EPA-AA-T EB-511-8 3-5
EPA Evaluation of the Gas Saving and
Emission Control Improvement Device Under
Section 511 of the Motor Vehicle Information
and Cost Savings Act
by
Edward Anthony Barth
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 Gas Saving and Emission Control Improvement 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 "Gas Saving and Emission Control Improvement
Device" was conducted upon the application of the manufacturer. This
device is a 3/4 inch thick carburetor adapter plate that is installed
between the carburetor and intake manifold. The device has internal
passages that are connected to the throttle bore openings in the plate.
These passages in the device are connected by a hose to a tee fitting
installed in the hose between the carburetor and PCV valve. The device
is claimed to reduce emissions, improve fuel economy, clean the engine
and make it virtually maintenance free, and improve engine power.
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 Gas Saving and Emission Control
Improvement Device Under Section 511 of the Motor Vehicle Information
and Cost Savings Act
2. Identification Information;
a. Marketing Identification of the Product;
"Gas Saving and Emission Control Improvement Device"
The application identified it as the "Gas Saving Device", see
Section 6a(l).
b. Inventor and Patent Protection;
(1) Inventor
Jack C. Shaffer
P.O. Box 243
Lynnville, IA 50153
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(2) Patent
"The only copy of patent application is one which was
certified and mailed to myself." This is further discussed
in Section 6a(2).
c. Applicant;
Jack C. Shaffer
P.O. Box 243
Lynnville, IA 50153
d. Manufacturer of the Product;
(1) Shaffer Enterprises, Inc.
P.O. Box 243
Lynnville, IA 50153
(2) Principals
Jack C. Shaffer
3. Description of Product (as supplied by Applicant);
a. Purpose;
"This gas saving device is devised to enhance power, produce
high level gas savings, clean the engine and make it virtually
maintenance free, as well as drastically reduce emission
pollutants."
b. Applicability;
(1) "This product is designed to provide better results on all
U.S. manufactured automobiles and pickups, motorhomes,
school busses, etc. on 4-8 cylinders engine from the
current model year all the way back to models incorporating
PCV in the [intake] manifold. One Toyota Celica was tested
with excellent results."
(2) "This product has been tested from 100 ft @ 90° plus to
over seven thousand feet @ temperatures in the high 20's,
from Phoenix, AZ to Tulsa, OK in March of 1980 (see exhibit
A enclosed)." Exhibit A was a copy of the United States
Testing Company, Inc. trip report for one vehicle.
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c. Theory of Operation;
"A plate has been designed for placement under the carburetor
with routing holes which disperse and atomize the liquid fuel
for longer burn time, [thereby] enabling the gasoline fumes to
burn at a much higher rate of thrust, thus leaving less solids
to drop to the [intake] manifold and eject out of the muffler
system. This cleans up the engine allowing a cleaner tail pipe
without having to lean out the engine. No adjustments are
required on an automobile that is already up to manufacturers
specifications."
d. Construction and Operation;
"The plate is 3/4 inch thick with internal grooves to control
air flow on the gas jets which enables the gas to atomize and
form a cyclonic mode which keeps solids [liquids] in the
carburetor [throttle bore] rotating long enough to break them
down into fumes which create engine thrust and forward movement
for a significantly longer time span to eliminate premature
solids [liquids] dropping onto the manifold and becoming waste
for the exhaust system. The air is taken on demand from the PCV
and utilized at optimum."
e. Specific Claims for the Product;
"A copy of everything available is enclosed. All installations
shall be made by factory trained dealers with diagnostic
equipment to measure, power, emissions, gas consumption, etc.
prior to installation and retested after installation."
f. Cost And Marketing Information (as supplied by Applicant);
"The unit will retail for one hundred fifty dollars ($150.00)
installed. The product has been developed over the past four
years and tested since March, 1980, by an independent testing
company (see exhibit A)." Exhibit A was a copy of the United
States Testing Company, Inc. trip report for one vehicle.
