for the effect of the
device on driveability and safety.
FOR FURTHER INFORMATION CONTACT; Merrill W. Korth, Emission Control
Technology Division, Office of Mobile Sources, Environmental Protection
Agency, 2565 Plymouth Road, Ann Arbor, MI 48105, (313) 668-4299.
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15
Attachment A
Attachment B
Attachment C
Attachment D
Attachment E-l
Attachment E-2
Attachment E-3
Attachment F
Attachment G
Attachment H
Attachment I
List of Attachments
Copy of U.S. Patent No. 3695438
Excerpt from Section 3.b. of the application for
evaluation containing the theory of operation of the
device.
Excerpt from Section 3.d of the application for
evaluation containing supporting test results.
Copy of installation instructions (excerpt from Blue
Book).
Copy of Air Resources Board of California Executive
Order D-79, April 17, 1978.
Copy of Air Resources Board of California Executive
Order D-79-1, January 12, 1979.
Copy of Air Resources Board of California Executive
Order D-79-3, April 1, 1981.
Copy of letter from EPA to Techimport Limited, April
20, 1982.
Copy of letter from EPA to Techimport Limited, June
24, 1982.
Copy of letter from EPA to Techimport Limited, July
22, 1982.
Copy of letter from EPA to Techimport Limited,
November 8, 1982.
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.'' .:- •.' V " -.••••••.'•••. • - .-/: ;• 2
GASOLINE PRESSURE REGULATOR DEVICE vcntion, illustrated by. way of example in the accom-
BACXGROUND-OFTHE INVENTION' ''.
1 is a longitudinal sectional view of a petrol-
The present invention relates to a petrol or gasoline pressure adjustment device according to the invention;
tenure regulator device which is of particular, but not 3 FIG. 2 is a sectional view, to an enlarged scale, of a
sclusive, use in motor vehicles.. . "• . '.•••• valve portion of the device of FIG. I; :"
It is known thai in motor vehicles the fuel (petrol) FIG. 3 is a perspective view of the same petrol-pres-
untamed in the vehicles fuel tank is passed to the car- sure adjustment device; and
-ureter and thence to the explosion chamber by a 'FIG. 4 is a view in an enlarged scale, of a valve ele-
Mmp called the petrol pump, ment according to a further embodiment thereof.
Since the thrust exerted on the fuel by the pump is
'^continuous or fluctuating, it has for long been sug- • DESCRIPTION OF THE PREFERRED
*««ed to interpose a petrol-pressure adjustment EMBODIMENTS^
•ember between the petrol pump and the carburetor. ,5 With reference to the figures, 1 indicates the rezula-
whkh m xpmWli by a Iajnirar diaphragm 9 The
«. even when the pressure of the petrol amvmg at 23 ^ chajnber 7 u $ubstantiajjy dosed. The position of
-« device is subject to considerable variations, such , ^ ^^ diaphrasm 9 may ^ ^fuied by mean, of
<"*w beinS adjust" e over a wi e range o v ucs in m adjustment screw 10. The head of the screw 10 is
Jer to satisfy_the needs of the members employing covefed fa a „ ^ H
-fueKthe carburetor and the engine). '„ between the screw 10 and the diaphragm 9.
bother object of the present Invention ,, that of 30 ^ ^ ^ ^ ^ fluid. ht communjcation w{th
/ : -.HJing a petrol-pressure adjustment or regulator ^ ^ maintained in
V ^e which adjusts the pressure of the petrol by ^tijb , U-shaped tie-rod whos« ends are engaged
- -^matinz impunties contained in the petrol, the ele- : . . . ... . , . . .
...,:. . . . . ,r . . in the body 1 and whose central portion n engaged in
.. it which eliminates such impurities being replaces- • .. . ,i r u «-i i i i •£. ^. ra "'5 8
.33 the tang 15 of the filter body 2. The body 2 internally
voother object of the present invention is that of £?"** a fi'f .»«nber 16 of the replaceable cartridge
. - ..ding a petrol-pressure adjustment device which b .k'nfd' comprising filter surfaces, (not shown) arranged
nple construction and use. ' in 17 between end plates 18 and 19 and the cylindrical
. further object of the invention is that of providing cavily 20- *&"** the Jower end Plate 13 of the filter
.ol-pressore adjustment device which may be 4O "ember 16 there acts a spring 21. The upper end plate
-luced in relatively small sizes and^may be readily 19 of-the. filter 16 has a circular hole adjacent a com-
ried and mounted in very small spaces. , mumcation passage 22 between the body 2 and the
^cording to the invention there is provided a body 1. A» is clearly shown in FIG. 2, said communica-
-• -l-pressure adjustment device, particularly fer 4J »»" passage 22 includes a cylindrical *cat 23 for the
• .4 vehicles, characterized in thai it comprises an valve member 3 and a relative thrust spring 24. The
• ...imcnt body and a filter body which are in fluid- upper end of said seat 23 has a conical tapered portion
.,».: communication through an aperture and a com- which opens into a cylindrical duct 26 whose upper end
-otcation duct, said adjustment body comprising a communicates with a apertures 27, provided in the
• »< and a second chamber separated by a laminar 50 number 27a which also forms guiding means for the
ir-hragm, said first chamber being substantially valve stem 30. ' . -.
—*o for said delivery duct.
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< 3,695,438 -.
. • ' • 3 '".;••'. . '•• .:• 4 ;
» Kj 3 ii. -t union 32, respectively.- / ' such a manner, "however, as to cause the latter to pro-
Th« w«.*ktAg of the petrol-pressure adjustment ject through a substantial portion of its inner and lower
device »co"t!mg to the embodiment will now be 3 surface over its seat. The inner diameter of the gasket
described. . . • - ,37. is selected so as to be smaller than the maximum.
Th* petrol pump 33 passes fuel under pressure into diameter of the frusto-conical section 35. '
the mternal tp.ce 6 of the filter body 2 through the ' • ™.e considering now the operation of this valve in
duct S Such fud ( petrol ) passes through the niter cle- ?*tail. it may be seen that the fnisto^onical section 35.
menu 17 to th« cylindrical ipace 20 'and thence, IO m the closed cpndiUon. first makes contact along a cir-
through the communication duct 22 controlled by the ewnference wuh the fixed gasket 37, the said contact
valve member 3. into the chamber 8. The fuel then «f*ing Pla« when the gasket u not m contact with the
leaves the chamber 8 through the outlet union 32 and shoulder 28 yet. Upon a further closing operation the
passes into the carburetor 34. Since the fuel under »*«»» *S «*«« the gasket to expand due to said sur-
preswre which » delivered by the pump 33 has a sub- 15 face having a greater diameter than the gasket 37. Seal-
UantiaJly fluctuating pressure, the chamber 8 will be '"« « al» Pr™de? ^ *? P'««« contact between
forced to expand or contract, like a lung, under the ac- the shoulder 28 and the gasket m the lower portion.
not, of tS. fluctuating pressure of the fuel pacing into Conversely the conical surface permits a more
Ike chm«ber 8 through the duct 22. In particular, the uniform adjustment of the passage opening relative to
..^•^-ionc/ said chamber 8 causes the comprwsion of » ««»"W«"^« of th. valve element. . '•
the son«t 1 2 through the laminar diaphragm 9, while in / or carrying out the elements forming the pressure
the cmiinctioii of the chamber 8, the serin, 12 forces adjuster according to the mvention the used materials
,W dunhram 9 downwards, reducing the volume of could * »* according to requirements.
• . idajm: ' . ,.-.,",,
lowering of the diaphragm 9 ouses the 03 , ?• A P«=««r«r regulator device, particularly for regu-
rUvr valve member 3 and, consequently, the lat»ng gasoline pressure in motor vehicles, of the
owning of th^ communication d«ct 22. It character comprising a regulator body and a filter body
follow* that the pressure of the fuel in th« chamber 8 removably attached thereto, a first and a second
d,p*»rf. J«.-i exclusively on the rate of Oow of fuel chamber provided inside said regulator body, a
,.H-«.., -, .K* c^huretor 34, and is independent of 30 diaphragm mside said regulator body separating said
the pie~- . ,.pp**d to the fuel by the pump 33 up- . first and second chamber from each other, an inlet for
stream ^ '.*. p«tml.pre»ure adjustment device. In this «a»l«« >nto said filler body, means defining a commu
„„, ,h, i,,** p».«HJ« the carbureior and tS* esplo, »eaOon passage between aid second chamber ano
. -«th a now of fuel which does MM fluctu- ««d filter body, valve means inside said communicator
»t-»4c m »ll driving conditions. Differences in 35 Passa8e for opening and closing said communicator
clin,-ie ^ alutua* in which the motor vehicle finds it- P3353^' . »'d . ^v« »«"• hav">8,. » valve sterr
self arr compen,a«cU by the reaction of the diaphragm cooperating with said diaphragm, resilient means ur,
9 The petrol.pre«ure adjustment device can provide a «"«.«^ diaphragm and said valve stem against eaci
•aeHverTpresaure of up to five tim-» that necessary for other and an outlet for gasoline from said, secono
supplying the carburetor with the normal quantity of « chamber and wherein, according to the improvement
* Y 7 * said valve means comprises a generally cyiindrica
" The characteristics described above lead to a savin*! ^ «Be ^^ "ially movable inside said communi
in fuel of from 10 to 15 percent with respect to »imUa71 fa"on P3553^ and ngid w.th sa,d valve stem, an annu
motor vehicles which do not employ an ad,u,«menTl ** V°°™ » «d valve cone body, a projectm,
device according to the invention/ "* - - 1«5 »houWer on said valve cone body adjacent said groov,
Now con.KJcnng Flfl. 4 ,n detail, where the MIT*^ and "^mg two opposite faces, resilient means msidt
elements ~ in FIG- 2 are indicated with the «m* «»d communication passage bearing wuh one enc
r«ferencrn«mber,,«h-evajveelementconsistsofanin-. ' thereof against one of said face, of »,d projcctin,
termed.,** fru,i.-<:onical member or section 35. to the «hauWer and connected wuh other end thereof to sai,
h«« of whwh .here are rigidly connected the stem 5O regulator body, an annular gasket means retaine,
member u. ,- M »« the smaller base and the annular "«h'n f'd .an"ujar 8roore and abu«'n| against th.
shoulder » re^ctively. which radially projects over other of said faces of said projecting shoulder sa,.
he b?«rh^VJm«ly thereto.. . '. means defining sa«l communication passage havmg .
Or L -nnular thoulder 28 at the side opposite the fnisto-comcal portion cooperating with sa,d annula.
fn»u^coo,cal section 35 a spring 24 also acts. The 55 ***« means ,n sealing off. said ccmmun.catio,
Liter re,ts at the other end thereof agairtst a shoulder . P^S* '.when said generally cylindrical valve con.
defined by the seat 23 becoming narrower towards the • body « m its closing position and guidmg means fo
c,,!nmunica.K,n passage 22. said stem of said valve means.
At the frusto-conical section 35 of the valve element • • • • •
«O . •
-------
L nited States Patent
M*l?assi
p «l GASOLINE PRESSURE REGULATOR
DEVICE
.
. 3,228.323 •
'2,633.146
1.863.103
•
1/1966
3/1953
6/1932
;4;-n.si •
.'• t43'
Koate et aJ. .
Witt. _
Do wins..
3,695,438
Oct. -3, 1972
210/137
210/137 X
210/137
Seregno, Italy
221 Filed: July 6, 1970
2 ] Appl. NOJ 52,627
1C?"
Foreign Application Priority Data
July 19, 1969
Feb. 14, 1970 Italy..
B/69
.20863 B/70
l\ UJS.
InCd
Held of Search..
..210/137,210/430
BOld 29/36
210/137,430
( 1 References Cited
UNITED STATES PATENTS
2. 7.051 4/1955 Mailhotetal i 210/137
Primary Examiner—John Adee
Attorney—Quido Modiano and Albert Josif
157]
ABSTRACT
A petrol or gasoline pressure regulator device, par*
ticuiariy for motor vehicles,' comprising a regulator
body with two chambers separated by a diaphragm
and a valve member controlling a communication duct
to one of said chambers and acting on said diaphragm,
the combinated effect of said valve member and of
said diaphragm controlling the pressure of the petrol
or gasoline inside said regulator body.
1 Qaira, 4 Drawing Figures
•*.
•£
-------
PATENTED OCT 3 1972
3.695,438
INVENTOR
Alb«rto MALPAS5I
BY
r
f:
2,7
AGENT
-------
16 - 20
ATTACHMENT A
Patent on device not submitted due to poor legibility.
Information contained in Patent No. 3,695,438 available
upon request.
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21
ATTACHMENT B
[The following information is an excerpt from
Section 3b of the application]
In most automobile engines which operate on gasoline, the fuel
is drawn from the fuel tank and delivered to the carburetor by a
pump which may be either mechanically or electrically driven.
The amount of fuel supplied by the pump is controlled by the
float and the float valve in the carburetor float bowl. When
fuel is consumed, the float bowl level falls and the float
drops, opening the valve which admits fuel to the float bowl.
As this flow of fuel restores the level in the float bowl, the
float rises and closes the float valve, thus shutting off the
flow of fuel from the pump. The intent of this arrangement of
float and float valve is to hold the level of the fuel in the
float bowl at the chosen design height and thus allow the
carburetor to function at maximum efficiency. As power demand
increases from idle to maximum, the level in the float bowl
falls slightly because the float valve must be opened an
increasing amount to provide an increased flow of fuel into the
engine.
Automotive fuel pumps present the fuel to the carburetor float
valve at pressures ranging from three (3') to nine (9) pounds per
square inch, which are considerably in excess of those actually
needed. At pressures of this magnitude, the opening of the
float valve allows the fuel to enter the carburetor in spurts,
and any failure of the float and float valve to properly reflect
the correct amount of fuel required will cause the float bowl
level to rise above the design point. Any fuel admitted to the
float bowl, after the fuel level reaches the design point,
immediately results in an overrich mixture which wastes fuel.
Such a condition is equivalent to continuing to operate an
automobile with the choke partly on.
Two influences act to cause the float to drop and thus admit
fuel to the float bowl - first, consumption of fuel by the
engine and, second, the 'sloshing' of the fuel in the float bowl
caused by the lateral forces due to accelerating, braking and
cornering. When the fuel 'sloshes' in the float bowl, the float
action becomes erratic and float valve opening is unrelated to
actual fuel requirements, with the result that the spurts of
high pressure fuel which are admitted by the valve are
continually overfilling the float bowl with consequent wastage
of fuel.
Apart from high pressure, the very nature of the flow of fuel
between pump and carburetor creates a problem. The pressure of
the fuel fluctuates with each stroke of the pump. In addition,
when the float valve is closed, the expansion and contraction of
the butane bubbles in the fuel stream cause cyclic reversals in
-------
22
the direction of flow, i.e. the fuel actually flows backward
during the suction stroke of the pump. At the high pump
delivery pressures, such pressure pulsations have a hammering
effect upon the carburetor float valve, which can lift it off
its seat.
The effect of fuel sloshing in the carburetor bowl and the
matter of fluctuations in pressure and flow direction downstream
of fuel pumps is clearly set out in an address made by Wilfred
Baatz of the FlowScan Instrument Company Inc. to the Society of
Automotive Engineers in February, 1976. Part of this address is
given in the Technical Section of the Blue Book.
