EPA-AA-TEB-511-83-11
EPA Evaluation of the Gyroscopic Wheel Cover Device Under
      Section 511 of  the Motor Vehicle Information
                  and Cost Savings Act
                           by

                    Stanley L. Syria
                        June 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  Gyroscopic Wheel Cover  Device  Under Section 511  of
the Motor Vehicle Information and Cost Savings Act

The  Motor Vehicle  Information  and  Cost  Savings Act  requires  that EPA
evaluate  fuel economy  retrofit  devices  and  publish  a  summary  of  each
evaluation in the Federal Register.

EPA evaluations  are  originated  upon  the  application of  any manufacturer
of a  retrofit  device,  upon the  request  of  the  Federal Trade Commission,
or upon the motion  of  the EPA Administrator.  These  studies are designed
to determine  whether the  retrofit device  increases  fuel economy  and   to
determine whether the representations  made  with  respect to the device are
accurate.   The  results  of  such studies  are  set  forth  in  a  series   of
reports, of which this is one.

The evaluation  of the  Gyroscopic Wheel  Cover device  was  conducted  upon
the  application  of  Zimmer  Wheels,  Incorporated.    The  device  is   a
mechanical assembly which replaces each of  the standard wheel covers  on a
vehicle.   The  device is  claimed  to  improve  fuel  economy,  handling and
braking characteristics, and the life of the brakes and tires.

1.  Title;

    Application for Evaluation of  the  Gyroscopic Wheel  Cover Device Under
    Section 511 of the Motor Vehicle Information and Cost Savings Act
The information contained  in sections two through five  which  follow,  was
supplied by the applicant.
2.  Identification Information;

    a.   Marketing Identification of the Product;

         "Zimmer  Wheels,   Inc.   has  exclusive  marketing  rights  in  the
         United States  for  both  the Executive and Sport  Model  GYROSCOPIC
         WHEEL COVER."

    b.   Inventor and Patent Protection:

         (1)  Inventor

              "Kim Rush of 6 Emperor, Irvin,  CA   92714  is the  inventor  of
              this invention."

         (2)  Patent

              "Copy  of  patent  is  enclosed."    [Attachment  A  of   this
              evaluation]

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    c.    Applicant;

         (1)   Name and address

              "Zimmer Wheels,  Inc. of 1330 Leyden  #103,  Denver,  CO  80220
              is applying for  this evaluation."

         (2)   Principals

              "President of Zimmer  Wheels,  Inc.  is  Suzanne Branch,  Vice
              President  is  Linda  Potter and  Chairman  of  the  Board  is
              David  Branch."

         (3)   "Dave  Hudson of  6759 West  70th Street, Arvada, CO  80003  and
              Tom Johnson  of   2013  Beech  Court,  Golden,   CO   80401  are
              authorized   to    represent    Zimmer   Wheels,     Inc.    in
              communications with EPA in connection with this  evaluation
              request only.  Their phone  numbers are (303)   425-1870  and
              233-3053 respectively."

    d.    Manufacturer of the Product;

         (1)   Name and address

              "Konzu Machinery  and Industry  C., Ltd.  NO.  77-3,  Nanshin
              Village Linkou,  Taipei,  Shien,  Taiwan, ROK manufactures  the
              product."

         (2)   Principals

              "Principal owners are Mr.  S. L.  Wang,   Mrs.  Wang  and  Patsy
              Cheng."

3.   Description of Product;

    a.    Purpose;

         "The   purpose  of   this   invention  is   to  provide  an  imbalance
         compensating vehicle  wheel  attachment  to  improve  stability  and
         performance."

    b.    Applicability:

         (1)   "This  invention  fits all rear wheel drive vehicles with  13,
              14,  and 15 inch standard wheels.   It will not fit  on wheels
              that have  the axle extending  out  beyond  the  outer  edge  of
              the wheel rim."

         (2)   "Gyroscopic Wheel Covers improve vehicle performance in  all
              driving  conditions,  i.e.,  icy,   snowy,  rough  roads,  wet,
              cornering and stopping."

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    c.   Theory of Operation:

         "The Gyroscopic  Wheel Cover  has  a  12-gauge  steel  movable  back
         plate,   movable  spokes,  and  is  suspended  within  the  wheel  by
         steel spring grippers.   The force  created  by the  tire  striking
         the ground  creates  a radius  of  gyration,  six pounds  of  movable
         heavy-gauge steel which  gives  a  perfect geometric center  with a
         perfect   center  of  gravity giving  a  perfectly  balanced  wheel.
         This eliminates tire bounce and greatly enhances stabilization.

         "The  360   [degrees]  of   flexing   gyroscopic  mass   forces   the
         geometric center and center of gravity  to  become  aligned  thereby
         causing   an  automatic wheel balance that  shifts  and adjusts  to
         compensate  for  any  imbalance  in  road   conditions   or   speed
         change.   The Gyroscopic  Wheel Covers react  in  millimicroseconds
         to maintain constant  balance.   This continuous response  creates
         a perfect wheel  balance  and constant stabilization  that  results
         in the  rear wheels exerting a  steady push  while the  front  wheels
         offer less  resistance  to rolling."   [See Attachments B and C  for
         additional information regarding  the theory of operation.]

    d.   Construction and Operation;

         "Detailed   description   -  See  Patent   which   is   enclosed."
         [Attachment A].

    e.   Specific Claims for the Product:

         "Up  to   16% or  better  in gas  mileage.   Testing  done  by  an
         approved Federal testing  laboratory, National Testing  Standards,
         Inc.C1]   (DCAS  No.   4-S-502).   Several  tests  were done;  a  copy
         of one  of the tests is enclosed  [Attachment  D], others  have  been
         requested and will be forwarded upon receipt."  [See  Attachment E
         for additional  claims.]

    f.   Cost And Marketing  Information;

         "Suggested retail prices:

                        Executive model   £390 (set  of four)

                        Sport Model        $350
[1] National Testing Standards, Incorporated is neither a U.S.  Government
entity,   nor  is  it  currently  recognized  by  EPA  as  being  capable   of
performing  fuel  economy  and  exhaust  emissions  tests  for  purposes   of
Section 511 of the  Motor Vehicle Information and  Cost  Savings Act.

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         Marketing  is   through  a   multi-level  marketing  system.   The
         product is in production."

4.  Product Installation, Operation, Safety and Maintenance:

    a.   Installation - Instructions, Equipment, and Skills Required:

         "A  copy   of   the   installation  instructions   is   enclosed."
         [Attachment F]

    b.   Operation:

         "This invention does not require operating instructions."

    c.   Effects on Vehicle Safety;

         "Not applicable"

    d.   Maintenance:

         "Not applicable"

5.  Effects on Emissions and Fuel Economy;

    a.   Unregulated Emissions;

         "Not applicable"

    b.   Regulated Emissions and Fuel Economy;

         "This  invention  does   not  affect   emissions.   Fuel   economy
         increases  as  shown  in  the enclosed  literature." [Although  not
         specified, the enclosed literature  referred  to by the  applicant
         is assumed  to be Attachments  D, E,  and  G.    Attachment  G is  a
         collective testimonial.]
The following Sections are EPA's analysis and conclusions for the device.
6.  Analysis;

    EPA  evaluated  the  application  and   found   no   problems   with   the
    information  regarding  device  identification,  purpose,  construction,
    operation,   cost,   marketing,   maintenance,   and   unregulated  exhaust
    emissions.

    With  respect  to  the  information  given   in the   balance  of   the
    application,  EPA has  noted the following concerns.