4. Product Installation, Operation, Safety and Maintenance (as supplied
by Applicant);
Installation - Instructions, Equipment, and Skills Required;
"The carburetor must be raised and the existing bolts or studs
removed. A gasket furnished by the Co. is then put in place
followed by the Gas Saver Plate. The existing gasket and
carburetor are then replaced and 3/4 inch longer bolts are used
for reinstallation. We furnish a tee and the required hose to
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go from the "plate" to the tee and from the tee to the PCV and
existing carburetor opening. Two clamps are furnished if
required for the plate outlet and the carburetor outlet. On
some models the accelerator linkage must be adjusted and a
longer lifting pin is then furnished. A 1/2" box end wrench or
ratchet is required as well as a screwdriver and a pair of
pliers. General mechanical skills are all that is required."
b. Operation;
"Nothing will be furnished since the product does not require
service nor maintenance."
c. Effects on Vehicle Safety:
"Since this is a solid plate and nothing on the engine has been
modified, no safety precautions are required."
d. Maintenance;
"No maintenance is required on the product, and normal vehicle
maintenance will be required less than before product
installation."
Effects on Emissions and Fuel Economy (submitted by Applicant);
a. Unregulated Emissions;
"See Exhibits B and C". The exhibits to the application were
not labeled. In addition to the United States Testing Company,
Inc. trip report, there were two State of Arizona 'Vehicle
Inspection Reports' on a 1973 Cadillac and one on another
vehicle. There were also copies of Sun Diagnostic Analyzer
printouts for the 1973 Cadillac.
b. Regulated Emissions and Fuel Economy;
"See Exhibits B, C, and D." See comments under 5a preceding.
Analysis
a. Identification Information;
(1) Marketing Identification:
The application identified the device as an air injected
gas saving device that was to be identified as "Gas Saving
Device" until a trade name was selected. Shortly
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thereafter, the applicant chose "Gas Saving and Emission
Control Improvement Device" as the marketing identification
for the device (Attachment B).
(2) Inventor and Patent Protection:
To improve our understanding of the device, EPA requested
the applicant to provide a copy of the patent (Attachment
A). The applicant did not provide a copy. His response
indicated that the patent application contained only a
brief description of the device and that no detailed patent
description of the device was available (Attachment B).
b. Description:
(1) The applicability of the product, as stated in Section 3b,
to all US manufactured vehicles, was clarified to mean all
US manufactured vehicles with carburetors (Attachments A
and B). This excludes diesels and fuel injected vehicles.
The applicant stated that there are several models sold.
These are identified by vehicle year and carburetor.
Typically, one model fits several vehicles/carburetion
configurations (Attachment B). However, the specific model
numbers and specific vehicle application were not given.
(2) The theory of operation given in Section 3c describes the
types of effects the device might have on the fuel/air
mixture. However, installing a device like the Gas Saving
and Emission Control Improvement Device in the induction
system of an engine does not necessarily guarantee
beneficial changes. For example, the device may not
perform as expected, because the desired dispersion and
atomization improvements do not occur. Alternately, the
induction system of the vehicle may already perform
efficiently and therefore no change would be noted.
(3) The description of the device provided in the application,
Section 3d, was a very short, simplified, general
description. Because a detailed description of the
construction and operation of the device was needed to
evaluate it, EPA requested the applicant to provide
additional information (Attachment A). In response to this
request, the applicant provided a clear plastic model of
the device that permitted the internal passages to be
readily seen (Attachment B). This model measured 4 1/2 x 6
x 3/4 inches (width x length x thickness) and had two large
holes that were positioned inline with the two throttle
bores of a two barrel carburetor. Two passages that are
located 90 degrees apart bleed air from the PCV line into
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each of these two larger holes. The bleed air enters at
right angles to the fuel/air mixture passing through the
throttle bores and these holes in the device. These four
passages are manifolded together inside the device for
connection by a hose to a tee fitting that is installed in
the PCV line.
However, there were no internal grooves or gas jets to
control the flow as stated in Section 3d. The passages
measured one-fourth of an inch in diameter from the
throttle bore holes to the point where they were manifolded
together.
(4) No specific claims were made for the device in Section 3e.
The claims made for the device in Section 3a are
generalized claims. We therefore requested the applicant
to state "what specific numerical improvements or range of
improvements do you claim for reduction in emissions,
improvements in fuel economy, and increase in power? To
what mileage or time interval does '... cleans the engine
and makes it virtually maintenance free...' refer?"