The adverse effect of pressure pulsations created by the fuel
pump is discussed by Stockel in his Auto Mechanics Fundamentals.
Further references to the effects of float bowl slosh and
pressure pulsations are given in Rochester Carburetors by Rowe
and Fisher and in Holley Carburetors and Manifolds by Urich and
Fisher.
Parts of the above three books are reproduced in the Blue Book.
The high pressure at which the fuel is delivered to the
carburetor, together with the pressure pulsations created by the
pump in the fuel line flow, combine with the effect of the fuel
'sloshing' inx the float bowl to create recurring periods of
flooding of the carburetor which, in turn, result in
corresponding periods of over-rich mixture.
The purpose' of the Malpassi Filter King is to reduce the
pressure of the fuel reaching the carburetor to minimum pressure
actually needed to supply adequate fuel and, thus, minimize the
amount of excess fuel entering the carburetor during periods of
erratic float action due to the 'sloshing' of the fuel in the
float bowl.
Also, the large diaphragm in the device acts to eliminate the
pressure pulsations generated by the fuel pump and, thus, the
fuel is presented to the carburetor at a rock-steady pressure,
with laminar flow characteristics, at all flow rates.
In practice, the pressure of the fuel delivered to the
carburetor is reduced to about two (2) pounds per square inch,
the exact pressure being adjusted to suit the particular
requirements of the automobile. This pressure is more than
ample to supply the fuel needs to the largest automobile
engine. The Air Resources Board of California found that, at
1-1/4 pounds pressure (the lowest possible pressure setting),
there was no "leaning" of the air/fuel mixture, and, thus, no
possibility of 'lean burn1 damage to the engine.
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23
The net effect of the functioning of the Malpassi Filter King is
to permit the carburetor float and float valve mechanisms to
function more effectively, as intended by their designer, and
thus reduce the incidence and severity of overfilling of the
carburetor float bowl, with its associated over-rich fuel
mixture and consequent fuel wastage. Thus, the only aspect of
carburetor operation which is affected by the Malpassi Filter
King is the elimination of the peaks of over-rich fuel mixture,
which would otherwise recur constantly.
The carburetor is by no means the perfect instrument for
providing the correct air-fuel mixture to the engine, at all
times. But, when fuel is supplied at a steady, lower pressure,
it is able to perform its intended function more effectively and
consistently. This benefit from fuel pressure regulations has
been recognized for many years and is mentioned in the standard
texts dealing with carburetor operation.
The comments of Professor Huf on the effectiveness of the
Malpassi Filter King, which are contained in the Blue Book, will
be of special interest. Professor Huf, a leading European
expert on internal combustion and the designer of the gas
turbines used by the German air force during the last war, was
retained by the Noldeke firm to advise them as to which of the
several available 'fuel saving devices' they should adopt for
marketing. He recommended the Malpassi Filter King.
In practical terms, the results of many tests in many countries
and the experience of some two million users show that the use
of the Malpassi Filter King Fuel Pressure Regulator will, on the
average, reduce fuel consumption by about ten per cent. These
fuel savings are achieved without penalties in the form of
either loss of engine performance or risk of engine damage.
A similar outline of the theory of operation of the Malpassi
Filter King is contained in the Technical Section of the Blue
Book.
-------
H i . MLni'icrt i C
24
[The following information is an excerpt from
Section 3.d of the application]
The daims made for the Maipassi Filter King, with respect to fuel savings,
are based upon and have been confirmed by a mass of independently-
conducted test work. Two examples of such test work are given below -
(i) American Motors Corporation -
In September, 1977, AMC carried out a series of 23 city-highway CVS
dynamometer tests and achieved a six (6) per cent improvement in
economy without any 'real world1 operating problems.
As the staff of EPA has confirmed that the test work carried out by
AMC is quite as acceptable as that done by the test laboratories
recommended by EPA, the result of the AMC test program must be
accepted as valid and representative of the fuel-saving capabilities of
the Maipassi Filter King, under the particular conditions of the tests.
It should be mentioned that, under the conditions of dynamometer
testing, the lateral forces which act upon the carburetor float bowl
to cause fuel-wasting 'fuel bowl slosh1, i.e. acceleration forces due to
-------
.25
3. d. Specific Claims - cont'd
(i) American Motors Corporation - cont'd
braking, accelerating and turning, are not present as they would be if
the tests were conducted 'on road'. In other words, dyanmometer
testing eliminates a source of fuel wi stage with which the Maplassi
Filter King is designed to deal. Therefore, for basic reasons, the fuel
savings obtained by dynamometer testing will be smaller than if the
same vehicle had been tested on the road. Thus, the six (6) per cent
improvement observed by AMC would be almost doubled if the
vehicle had been tested on the road.
The absence of lateral forces and, therefore, of 'fuel bowl slosh1
during dynamometer testing is one of the reasons why fuel mileage
figures derived on the dynamometer cannot be duplicated when the
same vehicle operates under 'on road1 conditions.
The AMC conducted a further test of the Malpassi Filter King under
what is described as a 'hot soak' test and reported that problems were
encountered - "... several problems after a 20 minute hot soak. In
fact, the test vehicle runs out of fuel at about 45 mph on a wide open
throttle acceleration."
However, if we refer to Rochester Carburetors by Rowe and Fisher,
we find on page 222 - 'One other situation that rises occasionally is a
result of hot soaking during brief stops. It is a fuel-flash condition.
If a car is run at expressway speeds in hot weather then stopped for 5
to 20 minutes, restarted and accelerated at WOT back to highway
speeds it may falter and die out momentarily if the fuel is high in
vapours'.
As all the fuel would have boiled and evaporated from the carburetor
during the 20 minutes of AMC's Yuma desert hot soak, it it quite
normal for the engine to stall if accelerated at WOT to 45 mph.
The fitting instructions for the Malpassi Filter King state specifically
that, with the AMC vehicles, the unit must be installed between the
AMC filter/return and the carburetor. During AMC's hot soak test,
the unit was installed between the fuel pump and the filter/return.
The Malpassi Filter King does not function at its best when installed
in this manner and users are warned to avoid it.
In any.event, considering the common occurrence of stalling under
hot soak conditions, the AMC Yuma desert hot soak test has no
relevance to the fuel saving capabilities of the Malpassi Filter King.
From the foregoing, it can be seen that, under the test conditions
specifically established by EPA for the evaluation of retro-fitted fuel
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26
3. d. Specific Claims - cont'd
(i) American Motors Corporation - cont'd
saving devices, the Malpassi Filter King has proved it is capable of
producing an improvement in fuel economy of six (6) per cent. As
explained above, this fuel saving is equivalent to about 12 per cent
under actual on-road driving xmditions.
(ii) Independently Conducted On-Road Tests -
In our files, we have the results of a large number of independently
conducted, on-road fuel economy tests of the Malpassi Filter King.
Last May, we selected 47 such tests and passed their details and
results to the Office of Energy Savings of the Government of Quebec
for statistical analysis. The results provided ranged from the very
low to high but the criterion for selection was that those conducting
the tests should be considered capable of maintaining accurate
records of fuel and mileage.
This statistical analysis showed that, in 9 cases out of 10, the
potential for gasoline saving, through the use of the Malpassi Filter
King, ranged from 9 to 13 per cent, on an annual basis.
The conclusions of this analysis were subsequently examined and
confirmed as correct by Professor Garneau of the University of
Montreal.
While we recognize the difficulty of achieving the precision of
dynamometer tests under on-road conditions, yet the on-road tests
reflect the effect of fuel bowl slosh on fuel economy and the-
dynamometer tests do not. Also, most of the on-road tests were
continued over a period of time and over substantial mileage which
would enhance their accuracy.
These on-road tests involved many drivers, a wide range of vehicle
types and makes and many thousands of miles of regular vehicle use.
Under these 'real world1 conditions, the Malpassi Filter King showed a
consistent pattern of significant fuel savings, without one instance of
interference with the normal performance of the vehicle.
In the AMC CVS test program, the Malpassi Filter King demonstrated
good fuel savings, without any real world problems. As these tests
conformed in all respects to the requirements set up by the EPA, it
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27
3. d. Specific Claims - cont'd
(ii) Independently Conducted On-Road Tests - cont'd
follows that adequate proof of significant fuel saving capability has
been provided to the EPA.
The results of the AiVlC Yuma desert 'hot soak1 test are commonplace
and have no relevance to the fuel saving capabilities of the Malpassi
Filter King. To apply such a test to the Malpassi Filter King would
be to discriminate against it.
While the AMC tests showed that the Malpassi Filter King could save
fuel under the laboratory conditions specified by the EPA, the results
of the many on-road tests showed that these results were repeatable
outside the laboratory and even larger savings could be achieved with
good consistency.
-------
ATTACHMENT D
28
[This is an excerpt from the Blue Book]
May, 1979
IT MAY BE BORING. BUT-
PLEflSE READ THESE INSTRUCTIONS CflEEFULLY BEFOEE INSTflT.T.TMG OR ADJUSTING THE FILTER
KING. IT IS IMPORTANT TO KEEP THESE INSTRDCTICNS FOR FUTURE KKJ:EKENCE.
FITTING AND ADJUSTING INSTEDCTICNS:
1. FITTING
The Filter King cones with all the parts necessary to fit the unit onto your
vehicle, i.e. mounting bracket, nuts and bolts, self-tapping screws, hose clanps
and connecting hose. Since the Filter King has to be connected into the metal
fuel line coining from the fuel pump (usually located at one side of the engine
block) to the carburetor, the Filter King should be mounted as close as possible
to the part of the fuel line to which .it is to be connected. The unit must not
be mounted on the engine or too close to a source of heat, e.g., the exhaust
manifold.
Before assembling the unit and mounting bracket, check that the glass bowl
is being held tightly against its seal, and if necessary, tighten the bowl
retaining knob. Bolt the mounting bracket to the Filter King, using the two nuts
and bolts together with the two flat washers and lock washers.
Locate the mounting point nearest to the intended 'splice-in' point into the
metal fuel line. Depending on the position of the fuel line, these locations are
normally: the inside of the fender well, the lip where the fender is bolted to
the automobile, on the cowling at each side of the radiator, (keeping the unit
and hose well away from the radiator itself and the fan), and the passenger compart-
ment bulkhead. On vans and trucks other mounting locations are: the lip of
metal at the body end of the hood, or the grillwork at the front of the engine
compartment. In many cases, there will be a nut and bolt securing another piece
of equipment to' the body, which can be unbolted, the mounting bracket inserted,
and the nut and bolt re tightened. There may be holes already drilled but not
used which can be utilized. If no such readily available fixing holes exist,
you can drill or punch two small holes at the mounting location and then use the
to*3 self-tapping screws and flat washers supplied to attach the mounting bracket
and Filter King to the car.
Make sure that the selected mounting location is free from any excess vibra-
tion. The mounting bracket can be bent and twisted in order to use an awkward
mounting location.
Remember that every 10,000 - 12,000 miles, the filter in the glass bowl must
be changed, so allow for the removal of the glass bowl either by mount-ing the
unit far enough away from any engine or body part beneath it to allow for removal
"in situ" or for easy removal of the whole unit by using a nut and bolt to hold
the mounting bracket to the mounting locations. The filter is changed by undoing
the plastic nut at the base of the glass bowl. This will enable the retaining
loop to be slipped over the glass bowl, allowing the bowl to drop free. When
inserting the new filter, make sure that it is the correct way up, i.e. hole upwards,
and ensure that both rubber sealing rings are in place.
The Filter King need not be absolutely vertical, but do not mount the unit hor-
izontally or upside down. Filtration will work most efficiently with the unit
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29
-2-
upright. Do not mount the unit in a place where it could get hit by stones
thrown up from the road. This could lead to a cracked bowl and gasoline leakage.
In some cases, in particular the larger automobiles, due to the amount of
underhood equipment, the only available mounting location may be some distance
from the connecting point to the metal fuel pipe. In this case, it may be
necessary to purchase an extra length of hose from auto-parts supplier. Be care-
ful not to route the tubing so that it touches any hot engine parts, or so that
it comes into contact with any chafing object. The type of engine will also have
an effect on the mounting location in the following way. Most Ford engines have a
metal fuel line which stops an inch or so from the carburetor. The metal fuel line
is connected to the carburetor by a short length of rubber hose. By removing the
air filter, it is possible to take out this length of rubber hose, leaving a gap
into which the tubing from the Filter King can be connected.
On some other vehicles, there is an in-line fuel filter connected into the metal
fuel pipe, shaped like a small drum. This is connected to the metal fuel pipe by
a rubber hose at each end. If this filter is removed, the Filter King tubing can
then be connected into the resulting gap. In these cases, the Filter King should .
be mounted as close as possible to the gap in the metal fuel line. In the case of j
vehicles with a 'return line1 from the in-line fuel filter to the fuel tank, i.e.
1 most A.M.C. vehicles, Ford Pintos, Toyotas, etc., connect the Filter King between
1 the in-line filter and the carburetor, leaving the filter and return line intact.
If the metal fuel line has no breaks in it from the fuel pump to the carburetor,
as in most <3A models, then it will have to be cut, either with a hack-saw or a tube
cutter. Ideally, the pipe should be removed from the engine and cut at the approp-
riate place with a tube cutter. If this is not practical, and it is not possible
to use a tube cutter, a hack-saw can be used to cut the metal fuel pipe.
Do not cut the metal fuel pipe while the engine is hot. Let the engine cool
uuupletely to avoid any possibility of the gas leaking from the cut pipe and
igniting.
If you use a hack-saw, try to find a place in the line which is vertically
inclined. This will cut down the chance of metal filings being carried into the
carburetor and causing the inlet-needle-valve to stick open. If this does occur,
gasoline will flood out of the carburetor. This can be cured, in most cases, by
tapping the carburetor at the point where the metal fuel line enters it, thus clearing
the blockage.
Most G.M. vehicles have a paper filter contained in a 'bell housing1 where the
fuel line connects to the carburetor. After cutting the fuel line in order to attach
the Filter King, leave this filter in place for a few miles of driving. Any metal
filings will then be trapped, and later are thrown away with the filter.
Ensure that no jagged edges are left on the cut fuel line. The hose supplied
should now be measured for correct length and cut to size. (The length is measured
between the Filter King and the connecting point of the metal fuel line) . The inlet
and outlet nozzles on the Filter King are clearly marked on the underside, close to
the nozzles, in raised lettering. Make sure that they are connected the right way.
The nozzle pointing downwards connects, via the hose supplied, to the metal fuel
line going to the fuel pump. The nozzle pointing horizontally connects, via the tube
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30
-3-
supplied, to the line going to the carburetor. If any difficulty is experienced
in getting the hose to go over the fuel line, the hose end can be stretched by
placing it in boiling water. The hoses, now connected in the correct manner
to the metal fuel lines, should now be clamped into place, both at the connec-
tions to the metal fuel lines and the two nozzles, using the four clamps supplied.
Make sure that the clamps are reasonably tight. Ensure that there are no sharp
bends in the connecting hose. This may restrict or entirely cut off the fuel
supply to the carburetor, causing hesitation and stalling.
Check once more that everything has been connected safely and correctly.
Start the engine and check for any leaks. Drive the car a few blocks and
then check again for leaks.