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a.   The applicant  states the device is  applicable  to all rear wheel
     drive  vehicles  but does not mention whether it is applicable  to
     front  wheel  drive vehicles.   It  appears to  EPA  that the device
     could  be applicable  to  front wheel drive vehicles, although when
     the  applicant   was  asked  about   this  he   did  not  respond
     (Attachment  H).   Additionally, although "Mag"  type  wheels were
     not addressed,  EPA  is  doubtful  that  the  device will  adapt  to
     these  because of  the wheel flange and bead design.

b.   The  theory  of  operation  given by  the  applicant  suggests  the
     device  is  capable of compensating for  imbalance in  wheels  and
     tires.   However,   since  adequate  data  were  not  submitted  which
     substantiated the  theory of  operation,  and  since  a sample device
     was not  provided,  EPA does  not know if the  device  functions  as
     claimed.

c.   Several  benefits  are  claimed  for   the   device  although  the
     applicant did not  submit adequate  substantiating  data for any  of
     the claims.  If the  device is  indeed capable of compensating for
     imbalance, then  EPA would  expect  insignificant,   or  no benefits
     when compared  to  a  tire  that is  balanced  in  the  conventional
     manner,  i.e.,  with  wheel  weights.  To  achieve  a gain  in fuel
     economy  of  16   percent,   would  require   that   initially  the
     tires/wheels be  terribly out  of balance.   EPA is. doubtful that
     very many  vehicles are  being  driven with  tires in  such  a  state
     of  balance,  or  that they  are driven  very  far.   Additionally,
     considering  the six  pounds of  extra weight added  to  each of  the
     four wheels, the device  may  have  an  adverse  effect  on  fuel
     economy due  to  the increased weight.  The  extra  weight  may also
     have an adverse effect  on  readability  and  riding  quality because
     the unsprung weight  of  the wheel/axle system is  increased.   For
     lack of adequate  data to  support  the various claims  made by  the
     applicant, and also  because  it was not  proven  to  EPA the device
     could  compensate  for an imbalance  condition, the Agency has  no
     technical reason  for expecting the device to achieve  any  of  the
     claims made for it.

d.   The installation  instructions  state  to  remove certain components
     i.e.,  cap and basket, but  fail to  mention whether they are  to be
     reinstalled.   Additionally,  although  retaining clips are  shown
     in  the instructions and discussed in the  patent, they  are  not
     mentioned  in the  installation  instructions.   The applicant  was
     asked  about this but he  did not respond.

e.   With respect to safety, the  applicant  states, "not applicable."
     However,  in  Attachments B,  C  and  E  it  is stated  the  device
     provides for safer vehicle operation.   EPA does not  know if  the
     applicant's  statement of  "not  applicable"  means  the  device  has
     no  effect   on   safety  (contrary  to  that  claimed   in   the
     attachments), or  if it was  an oversight  by the  applicant.   If
     the  device  is  indeed   capable  of  improving   tire  and  wheel
     balance, then  the safety  factor would  also be improved  through
     better tire contact with the road surface.

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    f.    The  applicant  states   the   device   does  not   affect   exhaust
         emissions.    However,  Attachment  C states  that  vehicle  rolling
         resistance  is reduced when using the device.   If  this  were true,
         then emission levels  as well as fuel  economy  levels  are  likely
         to change.    The  applicant did  not submit  any data showing  the
         effect on emissions due to the device.

         The  applicant  did   submit   data   (Attachments  D  and   G)   to
         substantiate the. fuel economy benefits claimed.   Those data  were
         not  adequate because multiple  vehicles  were  not  subject  to
         replicate testing under closely controlled  test conditions.   EPA
         requested additional test data following an EPA recommended  test
         plan (Attachment H).   However,  the applicant  did  not  submit  any
         additional   data.    Eventually,  the  applicant  notified   EPA  he
         would not be testing the device in  the  immediate future.

         EPA did not test the device for this evaluation because  the  data
         submitted by  the  applicant  did not substantiate  the claims  for
         better wheel  balance  or that better wheel  balance would  result
         in any fuel economy or handling benefits.

7.   Conclusions;

    EPA  fully  considered  all  of  the  information   submitted  by   the
    applicant.  The  evaluation of the Gyroscopic Wheel Cover device  was
    based  on  that   information  and   EPA's  engineering  judgment.    The
    applicant failed  to submit adequate information  and data which would
    substantiate his claims  for the  device.  Additionally, if  the  device
    can  correct  an  imbalance  condition, EPA is  doubtful  it  can cause
    significant benefits  over  tires and  wheels  that  are  balanced using
    conventional methods and wheel weights.  Thus,  EPA has no technical
    reason to  support  the  claims made for  the device  or  to continue  the
    evaluation on its own.

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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                           List of Attachments

Attachment A       Copy  of  the  Patent  Application   (provided  with  511
                   Application).

Attachment B       Copy  of report  titled,  An  Automatic  Tire  and  Wheel
                   Balancer, by George S. Schlemmer.

Attachment C       Copy  of  report  titled,  Has  Rolling  Resistance  Been
                   Decreased at Last, by George S. Schlemmer.

Attachemnt D       Copy  of test  report  from National  Testing Standards,
                   Inc., November 5, 1979.

Attachment E       Copy of advertising brochure.

Attachment F       Copy of installation instructions.

Attachment G       Collective testimonial.

Attachment H       Copy  of  a   letter  from  EPA  to  Energy  Team  for
                   Conservation,  February 24, 1983.

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                                            — - -, • •<•<••.« j i i«*;.,i £j [- '""/n

United States Patent   m   i^SScSli
Rush
          ATTACHMENT A
[ii]        4,260,090
[45|     May 19, 19S
                                                                                             1
[541  IMBALANCE COMPENSATING VEHICLE
     WHEEL ATTACHMEN^
[75]  Inventor   Kim E. Rush, Irvine, Calif.
(211  AppL No.: l*/,>»/
[22)  Filed:     Jun. 9. 1980
[5IJ  Int. C!.» 		-.... B60B 7/04; B60B 13/00
[52]  U.S. CL		—	30I/S BA; 301/37 R;
                                      74/573 R
(58)  Field of Search	301/37 R. 37 N. 37 CM.
        3Ct/37 S. 37 SS, 5 B. 5 BA. 37 B. 41 \V: 74/573
                                 R. 574; 295/6-7
[56]             References Cited
          u.s. PATENT DOCUMENTS
    3.312.503  4/1967 Huichiiw	301/37 SS
                                                     4.178,041  12/1979  Rush			 301/37 R X

                                                 Primary Examiner—Charles A. Marmor
                                                 Attorney. Agent, or Firm—Fulwidcr. Hal ton. Riebci.
                                                 Lee & Uteuiu

                                                 [57]               ABSTRACT
                                                 An imbalance compensating vehicle wheel attachment
                                                 having a rim structure for mounting to a vehicle wheel.
                                                 and funhcr having a plurality of spokes or sea on cou-
                                                 pled to the rim structure and extending radially in-
                                                 wardly to a hub structure. A mounting arrangement i>
                                                 provided to couple the inward catrtmiucs of the sectors
                                                 to the hub structure to enable radial slidable movement
                                                 of the sector* relative to the hub structure whereby me
                                                 masses of the hub structure and sectors are dynamically
                                                 movable lo establish a  radius of gyration tending to
                                                 compensate for any wheel imbalance.

                                                            11 Claims, 3 Drawing Figures

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U.S. Patent   May 19, 198
Sheet 1 of 2
4,268,090
                                             10
    F/G.4
         F/G.5


© ' V* J &
x_x
J


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U.S. Parent  May 19, 19x1
       Sheet 2 of 2     4,268,090'  11
  F/G.6
FIG.7
                                     k

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w       EPA Evaluation of the Gyroscopic Wheel Cover Device

       Under Section 511 of the Motor Vehicle Information
       and Cost Savings Act             	
                  ATTACHMENT  A
                   Page(s)  12   -    15
         Not  clearly   reproducible   from submitted
         document.  Copy  will   be   furnished upon
         request  from the  U.   S.  Environmental
         Protection Agency,  Emission Control Tech-
         nology Division, Test & Evaluation Branch,
         2565 Plymouth Rd.,  Ann Arbor,  MI  48105.

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                                                                      16
                                                           ATTACHMENT B
              AN AUTOMATIC TIRE AND WHEEL BALANCER

                             IS HERE

            This is an imbalance compensating vehicle
            wheel attachment invented by Kim Rush of
                           Irvine, California.

                           By:  George S. Schlemmer, P.E.
                                Member SAE & Veterans of Safety
Any one who has driven a small car very much must know that the
two things which affect the stability, handling and the riding
comfort of the vehicle the most are the overall weight of the car
and the short wheel base.  The two characteristics, together, make
it imperative that the tire and wheel assembly be perfectly
balanced, or as nearly so as possible, and that the balance is also
important, on a car of greater weight and with a longer wheel base.