(Attachment A).
The applicant responded that the "Emissions improvements
exceed twenty percent. Fuel economy improvements exceed
minimum requirements delinated in your letter of August 19,
1982 and exceed twenty to fifty percent in most cases. It
requires from five hundred to one thousand miles to attain
optimum efficiency on cleanliness, as well as emissions and
gas savings" (Attachment B).
(5) The cost of the device plus installation was given as
$150.00. However, due to the potential problems likely to
be encountered in installing the device and the expensive
specialized equipment required, see Section 6c(2), this
cost is judged to be unrealistically low.
Installation, Operation, Safety and Maintenance:
(1) Installation - Instructions, Equipment and Skills Required;
The installation instructions given in Section 4a were a
simplified, short summary of the device installation.
However, for evaluation purposes, a more detailed
description was needed and therefore requested (Attachments
A and C). The instructions provided (Attachment B) were
judged to be adequate for the installation of the device in
the vehicle but inadequate in describing the necessary
vehicle adjustments and skill levels required.
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These instructions make only a brief mention of the
necessity to readjust linkages to compensate for the device
raising the carburetor 3/4 of an inch. EPA's experience
with a similar device* which raised the carburetor one inch
suggests that there are a number of problems with hood
clearance and linkages to the throttle, choke, and
automatic transmission. In addition, air hoses, electrical
leads, fuel lines, and vacuum lines also required
repositioning or relocating. Installation, including
fabrication of parts and necessary adjustments, was judged
to require more than two hours for the Turbo-Garb device.
The same problems are anticipated for this device.
The applicant requires the use of specialized test
equipment to checkout the vehicle before and after device
installation. These include a Sun diagnostic analyzer,
with emissions capability, a chassis dynamometer, and a
fuel measuring device. This equipment is expensive and
will add appreciably to the time and cost of installing the
device.
The applicant does not state how this equipment is to be
used or adjustments to the vehicle made. This presumably
would be covered in the factory training given to the
dealers.
The applicant statement that only general mechanical skills
are required for proper installation and checkout of the
device is very misleading. The installer will have to also
be thoroughly familiar with the vehicle and have access to
shop manuals. Also, he will need to be properly trained in
the use of the sophisticated shop analyzer, chassis
dynamometer, and fuel measurement unit.
(2) Operation;
If the various carburetor linkages altered by the
installation are properly readjusted, the device is judged
to not have any adverse effect on vehicle operation nor
require special attention when operating a vehicle with the
device installed.
*"EPA Evaluation of the Turbo-Garb Device Under Section 511 of the Motor
Vehicle Information and Cost Savings Act." EPA-AA-TEB-511-82-12.
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(3) Effects on Vehicle Safety:
If the linkages are properly readjusted and the seal of the
device to the intake manifold and carburetor is leakproof,
the device is judged to have no adverse affects on safety
as claimed in Section 4c.
(4) Maintenance;
The device will require the minimal maintenance given
similar components in a vehicle (hoses, vacuum tees, leak
checks of the carburetor base). However, there is no data,
information, or technical basis that substantiates the
claim of the applicant that "...normal vehicle maintenance
will be required less than before product installation." as
claimed in Section 4d.
d. Effects on Emissions and Fuel Economy;
(1) -Unregulated Emissions;
The applicant referred to Exhibit B and C of the
application for unregulated emissions. As noted in Section
5a, these data were not clearly identified. Also, these
data were for hydrocarbon and carbon monoxide which are
regulated emissions. However, since the device does not
appreciably modify the emission control system of a
vehicle, the device should not significantly alter the
unregulated emissions of a vehicle.
(2) Regulated Emissions and Fuel Economy;
The applicant did not submit test data in accordance with
the Federal Test Procedure and the Highway Fuel Economy
Test. These two test procedures are the primary ones
recognized by EPA for evaluation of fuel economy and
emissions for light duty vehicles.*
The data the applicant supplied in exhibits A through D
consisted of a 3000 mile road trip of a 1974 Lincoln
Continental, State of Arizona vehicle inspection reports on
a 1973 Cadillac and one other vehicle, and a diagnostic
printout for the Cadillac. However, these data do not show
*The requirement for test "data following these procedures is stated in
the policy documents that EPA sends to each potential applicant. EPA
requires duplicate test sequences, both before and after installation of
the device on a minimum of two vehicles. A test sequence consists of a
cold start FTP plus a HFET or, as a simplified alternative, a hot start
LA-4 plus a HFET. Other test results which have been collected in
accordance with other standardized procedures are acceptable as
supplemental data as long as the results are statistically significant.
