EPA-AA-TEB-511-83-9
EPA Evaluation of the Optimizer Device Under
Section 511 of the Motor Vehicle Information
and Cost Savings Act
by
Edward Anthony Earth
May 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 Optimizer 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 "Optimizer" was conducted upon the application of
the manufacturer. The basic device is a combustion catalyst consisting
of an electric fuel heater containing a bed of platinum deposited on an
inert substrate. The remainder of the system includes a heater relay, a
condenser to cool the fuel to operating temperature, and the associated
plumbing. According to the applicant, the device Introduces a very small
amount of platinum into the fuel. This enhances the combustion process
and allows ignition timing to be advanced. The device, coupled with the
ignition timing adjustments, is claimed to improve fuel economy, increase
performance, and reduce engine maintenance while keeping emissions low.
1. Title;
Application for Evaluation of the Optimizer Under Section 511 of the
Motor Vehicle Information and Cost Savings Act
The information contained in sections two through five (enclosed in
quotation marks) which follow was supplied by the applicant.
2. Identification Information;
a. Marketing Identification of the Product;
"The product is the Optimizer (trade mark and patent pending),
and will be marketed with the following model numbers:
1150G - Gasoline Units - 4/6/8 cylinder automobile and light-
duty trucks.
1200G - Gasoline Units - Heavy-duty trucks.
2150G - Gasoline Units - Heavy-duty trucks.
1200D - Diesel Units - Automobile and light-duty trucks.
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2200D - Diesel Units - Heavy-duty trucks.
4200D - Diesel Units - Detroit Diesel only (where dual feed
system is used)."
"Each unit will also have an identifying stock number for
quality control purposes."
The applicability of model 1200G was later changed to apply to
both passenger vehicles and heavy-duty trucks (Attachments H, I,
and K). Since evaluation of the diesel units would require the
additional test data from an independent lab, the applicant
withdrew the diesel unit from consideration (Attachments G, H,
and I).
The applicant was also notified that devices for heavy-duty
vehicles are not covered under the Section 511 evaluation
process (Attachment G).
b. Inventor and Patent Protection;
(1) Inventors
George Reinhardt Ronald Kinde
11901 13 Mile Road 95 Avery
Warren, Michigan 48093 Mt. Clemens, Michigan
Dr. Leon Rosky Simca Singer
1213 Maxine Street Haifa
Flint, Michigan 48053 Israel
(2) Patent
"Copy of patent application is appended." (See Attachment
A.)
c. Applicant;
(1) Optimizer, Ltd.
220 Lynn Street
Flushing, Michigan 48433
(2) Principals
Dr. Leon I. Rosky
Oskar A. Singer
Edward H. Powers
Daniel F. Spaniola
Gabriel T. Anslow
(3) Dr. Leon I. Rosky is authorized to represent Optimizer Ltd.
in communication with EPA.
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d. Manufacturer of the Product;
Optimizer, Ltd. Principals
220 Lynn Street Dr. Leon I. Rosky
Flushing, MI 48433 Oskar A. Singer
Edward H. Powers
Daniel F. Spaniola
Gabirel T. Anslow
Matechet Carmel Mifratz, Ltd. Principal
9 Hamasger Str. Mr. Evin Singer
Haifa-Bay, Israel
3. Description of Product;
a. Purpose;
"The Optimizer is a fuel savings device which can be used on
both gasoline and diesel engines, including automobiles, light-
and heavy-duty trucks. In addition to the fuel savings aspect,
emissions are well within the EPA guidelines for CO, HC and
NOX. Performance of the vehicles is seen as markedly improved
due to a cleaner, more complete combustion of the fuel.
Consequently, an increase in the time intervals between tune-ups
and extended engine life may be the long term benefits."
b. Applicability;
"Fuel economy [improvement] will be seen using the Optimizer on
all gasoline and diesel vehicles. In 4-cylinder vehicles, which
are very fuel efficient, the results may be less, again
depending on the driver, weather conditions, engine size and
type of carburetor.
The product will be marketed under the model numbers as
described above." The model numbers are given in Sections 2a
and 3f.
"The Optimizer heats fuel over a bed of a platinum-based
chemical. This is done by means of running the fuel in close
proximity both to a heating element and the chemical. Because
heating is necessary, the unit will work less efficiently in
very cold temperatures (35 degrees Fahrenheit or below). High
winds, topography of the road, weather conditions and the
driver's skill will greatly influence the fuel economy
obtained. In most instances, without any fuel savings device, a
motor vehicle will lose miles per gallon in the above described
situations. With the use of the Optimizer, while the fuel
savings may not be as great, there will not be the loss in miles
per gallon as seen without the unit."
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c. Theory of Operation;
"The improvement in fuel economy is attributed to an enhancement
of the combustion process mainly by the on-site introduction of
platinum or noble metals*
"The platinum or other noble metals are introduced into the fuel
by passing the fuel through a bed of noble metals coated on an
inert substrate.
"The bed is contained in a specially designed container housing
attached in the fuel lines. The bed is heated with the gasoline
remaining in the liquid state.
"Based upon many vehicle and dynamometer tests, trace amounts of
platinum are 'dissolved' into the fuel and enter the cylinder
combustion chamber where combustion takes place at a higher
temperature. The hydrocarbon and carbon monoxide levels are
substantially reduced with a slight increase in oxides of
nitrogen, but well below the emission guidelines. This
mechanism is not yet understood and is being studied with an
on-going research effort.