In the July 1981 issue of the Automotive Engineering magazine,
Mr. Daniel J. Holt, Associate Engineering Editor, stressed the
importance of tire and wheel balancing^ especially on small cars.
He also discussed the difficulty of always attaining such a
balance, even with the electronic equipment and computers that are
now available for showing the compensating weight required, since
human error can always be experienced when the balancing weights
are installed.

At last a tire and wheel balancer is available where the possi-
bility of human error in the installation of the tire and the
balancing weights is eliminated.  In fact, with this balancer, the
entire tire and wheel assembly is automatically balanced with every
revolution of the wheel  in  the driving speed range.  This is an
item that does not require  expensive shop installation or mainten-
ance since the only requisite is to be sure that all of the
balancing weights that may  have been previously used are removed
and that the balancer is well seated when it is installed.  This  is
an item that will replace the existing wheel cover or hub cap and
it should not be discarded  when the automobile is  sold or traded,
but rather it should be  moved from car to car since it is long-
lasting; providing, of course, that both cars have the same  size
wheels.

In operation, the principal application is the force of the  radius
of gyration which attempts  to realign the centers  of mass or
gravity and  the  geometric center of the tire and wheel assembly,
after  the  two centers have  been deliberately caused to be out of
alignment  by  the tire  striking a bump, a rough spot or an obstruc-
 tion  on  the  surface  of  the  road.  Any roughness of about one-eighth
 inch  or more will  cause  the two centers to be out  of alignment,  and
 since there  are  few  perfectly  smooth  road  surfaces, the reactions
 to  the rough surfaces  at driving  speeds are occuring in milli or
micro-seconds,  and every such reaction  is  a balancing action of  the
 tire  and wheel.

                                                Enclosure (1)

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                                                                       17
Figures 1 aud 2 show that  this  imbalance compensating vehicle
wheel attachment has a rira structure  for mounting  to a vehicle
wheel, that it has a pularity of  spokes or  sectors coupled to the
rim structure and which extend  radially inward to  where they are
connected to a hub structure of heavy gauge steel.  The inner end
of the spokes or sectors are connected to the hub  structure by a
bolt and two washers with  a pre-determined  degree  of tightness,
and that they are so connected  that they can slide and move
radially in. relation to the hub.   The hole  in Che  spoke is larger
than the bolt which holds  it to the hub, and this  permits the
masses of both Ch%» hub and ths  spokes to move dynamically in a
radial slidable movement  to establish the radius of gyration which
tends to compensate for any tire  and wheel  imbalance.

The outer ends of the  spokes are  connected  by resilient material
to the surrounding trim ring and  the entire assembly is attachable
to the vehicle wheel by gripper members which extend through the
ring as  shown in Figure 3. Sharp points on the grippers are.
directed radially and  outward which enhances mounting on the wheel
by pennituing the trim ring to  be pressed axially  inward due to the
resiliency of the gripper base, and once in place, the outward
directional points on  the gripper prevent outward  axial movement
as the points dig into the rim.  Holding of the grippers is
accentuated by the centrifigal  force of the masses as the wheel
revolves.

By balancing the  tire  and wheel assembly on each revolution above
about ten  to fifteen miles per  hour, the bounce of the tira from
the  surface of the road has been  greatly reduced,  and a substantial
saving of  fuel, or an  increase  in the! number of miles travelled per
gallen of  fuel used  is realized.   This fuel saving has been verified
by comparative test  driving over  a pre-deterxnined  course with many
different •vehicles of  various  sizes, weights, wheel bases, power
plants,  etc.., and by many vehicles fitted with proto-type balancers
being driven hundreds  of  thousands of miles.

With no  bounce, and with perfect  contact between  the  tire and  the
 surface  of the road,  the  rel-inive speed between the bottom dead
 center of  the  tire  and the surface of the road is  zero; however,
 as  the driving wheels  of  the  vehicle bounce and the contact is
broken with the  surface of the  road, and  the weight of  the vehicle
 or load  is removed,  the driving torque will cause  che wheel to
 rocate at  a  greater  spied and che relative  :,,.,:f:d between  che  cire
 and  che  road will be changed.   Any such losu »-L concact or change
 in  the angular velocity of the  tiro wastes  energy  and fuel.   By
 greatly  reducing  che bounce and by applying an inward pressue  co
 che  surface  of  the  road and by  providing  a  greater "footprint" of
 che  tire,  boch energy and fuel  have been  saved.

 Alchough che exact theory of operation of  these wheel covers  is  noc
 known,  it is believed that in addition to reducing the  bounce, c!:ac
 rolling friccion is also partially overcome by  che action  of  che
 balancers.  1C is believed that when a Cire rocates ac  high  speed,

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                                                                      18
                                                Page Three


that due to forces including centrifugal force, rotational inertia
and gravitational forces, that where the tire strikes the surface
of the road, or at the "kiss point", that there is a bulge extend-
ing to the fore of the tire in addition to the flattening of the
side walls when the load is applied to that portion of the tire.

It is believed that since the same forces, centrifugal, rotational
inertia, and gravity, apply to the balancer; but more so because
the parts are. permitted to move radially in relation to each other,
that the reaction of the balancer is at the "kiss point" where the
tire mee;:s the road and that the reaction to the bulge in front of
the tire is the same as the reaction of the balancer when the tire
hits a bump, and that the compensating action helps the tire roll
over the bulge and reduce rolling friction to the same extent.  It
is also believed that less heat is  lost since much heat is gener-
ated by tire hysterics and since by decreasing  the bounce, some
flexing of the side walls has also been eliminated and thus less
heat is generated.

One of  the main benefits derived from the balancers is the affects
to vehicle safety.  By maintaining  better contact with the surface
of the  roa-l, the stability of the vehicle has been enhanced.  It
has been documented by N.B.C. that  at fifty-five miles per hour,  a
vehicle car be stopped in up to fifteen feet less distance when it
is equipped with the balancers, and it also  follows that  the better
the road contact the less possibility there  is  of planing or of
vehicle spin out.
                                                Enclosure  (1)

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                                            19
'   FIG.3
                    FIG. 2
'•?
                            ^r-"1 onure

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                                                                    20
                                                           14
                                                            13
                                      FIG. 3
          3  -
 2)
 3)
 I)
'o)
 t> )
 '" )
 8)
 •••' )
LOj
11)
12)
13 )
11)
15)
Spokes in section
Heavy gauge seed hub
Trim rin^
Connecting bolt
Vent holes for brake cooling i  tire  valve
Gripper assembly
Resilient gripper base
Gripper points
Hole in trim ring
Washers
Lug nuc on wheel
Lug bolt on wheel
Rim of wheel
Tire
Cap nut of wheel cover
                                             15

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                                                                                      21
                                                                          ATTACHMENT C
               HAS .ROLLING RESISTANCE BEEN DECREASED AT LAST?
         The following is a hypothesis of what happens In an automobfle
accessory recently invented by Kim Rush which decreases rolIfng resistance
and provides more miles per gallon of fuel.

                                    George S. Schlemmer
                              v      Commander, U.S. Navy (Retired\
                                    P.E., Member SAE and Veterans
                                    of Safety

 It  is of little consequence whether we say that a tire crawls or rolls
 across the surface of the road, since both must have one thing  in common —
 and that is that the tire must"have good contact or traction with the surface
 of  the road.

 With perfect contact the relative  speed between the rotating tfre and the
 surface of  the road  is zero at bottom dead center and the  vehicle will move
 the sane distance as the periphery of the tire  is rotated, however,  if we break
 the perfect contact even so slightly the speed  ratio between The two surfaces
 •3  no  longer zero.  This can  be demonstrated by watching the effect  of a
 spinning tire or  *heel when a sheet of water separates the two  surfaces
 and a  planing effect  is established.  The vehicle does not move the  same
 distance as  tr.e fire  and some rolling resistance must be attributed  to
 siippage.

 Since  the  pressure  build up  in  a  tire  is  the function of heat mostly generated
 by  -i-ire  hysteresis  and  since  the  temperature/pressure relationship  does  reach
 equilibrium,  it  is  assumed  that the energy  lost in  this process can  be con-
 trolled  only  in the selection of  materials  and  in  the method of and  type of
 construction.   It has been  determined  that by using a more resilient and
 more elastic material  of a  steel  band  around the  periphery of  a tire that
 another  obstacle  to rolling could be somewhat overcome.  This  is the rotational
 inertia  and gravitational  distortion that occurs  at the  kiss  point and wnicn
 is created as  the vehicle  moves along.   Side *all  distortion  from weight
 being^placed on  the tire and the kiss point distortion wit I  continue to  create
 nysterasis and heat and it is only by assisting the tire to  roll  or crawl  over
 this distortion  that rolling resistance can be improved  in this area.