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that the testing was conducted in a controlled manner. For
example, the road test of the Lincoln showed two hundred
miles difference in the trips, they were not over the same
route, and the device tested appears to be substantially
different than the model being evaluated. Also, the state
inspections of the Cadillac were a year and 5,000 miles
apart and did not specify with or without the device.
There was only one state inspection for the other vehicle.
The diagnostic printout also did not identify with or
without the device.
The applicant was advised of the deficiencies in the data
submitted (Attachment C) and the need to conduct FTP and
HFET tests of the device at an independent laboratory
(Attachments A, C, D, and E). This limited amount of
testing would have readily confirmed the benefits for the
device if it had been able to meet the specific claims
given in Section 6b(4). The applicant did not provide this
test data nor undertake this testing (Attachment E).
EPA has tested and evaluated a variety of air-bleed and
carburetor base-plate adapters that are claimed to reduce
emissions and improve fuel economy by promoting better
mixing of the fuel and air. Although they are not
identical to the Gas Saving and Emission Control
Improvement Device, several of them function in a similar
manner. These devices showed no emissions or fuel economy
benefits*. Copies of several of these reports were given
to the Applicant (Attachment C).
7. Conclusions
EPA fully considered all of the information submitted by the
applicant. The evaluation of the Gas Saving and Emission Control
Improvement Device was based on that information, EPA's engineering
judgment, and our experience with other devices that function in a
similar manner.
*A few air-bleed devices have shown a small improvement in emissions or
fuel economy by leaning out the richer fuel/air mixtures which were used
by the manufacturers prior to emission controls. Without using a device,
the same effect could also be achieved on these vehicles by leaning out
the idle mixture screws. However, with the leaner fuel/air ratios now
used by the manufacturers to control emissions and improve fuel economy,
even these few devices would not show improvements. On the recent
vehicles with computerized emission control systems, any changes a device
caused in the fuel/air mixture, would automatically be negated by the
computerized control system.
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The information supplied by the applicant was insufficient to
adequately substantiate either the emissions or fuel economy benefits
claimed for the device. EPA testing of devices that function similar
to the Gas Saving and Emission Control Improvement Device showed no
signfleant emissions or fuel economy benefits. Thus, we have
concluded that there is no technical basis to expect that the device
would significantly improve either emissions or fuel economy or to
justify an EPA confirmatory test program on the Gas Saving and
Emission Control Improvement Device.
Installation of the device is likely to be considerably more costly
and difficult than claimed. Since the device raises the carburetor
and its linkage, considerable time and skills are likely to be
required to design and fabricate special parts and perform critical
readjustments. Also the required shop test equipment is both
expensive and not available in most shops.
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 Letter of September 7, 1982 from EPA to Jack C. Shaffer of
Shaffer Enterprises, Inc. acknowledging receipt of the 511
application for the device and requesting additional
information.
Attachment B Letter of September 14, 1982 from Jack C. Shaffer to EPA
responding to request for information (Attachment A). This
is a typed copy of the handwritten letter received.
Attachment C Letter of September 28, 1982 from EPA to Jack C. Shaffer
clarifying and discussing information previously received
and explaining need for independent lab testing of the
device.
Attachemnt D Letter of November 15, 1982 from EPA to Jack C. Shaffer
discussing test plan for the device.
Attachment E Letter of December 9, 1982 from EPA to Jack C. Shaffer
confirming telepone discussions of the device and
concluding evaluation process.
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Attachment A 13
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
ANN ARBOR, MICHIGAN 48105
OFFICE i
September 8, 1982 A,R, NO.SEAND
Mr. Jack C. Shaffer, President
Shaffer Enterprises, Incorporated
P.O. Box 243
Lynnville, Iowa 50133
Dear Mr. Shaffer:
We received your undated letter on August 31, 1982 in which you applied
for an EPA evaluation of the "Gas Savings Device" as a fuel economy
retrofit device.