2. TUNING
Like the carburetor, the Filter King can only be pre-set at the factory to
an approximately correct setting. The final tuning can only be done once the
Filter King is mounted on the car, and is operational. At the top of the Filter
King is a dared nut. If this is unscrewed and taken off, a screw will be seen.
This screw is the adjusting screw and is held tight by a lock nut. To make •
adjustments, the doned nut must be- removed and the lock nut slackened. By
unscrewing the adjusting screw (anti-clockwise) a drop in output pressure to
the carburetor is obtained. By screwing the adjusting screw in (clockwise)
an increase of pressure to the carburetor is obtained. Do not adjust the pressure
setting unless the fuel economy gain is less than 10%, in which case unscrew
the adjusting screw counter-clockwise by half a turn at a time.
In the event that an increase in fuel economy is not obtained by decreasing
the Filter King output pressure from the original pressure setting, the procedure
should be reversed and the output pressure setting adjusted by steadily increasing
amounts above the original output pressure setting. In order to accomplish this,
a note of the number of turns anti-clockwise made in originally adjusting the
unit output pressure downwards should be made, so that the output pressure of the
unit may be re-set to the original pressure before employing the adjustment
procedure for increasing the output pressure above that point.
If the performance of the car under maximum fuel demand periods, i.e. heavy
acceleration and high speed cruising suffers as a result of installing the Filter
King, e.g. hesitation on acceleration, screw in the adjusting screw clockwise by
half a turn at a time until the symptoms disappear. In principle, the further out
the adjusting screw is turned, (counter-clockwise) , the greater the economy gain.
There will come a point however, when the performance of the car will suffer, in
which case, the adjusting screw must be turned in (clockwise) a half a turn at a
time until the car performs properly again. At that point, the optimum point for
fuel economy will have been reached, consistent with proper engine performance.
When the adjusting screw is turned too far out (counter-clockwise) it will beccme
'loose. Be careful it doesn't come out because the spring beneath it will jump
out and probably get lost.
3. CCNCLOSICN
If the Filter King is installed in accordance with these instructions, a
minimum 10% improvement in m.p.g. should be obtained. The performance of the
vehicle should also be noticeably improved, i.e. easier starting, better idling,
-------
31
-4-
improved acceleratioa and smoother gear changing. If your automobile is fitted
with an in-line filter downstream of the Filter King (between the unit and the
carburetor) replace it with a new filter in the case of Ford vehicles which are
fitted with filters that screw into the side of the carburetor. Remove and do
not replace all other in-line fuel filters with the exception of those with
'return lines' to the fuel tank referred to in Section 1.
Remember that in order to assess the true increase in m.p.g. obtained with
the Filter King, you must knew fairly accurately what your present gasoline
consumption is. Many drivers have the inpression that their car does many more
miles to the gallon that it actually does. E.P.A. and Transport Canada ratings
are not a reliable guide to the actual m.p.g. figures for your car under actual
driving conditions.
Your m.p.g. figures will tend to rise and fall with changes in the weather.
Winter mileage figures are considerably less than summer figures, due to such
things as the prolonged use of the choke as the weather gets colder. Other
factors can change your m.p.g. figures significantly, such as crowded traffic
conditions, heavy loads in your vehicle, under-inflated tires, etc. The use of
the air-conditioner can cost you 2-3 m.p.g.
Should any problems arise that are not covered by these instructions, resist
the temptation to play with the Filter King to find out what the problem is. Ring
your local Filter King dealer, who will in most cases be able to tell you straight
away what the problem is and how to overcome it.
On certain vehicles, mostly G.M. models, a hesitation will be experienced
under light acceleration. This, if not accompanied by similar hesitation under
heavy acceleration and high speed motoring, is usually due to a defective
'accelerator pump1 on the carburetor. This problem, although present before-
hand, may not show up until the Filter King is connected, since the excess of
gasoline previously present in the carburetor (which the Filter King prevents)
will have hidden the effect. To rectify this problem consult your local
licensed mechanic. •
The Filter King is original equipment on Italian automobiles such as Maserati,
Lancia, Lamborghini and Alfa Romeo.
The Filter King is fully warranted against defects arising from faulty
material and workmanship for a period of CNE YEAR from the date of purchase. If
the unit has been rendered inoperative for any other reason, i.e. tampering,
.then the guarantee will not apply, and a charge will be made for repairs.
Spare filters may be obtained from your local Filter King distributor or fron -
F. K. Products
5 Cottingham Road
Toronto, Ontario
M4V 1B1 •
-------
\TE Or CALIFORNIA EDMUND G. 3ROWN JR.. Coy»fno;
IR. RESOURCES, BOARD ATraruMFMT FT 32
:.2< 9 STR^T. ATTACHMENT E-l
ASNTO. CA 95812 [This is 3n excerpt from the Blue Book]
April 17, 1978
Mr. Neville Weare
F. K. Products
5 Cottingham Road
Toronoto, Ontario
Canada M4V1B1
Dear Mr. Weare:
The Air Resources Board (AR3) has evaluated the
"Filter King Unit No. 5" in accordance with Section 2222,
Title 13- of the California Administrative Code. The results
of our evaluation are documented in the attached staff
report.
It is our opinion that the device does not reduce
the effectiveness of any required vehicle pollution control
system and therefore complies with the requirements of Vehicle
Code Section 27156.
The enclosed Executive Order 0-79, grants your
device an exemption from the prohibitions of Section 27156
of the California Vehicle Code. I wish to draw your attention
to Section'43644 in the Executive Order prohibiting
you from, advertis-inc your "Filter King" as an air pollution
control device.
If you have any questions please call Mr. R. J.
Kenny, Manager, Aftermarket Parts Modifications and •
Evaluation Section, (213) 575-6839.
Sincerely,
Thomas C. Austin
Deputy Executive Officer
Attachment
-------
33
State of California
AIR RESOURCES BOARD
EXECUTIVE ORDER D-79
Relating to Exemptions under Section 27156
of the Vehicle Code
F.K. PRODUCTS
"FILTER KING UNIT NO. 5"
Pursuant to the authority vested in the Air Resources Board by Section
27156 of the Vehicle Code; and
Pursuant to the authority vested in the undersigned by Section 39515 of
the Health and Safety Code and Executive Order G-30A;
IT IS ORDERED AND RESOLVED: That the installation of the Filter King
Unit No. 5 manufactured by Alberto Malpassi, Italy, and to be
marketed by F. K. Products, 5 Cottingham Road, Toronto, Ontario
Canada, M4V1B1 has been found to not reduce the effectiveness of
required motor vehicle pollution control devices and, therefore, is
exempt from the prohibitions of Section 27156 of the Vehicle Code
for installation on 1978 and older gasoline powered vehicles.
This Executive Order is valid provided that installation instructions
for this device will not recommend tuning the vehicle to specifications
different from those listed by the vehicle manufacturer.
Changes made to the design or operating conditions of the device, as
exempted by the Air Resources Board, that adversely affect the per-
formance of a vehicle's pollution control system shall invalidate
this Executive Oruei.
•Marketing of this device using an identification other than that shown
in this Executive Order or marketing of this device for an application
other than those listed in this Executive Order shall be prohibited unless
prior approval is obtained from the Air Resources Board.
This Executive Order, does not constitute any opinion as to the effect
that the use of this device may have on any warranty either expressed or
implied by the vehicle manufacturer.
THIS EXECUTIVE ORDER DOES NOT CONSTITUTE A CERTIFICATION, ACCREDITATION,
APPROVAL, OR AMY OTHER TYPE OF ENDORSEMENT BY THE AIR RESOURCES BOARD OF
ANY CLAIMS OF THE APPLICANT CONCERNING ANTI-POLLUTION BENEFITS OR ANY
ALLEGED BENEFITS OF THE "FILTER KING UNIT NO. 5."
No claim of any kind, such as "Approved by Air Resources Board" may be madj
with, respect to the action taken herein in any advertising or other oral
or written communication.
-------
"FILTER KING UNIT NO. 5" (Page 2 of 2)
34
Section 17500 of the Business and Professions Code makes untrue or mis-
leading advertising unlawful, and Section T7534 makes violation punishable
as a misdemeanor.
Section 43644 of the Health and Safety Code provides as follows:
"43644. (a) No person shall install, sell, offer for sale, or
advertise, or, except in an application to the state board for
certification of a device, represent, any device as a motor vehicle
pollution control device for use on any used motor vehicle unless
that device has been certified by the state board. No person shall
sell, offer for sale, advertise, or represent any motor vehicle
pollution control device as a certified device which, in fact, is
not a certified device. Any violation of this subdivision is a
misdemeanor."
Any apparent violation of the conditions of this Executive Order will be
submitted to the Attorney General of California for such action as he
deems advisable.
,
(1
Executed at Sacramento, California, this « ' day of April, 1978
Thomas C. Austin
Deputy Executive Officer.
-------
35
State of California
AIR RESOURCES BOARD
Feburary 24, 1978
Evaluation of the F. K. Products "Filter King Unit No. 5"
Device in Accordance with Section 2222, Title 13 of the
California Administrative Code
I. Introduction
F. K. Products, 5 Cottingham Road, Toronto, Ontario, Canada,
H4V1B1, has applied for an exemption for the "Filter King"
device from the prohibitions of Section 27156 of Vehicle
Code (See Exhibit A). The device is manufactured by Alberto
Halpassi, via Montebello, 56, 20033 Seregnb, Italy. The1
applicant is requesting that an exemption be granted for
1978 and older gasoline powered vehicles.
II. System Description
The "Filter King" device is a fuel pressure regulator
installed between the fuel pump and carburetor. It is designed
to maintain the proper fuel flow to the carburetor at optimum
pressure. The applicant claims that by regulating the pressure
to what is actually needed to supply the engine with enough
fuel, the device eliminates most or all of the fuel pulsations
emanating from the fuel pump. It also prevents excess gasoline
from flowing into the float bowl during periods of heavy
fuel bowl slosh. As a result, the carburetor is able to maintain
a more uniform level of fuel in the float bowl, thereby,
reducing carburetor flooding and increasing fuel economy.
The device cons-ir^s o^ an upper aluminum housing that contains
the fuel inlet and outlet, the valve, and the spring loaded
diaphragm that regulates the opening and closing of the valve,
the lower glass container that holds the fuel and a high
capacity fuel filter. Figure I shows a cross-section of
the device.
Initially, fuel under pressure enters the pressure regulator
into the glass compartment where the fuel is filtered. The
proper amount of fuel is then metered past the valve, thence
to the carburetor, by the action of the spring loaded diaphragm.
When the fuel pressure under the diaphragm is high the diaphragm
moves up causing the valve to seat against the port reducing
the output pressure. When the fuel pressure is low, the diaphragm
moved down allowing the valve to open the port thus increasing
the output pressure. The modulation of the diaphragm tends to
smooth out the fuel pressure pulsation from the fuel pump. The
pressure regulator output pressure can be adjusted by means
of a screw located on the top of the aluminum housing.
-------
III. System Evaluation 36
A. Applicant's Submitted Documents - The applicant claims
that the installation of the device on the motor vehicle's
fuel system will not 'have any adverse affect on exhaust
emissions. The following supporting documents were
submitted to the ARB.
f
1. Evaluation of Filter King Pressure Regulator
dated January 3, 1975 by Professor Franz Huf o
Polytechnic of Konstanz, West Germany. The tests
were conducted on a chassis dynamometer. The report
concluded that back-to-back tests, with no vibration
induced on the vehicles, showed no change in emissions.
With vibration induced on the vehicles (simulating
.actual road conditions), the emissions decreased
with the installation of the Filter King device.
Test data was not included in the report but would be
made available upon request. . -
2. ' American Motors Corporation CVS- 75 tests, dated
September 30, 1977. Table I summarizes the test
results. The test data indicate no significant
change in the vehicle emissions when the Filter
. King was installed and set v/ith fuel output pressure
of 1.7 and T.2 psig.
3. Filter King is used as an original equipment part
by several major Italian automobile manufacturers. The
fuel output pressure is preset in the factory to
"optimize" the effectiveness of the fuel pressure
regulation. .
B. ARB Tests
The ARB Laboratory evaluation of the device consisted
of parametric pressure tests at different speed and
engine loading conditions to determine the effect
of the Filter King device on a typical carburetor. The
purpose was to identify any flow anomalies which, might
indicate potential conditions which could adversely affect
exhaust emissions.
Tests were conducted on a 1976 Canadian Ford 302-2V non-
catalyst engine installed on a chassis dyno test stand. The
output fuel pressure of the device was adjusted by
increments of 0.5 psig from maximum to minimum output
allowed by the engine without causing fuel starvation.
For each fuel pressure output setting, steady state '
tests were performed at Idle, 1,000, 1,500, 2,000 and
2,500 rpm with the engine loaded at 25%, 50%, and maximum
torque at each speed setting. Fuel flow rates and .
exhaust emissions were measured and compared to baseline.
data. Table II summarizes the pertinent test data.
-------
me uesu resumes snow that the oevice can reguiate
fuel pressure from zero to fuel pump output pressure. 37
The minimum pressure output that will not cause
perceptible engine fuel starvation is 1.1 psig. At
any one pressure setting the device regulates constant
output pressure at all engine speed and loading conditions.
At any particular combination of engine speed and loading
condition, varying the output pressure setting down to
1.1 psig showed no change of fuel flow rate. "This indicates
the device pressure regulation down to 1.1 psig will not
change the carburetor's a-ir fuel mixtures, and consequently
will not have any adverse affect on exhaust emissions.
Measurements of HC, CO, and NOx exhaust emissions at these
test conditions confirmed the above findings.
•
Since the device will be-marketed as an off-the-shelf item,
the owner of the vehicle attempting to install the device
may set output pressure below the acceptable level which
may result in an increase in vehicle emissions. This concern
was relayed to the applicant. Subsequently, the applicant
stated that the only device to be marketed in California will
be Unit No. 5. This unit will be equipped with a modulating
spring that will not allow fuel output pressure to fall below
1.25 psig. A sample of the spring was sent to the ARB
for testing and was found to have a pressure cut off
point of 1.6 psig. Since the spring is designed to
have a minimum cut-off point of 1.25 psig, higher than the
1.1 psig found to have no adverse interaction with the
carburetor, the ARB anticipates no problem in the field
due to the adjustable feature of the device.
IV. Manufacturer's Claims
The applicant claims the installation of the device on vehicles
v.ilT improve fuel ccc.iomy up tc 15% by reducing carburetor
flooding. This statement was based on tests conducted, by
Prof Franz Huf of Polytechnic of Konstanz, West Germany. These
data, however, were not made available to the ARB. Extensive
fuel economy tests by AMC (see Table-I) only showed-an average
of 6% improvement in fuel economy.
It is the staff's opinion that the argument and supporting
documents presented by the applicant regarding fuel economy
benefits have merit and can be achieved under certain road
driving conditions with the installation of the Filter King
device.
V. Conclusion and Recommendation
The applicant submitted technical studies and emission tests
showing that the installation of the "Filter King" device
on typical in-use vehicles would not increase exhaust emissions,
-------
AR3 Laboratory flow tests showed that within the device 38
operating range, and under al] engine speeds and loading
conditions, the fuel flow rates would not change with the
installation of the "Filter King Unit No. 5". The device,
therefore, would -not adversely affect the carburetor's
performance and "Hence no increase of vehicle emissions
would result from the use of the device.This was demonstrated
by the applicant's and the ARB emission test data.