 Many struts and  springs have been devised to dissipate the upward acceleration
 forces when the wheel bounces and to some extent to aid  in maintaining contact
 bet-.vee the tire and the surface of the road, but only recently has a metnod
 of both reducing slippage and to  assist the-tire to roll  over the distortion
 obstruction been developed.  This method puts the reaction to the upward
 thrust when an obstruction to the smooth surface of the road is encounterse
 down  in the wheel where it belongs instead of up in the strut or in the
 springs.

 A  Treatise by Or. Franklin Potter, head of  the Phvsics Department at the
 'jn i vers i ty of California,  Irvine, explains  this theory and a portion cf
 paper is  as follows:
                                                           Enclosure  (1)

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                                                                                     22
ABSTRACT-.  The upward acceleration of a rolling wheel striking a bump can
be decreased by a movable plate attached to the wheel.
                                                                 •
TEXT.  When a rolling wheel ancountares a  small bump, the upward acceteration
can be decreased by a movable plate  held with  springs concentric to the wheel
axi*.  In the first approximation the bump is  small  enough to produce an
impulsive blow.  The wheel  is treated as a solid  disc with a  rubber perimeter
and tna plate is attached by five springs  to keep the plate concentric  with
the rotation of the axis.   A simple  calculation  leads to resulting decrease
in upward acceleration.

A specific example  is a  circular plate of  mass M  held by five springs to the
disc  so that  its equilibrium position corresponds to having the plate concen-
tric  with the disc.  When the bump  impulse displaces the plate from equilibrium
by a  distance .£, the springs with the effective modulus Ks acts to restore the
plate to the equi I ibrium position.   The  resonant  frequency us* for the plate
oscillation must be much greater than the  wheel turning frequency so that
a resonance condition cannot be established.

When  a small  bump  acts,  the impulse in  this approximation occurs within a
tenth of a  radian  or  less of the  rotation  angle for the wheel.  Both vertical
and  horizontal  acceleration components  are present, but this  approximation
only  considers  the vertical motion.   The summation of  vertical  forces on
the  disc of mass M is:

       ( 1)  -M   - K i +• F.     = Ma^
            g    s     bump     d

           and on  the plate is

       (2)  -m   •»• K jL-
            —      3
 The tann moj. is the centrifugal force term produced by inertia and it
 deoends upon the d i sp I acement JJL This term adds an additional downward force
 on the plate and on the wheel through the springs.

 If the plate were simply rigidly affixed to the disc, the summation of the
 vertical forces acting upon the disc-plate  is:
       (3) -M  - m  +• F*    = (M +• m-) a'.
             g   -g    oump        —
 Thars is more, however Or. Potter concludes by stating that a practical
 solution to reduce the upward acceleration ofvthe tire on a wheel has been
 invented by Kim Rush, inventor of the Gyroscopic Wheel Cover (TM) .

 The Gyroscopic Wheel Covers are made with heavy gauge flexible steel spokes
 connected TO a trim ring on the outer end and connected to a center hub or
 floating back plate made of  12 gauge stael , on the  inner end. v In the present
 covers,  five spokes encompass the  inner circumference of the trim ring and
 ~~ey are connected to the  floating  back plate by a  bolt, nut and gasket or
 •«asfier assembly.  Grippers on the outer end of each spoke, projecting through
 the  trim ring, hold the assembly to the rim of the  wheel.

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                                                                                   23
As an uneven surface or obstacle or 1/3  inch or more is encountered on the
surface of the road, tha upward acceleration or force causes a reaction of
the floating back plata which then moves down about 1/3 inch and causes a
mis-alignment between the geometric center and the center of gravity in the
wheel cover.  This causes a radius of gyration to attempt to realign the
two centers, which creates an additional downward force.

It is obvious then, that  in order to actuate the floating back plate that
the tire must encounter an uneven surface on the road; however travelling
at 55 mph or about 80  feet per  second, many such obstacles of  1/8  inch or
T.ore are encountered  in each  revolution  of the wheel and therefore, reaction
is in mi I Ii- or  micro-seconds.  Since  the upward force was generated at the
kiss point, or within  1/10 radian of the bottom dead center, with  this fast
reaction,  the additional .downward  force  is returned to the same  position.

Newton's  Law of  Motion states that  for every  force there must  be an opposite
and  equal  force..  Since we know that the centripetal  force or  tension  in a
 rotating-body  is equal  and opposit  to  the centrifugal  force, then  any
additional  force originating  within the body  would be  additive to  the
centrifugal  force.

 The  construction of the wheel covers  permit the back  plata  to  move about
 1/3  inch which  it does in a downward  direction  when an outside force moves
 it frcm its equilibrium position.   Tha assembly and construction of the
 flexible spokes also permit an outward movement of about 1/8 inch against
 the grippers.   Vihen the two units move, tha force of• tha plate (F = map)
 striking tha spoke is additive to the force of the moving spoke (F =  mas)
 and in addition, tha same rotational  inertta-and gravitational force that
 developed tha distortion bulge on tha tire is applied to the movable spoka.
 This force is also additive to the force of tha moving plata and spoke.

 Since all action is in mi 11i-micro-seconds, tha entire force of movable
 plata and spoka  is applied to the -listortion bulge.  Tha reactive force to
 this total additional downward force (including tha force of the radius of
 gyration) are those of an imperfect-elastic body reacting to tha  impact
  'arcs-.  These are tha farces of compression and the force tending to
  restore the body to  its  shape before the compression.

 -Thus, tha additional  forces  originating in the wheel  cover tend to decrease
  the upward acceleration  of the tire and provide additional tire/road contacT
  TO decrease slipping, and by adding extra energy, they assist the tire to
  -oil or crawl over the rotational  inertia, gravitation bulge obstruction,
  2na reduca rolling friction.

  .my a hypothesis?  Because,  as Or. Potter stated, "These wheel  covers seem
  TO  be smarrer  that we are."  This  though, does seem to be the only logical
  conclusion to  how  such amazing results  have  shown up  in test  runs and 2T
  —'.e fuel  pump.
                                                      Enclosure (1)

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                                                                               24
T-tl .  EPA Evaluation of the Gyroscopic Wheel Cover Device Under

       Section 511 of the Motor Vehicle Information and  Cost Savings Act

       (Applicant's Encl (2) Simple  Physics  Explanation
                        ATTACHMENT  C


                        Page(s)  24   -     26
              Not clearly  reproducible  from submitted
              document.  Copy  will  be  furnished upon
              request  from  the  U.  S.  Environmental
              Protection Agency, Emission Control Tech-
              nology Division, Test & Evaluation Branch,
              2565 Plymouth Rd.,  Ann Arbor,  MI  48105.

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                                                                                           27
                                                                             ATTACHMENT D
Client;
Subject;
Reference;
   NATIONAL. TESTING STANDARDS
           RESEARCH AND TESTING LABORATORIES
                      877 S.ROSE PLACE
                  ANAHEIM, CALIFORNIA 92805
                        (714)99l-5i»20
                                               REPORT MO. 10751

                                               November 5, 1979
fir. Ken Rush,
#6 Emperor,
Irvine, Ca. .97214

Evaluation of Gyroscopic Wheel Covers
Conferences with Messrs. R.lilinkler and K. Rush
Sample Description;
           One sat  (4 each) of patented automotive hub caps uias
submitted by  the Client and identified as the Gyroscopic Wheel
Covers.
           Leased from Dollar Rent-a-Car in Santa Ana by National
Testing Standards Inc. was one stock  1979 Chevrolet  Camaro with  a
      3
350 in  V/8 engine,  two barrel carburator, automatic  transmission
and H78-14 tires.   Published  weight  for  this car  is  3,500  Ibs.
Request;
           Determine the  effect  on gasoline mileage  of  the  submitted
patented automotive hub caps.
Method;
           One hub  cap uias attached  to each wheel of the  furnished
car and the  car  fuel tank uias filled uith gasoline  to a  reproducible
mark.
           The car  was driven by a representative of National
Testing Standards Inc.  for  twenty-one and five  tenths (21.5)  milaa
south  east along Interstate  5 departing  from  Irvine, Ca.   The car
was driven at a  steady 54 milas  per  hour uith mileage and  air temper-
ature  recorded every ten  minutes. At the end of  the tuenty-one  and
 five  tenths  miles the car was driven off the  freeway, across  the
over  pass  and back  on the freeway headed back  toward Irvine.