Our Engineering Evaluation Group has made a preliminary review of your
application and has identified several areas that require additional
information or clarification prior to further processing. Our comments
below address each section individually.
1. Section 2a. - Marketing identification. The marketing identifi-
cation of the device is presently "Gas Savings Device". We will
use this designation until you notify us of the final name.
2. Section 2b. - Inventor and patent protection. Please provide a
copy of the patent application and identify the inventor.
3. Section 3c. - The theory of operation states ..."A plate has
been designed with routing holes which disperse and atomize the
liquid fuel for longer burn time enabling the gasoline fumes to
burn at a much higher rate of thrust, thus leaving less solids
to drop to the manifold and eject out of the muffler system."
To which manifold does this refer, intake or exhaust?
4. Section 3c. — Construction and operation. This is a very
simplified, short description of the device and appears to
provide an adequate general description of the device. However,
for evaluation purposes, a much more detailed description of the
construction and operation is required. Please supplement the
patent description, as necessary, to provide a more detailed
description of the actual construction of the device.
5. Section 3e. - No specific claims were made for the device in the
application or attachments. The claims given in Section 3a
(purpose of the device) are generalized claims. What specific
numerical improvements or range of improvements do you claim for
reduction in emissions, improvement in fuel economy, and
increase in power? To what mileage or time interval does
"...cleans the engine and makes it virtually maintenance
free..." refer?
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6. Section 3e. - Cost and marketing information. Who are these
"factory trained dealers" who will be selling and installing the
device?
7. Section 4a. - Device applicability. The information provided
indicates the device applies to all gasoline powered vehicles.
Does this include vehicles with fuel injection or turbo-
chargers? Is there more than one model sold to fit the various
different carburetors? If yes, how are they identified?
8. Section 4b. - Installation, equipment and skills is a very
simplified, short summary of the device installation. However,
for evaluation purposes, a much more detailed description of the
installation instructions is required. Please provide a copy of
the installation instructions you provide to your factory
trained dealers.
9. Section 4b. - What is the dealer-owned "...diagnostic equipment
to measure power, emissions, gas consumption, etc...?"
10. Section 5. - Effects on unregulated emissions, regulated emis-
sions, and fuel economy. The attachments to your application
were not labeled B, C, and D as you indicated in your applica-
tion. Only one of the attachments identified the test condition
(with or without device). As I indicated in my previous letter
to you, this type of data is of limited usefulness and then only
for preliminary evaluation purposes. The supporting test data
for an evaluation must be based on tests of the device (baseline
and with device) at an independent laboratory using the Federal
Test Procedure or Highway Fuel Economy Test.
This above information is needed to further process your evaluation. In
order for us to conduct our evaluations efficiently, we have established
a schedule for each. I ask that you respond to this letter by October 1.
If you have any questions or require further information, please contact
me.
EPA has evaluated and tested many fuel economy retrofit devices, some of
which may be similar to the "Gas Savings Device." When you have supplied
the information requested by paragraphs 1 through 10 above, I will send
you a copy of those reports which appear most similar. Even if you do
not consider your device to be similar to other devices we have evalu-
ated, you may find them useful as an example of an EPA test and evalua-
tion program.
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Processing your application will require you to submit test data obtained
at a recognized independent laboratory in accordance with the procedures
indicated in the information I previously provided you. For your conve-
nience, I have enclosed the current packet describing this procedure. I
am prepared to assist you in developing a test plan which will allow you
to conduct the appropriate testing at an independent laboratory.
Sincerely,
Merrill W. Korth
Device Evaluation Coordinator
Test and Evaluation Branch
Enclosures
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Attachment B
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September 14, 1982
Mr. Merrill W. Korth
Device Evaluation Coordinator
Test and Evaluation Branch
Environmental Protection Agency
Ann Arbor, Michigan 48105
Dear Mr. Korth:
Since our telephone conversation of this date, I shall attempt to answer
questions one through ten.
1. "Gas Saving and Emission Control Improvement Device".
2. Jack C. Shaffer. I only have a registered letter sent to myself for
patent protection.