4
Therefore, the staff recommends that F. K. Products be
granted an exemption from the prohibitions of Vehicle Code
Section 27156 for its "Fiter King Unit No. 5" for 1978
and older gasoline powered vehicles.
-------
\ '916009
39
Pressure Adjusting Screw'
.10
Diaphragm (—** ™e
' "• J~ C3 - '
v--j i;i
Fuel Outlet
Fig. 1 - Filter King Pressure Regulator
-------
Table I - Filter King Back-to-Back CVS-75 Test
Data on a 1978 AMC 1-3 Package (Test
conducted by AMC)
40
Grams per Mile
HC CO NOx
'MPG
Baseline @ 0.52 5.4
5 psig.
Filter King @ 0.49 4.1
1.7 psig
Filter King @ 0.52 5.0
1.2 psig
1,23
1.51
1.32
City
16.6
17.5
17.8
Highway
25.8
26.5
27
Comoosite
19.8
20.6
21.0
-------
% of ix. To
Filter King
Output
Pressure
psig
Fuel Flow
gm/sec
CO gm/mtn.
HC gm/mln
14 i
NOx gm/mln
rque
Baseline
Device (1)
Device (2)
__Dey1ce .(3.)
Device (4)
Device (5)
Baseline
Device (1)
_0ey1ce (2)
Device (3)
. Device (4)
Device (5)
Baseline
Device (1)
Device (2J
Device (3)
Device (4)
Device (5)
Baseline
Device (1)
Device (2)
Device (3)
Device (4)
Device (5]
.Baseline
.Dfiidce-ll)
.QevJceJ2)
..Pevice__[3j
..D(jyjce_(4j
Idle
5.5
5.6
3.0
2.0
.*«.<. • . .
1.6
1.1
0.9
0.9
.0..8
0.8
0.0
0.8
0.70
0.80
0.65
0.67
0.7
0.7
0.24
0.26
0.23 •
0.22
0.29
0.22
JL23 ..
..0*26.....
oja
0.14
_QiQ? -..
100%
5.1
5.2
3.0
2.0
1.6
1.1
2.7
2.8
2.9
2.7
2.7
2.7
*
*
*
*
*
2.3
2.36
2.35
2.18
2.21
2.10
*
*
*
*
*
50%
4.9
5.5
3.0
2.0
1.5
1.1
1.4
1.4
M .
1.4
1.4
1.4
1.4
1.3
.1.2
1.0
0.9
0.8
0.73
0.81
0.82
0.79
0.76
0.72
.2.51.
.2,57
2.64
2.71
2.6?.
25%
4.3
5.5
3.0
2.0
1.5
1.1
1.1
1.1
1.1
V « *
1.1
1.1
1.1
0.8
1.0
0.9
0>3
0.8
0.8
! 0.27
0.28
0.30
0.33
0.31
0.32
0,51
0.48
0.51
0.50
n.4fi
i~-x
4.4
3.5
3.0
Z.Q
1.5
1.1
4.2
4.2
4.2
4.2
4.1 {
4.1
*
it
*
*
*
*
3.21
3.33
3.11
3.29
2.97
3.13
*
*
*
*
*
50% .
4.5
4.2
3.0
2.0.
1.6
1.0
2.1
2.2
2.1
2.1
2.1
2.1
4.1
4.2
4.7
4.0
3.2
2.8
'1.32
1.40
1.32
1.38
1.26
1.26
4.42
4.40
4.22
2.94
4. 00
252
4.6
4.3
3.0
1.9
T.5~
1.0
1.4
1.6
1.4
1.4
1.4
'1.4
1.4
l.G
1.5
1.4
1.3
1.3
0.47
0.51
O.CO
0.56
0.53
0.80
1.28
1.36
1.34
1.96
1 .?}
100% ,
4.2
4.2
3.0
1.9
iTs
T.O
5.8
5.8
5.7
5.9
5.7
5.7
*
*
*
*
*
*
4.03
4.46
4.21
4.58
4.22
4.16
*
*
*
*
*
50% '
4.5 '
4.4
3.0 |
2.0
K6
. . i
1.1
2.9
2.9
2.9
3.0
2.9
2.9
9.7
13.1 1
11.2
12.7
10.7
7.9
1.52
1.91
1.57
1.84
1.89
1.74
6.33
7.34
6.05
7.44
7 in
25%
4.5
4.5
3.0
2.0
f.6~
1-1
1.9
1.9
1.8
1.8
1.8
1.8
2.9
2.8
2.4
2.3
2.1
1.9
0.89
0.98
0.89
0.96
0.76
0.94
2.81
3.03
2.6
2.65
9 /in
100%
4.2 .
4.0
3.0
1.9
'1.5
1.0
7.2
7.2
7.1
7.0
6.9
6.9
*
*-
*
*
*
*
5.15
5.36
4.9
4.9
4.82
4.74
*
*
*
*
*
50%
4.3
4.3
3.0
2.0
1.5
1.1
3.8
3.8
3.7
3.7
3.7
3.7
21.6
17.9
,17.6
:19.4
16.8
•14.1
1 1.76
1.83
1.73
2.07
2.03
1.92
9.62
9.96
9.58
10.75
in in
'^
4.4
4.4
3.0
2.0
1.5
T.I
2.4
2.4
2.4
2.4
2.1
2.4
6.7
6.4
5.0
5.7
5.5
4.1
1.09
1.12
1.01
1.26
1.28
1.18
5.03
5.13
4.43
4.97
A ni
-------
. - . 42
STATE OF CALIFORNIA EDMUND G. BROWN JR., Govomor
AIR RESOURCES BOARD LABORATORY ATTAPUML-MT c o
9MS TELSTAR AVENUE ATTACHMtNT E-2
EI MONTE* 91731 ryhis is an excerpt from the Blue Book]
(213) 573-4800 L ^
Reference No. A-79-006
January 12, T979_
• Mr. P. F. Coulter
F. K. Products
5 Cottingham Road
Toronto, Ontario
Canada M4V 1B1
Dear Mr. Coulter:
In response to your letters of January 4 and January 5, 1979, we
understand that there is no physical difference between Filter King
models No. 4 and No. 5. They use the same spring and differ only in
pressure setting for marketing purposes.
The enclosed Executive Order, D-79-1, covers both models for 1979 and
older vehicles used in California. Please send us a copy of your
new advertising material as it becomes available.
If you should have any questions, you may contact Mr. Norman Kayne,
Manager, Aftermarket Parts and Modifications Evaluation Section at
(213) 575-6839.
C. Mass, Chief
Vehicle Emissions Control Division
Enclosure
-------
43
State of California
AIR RESOURCES BOARD
EXECUTIVE ORDER D-79-1
Relating to Exemptions under Section 27156
of the Vehicle Code
F. K. PRODUCTS
"FILTER KING, MODEL NO. 4"
"FILTER KING, MODEL NO. 5"
Pursuant to the authority vested in the Air Resources Board by Section
27156 of the Vehicle Code; and
Pursuant to the authority vested in the undersigned by Sections 39515 and
39516 of the Health and Safety Code and Executive Order G-45-5;
IT IS ORDERED AND RESOLVED: That the installation of the Filter King
Unit No. 4 and Filter King Unit No. 5 manufactured by Alberto Malpassi,
Italy and marketed by F. K. Products, 5 Cottingham Road, Toronto, Ontario,
Canada M4V IB! has been found to not reduce the effectiveness of required
motor vehicle pollution control devices and, therefore, is exempt from
the prohibitions of Section 27156 of the Vehicle Code for installation on
1979 and older gasoline powered vehicles.
This Executive Order is valid provided that installation instructions
for this device will not recommend tuning the vehicle to specifications
different from those listed by the vehicle manufacturer.
Changes made to the design or operating conditions of the device, as
exempted by the Air Resources Board, that adversely affect the per-
forrr?r>ce of a vehicle's pollution control systeir shell invalidata
this Executive Order.
Marketing of this device using an identification other than that shown
in this Executive Order or marketing of this device for an application
other than those listed in this Executive Order shall be prohibited unless
prior approval is obtained from the Air Resources Board.
This Executive Order does not constitute any opinion as to the effect
that the use of this device may have on any warranty either expressed or
implied by the vehicle manufacturer.
THIS EXECUTIVE ORDER DOES NOT CONSTITUTE A CERTIFICATION, ACCREDITATION,
APPROVAL, OR ANY OTHER TYPE OF ENDORSEMENT BY THE AIR RESOURCES BOARD OF
ANY CLAIMS OF THE APPLICANT CONCERNING ANTI-POLLUTION BENEFITS OR ANY
ALLEGED BENEFITS OF THE "FILTER KING" MODELS.
No claim of any kind, such as "Approved by Air Resources Board" may be made
with respect to the action taken herein in any advertising or other oral
or written communication.
-------
44
F. K. PRODUCTS
"FILTER KING, MODEL NO. 4"
"FILTER KING, MODEL NO. 5"
EXECUTIVE ORDER D-79-1
(Page 2 of 2)
Section 17500 of the Business and Professions Code makes untrue or mis-
leading advertising unlawful, and Section 17534 makes violation punishable
as a misdemeanor.
Section 43644 of the Health and Safety Code provides as follows:
"43644. (a) No person shall install, sell, offer for sale, or
advertise, or, except in an application to the state board for
certification of a device, represent, any device as a motor vehicle
pollution control device for use on any used motor vehicle unless
that device has been certified by the state board. No person shall
sell, offer for sale, advertise, or represent any motor vehicle
pollution control device as a certified device which, in fact, is
not a certified device. Any violation of this subdivision is a
misdemeanor."
Any apparent violation of the conditions of this Executive Order will be
submitted to the Attorney General of California for such action as he
deems advisable.
Executed at El Monte, California, this
day of January, 1979.
C. Hass, Chief
Vehicle Emissions Control Division
-------
?rATE OF CALIFORNIA EDMUND G. BROWN JR., Gov.fno
AIR RESOURCES BOARD LABORATORY ATTACHMENT E-3 ^
ofcrSETA9i73ENUE IThis is an excerpt from the Blue Book]
57"800 Reference No. A-81-067
1 1981
Mr. R. H. Scrivener, P.E.
119 Glen Road
Toronto, Canada M4W 2W1
Dear Mr. Scrivener:
This is in response to your request for an update of the existing Air
Resources Board's Executive Order D-79-2 dated March 6, 1980 to include
1981 model year gasoline powered vehicles in the exemption of the "Filter
King Model No. 4" and "Filter King Model No. 5" fuel control device from
the prohibitions of Vehicle Code Section 27156.
Enclosed please find Executive Order No. D-79-3 exempting your device
described in the staff report (also enclosed) as per your request. &'. '"
If you should have any questions concerning your exemption, please contact
Mr. John Chao, Manager, Aftermarket Parts and Modifications Evaluation
Section, at (213) 575-6839.
K. D. Drachand, Chief
Mobile Source Control Division
Enclosures
-------
46
State of California
AIR RESOURCES BOARD
EXECUTIVE ORDER D-79-3
Relating to Exemptions under Section 27156
of the Vehicle Code
TECHIMPORT LIMITED
"FILTER KING, MODEL NO. 4"
"FILTER KING, MODEL NO. 5"
Pursuant to the authority vested in the Air Resources Board by Section
27156 of the Vehicle Code; and
Pursuant to the authority vested in the undersigned by Sections 39515 and
39516 of the Health and Safety Code and Executive Order G-45-5;
IT IS ORDERED AND RESOLVED: That the installation of the Filter King
Model No. 4 and Filter King Model No. 5 manufactured by Alberto Malpassi,
Italy and marketed by Techimport Limited, 119 Glen Road, Toronto, Canada
M4W 2W1, has been found not to reduce the effectiveness of required motor
vehicle pollution control devices and, therefore, is exempt from the pro-
hibitions of Section 27156 of the Vehicle Code for installation on 1981
and older gasoline-powered, vehicles with conventional carburetor systems.
This Executive Order is valid provided that installation instructions
for this device will not recommend tuning the vehicle to specifications
different from those submitted by the device manufacturer.
Changes made to the design or operating conditions of the device, as
exempted by the Air Resources Board, that adversely affect the per-
formance of a vehicle's pollution control system shall invalidate
this Executive Order.
Marketing of this device using an identification other than that shown
in this Executive Order or marketing of this device for an application
other than those listed in this Executive Order shall be prohibited unless
prior approval is obtained from the Air Resources Board. Exemption of
a kit shall not be construed as an exemption to sell, offer for sale
or advertise any component of a kit as an individual device.
This Executive Order does not constitute any opinion as to the effect
that the use of this device may have on any warranty either expressed or
implied by the vehicle manufacturer.
THIS EXECUTIVE ORDER DOES NOT CONSTITUTE A CERTIFICATION, ACCREDITATION,
APPROVAL, OR ANY OTHER TYPE OF ENDORSEMENT BY THE AIR RESOURCES BOARD OF
ANY CLAIMS OF THE APPLICANT CONCERNING ANTI-POLLUTION BENEFITS OR ANY
ALLEGED BENEFITS OF THE "FILTER KING MODEL NO. 4" AND "FILTER KING MODEL
NO. 5".
-------
47
TECHIMPORT LIMITED
"FILTER KING MODEL NO. 4"
"FILTER KING MODEL NO. 5"
EXECUTIVE ORDER D-79-3
(Page 2 of 2)
No claim of any kind, such as "Approved by Air Resources Board" may be made
with respect to the action taken herein in any advertising or other oral
or written communication.
Section 17500 of the Business and Professions Code makes untrue or mis-
leading advertising unlawful, and Section 17534 makes violation punishable
as a misdemeanor.
Section 43644 of the Health and Safety Code provides as follows:
"43644. (a) No person shall install, sell, offer for sale, or
advertise, or, except in an application to the state board for
certification of a device, represent, any device as a motor vehicle
pollution control device for use on any used motor vehicle unless
that device has been certified by the state board. No person shall
sell, offer for sale, advertise, or represent any motor vehicle
pollution control device as a certified device which, in fact, is
not a certified device. Any violation of this subdivision is a
misdemeanor."
Any apparent violation of the conditions of this Executive Order will be
submitted to the Attorney General of California for such action as he
deems advisable.
Executive Orders D-79 dated April 17, 1978, 0-79-1 dated January 12, 1979,
and D-79-2 dated March 6, 1980 are superseded and of no further force and
effect.
Execu.ted-at El Monte, California, this
day of Mai-di, 1981.
K. D. Drachand, Chief
Mobile source Control Division
-------
48
State of California
AIR RESOURCES BOARD
March 2, 1981
Evaluation of the Techimport Limited "Filter King Model No. 4". and "Filter
King Model No. 5" for Compliance with the Requirement of Section 27156
of the Vehicle Code.
I. INTRODUCTION
Techimport Limited, of 119 Glen Road, Toronto, Canada M4W 2W1, has
requested by letter dated January 31, 1981 (See Appendix A) an update to
the existing Air Resources Board's Executive Order D-79-2. The applicant
requested that the exemption from the prohibitions of Vehicle Code (VfC.)
Section 27156 for their "Filter King Model No. 4" and "Filter King Model
No. 5" fuel control device be updated to include all 1981 and older model
year gasoline-powered vehicles with conventional carburetor systems.