                          (Cont'd)
                                                               Enclosure

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                                                                            28
   NAT1OISJA3L TESTS MO STANDARDS INC.

To Alpha N0va Engineering      Page  2           REPORT NO.  10751

                                                November  5,  1979
           At the end of  the  return  trip  the  car uas parked in
exactly the same spot.  The fuel  tank uas  filled to the  original
mark uith a measured quantity of  gasoline.  This quantity  uas
measured with a calibrated volumetric graduate.
           The hub caps uere  removed and  tho  exact same  route
repeated to the exact minute  of elapsed time.
           The round trip uith the hub caps on  uas performed
between 11:07 A.M. and 12;03  P.fl.  The round  trip without  the hub
caps on uas performed betueen 12:27  P.PI.  and  1:24 P.M.
           Tire pressure  uas  measured before  and after each round
trip.
Results:
           The total mileage  for  each  round  trip uas  43.4  miles.
           Uith the gyro  stabilized  hub caps  on,  the  leased car
consumed 1.55  gal. per  round  trip which  is an avermju of 20.0 miles
per gallon.
           Without the  gyro  stabilized hub caps on,  the  leased car
consumed 1.95  gal. per  round  trip which  is an average of 23.5 miles
per gallon.
           Durinc; the  round  trip  uith  the gyro stabilized hub caps
on, the air  pressure  remainau *t  28  psi  in all four  r.ires.
           During the  round  trip  without  the gyro  i-. ".inilized hub
caps  on,  the  air  pressure increased  from  28 psi to  .•' psi  in both
laft  tires.
Conclusion;
           The average  miles  per  gallon  increased  by  19.1/S for tha
                                           •* *•"
round  trip uhich  used  the gyro  stabilized hub caps.
Ref:99107
                                        NATIONAL TESTING  STANDARDS
                                        by Leuis F.  West

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energy efficient... money saver...29
                                  ATTACHMENT E
          greater road safety
increase
   mileage
increase tire life
increase brake life
increase traction in snow
filmed rests indicate vehicle braking reduced by fifteen feet ar 55 m.p.h.

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what  makes  it work...

The Gyroscopic Wheel Cover™ has a 12-gauge steel movable back
plate, movable spokes, and is  suspended within the wheel by
steel spring grippers. The  force created by the tire  striking the
ground  creates a radius of gyration, six pounds of movable heavy
gauge steel which gives a perfect geometric center with a perfect
center of gravity giving a perfectly balanced wheel. This eliminates
tire bounce and greatly enhances stabilization.
The 36O°  of flexing gyroscopic mass forces the geometric center
and center of gravity  to become  aligned thereby .causing  an
automatic wheel balance that shifts and adjusts to compensate for
any  imbalance  in  road  conditions  or  speed  change. The
Gyroscopic Wheel Covers™ react in milli-microseconds to maintain
constant balance. This continuous  response  creates a  perfect
wheel balance and constant stabilization that results  in the rear
wheels  exerting a steady push  while the front wheels offer less
resistance to rolling.
The increased stability from the Gyroscopic Wheel Covers™means
a smoother ride, better road contact, reduced front end wear, less
uneven tire wear and an increase in gas mileage.

fuel saver — patented  and  tested
Patent No. 4,268,09O was issued by the United States Patent Office
to Kim  Rush,  noted inventor on May  19,  1981. The patent was
issued on a device that was in  development  for 15 years and in
testing  for four years.  Testing  was done  by the  University of
California   at  Irvine,   State  of  California.   Federal Certified
Independent Testing Laboratory. Firestone Tire  Company, S.A.E.
Engineer, Technology Transfer. N.B.C. News and many others. All
tests showed in excess of 16% increase in gasoline mileage.

tests prove
Tests prove - Greatest Safety Invention since rhe Hydraulic Brake!
N.B.C. News tests on film show  vehicle braking distance reduced.
by  15 feet at 55 M.P.H. National Safety Council  viewed rests.
"unquestionably Gyroscopic Hubcaps™ will provide  safer  vehicle
operation by  motorists throughout the world." Tests  run by
McDonnell  Douglas aircraft  on wet  pavement  showed absolutely
no indication of hydroplaning or side sliding.
9O day money back guaranty
If product does not perform as described herein, after 9O days of
continuous usage your purchase price will be refunded.
30

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exclusive marketer of
                                                    31
Gyroscopic  Wheel Covers
                 TM
                               INC.
  133O Leyden Street • Denver, Colorado 8O22O • (3O3) 329-O2O6
Gyroscopic Wheel Covers™ offer you:
Safety
l. Better tracking and control.
2. Vehicle holds road better.
3. Wheel stability adds traction
  in snow and ice.
4. Smoother ride.
5. Reduced braking distance.
6. High-speed throwoff of cover
  almost impossible due to
  wheel cover expanding while
  in motion.
7. Stability reduces hydroplan-
  ing on wet pavement.
Savings
1. Up to 16% or better mileage -
  16% equals over S4.OO sav-
  ings on a 2O-gallon tank of gas.
2. increased tire life.
3. Improved brake life.
4, Stabilized wheels reduce
  front end maintenance.
Gyroscopic Wheel Covers™are available from:

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INSTRUCTIONS  FOR GYROSCOPIC  WHEEL COVER INSTALLATION
                                                                      ATTACHMENT  F

    1.  Pull factory hub  cap off.  Remove any lead weights.
        (Pig.  1)   Take gyroscopic wheel and unscrew  cap to ramove basket.
        (Fig.  2)   Sase tension in metal grippers  with  screwdriver between flange
        and gripper.  Install gyroscopic wheel covers  by first aligning valve
        stem with valve stem opening (Jig. 2)  (Valve  stem extender available
        at your local auto parts store)  (Jig. 3)  Set bottom of cover in first
        (bottom 3 grippers) all the way in.  Next with a rubber aallet hit  with  a
        downward  blow the top 1/3 °f triffl ri^S at a  **5  angle.  Make aure  trim ring
        sits flush with wheel or internal forces  cannot operate.
    2.  Repeat same procedure to remaining wheels.
    3.  Head test car.
                                                                       G«nH«  Pryiitq Mono*
                                                                        with  Scr«wdri »«r.
                                                                    (Fig. 2)
                                               45*  3lo« «.fh MaiUt
                                               Oir«Cfiy  Ov«r Grippcr

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                                                                               33
                                                                ATTACHMENT G
      NATION ATTESTING STANDARDS INC.
              RESEARCH ANQ TESTING LABORATORIES
                         377S.flOS£?lJ>.Cc
                      ANAHEIM, CALIFORNIA 92805
                           (7U)99l-552Q
                                           April 2,  1981

TO ynon IT HAY CONCERNr

              bJa aca  an  official  tasting  Laboratory racognizad
by tha U.5. Federal Government, Army,  Navy,  Stata-of Calif., ate.
              Our  naraa ia  listad  in  tna "Qualified Laooratary List"
No. 2&r published  by  Oafansa  Lagiatica Agancy.   Our numdar in tnia
publication ia 12248.
              Wa alaa have an assigned OCAS  number (Oafanas Contract
Administration Sarnica)  No.  4—S—502.  Our Local OCAS offica ia. in
Santa Ana, unan it bacomaa nacaaaary to contact our inapactoa far
aur Clianta1  government  contract  projects.

                                        Respectfully,
                                         Lsuiis F. lUaat,
                                         PraaidantT
LHJ/ca                                   NATIDNAL TESTING STANDARDS

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                                  HOWARD  Chevrolet
                                      395 Oa«« Si. at
                                 NEWPORT flEACM. CAUfO»N»A
                                      T«<«p*wu>e (714) 333 Oi.S.5
July 16, 1979
G. S. P.