3. Exhaust
4. I am enclosing one of the devices for your inspection.
5. Emission improvements exceed twenty percent. Fuel economy
improvements exceed minimum requirements delineated in your letter of
August 19, 1982 and exceed twenty-to-fifty percent in most cases. It
requires from five hundred to one thousand miles to attain optimum
efficiency on cleanliness, as well as with emissions and gas savings.
6. Cost is $150.00 installed. The only qualified installers are
mechanics with training and diagnostic equipment (for example: new
car dealerships).
7. Their is a model to fit all U.S. manufactured vehicles with all
carburetor configurations which can produce greater economy being
manufactured and identified as to type of carburetor, model years
included as well as interchangeability.
8. To install this equipment, one must remove the carburetor and add the
furnished kit as follows.
a. Remove studs and replace with studs 3/4" longer.
b. Put on the gasket supplied.
c. Put on the plate supplied.
d. Put on original gasket.
e. Put the carburetor back on and tighten down.
f. Make any other adjustments which may be required on throttle
linkage, etc., to compensate for the additional 3/4" height
created by the installation of the plate.
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g. Cut hose from PCV on exhaust manifold and replace with the new
hose in kit. A tee is furnished to receive 3/8" I.D. hose from
PCV to tee. Another hose and clamp is furnished to go from the
straight through portion of the tee opposite hose to PCV. The
last hose goes from tee position to the tee back into the
carburetor where hose from PCV previously entered. Replace
filter assembly and the job is complete after all other hoses
are reconnected to their original positions.
9. Sun diagnostic equipment or equivalent. With full range of test
equipment which is now the state-of-the-art.
10. I have contacted both ATL, Inc., East Liberty, Ohio and Bendix Test
Operations, Troy, MI for proposals on this testing along with their
recommendations.
I hope this gives you a clear picture and will resolve those problems
posed.
Sincerely,
Original signed by Jack C. Shaffer
Jack C. Shaffer
Box 243
Lynnville, Iowa 50153
P.S. The enclosed plate is made from clear plastic in order for your
people to be able to see the principle. Their are obviously a great many
different configurations.
NOTE: The original letter was handwritten. It has been typed to ensure
legibility and reproducability.
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Attachment C
18
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
I
ANN ARBOR. MICHIGAN 48105
September 28, 1982
f OFFICE OF
AIR. NOISE AND RADIATION
Mr. Jack C. Shaffer, President
Shaffer Enterprises, Incorporated
P.O. Box 243
Lynnville, IA 50133
Dear Mr. Shaffer:
We received your letter of September 14 in which you provided additional
information about your "Gas Saving and Emission Control Improvement
Device". We wish to clarify the information you provided and address
some of the questions you raised in your recent telephone call.
Our Engineering Evaluation Group has reviewed your application and the
supplemental information you supplied. We have identified several areas
which still appear to require further clarification or on which you may
still wish to comment. Our comments below address each section individ-
ually.
1. Section 4b - The installation instructions you 'provided (copy
enclosed) appear to be incomplete. The instructions do not tell
how to hook up the device. It appears you wish to have the-
device connected by a hose going from the device to the straight
portion of the tee that was inserted in the PCV line.
2. Section 4b - The installation and diagnostic test equipment
consists of an engine analyzer which has the capability of
measuring the compression, electrical, emission, fuel pressure,
ignition, and vacuum characteristics of an engine. We now
understand that this does not include equipment to measure fuel
consumption or engine power, i.e. fuel flow meters or dyna-
mometers.
3. Section 5 - Effects on unregulated emissions, regulated emis-
sions, and fuel economy. EPA does not require a specific mini-
mum level of improvement in emissions or fuel economy. The
numbers cited in our letter of August 19, 1982 relate the number
of tests required to demonstrate a statistically significant
improvement to the expected level of improvement in fuel economy.
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The data used to evaluate the performance of a device must be obtained
under controlled test conditions using appropriate test procedures. This
is why we require- the substantiating testing of the device to be per-
formed on a minimum of two vehicles (two test sequences without the
device and two test sequences with the device on each vehicle). The
procedures specified are the Federal Test Procedure (FTP) and/or the
Highway Fuel Economy Test (HFET). However, the data you submitted do not
show that the testing was conducted in a controlled manner. For example,
the road test of the Lincoln showed two hundred miles difference in the
trips, they were not over the same route, and the device tested appears
to be substantially different than the model you provided. Also, the
state inspections of the Cadillac were a year and 5,000 miles apart and
did not specify with or without the device. While this information may
have been of value to you in the development and evaluation of your
device, these data will not withstand the scrutiny of an objective,
impartial review.