Section 27156 of the V.C. prohibits the installation, sale, or
advertisement of any device which alters the performance of the vehicle's
emission control system. The Air Resources Board (ARB) is empowered to
exempt any device from this prohibition if it can be shown thjc the
installation of the device will not reduce the effectiveness of the existing
emission control system.
II. SYSTEM DESCRIPTION AND OPERATION
The "Filter King" device is a fuel pressure regulator installed
between the fuel pump and the carburetor. It is designed to maintain the
fuel pressure in the carburetor at optimum levels. .The applicant claims:
1. By regulating the fuel pressure to supply the engine with the
required amount of fuel, the device eliminates most or all of the fuel
pulsations emanating from the fuel pump.
-------
49
2. The device also prevents excess gasoline from flowing into the
float bowl during periods of heavy fuel bowl slosh.
3. As a result, the carburetor is able to maintain a more uniform
level of fuel in the float bowl, thereby, reducing carburetor flooding and
increasing fuel economy.
The device consists of an upper aluminum housing and a lower glass
container. The aluminum housing contains a fuel inlet, a fuel outlet, a
valve, and a spring loaded diaphragm that regulates the opening and closing
of the valve. The lower glass container holds the fuel and a high capacity
fuel filter. Figure I shows a cross-section of the device.
Inititally, fuel from the fuel pump under pressure enters the glass
compartment where the fuel is filtered. The amount of fuel that passes the
valve and thence to the carburetor is metered by the action of the spring
loaded diaphragm. When the fuel pressure under the diaphragm is high, the
diaphragm moves up causing the'valve to seat against the port thus reducing
the output pressure. When the fuel pressure is low, the diaphragm moves
down allowing the valve to open the port thus increasing the output
pressure. The modulation of the diaphragm tends to smooth out the fuel
pressure pulsation from the fuel pump. The pressure regulator output
pressure can be adjusted by means of a screw located on the top of the
aluminum housing.
III. DEVICE EVALUATION
The applicant submitted emissions test data for the original application,
The tests, conducted by AMC, were performed on a 1978 AMC vehicle. The
data in Table 1 shows that the device has little effect on emissions at
low outlet pressures of 1.2 and 1.7 psig.
2.
-------
50
The ARB evaluated the device during the orignal application. The
evaluation consisted of parametric pressure tests at different speed
and engine loading conditions on a typical 2 barrel carburetor. The
results in Table 2 indicated that the amount of fuel delivered to the test
carburetor and emissions were unaffected due to fuel pressure differences.
The Air Resources Board staff report titled "Evaluation of the F. K.
Products Filter King Unit No. 5 Device in Accordance with Section 2222,
Title 31 of the California Administrative Code", dated February 24, 1978,
contains a detailed description of the tests performed.
IV. DISCUSSION
Based on the above data the Filter King does not seem to have any
effect on fuel delivery and on exhaust emissions of an automobile engine
equipped with a conventional carburetor. Since the "engine out" emissions
are not changed, the operation and the efficiency of a three-way catalyst
does not change either.
Also whan the fuel delivery rate remains unchanged, the float level
will not change. An air/fuel ratio feedback control system on late model
year cars draws fuel from a bowl in the same way as a conventional car-
buretor, and should not be affected if the float level does not alter.
V. CONCLUSION AND RECOMMENDATION
The previous test data submitted by the applicant and generated by ARB
showed that the use of the "Filter King" device did not have any effect
on the exhaust emission control system of 1978 model year vehicles.
3.
-------
51
%
Based on the test data Techimport Limited was granted an exemption
(.Executive Order D-79 dated April 17, 1978) from V.C. 27156 for 1978 and
older gasoline powered vehicles. The exemption was later updated to
include 1979 model year gasoline-powered vehicles (Executive Order D-79-1,
dated January 12, 1979) and for 1980 model year gasoline-powered vehicles
(Executive Order D-79-2, dated March 6, 1980).
The staff found no significant difference between the 1981 and 1978
vehicle's fuel system design and the engine-out emissions are not affected
by the use of the Filter-King device.
Based on the above, the staff concluded that the installation of the
"Filter King Model No. 4" or "Filter King Model No. 5" fuel control device
will have no effect on vehicle exhaust emissions. The staff recommends
that Techimport1s exemption, Executive Order No. D-79-2, be updated to
include 1981 and older model year gasoline-powered vehicles with conventional
carburetor systems. The staff, therefore, recommends that Executive Order
D-79-3 be adooted
-------
Table I - Filter King Back-to-Back CVS-75 Test
Data on a 1978 AMC 1-3 Package (Test
conducted by AMC)
52
Grains per Mile
HC CO NOx
MPG
City Hi ghway Composite
Baseline @
5 psig.
0.52
Filter King @ 0.49
1.7 psig
Filter King 13 0.52
1.2 psig
5.4
4.1
5.0
1,23
1.51
1.32
16.6
17.5
17.8
25.8
26.5
27
19.8
20.6
21.0
-------
1C of ix. To
Filter King
Output
Pressure
pslg
Fuel Flow
gm/sec
CO gm/inln.
HC gm/mln
i
NOx gm/mln
rnue
Baseline
Device (l)
Device (2)
JDeytce (3)
Device (4)
Device (5)
Baseline
Device (1)
_Jey1ce (2)
Device (3)
Device (4)
Device (5)
Baseline
Device (1)
_Dey|ce (2J
Device (3)
Device (4)
Device (5)
Baseline
Device (1)
Device (2)
Device (3)
Device (4)
Device (5]
.Bas,aUne_
-Dejd£e_.ll)
.Pevjce._(2)
..Peyjce_(3]
Device (4)
Idle
5.5
5.6
3.0
2.0
1.6
1.1
0.9
0.9
0.8
0.8
0.0
0.8
0.70
0.80
.0...65
0.67
0.7
0.7
0.24
0.26
0.23
0.22
0.29
0.22
JL.23 ..
..0.2.5...
.PJ.8 .
_0.14_
0.09
100%
5.1
5.2
3.0
2.0
1.6
1.1
2.7
2.8
2.9
2.7
2.7
2.7
*
*
*
it
*
*
2.3
2.36
2.35
2.18
2.21
2.10
*i
*
*
*
*
502
4.9
5.5
3.0
2.0
1.5
1.1
1.4
1.4
M..
1.4
1.4
1.4
1.4
1.3
.1:2..
1.0
0.9
0.8
0.73
0.81
0.82
0.79
0.76
0.72
2,51
.2,57
.2,64
2.71
2.6?
25*
4.3
5.5
3.0
2.0
1.5
1.1
1.1
1.1
J?l.
1.1
1.1
1.1
0.8
1.0
0.9
~0>9~
0.8
: 0.8
!• 0.27
0.28
0.30
0.33
0.31
0.32
-0,5]
0.48
Ml
0.50
0.46
l'~«
4.4
3.5
3.0
2.0
1.5
1.1
4.2
4.2
4.2
4.2
4.1 |
4.1
*
*
*
*
*
*
3.21
3.33
3.11
3.29
2.97
3.13
*
*
*
*
*
50*:
4.5
4.2
3.0
2.0.
1.6
1.0
2.1
2.2
2.1
2.1
2.1
2.1
4.1
4.2
4; 7
4.0
3.2
2.8
'1.32
1.40
1.32
1.38
1.26
1.26
4-12
4.40
A-M.
2.94
4.00
25*
4.6
4.3
3.0
1.9
T.5~
1.0
1.4
1.6
1.4
1.4
1.4
'1.4
1.4
l.C
1.5
1.4
1.3
1.3
0.47
0.51
O.CO
0.56
0.53
0.80
1.28
1.36
14!
1.96
1.21
100% ;
4.2
4.2
3.0
1.9
i.5
V.O
5.8
5.8
5.7
5.9
5.7
5.7
*
*
*
*
•Jc
*
4.03
4.46
4.21
4.58
4.22
4.16
*
*
*
*
*
50% l
4.5 '
4.4
3.0 |
2.0
" lie i
. |
1.1
2.9
2.9 1
2.9
3.0
2.9
2.9
9.7
13.1 1
11.2
12.7
10.7
7.9
1.52
1.91
1.57
1.84
1.89
1.74
6.33
7.34
6.05_
7.44
7 in
*b%
4.5
4.5
3.0
2.0
f.6~
1.1
1.9
1.9
1.8
1.8
1.8
1.8
2.9
2.8
2.4
2.3
2.1
1.9
0.89
0.98
0.89
0.96
0.76
0.94
2.81
3.03
2.JL.
2.65
9 /in
lUUA
4.2 .
4.0
3.0
1.9
'1.5
1.0
7.2
7.2
7.1
7.0
6.9
6.9
*
*
*
*
*
5.15
5.36
4.9
4.9
4.82
4.74
*
*
*
7*
*
ylU
4.3
4.3
3.0
2.0
1.5
1.1
3.8
3.8
3.7
3.7
3.7
3.7
21.6
•17.9
,17.6
•19.4
lY.8~
14.1
1 1.76
1.83
1.73
2.07
2.03
1.92
9.62
9.96
9^56
10.75
in 10
• >
4.4
4.4.
3.0
2.0
1.5
"T.I
2.4
2.4
2.4
2.4
2.1
2.4
6.7
6.4
5.0
5~. 7
"5.5~
4,1
1.09
1.12
1.01
1.26
1.28
1.18
5.03
5.13
4.43
4.37
/I 01
-------
54
916009
__ Pressure Adjusting Screw
Fuel Outlet
Fig. 1 - Filter King Pressure Regulator
-------
ATTACHMENT F
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 55
ANN ARBOR, MICHIGAN 43'!Co
f 1 T) 1 QS1? OF~ICEOF
i-L -U, -i.70- AIR. NOISE AXD RADIATION
Mr. R. H. Scrivener, President
Techimport Limited
119 Glen Road
Toronto, Ontario
Canada MAN 2W1
Dear Mr. Scrivener:
We have performed a preliminary review 'of your February 8, 1982
application for an evaluation of the Malpassi Filter King Fuel Pressure
Regulator, a fuel economy retrofit device. Our review also included your
letters of February 8, 1982 and all other documents provided to EPA
during the past several months. A more complete review will be performed
after all test data and any other required information are submitted to
us. Our preliminary review has resulted in the following conclusions:
1. Section 3(d) of your application includes a discussion of the
testing performed to support the claims made for the Malpassi
Filter King. 1 believe there are several problems with the test
data for the reasons stated in Attachment A. Overall, the test
data you have submitted do suggest that there may be fuel
economy benefits associated with the Malpassi Filter King.
However, there is a need for more test data obtained from a
carefully controlled program at an EPA-recognized independent
laboratory. The test program should include on-road testing of
both fuel economy and performance changes attributable to the
Malpassi Filter King. Although we have not decided on all the
specific details, we suggest you consider the features outlined
in Attachment B when designing your program.
I recommend that you contact independent test labs regarding the
program suggested above. Should you find, one capable of
performing the tests, then please contact me so that we can
further discuss the details of the program.
2. Section (5)(a) of your application addresses unregulated
emissions and refers to ARB testing and evaluation of the
Malpassi Filter King. Based upon our examination of the ARB
reports, we believe the ARB evaluation and testing were directed
at regulated pollutants, not unregulated pollutants. Therefore,
you need to submit information with respect to unregulated
pollutants. If you have tested for unregulated pollutants, then
please provide us with a description of the tests performed and
all test results. -If testing has not been performed, then
please state so.
-------
Because of our need to process all evaluations in a timely manner, I ask 56
that you respond to this letter by May 4 and that you submit all data by
June 4. Should you have questions regarding this matter, please contact
me.
Sincerely,
W\
1 \
Merrill W. Korth
Device Evaluation Coordinator
Test and Evaluation Branch
Enclosures
-------
57
Attachment A
EPA's comments with respect to the test data addressed in Section 3(d) of
the application are as follows:
1. Paragraph (3)(d)(i) addresses the AMC testing which included
both hot soak tests in the Yuma desert and CVS dynamometer
tests. There are several problems with that testing. First, as
you have stated in several documents, dynamometer testing is
unlikely to reveal the full potential of the device due to the
atypical amount of fuel bowl sloshing during the test
procedure. Second, because AMC vehicles (which have a return
fuel line) exhibit fuel pressure pulsation characteristics which
differ from those associated with most in-use vehicles (having
no return line), the test results might not be indicative of the
fuel economy benefits that may be realized with the majority of
vehicles today. At best, the test results should only be used
to predict what may happen with vehicles that have a return fuel
line. Third, only one vehicle was tested. Fourth, the data
summary attached to the November 28, 1977 AMC letter to Mr.
Coulter shows that a) of 23 CVS tests, some were performed with
a Filter King #5 while others were with a Filter King i?3,
b) some tests were run with no return line while others were
with the return line, c) only three tests were run in the
configuration which yielded the most improvement in fuel
economy, that being the 1.2 psi pressure setting, d) of the
three tests run with a 1.2 psi setting, only two were complete
test sequences, i.e., both FTP and HFET and these two tests were
apparently compared to the last three baseline tests to obtain a
6 percent improved combined MPG fuel economy. As we see it, the
6 percent improvement is not based on "hard data" using 23 CVS
tests but rather from 5 tests, i.e. two with the device set at
1.2 psi and three baseline. Based on EPA's current guidelines,
five tests on one vehicle is not a sufficient amount of
testing. This, combined with the aforementioned shortcomings of
using an AMC vehicle and a dynamometer test procedure to
indicate what might be realized in fuel economy improvements on
most in—use vehicles, makes the usefulness of AMC CVS test
results questionable.
To augment our concerns relative to the AMC test results, it
seems there is the possibility the Malpassi Filter King may have
been installed incorrectly during CVS testing as well as during
the Yuma hot tests. This concern rises from the last sentence
of the third paragraph of the Discussion section within the AMC
Detroit Research Report No. DR 11-77-91 which was included in
the Blue Book. That sentence .states, "the configuration and
settings resulting from this test series [referring to AMC CVS
tests with the 1.2 psi pressure setting] were then adapted to a
Western trip car which was currently being tested". If the term
-------
58
"configuration" includes the method of device installation, then
the next sentence which states, "installation was on the wheel
well, in an upright configuration, between the fuel pump and the
standard AMC fuel filter", would mean the device had been
installed incorrectly during the CVS tests. Please clarify as
to what method of installation was used, during the CVS tests.
With respect to the Yuma hot tests, it appears the device may
also have been incorrectly installed during testing. For this
reason, EPA does not intend to base its conclusions in this
reevaluation of the device on the Yuma hot tests. However, we
do intend to evaluate the driveability characteristics
associated with the device.
Paragraph (3)(d)(ii) addresses "independently conducted on—road
tests". Admittedly, the 47 referenced tests constitute a
considerable amount of testing. However, an examination of the
test reports, letters, etc. indicate there are problems with
most of the data. For example, some of the test vehicles were
not representative of recent models in that they were pre—1973
vintage. Therefore, they did not possess the sophisticated
emission controls, carburetor designs, etc. associated with
recent models. In some tests, only one vehicle was tested and
then without replicate testing. Although the reports are
usually not detailed enough to say for sure, it seeras that the
adequacy in controlling test variables may not have been
sufficient for a large number of the tests. In a few cases,
back-to-back testing was not performed. We are sure you can
appreciate some of our concerns because you have addressed them
in your own guidelines for testing which are included in the
September 5, 1979 memorandum located within the Section of the
Blue Book titled, "Comments on Testing". Although most of the
tests are inadequate for our purposes, there are some that are
satisfactory enough to indicate that there may be fuel economy
benefits associated with the Malpassi Filter King and
consequently additional testing should be conducted.