Anaheim, California  928C2



Gentlemen:
RE:  TESTING OF GYROSCOPIC
COVERS
Recently I received a set of wheel  covers  and have been testing then on ay 19", '
Chevrolet Caprice Classic Sedan;  the  results  are as follows:

    Running four CO coapiete tank  fulls of cas;  two (2)  in the city
    and two (2) on the highway,. with  standard Chevrolet wij;a  wheel
    covers.

    Then, installing th« Gyroscopic Wheel  Cavers and running  thru an
    additional four (*») tanks of  gas;  two  (2)  within the city,  (to and
    from work, etc.) and two (2)  between Palo Springs and T>S
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                                                                                35
Title:       EPA Evaluation of the Gyroscopic Wheel Cover Device
             Under  Section Ml of the Motor veni.de intormation
             and Cost Savings Act
                        ATTACHMENT G
                        Page(s)  35   -   42
              Not clearly  reproducible  from submitted
              document.  Copy  will  be  furnished upon
              request  from  the  U.   S.  Environmental
              Protection Agency, Emission Control Tech-
              nology Division,  Test & Evaluation Branch,
              2565 Plymouth Rd.,  Ann Arbor,  MI  48105.

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                                                               43
 3M  Business Products Sales Inc.
                                                 BRAND

    107 *»tST ASTBSIA SOui 6VAAO . COK*»TO* OU^OWMUk 8O22O    BUS|N£SS
Gyroscopic Wheel Covers
2521 W. La Palma Avenue
Anaheim, California 92801

From J.E. Bo lender
     3M Co. Sue. Supr.

To Whom it May Concern:

    As a satisfied customer of your Wheel Covers I  would
like to share an experience with you that I feel is quite
significant.

    The advertisment had indicated that the stability
of the ride would be improved by 16.7*.  I noticed  right
away that the _ridg on my Oldsmobile wagon seemed to
smooth out, the cornering ability improved, and it. held
the road alot better.  What surprised me was the way
that it held the road when a .blowout, occured on my  left
front  tire.  I was traveling "at 50-55 mph and there was
no swe:r*rg or veering whatsoever..  I am convinced that
Che wheel covers, because of the gyroscopic principle,
was significantly responsible for the increased handling
ability during  the blowout.  In addition the wheel  covers
stayed on the car.  In the past they have come off  during
3 out  of 4 blowouts.

    ?or the possibility of keeping me. from having an
accident, or even saving my life, I'd like to thank you
for putting your product on the market.

                                    Best Regards,
                                    J.E. Bolender

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                                                                                  44
I ' t?n«u. H-i I <.»!•..• flf-TI. COC. :/

                                  lU Dececber 19?8
     Gyroscopic Safety Products
     1207 So.  FXiclid
     Anahein,  CA 9^802
     Attention:  K. S. Rush, President

     Bear Mr.  Rush:

     Recently, during the inclement veather we had in I.'ovember  1978}  I
     privileged to take a ride in your car with you and your safety consul
     tant, George Schlesner, which was equipped with the gyroscopic wheel
     covers manufactured by your company.

     Several impressive tests were nadc at my request in the vehicle  during
     a heavy downpour.

     First, to determine stability factors and hydroplaning potential,  I
     requeste-.i that a 55-oils speed "be maintained on wet pavement and a. full
     braking maneuver executed when traffic permitted^  The car came  to~a
     straifrht-on 3top_ and absolutely no indication of hydroplaning or side
     .-?iidiT|g_ va.s noticed.  This was innressive in that the pavement was wet_
     with sheets of water and the braking distance and tracking of the
     vehicle was remarkable.

     The second test consisted of attaining a 55-
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                                                                                45
Title:  EPA Evaluation  of  the Gyroscopic Wheel Cover Device Under

        Section 511  of  the Motor Vehicle Information and Cost Savings Act

        (Letter from J.  Bennett to K. Rush, May 5, 1979
                        ATTACHMENT
                        Page(s)  45
              Not clearly  reproducible  from submitted
              document.  Copy  will  be  furnished upon
              request  from  the  U.  S.  Environmental
              Protection Agency, Emission Control Tech-
              nology Division,  Test & Evaluation Branch,
              2565 Plymouth Rd.,  Ann Arbor,  MI  48105.

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                                                                                46
   ^ _,                                                           ATTACHMENT H
|>  A  \       UNITED STATES ENVIRONMENTAL PROTECTION  AGENCY
\-^\^T-J                     ANN ARBOR. MICHIGAN  48105

    February  24,  1983
                                                                    OFFICE OF
                                                               AIR. NOISE AND RADIATION


    Mr. David Hudson
    Energy Team for  Conservation
    6759 W. 70th Avenue
    Arvada, CO   80003

    Dear Mr.  Hudson:

    We  have  performed a. preliminary  review of  your January  24,  application
    for  an EPA evaluation  of  the "Gyroscopic  Wheel Cover"  retrofit  device.
    We have the following concerns:

        1.  Since  section  2.c.(3)   of  the   application  states  you  are
            authorized to represent Zimmer Wheels, Incorporated, we  will need
            a letter from that  company substantiating your authority.

        2.  Please clarify  whether  the device  can  be  used  on front  wheel
            drive vehicles.

        3.  Section 3.e. states that testing was  "done  by  an approved  Federal
            testing  laboratory,   National  Testing   Standards,  Incorporated".
            While other government agencies  may have found  it  acceptable for
            their purposes, that  company has not  been recognized by  EPA for
            fuel economy and exhaust emission testing.  We would like  to have
            some additional information on their capabilities and credentials.

        4.  The  installation  instructions state  to  "unscrew cap and  remove
            basket".   No  further  mention is  made  about   reinstalling  these
            components.  Please clarify  this area.   Further,  the  patent  shows
            that clips  (item  40  in  Figure 2)  are used to ensure  the  cover
            does not  come off  the wheel.  No mention is  made of  these  clips
            in   the   installation   instructions.   .Please   resolve   this
            inconsistency.

         5.  The  test  results   from- National Testing Standards,  Incorporated
            show  that wichout  the  Gyroscopic  Wheel Covers,  the  Chevrolet
            Camaro traveled 43.^  miles  and  consumed  1.95  gallons of fuel and
            thereby  achieved  23.5 MPG.  These  values indicate  it  achieved
            22.3 MPG.  Please  clarify this apparent discrepancy.

            Your application indicates  that  test  results  have  been obtained
            on more chan this  one vehicle.   Please  submit  the  results  of all
            testing performed  on the  device.

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                                                                         47
Overall, the test data you  have  submitted suggest  that  there  may be fuel
economy benefits  associated with  the device.   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.    Although we  have  not  decided  on  all the  specific
details, we  suggest you  consider  the  features  outlined in  Attachment A
when designing your program.

I  recommend  that  you  contact  the  independent  test  labs  listed  in
Attachment B 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.

Because of our need  to  process  all evaluations in  a  timely manner,  I ask
that you respond  to  this  letter  by March 11 and  that  you submit all data
by  April  11.  Should you  have  questions  regarding  this  matter,  please
contact me.

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

Enclosure

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                                                                                 48
                               Attachment  A

Test Vehicles

Quantity:  Four
Model Range:  1975 thru 1983
Manufacturers:  General Motors, Ford, Chrysler, American Motors (see
                   Attachment C)
Number of Engine Cylinders: 8, 6, and 4
Transmission:  Automatic

Test Conditions
Test Type:  On-Road testing1

It is suggested that all  on-road testing be performed  on  the San Antonio
Road Route^ which  is  described  in  Attachment  D.  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°?
Wind:  5 MPH or less,  gust to 10 MPH maximum

Miscellaneous Comments
1.  All testing should be conducted between 9:00 am and 3:00 pm

2.  Two  or   more   practice  runs   should   be  made   to   assure  driver
    repeatability.

3.  One warm-up circuit  of  the  test route  should  be made  prior  to  start
    of data gathering.

4.  Tests  without   che   device   should  be   performed  with   all   cires
    intentionally  out  of balance  to  the  maximum  extent   possible  while
    still maintaining safe driving characteristics.

5.  Tests with  and  without  the device  should  be  randomly mixed  during
    each day.
    Because  the   device  is  installed  on  all wheels  and  also  because
    chassis dynamometer  testing includes  rotation  of only  the  front  o_£
    the rear wheels, the device will have  to  be evaluated  using road test
    procedures.

    The  San Antonio Road  Route closely  approximates  the driving  cycle
    followed  during chassis dynamometer  testing  using  the Federal  Test
    Procedure.