Thus, satisfactory processing of your application will require you to
submit FTP and HFET test data obtained at an independent laboratory. In
order for us to expeditiously process the evaluation of your device, we
have established a schedule for receipt of these data. Please submit
your data by November 30, 1982. This should allow you sufficient time to
develop a test plan, select a lab and have the device tested.
EPA has tested and evaluated a variety of air-bleed and carburetor base-
plate adapters that are claimed to reduce emissions .or improve fuel
economy. As I promised previously, I am providing you copies of several
of the reports which appear to be most useful to you.
Again, 1 am prepared to assist you in the development of your test plan.
Please let us know what laboratory you have selected and the scheduled
dates for your testing when you send us your proposed plan. Please
submit this information by October 12. If you have any questions or
require further information, please contact me.
Sincerely,
Merrill W. Korth
Device Evaluation Coordinator
Test and Evaluation Branch
Enclosures
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Attachment D 20
V
\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
UJ
? ANN ARBOR. MICHIGAN 48105
November 15, 1982 AIR. NOISE AND RADIATION
Mr. Jack C. Shaffer
Schaffer Enterprises, Inc.
P.O. Box 243
Lynnville, IA 50153
Dear Mr. Shaffer:
We received your letter of October 25 in which you requested our review
and comments on your proposed testing of the "Gas Saving and Emission
Control Improvement Device".
Based on the information supplied in your application, your responses to
our letters, and our several phone calls, we feel we have developed
sufficient understanding of your device to comment on the test plan. Our
comments are based on that information and the following assumptions that
appeared to be implied.
1. Installation of the device does not alter the vehicle character-
istics, (e.g., idle speed, shift points, idle mixture, etc.).
2. No engine readjustments are required and all settings are to
manufacturer's specifications.
3. Although the device takes 500 to 1000 miles to achieve its full
benefit, the majority of the improvement can be observed immedi-
ately after installation of the device.
It is not clear if you claim the device will or will not affect cold
start emissions or fuel economy. The Bendix quote was for cold start
tests but the ATL quote was for hot start tests. Either type of testing
would be acceptable to us.
Based on the preceding information and assumptions implied in your com-
munications, it appears that Test Plan A (no parameter adjustment
required and no mileage accumulation required) is appropriate for your
device. Use test sequence Code 1 or Code 4 depending on whether you will
be making claims for emissions or fuel economy improvements in cold
operating conditions.
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21
I have enclosed a copy of the basic test plan for 511 evaluations.
Please let us know by November 29 the test sequence you select, the
laboratory you select, and the scheduled dates for your testing. If you
have any questions or require further information, please contact me at
(313) 668-4299.
Sincerely,
Merrill W. Korth
Device Evaluation Coordinator
Test and Evaluation Branch
Enclosure
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Attachment E 22
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
ANN ARBOR. MICHIGAN 48105
December 9, 1982 AIR. NO,«AND RADIATION
Mr. Jack C. Shaffer
Shaffer Enterprises, Inc.
P.O. Box 243
LynviUe, IA 50153
Dear Mr. Shaffer:
The purpose of this letter is to confirm our understanding of our
telephone call of December 2 .
Although you are still endeavoring to test your "Gas Saving and Emission
Control Improvement Device" at an independent laboratory, you are
presently unable to undertake the program discussed in my letters of
September 28 and November 15. Therefore, we must complete our evaluation
of your device using the information that is available. Processing the
evaluation will take several weeks. I will send you a draft copy after
it has completed our internal review.
If, in the future, you are able to have the device tested at an
independent laboratory, we would welcome a new application from you.
Please contact me prior to testing so that I can advise you of our
current requirements. You may also contact me if I can be of any
assistance before that time.
Sincerely,
Merrill W. Korth
Device Evaluation Coordinator
Test and Evaluation Branch
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