We have one additional comment with respect to the road
testing. Among the test reports, there is one from SCI dated
July 12, 1979. The report references an attached table which
summarizes the test results. That table was omitted. We would
appreciate it if you could provide us with a copy.
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59
Attachment B
Test Vehicles
Quantity: Four
Model Range: 1975 thru 1982
Manufacturers: General Motors, Ford, Chrysler, American Motors
Number of Engine Cylinders: 8, 6, and 4
Transmission: Automatic
Fuel Line Configuration: Non-return line (except with AM.C vehicles)
Test Conditions
Test Type: On-Road testing
It is suggested that all on-road testing be performed on the San Antonio
Road Route which is described in Attachment C. Should you select some
other test location, It will be necessary to run a few pilot tests for
purposes of 'establishing the test-to-test variability and also the
required number of test vehicles/tests.
Test Quantity:
1. Twelve valid tests without device per vehicle
2. Twelve valid tests with device per vehicle
Temperature Range: 60°F to 90°F
Wind: 5 MPH or less, gust to 10 MPH maximum.
Miscellaneous Comments
1. All testing should be conducted between 9cOO a.m. and 3:00 p.m.
2. Two or more practice runs should be made to assure driver
repeatability.
3. One warm-up run should be made prior to start of data gathering.
4. Device should be installed with bypass valves in such a manner
as to allow fuel to flow through it or to bypass it, as desired
by test personnel.
5. Tests with and without the device should be randomly mixed
during each day. Test personnel (other than the driver) should
manipulate the bypass valves so that the driver has no knowledge
of when the device is actually functioning.
6. Testing should be snared equally between two drivers.
7. After all fuel economy test runs are completed, the vehicle
should be subjected to triplicate wide-open throttle (WOT)
acceleration runs of 0- to 60 MPH both with and without the
device.
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60
Driveability should be evaluated under "hot soak" conditions at
temperatures above 90°F. The evaluation should consist of
running the vehicle at 55 mph, then stopping the engine for 15
minutes followed by an engine restart and WOT acceleration back
to 55 mph. This sequence should be performed a minimum of three
times.
-------
Attachment C 61
(Excerpt from EPA Report titled,
"Evaluation of Gastell, A Device
-44- to Modify Driving Habits").
Appendix D
Road Testing with the Gastell Device
SAN ANTONIO ROAD ROUTE TEST PROCEDURE
A. The general procedure is as follows:
1. Drive test vehicle from Southwest Research Institute to Layover Point.
2. Start Vehicle
3. Start Fluidyne Recorder, wait 60 seconds. Then drive road course.
Use normal driving techniques.
4. Return to Layover Point, shift into park, idle for 60 seconds. At 60
sees, stop Fluidyne totalizer and hit print button. Record fuel and
temperature readings on work sheet.
5. Shut engine off, zero and start Fluidyne timer.
6. At 500 seconds, start vehicle using hot start procedure.
7. At 560 seconds shift into drive and drive road course using normal
driving technique. (Go to Step 4 - repeat as many times as possible
before 3:00 p.m.).
Note: The Mercury Marquis was run with 60 second layovers instead of 500
seconds.
B. General Test Requirements
1. The first test run of each day was considered warm up and the data
was not used in any subsequent calculations.
2. Only tests run between 9:00 a.m. and 3:00 p.m. were used due to San
Antonio traffic considerations.
3. Only tests run on weekdays, Monday through Friday, were used due to
San Antonio traffic considerations.
4. Temperature, humidity, barometer, wind speed and direction were taken
at 9:00 a.m. and 3:00 p.m.
5. All test fuel was from a single batch of Gulf pride unleaded fuel
provided by Southwest designated EM-356.
6. All test vehicle fuel tanks were drained prior to start of testing to .
avoid fuel mixing.
7. All vehicles were specification checked and examined for proper
vacuum line routing and evidence of tampering.
8. The Chevrolet Citation and Nova were extensively checked out to
manufacturers specifications at the EPA-MVEL prior to being driven to
San Antonio.
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62
-45-
9. Fuel Tanks on each vehicle were filled with EM-356 fuel each
morning. Vehicles used about 1/4 tank each testing day.
10. Tire pressure of all test vehicle tires was checked and set to
manufacturer's specifications each morning prior to leaving Southwest
Research.
11. Test runs with abnormal time, fuel consumption, or circumstances were
deleted from consideration. Examples of such circumstances were
funeral processions (3 occurences) and could not exit highway due to
traffic (1 time).
12. In all test days where the Gastell Device was to be used, the device
calibration was checked prior to leaving Southwest using the
following procedure.
An 8" diameter pressure gauge that was previously checked versus
a mercury manometer in Ann Arbor was attached to a hand vacuum
pump which was then connected to the device. Ray Smith of
Gastell had transmitted the following device specifications:
Oil OFF
4 cylinder vehicles 3.5" Hg 4.5" Hg
6 cylinder vehicles 5.0" Hg 6" Hg
8 cylinder vehicles 7.0" Hg 8"Hg
The devices did not need calibration until the setpoints were
modified on the Nova. The calibration checks of the 8 cylinder
devices were about on at 7.0" Hg. Since these devices were
submitted by Ray Smith with the 511 Application for evaluation
and the specifications given in the application only specified
the ON set point, the devices were deemed acceptable.
13. Testing run when the pavement was wet was not used in the analysis.
When pavement was damp the results were used if they appeared in-line
with other measurements.
14. A minimum of 5 tests were run with most vehicles to familiarize the
driver with the vehicle and route. Data was not collected during
driver familarization.
15. The fuel totalizer display was located in the vehicle so that the
driver could not see the display while driving.
16. The Fluidyne flowmeters were calibrated in July, 1980 and checked for
calibration in December 1980.
-------
San Antonio Road Route
Number of Stop Signs: 0
Number of Stop Lights: 28
Average Distance: 7.2 miles
Average Speed: 19.6 mph
Maximum Speed: 55 mph
Stops/Mile: 3.9
N
DOWN
OVER 0» UhOER PASS
TRAFFIC LIGHT
SCHOOL ZONE
1
-1
END T
K
at
Ul
j
3
O
nZARZAMORA
JTART
^ — LAYOVER PC
SPCB
SPCCO LIMIT-30 «PH UNLESS OTHERWISE SPECIFIED
Figure D-l San Antonio Road Route
-------
Hi.MCHMENT G
\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY <-,
b4
_- ;* ANN ARBOR. MICHIGAN 48105
June 24, 1982 OFFICE OF
AIR. NOISE AND RADIATION
Mr. R.H. Scrivener, President
Techimport Limited
119 Glen Road-
Toronto, Ontario
Canada M4N 2WI
Dear Mr. Scrivener:
I have received your June 9 response to our April 20 preliminary
evaluation of the Malpassi Filter King. Your letter had apparently
crossed our June 7 letter in the mail.
In the second paragraph of your letter, you expressed your position with
respect to the AMC testing of the device. Specifically, you state that
the findings and conclusions "stand as an accurate representation of the
effects of the Filter King on fuel consumption". Additionally, you state
it is surprising that anyone "would question the applicability of the
Filter King to other vehicle makes, since the fuel pump/carburetor
systems of all vehicles function in the same way, with any differences
being minor and not related to the fuel pulsation/fuel bowl slosh
problems that the Filter King deals with".
I am surprised that you make such statements considering that they seem
to take a different position from that stated, or implied, by Peter
Coulter in various letters to this Agency (see Enclosure). For example,
your statement that the AMC test results "stand as an accurate
representation" reflects a different position from that taken earlier
with respect to dynamometer testing of the Malpassi Filter King. FTP and
HFET dynamometer testing does not include on-road vehicle vibrations and
therefore the effectiveness of the device in coping with carburetor fuel
bowl sloshing (which is caused in part by the on—road vibrations) cannot
be adequately assessed. This concern was expressed by Mr. Coulter in
several letters to EPA (Letters A, B, and C) and was also noted by
Professor Huf during his testing of the device (Document D). This
concern was also expressed by EPA to Mr. Coulter (Letter E). Even if one
were not to consider the other problems associated with the AMC testing
which were noted in Attachment A of my April 20 letter, the AMC data
would at best, only indicate the effectiveness of the device on vehicles
traveling on extremely smooth roads, absent of turns, accelerations, and
decelerations. Certainly, this is not representative of most driving
conditions. For these reasons, EPA determined that the AMC test results
do not "accurately represent" the effects of the Filter King on fuel
consumption and therefore proposed an alternate test plan for evaluating
the device on the road.
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65
Your other statement regarding the applicability of the device is also
surprising in that Mr. Coulter previously stated (Letter F) that "AliC
fuel systems have an in-line fuel filter with a return line on the down
stream (exit) end. The effect of this return line is to bleed off fuel
from the fuel line, and therefore to intermittently bleed off pressure,
and this effect significantly increases the strength of the fuel line
pulsations. In this situation, the strength of the fuel line pulsations
by themselves are sufficient to lead to an observable loss of fuel
economy." The above statement was included in a letter in an effort to
explain to EPA why the device caused a fuel economy benefit on the AMC
vehicle (when dynamometer tested without road simulated vibrations) while
the benefit is not realized on other vehicles not having a return fuel
line. A similar position was also taken in another letter by Mr. Coulter
to EPA (Lettcvr G). Because the fuel line pulsation characteristics with
AMC vehicles are significantly different from those noted with non-raturn
line vehicles, and also because AMC vehicles constitute a small portion
of the total U.S. car sales, the AMC data were judged by EPA to be not
representative of, or "applicable" to, the majority of in-use vehicles.
With respect to fuel pump/carburetor design/function, EPA agrees that
generally there is basically little difference between AMC vehicles and
those of other makes. A more important difference that may exist is that
some carbureters have baffles within the fuel float bowl to control
sloshing while others do not. In general, our concerns were not with
fuel pump/carburetor design/function, but rather with pulsations.
You stated in your letter that you "will be seeking to finance" the kind
of testing suggested by this Agency. While we were pleased to sea you
are considering to test the device, we were also concerned about the
absence of dates when the testing would take place and when we could
expect to receive the results. Because it is essential that we process
all evaluations in a timely manner, and also because you have already had
approximately two and one-half months to complete your testing of the
device, we ask that your test plans (including dates) be submitted to
this office by July JSf.^ Should we not receive the information by that
date, we will proceed with completing the evaluation using all available
data. A copy of the final -report will be sent to you prior to its
announcement in the Federal Register. The name of the device will also
be placed on our list of evaluated devices which is made available to the
public. Should you have questions concerning- this course of action,
please contact me.
Sincerely,
Merrill W. Korth
Device Evaluation Coordinator
Test and Evaluation Branch
Enclosure
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66
Enclosure
A Letter, Peter Coulter to EPA, November 8, 1977. (Page one, first
paragraph, and item 1.)
B Letter, Peter Coulter to EPA, May 19, 1978. (Page two, second
paragraph.)
C Letter, Peter Coulter to EPA, February 16, 1979. (Page six, item 5
(c).)
D Application for evaluation of the Malpassi Filter King, November 8,
1977. (Page five, item 6, second paragraph including items (a), (b),
and (c).)
E Letter, EPA to Peter Coulter, January 18, 1978. (Last paragraph.)
F Letter, Peter Coulter to EPA, February 16, 1979. (Page three,
Section 1, second paragraph.)
G Letter, Peter Coulter to EPA, May 19, 1978. (Page one, second
paragraph.)
Note: The above listing constitutes only a partial examination of the
files.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
ANN ARBOR. MICHIGAN 48105
OFFICE OF
AIR. NOISE AND RADIATION
July 22, 1982
Mr. R.H. Scrivener, President
Techimport Limited
119 Glen Road
Toronto, Ontario
Canada M4N 2WI
Dear Mr. Scrivener;
We have reviewed your July 13 request for an extension, of the date for
when your test plans for the Malpassi Filter King are to be submitted to
this office. After carefully considering the ongoing evaluation program
and your request, we have decided to grant the extension you requested.
This decision was made despite the lengthy delays already noted in your
submittal of test plans and the need for us to complete all evaluations
in a timely manner.
We ask that your test plans, be submitted to this office no later" than
August 31 and that all test data be submitted by October 15. October 15
was chosen because it provides you with sufficient time to perform the
testing and also because of the necessity to complete all testing before
the onset of less stable ambient test conditions.
Should we not receive your test plans by August 31, we will finalize our
evaluation using all available information. As stated in my letter of
June 24, a copy of the report will be sent to you prior to- its announce-
ment in the Federal Register. Should you have questions regarding this
matter, please contact me.
Sincerely,
Merrill W. Korth
Device Evaluation Coordinator
Test and Evaluation Branch
-------
v? flb ^ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 68
\ rX7 s
ANN ARBQR. MICHIGAN 48105
November 8, 1982 OFFICE OF
AIR, NOISE AND RADIATION
Mr. R.H. Scrivener, President
Techimport Limited
119 Glen Road
Toronto, Ontario
Canada M4N 2W1
Dear Mr. Scrivener:
We are hereby notifying you of our intended course of action with respect
to the EPA evaluarion of the Malpassi Filter King.
We have carefully considered the entire evaluation program, including the
information and data received and the numerous delays experienced to
date. We have also considered the additional time which is still
required for you to obtain the required test data. Based on these
considerations and the need for us to conduct our evaluations in a timely
manner, we have decided to complete this one using the information
available at this time. Thus, any information or data henceforth
submitted to EPA will be considered part of a new evaluation.
Should you decide to submit a new application for your device, we suggest
that it include, but not be limited to, any information we requested in
previous letters and test data from on-the-road testing as described in
my letter of April 20. I recommend you give us an opportunity to comment
on your test plan prior to performing any testing.
As I told you in previous letters, a copy of our final report will be
sent to you prior to its announcement in the Federal Register and the
name of the device will be added to the list of devices which we make
available to the public. Should you have any questions regarding this
matter, please contact me.
Sincerely,
Merrill W. Korth
Device Evaluation Coordinator
Test and Evaluation Branch
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69
b. Tune vehicles to manufacturer's specifications and install conservation
system on each selected vehicle. Comment on ease of installation, difficulties
encountered., time to install, and any additional training required.
c. Establish adequate procedures ^for base mechanic installation.
(1) Include appropriate level mechanic required to perform installation
and any additional training needed.
(2) Comment on adequacy of manufacturer's installation instructions.
•*•*
(3) Specify any additional equipment/items necessary which exceed
normal kit requirements.
d. Develop forms/instructions, needed for operating/servicing personnel
to acquire MPG/OiM costs to operate Autotherm equipped vehicles in comparison
to vehicles not so equipped.
e. Assure that kit installation is proper by following Autotherm
Manufacturer's checks and insuring vehicle is still tuned to vehicle manu-
facturer's specifications after installation is completed.
f. Operate vehicles under normal mission assignment. Collect data to
obtain average MPG, battery current drain, and fuel/service costs for Autotherm
equipped and non-equipped vehicles over project test period. Identify all
project vehicles by registration number.
(1) Comment on any problems experienced and resolution of same.
(2) Record any adjustments necessary for satisfactory vehicle per-
formance.