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                                                                              49
                                            Issued: February, 1983
                                            To be revised: July, 1983

           Independent Laboratories Recognized by EPA as Capable
              of Performing Emissions Tests on Motor Vehicles

While  the  Federal  Government  does  not formally  approve  laboratories  for
emission  testing  of  motor  vehicles,  certain independent  laboratories  are
recognized by EPA as  having  this  capability.  Their equipment is identical
or equivalent to that used by  EPA.   The following  list  of such laboratories
also contains  the  "recognition  category"  of  the  laboratory and  any addi-
tional considerations.  These  additional items  were  provided by the labora-
tory as part of  their application.  The recognition categories  are as fol-
lows :

    Category Number  1;   Laboratories which have successfully  completed  all
    requirements  for recognition.   The recognition  category  is   shown  in
    parentheses following the  company name.

    Category Number  2;   Laboratories which  have submitted  formal applica-
    tions but have  not. yet  been inspected.   The application indicates that
    they have the appropriate  facilities, equipment and personnel.
Automotive Testing Laboratories, Inc. (1)
P.O. Box 289                                Myron Gallogly, President
East Liberty, OH  43319                     Telephone:  513-666-4351-

Additional Considerations:  Diesel,  evaporative,  catalyst  efficiency,  mile-
age accumulation, track, fuel consumption, undiluted emissions,  and RTAFRR.


Bendix Test Operations - Bendix Corporation (1)
Test Services Department                    Ward Diehl, Supervisor
900 West Maple Road                         Test Services
P.O. Box 2602                               Telephone: 313-362-1800
Troy, MI  48299

Additional Considerations:  Catalyst efficiency,  evaporative, fuel consump-
tion, mileage  accumulation,  track, engine dynamometer,  controlled environ-
ment, undiluted emissions, humidity control and alcohol.
Custom Engineering (1)
Performance and Emissions Laboratories      Robert Begue
7091 A Belgrave Avenue                      Laboratory Manager
Garden Grove, CA  92641                     Telephone:  714-891-5704

Additional Considerations:  Evaporative, undiluted  emissions, mileage  accu-
mulation and engine dynamometer.

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                                                                               50
EG&G Automotive Research,  Inc.  (1)
5404 Bandera Road
San Antonio, TX  78238
 Maurice Forshee
 Engineering Assistant
 Chassis Dynamometer Test Lab
 Telephone:  512-684-2310
Additional  Considerations:   Fuel consumption,  mileage accumulation,  track,
motorcycle,  undiluted  emissions,   catalyst  efficiency,  FEED  and   humidity
control.
Environmental Testing Corporation  (1)
1859 Jasper Street
Aurora, CO  80011
 A.  L.  Papay,  President
 Telephone:  303-344-5470
Additional Considerations:   High  altitude,  diesel, evaporative, particulate
and undiluted emissions.
Ethyl Corporation (1)
1600 West Eight Mile Road
Ferndale, MI  48220
William J. Brown
Supervisor, Vehicle Operations
Telephone:  313-399-9600
Additional  Considerations:   Diesel,  undiluted  emissions,  alcohol,  fuel
consumption, FEED and mileage accumulation.
FCI  (2)
International Testing Laboratories
3132 West Adams
Santa Ana, CA  92704
Jerry C. Coker
President
Telephone:  714-754-6424
Additional  Considerations:   Diesel,  evaporative, fuel  consumption,  mileage
accumulation and track.
New York Cicy (1)
Department of Environmental Protection
Mobile Source Control Division
75 Frost Street
Brooklyn, NY' 11211
John- Pinto
Assistant Director
Teleohone 212-388-4994
Additional Considerations:  Diesel, evaporative and particulate.
Olson Engineering, Inc. (1)
Automotive Research Center
15442 Chemical Lane
Huntington Beach,  CA  92649
James Buxton
Manager of Testing
Telephone:  714-891-4821

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                                                                               51
Additional Considerations:  Diesel,  evaporative,  fuel consumption, particu-
late emissions, undiluted  emissions,  mileage  accumulation,  track and engine
dynamometer with diesel and gasoline emissions and marine fuel economy.
SATRA Automotive Emissions Laboratory, Inc. (1)
Route U.S. 1 and 9 South
Newark, NJ  07114
Alexander Kulesha
Laboratory Manager
Telephone:  201-242-7665
Additional Considerations:  Evaporative, mileage  accumulation and undiluted
emissions.
Scott Environmental Technology, Inc. (1)
Route 611                      /
Plumsteadville, PA  18949      /
Duane Gulick
Manager, Auto Testing
Telephone:  215-766-8861
Additional Considerations:  Evaporative, diesel,  controlled  environment and
mobile laboratory.
Southwest Research Institute (2)
Department of Emissions Research
P.O. Box 28510
San Antonio, TX  78284
E. Robert Fanick
Research Scientist
Telephone: 512-684-5111
Additional   Considerations:    Alcohol,   Aldehydes,   Catalyst   Efficiency,
Diesel,   Engine  Dynamometer,   Evaporative,   Fuel   Consumption,   Mileage
Accumulation, Particulate, Undiluted Emissions, and Unregulated Emissions.
Texas Transportation Institute (2)

Mailing Address:
Texas ASM University System
College Station, TX  77843
Richard D. Tonda,  Manager
Automotive Research Program
Telephone:  713-345-6176
Laboratory Address:
Vehicle Emissions and Fuel Economy Laboratory
Research & Extension Canter, 31dg. 7490
Highway 21 West
Bryan, TX  77801

Additional Considerations:  Undiluted  emissions,  fuel consumption,  mileage
accumulation, track, and engine dynamometer.

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                                                                              52
University of Santa Clara  (2)
Mechanical Engineering Department           Ms. Kelly Erin O'Brien
Mechanical Engineering Lab., Room 511       Laboratory Manager
Santa Clara, CA  95053                      Telephone:  408-984-4325

Additional   Considerations:    Alcohol,   aldehydes,   catalyst   efficiency,
diesel,    engine    dynamometer,   evaporative,   fuel    consumption,    gas
chromatography, mileage  accumulation,  undiluted emissions  and  smog chamber
analysis.
The basic  condition for EPA  recognition is  the  capability to  perform  ex-
haust  emissions testing  on light  duty vehicles  according to  the  current
Federal Test  Procedure.   Each laboratory has  additional  capabilities.   Key
words listed with each, entry are explained below:

    Alcohol - Methanol and/or Ethanol fuel testing capability.

    Aldehydes - Aldehyde measurement capability using the MBTH method.

    Catalyst  Efficiency  -  Capability   to  measure  emissions  levels  both
    before and after a catalytic converter.

    Controlled  Environment  -  Capability  to  conduct  emission  tests   at
    ambient conditions outside the range of the Federal Test Procedure.

    Diesel -  Capability  to measure gaseous emissions  from  light  duty  vehi-
    cles equipped with diesel engines.

    Engine Dynamometer - Capability  to  test  engines  which are  not installed
    in vehicles.

    Evaporative  -  Capability  to  measure  evaporative  emissions  using  the
    enclosure technique  ("SHED")  specified  for late model  light  duty  vehi-
    cles.                          \

    Fuel Consumption  -  Capability to measure  fuel consumption using  volu-
    metric and/or gravimetric techniques.

    FEED - Fuel Efficient Engine Oil testing.

    High Altitude  - The  laboratory  is  located  at an  elevation  considered
    "high  altitude"  by  EPA  regulations.   Potential  applicants for  Section
    511 Evaluations  should  be  aware that test  results at  high altitude  on
    certain  types  of devices  (e.g. air bleeds)   will  not  be  accepted  by
    EPA.   Please check with Merrill  Korth,  EPA's  Device  Evaluation  Coordi-
    nator,   before  arranging  for  such   testing.   His   telephone  number  is
    (313) 668-4299.
                                                         i
    Humidity Control - Humidity in test  cell can be adjusted and  maintained.

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                                                                            53
    Mileage  Accumulation  -  Capability  to  accumulate mileage  over  estab-
    lished road routes.

    Motorcycles - Capability  to  measure exhaust emissions  from  motorcycles
    according to current Federal Test Procedures.

    Particulate - Capability to measure particulate emissions.

    RTAFRR - Real Time Air Fuel Ratio Recording.

    Track -  Access  to  facility for use  in  controlled  mileage  accumulation,
    coast down determinations, performance  testing and driveability evalua-
    tions.

    Undiluted Emissions - Capability to measure raw exhaust  emissions.
    Unregulated  Emissions   -   Capability   to  measure   ^S,   NH3 ,   S02,
    SO^,  N20,  total  cyanide,  organic  amines,  organic  sulfides,   phenols,
    methanol,  ethanol,  nickel  carbonyl,  individual  hydrocarbons,  soluble
    organic fraction, BaP,  PNA,  nitropyrenes,  Ames bioassay, metals,  CH&N,
    visible smoke,  etc.

    Mobile Laboratory - Capability  to  establish  a  portable laboratory  in
    remote locations.

For additional information, please contact John  White or Matthew Macocha  at
EPA's Motor Vehicle Emission Laboratory,  2565  Plymouth Road, Ann Arbor, MI
48105.  The telephone number is (313) 668-4315.

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                                  Table 1
           Suggested Test  Vehicle  and Engines for 511 Applicants

The following  are  suggested as suitable  candidate  vehicles  to  be  used to
generate  support  data for  a 511  evaluation by EPA.   By choosing  one or
more  of  these,   the  applicant   is   assured  chat   the   process/device  is
applicable to a representative portion of the fleet for  the  model  year of
interest.  The ease of obtaining  a test  vehicle  is  enhanced because of the
popularity of these models.   Newer vehicles  chosen  for testing should have
odometer readings of  10,000  to 20,000 miles.  The  following list is broken
down by year and  manufacturer.   The   ranking  for any given manufacturer is
by sales volume.

Model  Manufacturer   Suggested Gasoline Engine Test Vehicles  Engines (CID)
Year

1981     GM           Citation*/Skylark/Phoenix/Omega          151 1-4/173 V-6*
                      Chevette/T-1000                          98 L-4
                      Malibu*/Cutlass/Cantury/Regal            229/231 V-6
                                                              260/265/267* V-3

         Ford         Escort*/Lynx                             98 L-4*
                      Mustang/Capri                            140 L-4/200 L-6
                      Fairmont*/Zephyr                         200 L-6*/255 V-3

         Chrysler     Omni/Horizon                             105/135* L-4
                      Aries*/Reliant                           135*/156 L-4

         AMC          Concord/Spirit                           258 L-6

         Volkswagen   Rabbit                                   105 L-4

         Toyota       Corolla/Celica/Tercel                    108/144/89 L-4

         Datsun       210/310/200 SX                           91/119 L-4

         Ronda        Accord/Civic                             107/91 L-4

*Nota: These  vehicles and  engines are currently part  of  EPA's  cast  vehicla
fleet used Co evaluate 511 processes  or devices.

1980     GM           Citation/Skylark/Phoenix/Omega            151 L-4/173  7-6
          '            Chevecte                                 98 L-4      -  '
                      Malibu/Catlass/Cantury/Regal             229/231 V-6
                                                              260/265/267  V-3

         Ford         Mustang/Capri                            140 L-4/200  L-6
                      Fairmont/Zephyr                           200 L-6/255  V-3
                      Thunderbird/Cougar                       255/302 V-3

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         Chrysler    Omni/Horizon
                     Aspen/7olare

         AMC         Concord/Spirit

         Volkswagen  Rabbit

         Toyota      Corolla/Celica/Tercel

         Datsun      210/310/200 SX

         Honda       Accord/Civic
                                           105 L-4
                                           225 L-6/318 7-3

                                           258 L-6

                                           89/97 L-6

                                           108/134/89 L-4

                                           85/91/119 L-4

                                           107/91 L-4
      Suggested Powerplants for the 1973 - 1979 Model Year Test Vehicles

1979 Model Year    1978 Model Year     1977 Model Year     1976 Model Year
General Motors
  305 CID V8
  301 CID V8
  231 CID V6
   98 CID L-4

Chrysler Corp.
  318 CID V8
  225 CID L6

Ford Motor Co.
  302 CID V8
  200 CID L6
  140 CID L4

American Motors
  258 CID L6

1975 Model Year

General Mo cors
  350 CID V8
  400 CID 78

Chrysler Corp.
  318 CID 73
  225 CID L5
General Motors
  350 CID 78
  305 CID 78
  231 CID 76
Chrysler Corp.
  318 CID 78
  225 CID L6

Ford Motor Co.
  351 CID 78
  302 CID 78
  200 CID L6

American Motors
258 CID L6

   1974 Model Year

   General Motors
    350 CID 78
   Chrysler Corp
    318 CID 78
    225 CID L6
General Motors
  350 CID 78
  305 CID 78
Chrysler Corp.
  318 CID 78'
  225 CID L6

Ford Motor Co.
  400 CID 78
  351 CID 78
  302 CID 78

American Motors
  258 CID L6

   1973 Model  Year

   General Motors
    350 CID 78
   Chrysler Corp
    318 CID 78
    225 CID L6
General Motors
  350 CID 78
  305 CID 78
Chrysler Corp.
  318 CID L6'
  225 CID 78

Ford Motor Co.
  351 CID 78
  250 CID L4
  140 CID L6

American Motors
  258 CID L6

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                                                                              56
Ford Motor Co.
  351 CTD V8
  302 CID V8
  250 CID L6

American Motors
  258 CID L6
  232 CID L6
Ford Motor Co.
 400 CID V8
 351 CID 78
 140 CID L4

American Motors
 258 CID L6
 232 CID L6
?ord Motor Co.
 400 CID 78
 351 CID 78
 122 CID L4

American Motors
 258 CID L6
 232 CID L6
                         Suggested Diesel  7ehicles
1978 through 1981 GM 350 CID diesel powered passenger cars.
1977 through 1981 7olkswagen Rabbit diesel or Dasher diesel,

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                                                        Attachment D

                  SAN ANTONIO ROAD ROUTE TEST PROCEDURE

A.  The general procedure i_s 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.).

B.  General Test Requirements

    1.   The  first  test run  of  each  day  is considered  warm-up and  the
         data is not used in any subsequent calculations.

    2.   Only tests  run between  9:00 a.m. and  3:00  p.m.  are  used due  to
         San Antonio traffic considerations.

    3.   Only tests  on run on weekdays,  Monday through Friday,  are  used
         due to San Antonio traffic considerations.

    4.   Temperature,  humidity,  barometer, wind  speed  and  direction  are
         to be taken at 9:00 a.m. nd 3:00 p.m.

    5.   All test vehicle fuel tanks are to be  drained prior to start  of
         testing to avoid fuel mixing.

    6.   Commercially   available   pump    fuel   meeting   the   following
         requirements must be used for  all testing.

         a.   The fuel must be from a  major supplier  (e.g.,  Mobil, Shell,
              Texaco).

         b.   It must  meet  the octane  and lead requirements  recommended
              by the manufacturer of the test vehicle.

         c.   The fuel must  be  of a blend  appropriate  to  season for  the
              test  location selected.

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                                                                             58
     d.   For  each  car,   fuel  from  the   same  batch  must  be  used
          throughout the program.

7.   All vehicles  are  to  be  examined  for  proper vacuum  line routing
     and evidence  of  tampering and  the  engine set  to  manufacturer's
     specifications.

8.   Vehicle   tire   pressures   are   to   be   checked   and  set   to
     manufacturer's  specifications  each  morning  prior  to  leaving
     Southwest Research.

9.   Test runs with abnormal  time, fuel  consumption,  or circumstances
     are to be deleted from consideration.

10.  Testing  run  on wet pavement  will  not be  used in  the  analysis.
     When pavement  is  damp  the resits are  to  be  used  if  they  appear
     in-line with other measurements.

11.  A  minimum of  5  tests  are  to  be  run   with  most  vehicles  to
     familiarize the driver with  the vehicle  and route.   Data  is  not
     collected during driver familiarization.

12.  The fuel  totalizer display should  be  located  in  the  vehicle  so
     that the driver can not see the  display while driving.

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j«gn .-a.n»3r. _o  r.oac .•'.oucs

dumber of  Stop Signs: 0
Number of  Scop Lights: 2S
Average Distance:  7.2 siles
Average Speed:  19.6 tnph
Maximum Speed:  55  aph
S Coos/Mil a:  3.9
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