:*-
(3) Install ammeter in series with negative lead of battery and record
current drain. Record all data in accordance with appropriate MOls/forms/in-
structions for each test vehicle.
(4) Compare ease of servicing vehicle employing Autotherm Heaters
versus those without test units.
(5) Determine average costs required to install energy conservation
systems -on various Air Force vehicles.
'•/ .
(6) Compare effects of temperature extremes on heater effectiveness and
time period of comfortable ambient of vehicle interior. Site any locations where
heaters would be cost prohibitive/ineffective.
(7) Compare MPG/OsM costs to operate vehicles with and without
Autotherm units. (Be sure to include all costs for charging/replacing
batteries, if applicable.)
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71
10. Technical Publications: Manufacturer's manuals/guidelines will be furnishort
with Car ComEort System.
11. Technical Assistance: Will be provided by WH-ALC/1«8BB>W upon requer.t.
12. Special Fundinq Instructions: None. Test items will be furnished throuqh
no-cost imbailment initiated by WR-ALC>
13. Disposition of Equipment! Request for disposition kits will be forwarded
to WR-ALC/W«BBt with information copy to WR-ALC ;«t»w«BHL. Upon shipment of
returned items, a copy of shipping document will be forwarded to WR-ALC/
14. Project Classification: Unclassified. Project may be discussed verbally
with manufacturer's representative. However, no remarks will be nwide to
obligate the USAF. No information will be released to one manufacturer on
another's product. Advise commercial suppliers of bailment items, who desire
written evaluation report, to address their request to W
15. Project Monitor: James F. Cronin, alternate: Durwood Graham, WR-ALC/
AV 468-2676.
16. Reporting: To be accomplished in accordance with KEEP Reporting
Instructions.
1 Atch
Savings Computation Format
Cy to:
,ief, Aircraft Items & Vehicle Section «<|
ngineering & Reliability Branch ȣ
Kanag^ent Division. D/M
Peterson AFB CO 80914
y
Offutt AFD NE 681 13
Chanute AFB IL 61B68
Columbus AFB MS 39701
Lowry AFB CO 80230
Loring AFB ME 04750
a
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72
Autotherm Heater Installation
1981 AMC Jeep CJ-7
Atch 2
-------
73
Autotherm Heater Installation
1974 Chevrolet Pickup C-10
-------
74
Offutt AFB, NE
Test Vehicle 79B5112
Operation Cost:
Miles Traveled: 9,861
Fuel Consumed: 826.'9 x $1.29 = $1,066.70
Oil Consumed: 20.0 x .49 = '9.80
MPG: 11.93 $1,076.5(T»-
*•
Operation Cost per Mile: $1,076.50 * 9,861 = $0.109
Direct Maintenance Cost:
Material Cost: $108.02
Labor Cost: 353.71
$461.73
Direct Maintenance Cost per Mile: $461.73 t 9,861 = $0.047
Total O&M Cost per Mile: $0.156
125.1 hours accumulated on the Autotherm Heater.
Control Vehicle 79B5214
Operation Cost:
Miles Traveled: 11,705
Fuel Consumed: 808.8 x $1.29 = $1,043.35
Oil Consumed: 18.0 x .49 = 8.82
MPG: 14.47 $1,052.17
Operation Cost per Mile: $1,052.17 ? 11,705 « $0.090
•** •
Direct Maintenance Cost:
Material Cost: $167.46
Labor Cost: 254.73
$422.19
Direct Maintenance Cost per Mile: $422.19 ? 11,705 = $0.036
Total O&M Cost per Mile: $0.126
Atch 3
-------
Test Vehicle 79B5599
Operation Cost:
Miles Traveled: 1,389
Fuel Consumed: 72.9 x $1.29 = $94.04
Oil Consumed: 0.0 x .49 = .00
MPG: 19.05 $94.04
Operation Cost per Mile: $94.04 ? 1,389 = $0.067
•»•*
Direct Maintenance Cost:
Material Cost: $ 0.00
Labor Cost: 84.60
$84.60
Direct Maintenance Cost per Mile: $84.60 t 1,389 = $0.060
Total O&M Cost per Mile: $0.127
171.3 hours accumulated on the Autotherm Heater.
Control Vehicle 79B5601
Operation Cost:
Miles Traveled: 1,065
Fuel Consumed: 66.0 x $1.29 =
Oil Consumed: 2.0 x .49 =
MPG: 16.14 $86.12
Operation Cost per Mile: $86.12 t 1,065 = $0.080
Direct Maintenance Cost:
"Material Cost: $ 0.00
"'•Labor Cost: 0.00
$ 0.00
Direct Maintenance Cost per Mile: $0.00 t 1,065 = $0.000
Total O&M Cost per Mile: $0.080
32
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76
Loring AFB, ME .
Test Vehicle 74B631
Operation Cost:
Miles Traveled: 2,520
Fuel Consumed: 944.0 x $1.29 = §1,217.76
Oil Consumed: 9.0 x .49 = 4.41
MPG: 2.67 $1,222". 17
Operation Cost per Mile: $1,222.17 -r 2,520 = $0.485
Direct Maintenance Cost:
Material Cost: $ 0.00
Labor Cost: 111.48
$111.48
Direct Maintenance Cost per Mile: $111.48 .? 2,520 = $0.042
Total O&M Cost per Kile: $0.529
Control Vehicle 74B638
Operation Cost:
Miles Traveled: 1,867
Fuel Consumed: 769.2 x $1.29 = • $ 992.27
Oil Consumed: 8.0 x .49 = 3.92
MPG: 2.43 $ 996.19
Operation Cost per Mile: $996.19 t 1,867 = $0.534
Direct Maintenance Cost:
Material Cost: $ 30.51
Labor Cost: 136.98
$167.49
Direct Maintenance Cost per Mile: $167.49 ? 1,867 = $0.089
Total O&M Cost per Mile: $0.623
33
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77
Test Vehicle 81B2380
Operation Cost:
Miles Traveled: 2,225
Fuel Consumed: 673.4 x $1.29 = $R68.69
Oil Consumed: 2.0 x .49 = .98
MPG: 3.30 $869.67
Operation Cost per Mile: $869.67 ? 2,225 = $0.39*1
Direct Maintenance Cost:
Material Cost: $ 8.79
Labor Cost: 250.51
$259.30
Direct Maintenance Cost per Mile: $259.30 * 2,225 = $0.117
Total O&M Cost per Mile: $0.507
Control Vehicle 81B2379
Operation Cost:
Miles Traveled: 1,442
Fuel Consumed: 399.0 x $1.29 = $514.71
Oil Consumed: 4.0 x .49 = 1.96
MPG: 3.61 $516.67
Operation Cost per Mile: $516.67 t 1,442 = $0.358
Direct Maintenance Cost:
Material Cost: $ 30.99
* Labor Cost: 309.72
$340.71
Direct Maintenance Cost per Mile: $340.71 T 1,442 = $0.236
Total O&M Cost per Mile: $0.595
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78
Controlled Temperature Tests
Vehicle Reg. No.:
Date: 4 Feb 82
Time: 1310
o
Temperature: 12 F.
Weather Condition: Snowing/no wind
Occupants: One (1)
First Temperature Reading:
+ 15 minutes
-i- 30 minutes
+ 35 minutes
Test
Vehicle
79B5599
85
Control
Vehicle
79B5601
88V
78V
70'
67C
Comments: Temperature tests were ended when the Autotherm
Heater shut the fan off.
Atch 4
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79
Controlled Temperature Tests
Vehicle Reg. -No. :
Date: 21 Jan 82
Time:
Temperature: 12°F.
Weather Condition: Snowing/no wind
Occupants: One (1)
First Temperature Reading:
+ 15 minutes
+ 30 minutes
+ 40 minutes
With
Auto therm
0800
Test Vehicle
79B5112
Without.
Autotherm
0905
83^
80V
73V
68V
83
58
54V
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80
Cost/Savings Computation
1. Test Unit: Autotherm Heater
2. Unit Cost: $132.40
3. Quantity Required per Base: 25
4. Life Expectancy (Years): 5
5. Accumulated Hours During Evaluation: 148.2
(Based on One (1) Test Unit)
6. Accumulated Hours in One Year: 296.4
7. 296.4 ? 2.3 hours = Gallons of Fuel 128.7
8. 128.7 Gallons x $1.29 per Gallon = Saved $166.02
9. Installation Cost: $ 92.00
($16.00 x 5.75)
10. Life Cycle Cost Savings:
$830.10 _ $224.40 = $605.70
(8 x 4) (2 + 9) Savings per Unit
11. Command Savings:
25 „ 26 650 „ $605.70
Units per Base Bases Vehicles Life Cycle
Savings
= $393,705.00
Atch 5
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81
ATTACHMENT K
*• A \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
ANN ARBOR. MICHIGAN 48105
, _„ . OFFICE OF
July 26, 1984 AIR. NOISE AND RADIATION
Mr. Robert Jaeger
AUTOTHERM Sales Corporation
314 East Main Street
Harrington, Illinois 60010
Dear Mr. Jaeger:
This letter is to inform you that we received your May 21, 1984
application for evaluation of the "AUTOTHERM Energy Conservation System"
under Section 511 of the Energy Policy and Conservation Act. We have
performed a preliminary review and have the following concerns:
1. Section 2d of your application does not include your address, so
EPA will assume that 314 East Main Street, Harrington, Illinois 60010,
which appears at the bottom of each page of your application, is the
correct address.
2. Under Section 3b(l), your application states that the AUTOTHERM
Energy Conservation System is applicable to any vehicle with a water
cooled engine, except "Mercedes Benz vehicles, due to their use of vacuum
heater controls." Other vehicles also use vacuum heater controls; your
description does not provide enough detail to explain the unique features
of Mercedes Benz vacuum heater controls -that prevent the application of
the AUTOTHERM system. Please provide additional information to permit us
to further understand which types of heaters allow or prohibit AUTOTHERM
system utilization.
3. Section 3c of your application is rather brief and does not
reference any of the additional material you provided. EPA will assume
that the descriptions of the theory and principles of operation in, a)
brochure AMFSB-36-1/82-25M, and b) "Fleet Fuel Survey" - Form Number
AM-SB-EV-F-001 11/81-5M, are explanations that you wish to reference to
meet the requirements of Section 3c of the Application Format.
4. Section 3e make's claims for fuel and maintenance cost savings but
does not segregate them. Please provide additional information, or
reference information already sent, on the cost savings due to, a)
reduced fuel consumption, and b) the maintenance cost reductions you
attribute to the AUTOTHERM system. We also need information on how the
cost savings were calculated and the assumptions used.
A critical assumption will be the percentage of time that drivers
will forego idling and use the AUTOTHERM system. You have not given EPA
any information on driver willingness to use the AUTOTHERM system in lieu
of idling. The probability of 100 percent of the drivers, with AUTOTHERM
system equipped vehicles, using the AUTOTHERM system is very low. Some
drivers may not be willing to change their ways. The probability of
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82
optimum AUTOTHERM system use, by drivers who do use the system is open to
question. The question is then, what are the actual utilization rates?
Do you have any data that document driver utilization rates of the
AUTOTHERM system in suitably equipped fleet vehicles?
5. The price sheet referenced in Section 3f has an effective date of
September 1, 1983. Is this price sheet current?
6. Section 4b references a stick-on label (Form Number
AM-D-6-2M-4/83), but this label does not include information on
maintenance and diagnostics. Since the "Installation and Owners' Manual"
provides both operating instructions and diagnostics, EPA will assume
that you wish to reference this manual. No maintenance information was
provided, but the reason becomes apparent in Section 4d which states that
no maintenance is required.
7. The literature enclosed with your letter of September 22, 1983
included a "Fleet Fuel Survey" brochure (Form Number TC101-9/83) that
included a footnote that states the following: "Acknowledged by National
Bureau of Standards and U.S. Environmental Protection Agency as an
effective fuel saving device." Please explain the basis for your claim
as I am not aware of any previous EPA involvement with the AUTOTHERM
Conservation System. Additionally, I must caution you that the U.S.
Government does not "approve" fuel economy devices, but does permit test
data resulting from an evalution to be cited.
Please inform us if any of the assumptions EPA has made in paragraphs
numbered 1, 3, and 6 are incorrect. It will be helpful if you would
provide the information requested in paragraphs numbered 2, 4, 5, and 7
by August 20, 1984.
Sincerely,
Merrill W. Korth
Device Evaluation Coordinator
Test and Evaluation Branch
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83
ATTACHMENT L
August 10,
j Mr. Merrill W. Korth
! Device Evaluation Coordinator
! UNITED STATES ENVIRONMENTAL
i PROTECTION AGENCY
1 Motor Vehicle Emission Laboratory
| 2565 Plymouth Road
! Ann Arbor, Michigan *»8105
i
i Dear Mr. Korth:
\
I am sorry for the oversights in my May 21st application. I will cover them
as listed in your July 26th letter:
1. Since the address was included in 2.C.3, I neglected to repeat it in
\ 2.d. It is the same.
2. Section 3-b.l. The AUTOTHERM system does not work with vehicles whose
vacuum controlled air mix door switches to the air conditioning mode
on engine shutdown. The 197** Chrysler was the last American car made
with that system. We have not checked Mercedes beyond the 1979 model
year since practically none of the-fleets using the AUTOTHERM system
have Mercedes vehicles.
3. I appreciate your suggestion to reference brochure AMFSB-36-1/82-25M
and Fleet Fuel Survey form AM-SV-EV-F-001 11/81-5M as additional infor-
mation for section 3-C. If you believe it applicable, report 00*46** 1 ,
Office of Energy Related Inventions, National Bureau of Standards,
might also afford additional information to Section 3>c.
k. The fuel survey forms referenced in Section 3-c. have listed average
fuel consumption at idle for various size engines. Fuel savings would
be 100% of fuel that would be used for a given engine size multiplied
by the cost of fuel in a given area at a given time. I cannot cite
references at this time, but articles have appeared in automotive
journals on numerous occasions indicating that excessive idling will
cause formation of gum, sludge and corrosion in an engine leading to
poor performance and additional service costs. It has also been pointed
out that excessive idling can lead to overheating and burnout of the
catalytic converter -- a costly replacement item plus a possible fire
hazard. In addition to savings, each hour of idling elininated also
eliminates an hour of exhaust gas pollution. A copy of a newspaper
article is enclosed referring to a severe problem caused by excessive
idling.
314 EAST MAIN ST. • BARRINGTON, ILLINOIS 60010 USA • 312-381-6366
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84
SnS
Environmental Protection Agency
Ann Arbor, Michigan
August 10, 198V
Page - 2
We have no quantitative data on percentage use of the AUTOTHERM system
and we have had fleet administrators -- primarily law enforcement —
decline to purchase AUTOTHERM kits based on the fact that they did not
believe all of their drivers would use them. Those who purchased the
AUTOTHERM system usually ran a test and determined that they could con-
trol usage and a savings would result before ordering larger quantities.
A number of fleet operators have told us the AUTOTHERM system was so
well received, they would probably have the system installed for the
comfort and morale of their drivers even without a savings. We would
not expect 100% usage, but habits can be broken since it is certainly
more comfortable to sit in a parked vehicle without the noise, vibra-
tion and possible exhaust blowback of an idling engine. Another poiTit
regarding those who leave the engine idling while they are not in the
vehicle is that they are breaking the law in all but four states by leav-
ing the vehicle unattended with the engine running.
5. The price sheet referenced in Section 3«f- effective September 1, 1983
is current.
6. The AUTOTHERM "Installation and Owners Manual" is included with each
kit and will give the owner additional information over and above the
simple operating instructions on the label referenced in Section *».b.
7-- My predecessor had been using the statement, "acknowledged to be an
effective fuel saving device by the U.S. Environmental Protection
Agency" and it is my understanding this was based on a letter written
by you to the EPA in Alaska recommending the AUTOTHERM System. We are
aware the U. S. Government does not approve devices or products and
thought the statement used was acceptable. Please let me know if that
is not the case.
Sincerely,
AUTOTHERM SALES CORP.
ROJrhlt
enc.
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85
(The copy of the newspaper article referred
to by applicant in his letter of August 10,
1984 is not completely legible. That portion
of the article which the applicant underlined
appears below:
Chicago Tribune Friday, May 13, 1983
"...after the engine in her previous
car burned out because of the many hours
it spent idling in front of City Hall."
Copy of newspaper article will be furnished
upon request.
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73
Autotherm Heater Installation
1974 Chevrolet Pickup C-10
-------
74
Offutt AFB, NE
Test Vehicle 79B5112
Operation Cost:
Miles Traveled: 9,861
Fuel Consumed: 826.9 x $1.29 = $1,06.6.70
Oil Consumed: 20.0 x . 49 = '9.80
MPG: 11.93 $1,076.50"""
»
Operation Cost per Mile: $1,076.50 t 9,861 = $0.109
Direct Maintenance Cost:
Material Cost: $108.02
Labor Cost: 353.71
$461.73
Direct Maintenance Cost per Mile: $461.73 t 9,861 = $0.047
Total O&M Cost per Mile: $0.156
125.1 hours accumulated on the Autotherm Heater.
Control Vehicle 79B5214
Operation Cost:
Miles Traveled: 11,705
Fuel Consumed: 808.8 x $1.29 = $1,043.35
Oil Consumed: 18.0 x .49 = 8.82
MPG: 14.47 $1,052.17
Operation Cost per Mile: $1,052.17 ? 11,705 = $0.090
»•* •
Direct Maintenance Cost:
Material Cost: $167.46
Labor Cost: 254.73
$422.19
Direct Maintenance Cost per Mile: $422.19 -r 11,705 - $0.036
Total O&M Cost per Mile: $0.126
Atch 3
-------
Test Vehicle 79B5599
Operation Cost:
Miles Traveled: 1,389
Fuel Consumed: 72.9 x $1.29 = $94.04
Oil Consumed: 0.0 x .49 = .00
MPG: 19.05 $94.04
Operation Cost per Mile: $94.04 ? 1,389 = $0.067
-,.-
Direct Maintenance Cost:
Material Cost: $ 0.00
Labor Cost: 84.60
$84.60
Direct Maintenance Cost per Mile: $84.60 * 1,389 = $0.060
Total O&M Cost per Mile: $0.127
171.3 hours accumulated on the Autotherm Heater.
Control Vehicle 79B5601
Operation Cost:
•
Miles Traveled: 1,065
Fuel Consumed: 66.0 x $1.29 = $85.14
Oil Consumed: 2.0 x .49 = .98
MPG: 16.14 $86.12
Operation Cost per Mile: $86.12 •? 1,065 = $0.080
Direct Maintenance Cost:
"Material Cost: $ 0.00
"'•Labor Cost: 0.00
$ 0.00
Direct Maintenance Cost per Mile: $0.00 t 1,065 = $0.000
Total O&M Cost per Mile: $0.080
32
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76
Loring AFR, ME .
Test Vehicle 74B631
Operation Cost:
Miles Traveled: 2,520
Fuel Consumed: 944.0 x $1.29 = §1,217.76
Oil Consumed: 9.0 x .49 = 4.41
MPG: 2.67 $1,222^.17
^
Operation Cost per Mile: $1,222.17 ? 2,520 = $0.485
Direct Maintenance Cost:
Material Cost: $ 0.00
Labor Cost: 111.48
$111.48
Direct Maintenance Cost per Mile: $111.48 t 2,520 = $0.042
Total O&M Cost per Kile: $0.529
Control Vehicle 74B638
Operation Cost:
Miles Traveled: 1,867
Fuel Consumed: 769.2 x $1.29 = - $ 992.27
Oil Consumed: 8.0 x .49 = 3.92
MPG: 2.43 $ 996.19
Operation Cost per Mile: $996.19 t 1,867 = $0.534
JJirect Maintenance Cost:
Material Cost: $ 30.51
Labor Cost: 136.98
$167.49
Direct Maintenance Cost per Mile: $167.49 ? 1,867 = $0.089
Total O&M Cost per Mile: $0.623
,3
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77
Test Vehicle 81B2380
Operation Cost:
Miles Traveled: 2,225
Fuel Consumed: 673.4 x $1.29 = $R68.69
Oil Consumed: 2.0 x .49 = .98
MPG: 3.30 $869.67
Operation Cost per Mile: $869.67 ? 2,225 » $0.39*1
Direct Maintenance Cost:
Material Cost: $ 8.79
Labor Cost: 250.51
$259.30
Direct Maintenance Cost per Mile: $259.30 t 2,225 = $0.117
Total O&M Cost per Mile: $0.507
Control Vehicle 81B2379
Operation Cost:
Miles Traveled: 1,442
Fuel Consumed: 399.0 x $1.29 = $514.71
Oil Consumed: 4.0 x .49 = 1.96
MPG: 3.61
Operation Cost per Mile: $516.67 •? 1,442 =
Direct Maintenance Cost:
Material Cost: $ 30.99
" Labor Cost: 309.72
$340.71
Direct Maintenance Cost per Mile: $340.71 ? 1,442 = $0.236
Total O&M Cost per Mile: $0.595
34
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78
Controlled Temperature Tests
Vehicle Reg. No.:
Date: 4 Feb 82
Time: 1310
Temperature: 12 F.
Weather Condition: Snowing/no wind
Occupants: One (1)
First Temperature Reading:
+ 15 minutes
+• 30 minutes
+ 35 minutes
Test
Vehicle
79B5599
77
15"
Control
Vehicle
79B5601
88
78°
70°
67°
Comments: Temperature tests were ended when the Autotherm
Heater shut the fan off.
Atch 4
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79
Controlled Temperature Tests
Vehicle Reg. -No. :
Date: 21 Jan 82
Time:
Temperature: 12°F.
Weather Condition: Snowing/no wind
Occupants: One (1)
First Temperature Reading:
+ 15 minutes
+ 30 minutes
4-40 minutes
With
Autotherm
0800
Test Vehicle
79B5112
Without
Autotherm
0905
80^
73<
68V
83
65V
54
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80
Cost/Savings Computation
1. Test Unit: Autotherm Heater
2. Unit Cost: $132.40
3. Quantity Required per Base: 25
4. Life Expectancy (Years): 5
5. Accumulated Hours During Evaluation: 148.2
(Based on One (1) Test Unit)
6. Accumulated Hours in One Year: 296.4
7. 296.4 r 2.3 hours = Gallons of Fuel 128.7
8. 128.7 Gallons x $1.29 per Gallon = Saved $166.02
9. Installation Cost: $ 92.00
($16.00 x 5.75)
10. Life Cycle Cost Savings:
$830.10 _ $224.40 = $605.70
(8 x 4) (2 + 9) Savings per Unit
11. Command Savings:
25 „ 26 650 .. $605.70
Units per Base Bases Vehicles Life Cycle
Savings
= $393,705.00
Atch 5
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81
ATTACHMENT K
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
ANN ARBOR. MICHIGAN 48105
OFFICE OF
July 26, 1984 AIR. NOISE AND RADIATION
Mr. Robert Jaeger
AUTOTHERM Sales Corporation
314 East Main Street
Harrington, Illinois 60010
Dear Mr. Jaeger:
This letter is to inform you that we received your May 21, 1984
application for evaluation of the "AUTOTHERM Energy Conservation System"
under Section 511 of the Energy Policy and Conservation Act. We have
performed a preliminary review and have the following concerns:
1. Section 2d of your application does not include your address, so
EPA will assume that 314 East Main Street, Harrington, Illinois 60010,
which appears at the bottom of each page of your application, is the
correct address.
2. Under Section 3b(l), your application states that the AUTOTHERM
Energy Conservation System is applicable to any vehicle with a water
cooled engine, except "Mercedes Benz vehicles, due to their use of vacuum
heater controls." Other vehicles also use vacuum heater controls; your
description does not provide enough detail to explain the unique features
of Mercedes Benz vacuum heater controls -that prevent the application of
the AUTOTHERM system. Please provide additional information to permit us
to further understand which types of heaters allow or prohibit AUTOTHERM
system utilization.
3. Section 3c of your application is rather brief and does not
reference any of the additional material you provided. EPA will assume
that the descriptions of the theory and principles of operation in, a)
brochure AMFSB-36-1/82-25M, and b) "Fleet Fuel Survey" - Form Number
AM-SB-EV-F-001 11/81-5M, are explanations that you wish to reference to
meet the requirements of Section 3c of the Application Format.
4. Section 3e make's claims for fuel and maintenance cost savings but
does not segregate them. Please provide additional information, or
reference information already sent, on the cost savings due to, a)
reduced fuel consumption, and b) the maintenance cost reductions you
attribute to the AUTOTHERM system. We also need information on how the
cost savings were calculated and the assumptions used.
A critical assumption will be the percentage of time that drivers
will forego idling and use the AUTOTHERM system. You have not given EPA
any information on driver willingness to use the AUTOTHERM system in lieu
of idling. The probability of 100 percent of the drivers, with AUTOTHERM
system equipped vehicles, using the AUTOTHERM system is very low. Some
drivers may not be willing to change their ways. The probability of
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82
optimum AUTOTHERM system use, by drivers who do use the system is open to
question. The question is then, what are the actual utilization rates?
Do you have any data that document driver utilization rates of the
AUTOTHERM system in suitably equipped fleet vehicles?
5. The price sheet referenced in Section 3f has an effective date of
September 1, 1983. Is this price sheet current?
6. Section 4b references a stick-on label (Form Number
AM-D-6-2M-4/83), but this label does not include information on
maintenance and diagnostics. Since the "Installation and Owners' Manual"
provides both operating instructions and diagnostics, EPA will assume
that you wish to reference this manual. No maintenance information was
provided, but the reason becomes apparent in Section 4d which states that
no maintenance is required.
7. The literature enclosed with your letter of September 22, 1983.
included a "Fleet Fuel Survey" brochure (Form Number TC101-9/83) that
included a footnote that states the following: "Acknowledged by National
Bureau of Standards and U.S. Environmental Protection Agency as an
effective fuel saving device." Please explain the basis for your claim
as I am not aware of any previous EPA involvement with the AUTOTHERM
Conservation System. Additionally, I must caution you that the U.S.
Government does not "approve" fuel economy devices, but does permit test
data resulting from an evalution to be cited.
Please inform us if any of the assumptions EPA has made in paragraphs
numbered 1, 3, and 6 are incorrect. It will be helpful if you would
provide the information requested in paragraphs numbered 2, 4, 5, and 7
by August 20, 1984.
Sincerely,
Merrill W. Korth
Device Evaluation Coordinator
Test and Evaluation Branch
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ATTACHMENT L
August 10, 198*4
Mr. Merrill W. Korth
Device Evaluation Coordinator
UNITED STATES ENVIRONMENTAL
PROTECTION AGENCY
Motor Vehicle Emission Laboratory
2565 Plymouth Road
Ann Arbor, Michigan ^8105
Dear Mr. Korth:
I am sorry for the oversights in my May 21st application. I will cover them
as listed in your July 26th letter:
1. Since the address was included in 2.c.3, I neglected to repeat it in
2.d. It is the same.
2. Section 3-b.l. The AUTOTHERM system does not work with vehicles whose
vacuum controlled air mix door switches to the air conditioning mode
on engine shutdown. The 197** Chrysler was the last American car made
with that system. We have not checked Mercedes beyond the 1979 model
year since practically none of the-fleets using the AUTOTHERM system
have Mercedes vehicles.
3. I appreciate your suggestion to reference brochure AMFSB-36-1/82-25M
and Fleet Fuel Survey form AM-SV-EV-F-001 11/81-5M as additional infor-
mation for section 3-c. If you believe it applicable, report 00^6^1,
Office of Energy Related Inventions, National Bureau of Standards,
might also afford additional information to Section 3-c.
k. The fuel survey forms referenced in Section 3-c. have listed average
fuel consumption at idle for various size engines. Fuel savings would
be 100% of fuel that would be used for a given engine size multiplied
by the cost of fuel in a given area at a given time. I cannot cite
references at this time, but articles have appeared in automotive
journals on numerous occasions indicating that excessive idling will
cause formation of gum, sludge and corrosion in an engine leading to
poor performance and additional service costs. It has also been pointed
out that excessive idling can lead to overheating and burnout of the
catalytic converter -- a costly replacement item plus a possible fire
hazard. In addition to savings, each hour of idling elininated also
eliminates an hour of exhaust gas pollution. A copy of a newspaper
article is enclosed referring to a severe problem caused by excessive
idling.
314 EAST MAIN ST. • BARRINGTON, ILLINOIS 60010 USA • 312-381-6366
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84
Mr. Merrill W. Korth AUTOTHERM
United States
Environmental Protection Agency
Ann Arbor, Michigan
August 10, 198V
Page - 2
We have no quantitative data on percentage use of the AUTOTHERM system
and we have had fleet administrators -- primarily law enforcement —
decline to purchase AUTOTHERM kits based on the fact that they did not
believe all of their drivers would use them. Those who purchased the
AUTOTHERM system usually ran a test and determined that they could con-
trol usage and a savings would result before ordering larger quantities.
A number of fleet operators have told us the AUTOTHERM system was so
well received, they would probably have the system installed for the
comfort and morale of their drivers even without a savings. We would
not expect 100% usage, but habits can be broken since it is certainly
more comfortable to sit in a parked vehicle without the noise, vibra-
tion and possible exhaust blowback of an idling engine. Another poiTit
regarding those who leave the engine idling while they are not in the
vehicle is that they are breaking the law in all but four states by leav-
ing the vehicle unattended with the engine running.
5. The price sheet referenced in Section 3-f- effective September 1, 1983
is current.
6. The AUTOTHERM "Installation and Owners Manual" is included with each
kit and will give the owner additional information over and above the
simple operating instructions on the label referenced in Section k.b.
7." My predecessor had been using the statement, "acknowledged to be an
effective fuel saving device by the U.S. Environmental Protection
Agency" and it is my understanding this was based on a letter written
by you to the EPA in Alaska recommending the AUTOTHERM System. We are
aware the U. S. Government does not approve devices or products and
thought the statement used was acceptable. Please let me know if that
is not the case.
Sincerely,
AUTOTHERM SALES CORP.
Robert 0>c Jagger
ROJ:hlt
enc.
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85
(The copy of the newspaper article referred
to by applicant in his letter of August 10,
1984 is not completely legible. That po'.rtion
of the article which the applicant underlined
appears below:
Chicago Tribune Friday, May 13, 1983
"...after the engine in her previous
car burned out because of the many hours
it spent idling in front of City Hall."
Copy of newspaper article will be furnished
upon request.
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