"There also is an indication, based upon limited data, that
there may be a low temperature catalytic reaction taking place
within the device as evidenced by an increase in the ratio of
aromatics to saturates in gasoline samples after passing through
the devices. This is considered to be of minor impact at this
time."
d. Construction and Operation;
"See attached drawing (Figure 1)." A schematic of the device
and its installation are given in Figures 1 and 2 of Attachment
A, the patent application.
e. Specific Claims for the Product;
"The Optimizer has been independently tested at Automotive
Testing Laboratories, Inc. in East Liberty, Ohio, with the
results of fuel economy and emissions attached to this
application. The fuel economy obtained will vary from vehicle
to vehicle due to the type of engine, driving habits, outside
temperature, type of fuel and weather conditions. Test results,
both at Automotive Testing Laboratories, Inc, and on-the-road
testing, have established that between 5% and 15% improvement in
fuel economy may be obtained. Emission levels are very low and
there is an increase in performance of the vehicle. Our tests
show that maintenance of the vehicle is easier and does not seem
to be necessary as often. This again varies with the same
conditions described above." The laboratory emissions and fuel
economy results are summarized in Table I in Section 6d(2). The
complete lab and road test results are contained in the tables
and Figure in Attachment C.
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f. Cost And Marketing Information:
"This product will be initially marketed to fleet owners of both
gasoline and diesel vehicles. The suggested retail price of the
Optimizer units will be as follows:
Model Number
1500G
1200G
2150G
1200D 390.00
2200D 750.00
4200D 1,420.00
There is a quantity discount schedule available."
4. Product Installation, Operation, Safety and Maintenance:
a. Installation - Instructions, Equipment, and Skills Required;
"Enclosed in this application are the installation instructions
for the product which address technical and mechanical
procedures. Any mechanic will be able to install the unit and
no special tools or skills are required other than what would
normally be in a mechanic's tool chest. You will notice in the
installation procedure that a timing advance of 5 degrees on
gasoline engines is recommended. Our tests show that in order
to utilize the improvement in the fuel mixture and obtain
complete combustion, a timing advance is necessary. On some
vehicles, a timing advance by itself may improve fuel economy;
however, a long term detrimental effect on the valves and
pistons may occur, along with persistent detonation. In testing
done both at Automotive Testing Laboratories, Inc, and at
Optimizer, Ltd, no detonation was heard with the Optimizer
system (which includes the timing advance of 5 degrees). This
signifies a more complete, efficient burn of the fuel. After
installation of the unit, a break-in period of at least 1,000
miles is necessary in order to maximize the effect of the
platinum on the combustion chamber itself. Tests done in
intervals in that 1,000 mile break-in show a steady increase in
fuel economy. It should also be noted that the reverse
phenomenon is seen after the Optimizer unit is removed. If one
were to remove the unit and immediately do a dynamometer test
(as was done on one sequence at Automotive Testing Laboratories,
Inc.), then an improvement in miles per gallon may be seen even
though the device is by-passed." The installation instructions
are Attachment B.
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b. Operation;
"Once the Optimizer unit is attached to the vehicle, there is no
routine maintenance necessary. If the unit does not seem to be
functioning, then the relay or heating element should be
checked. (See Installation Instructions for amp output of
heating element.)" The installation instructions are Attachment
B.
c. Effects on Vehicle Safety:
"The Optimizer unit appears to be completely safe with no danger
to the occupants or vehicle. If for some reason there is a
malfunction within the unit, it is very easy to by-pass the unit
and restore the fuel line to its prior condition (prior to
installation of the device). While in most instances of heating
fuel there may be a pressure built up in the fuel line, which
could cause vapor lock, we have not had that situation occur
because of the condensing unit situated prior to the
carburetor. If in some case this should occur, by-passing the
unit and re-establishing the fuel line is all that is necessary."
d. Maintenance:
"Our tests have shown that due to the cleaner combustion within
the engine itself, the carbon build up on the spark plugs is
decreased and necessary maintenance of the automobile will
probably be at longer intervals. Our tests suggest that we may
be improving the aromatic composition of the fuels used. In
order to obtain a more efficient combustion within the engine,
timing is advanced in order to utilize the improved gasoline
mixture. This timing should be checked periodically, especially
after the initial installation. The type of fuel used and
whether it is winter or summer stock may necessitate a change in
the timing mechanism. If an engine knock is heard, then timing
of the vehicle should be re-checked. If the Optimizer unit
appears not to be functioning, then the electrical connections
and relays should be checked to make sure that the heating
element is in good working order. An amp meter should be used
to determine if there is approximately 13 to 15 amps being
drawn, which should decrease to approximately 10 amps or less
when the device and the engine are in normal working order.
There are no other maintenance procedures required to insure the
correct operation of the Optimizer."
5. Effects on Emissions and Fuel Economy;
a. Unregulated Emissions;
"All information relative to unregulated and regulated emissions
is submitted with this application. There appears to be no
untoward effects on the environment known to us." This
information contained no data on unregulated emissions.
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b. Regulated Emissions and Fuel Economy:
The applicant tested the device in several separate test
programs. The emission and fuel economy results of these tests
are given in Attachments C-4 through C-8.
The following sections are EPA's analysis and conclusions for the device.
6. Analysis
a. Identification Information:
(1) Marketing Identification:
The models of the device given in Sections 2a and 3f were
for both passenger vehicles and heavy-duty trucks. As
noted in Section 2a, the diesel models were withdrawn from
consideration and the Section 511 evaluation process does
not apply to devices for heavy-duty vehicles.
The applicant later informed us that the Optimizer models
500G, 115OG, and 1500G were identical (Attachments G, H, I,
and K).
(2) Inventor and Patent Protection:
The patent identified two different basic configurations of
the heated catalyst container and several catalyst
materials. The device being evaluated was clarified to be
of the single catalyst bed configuration shown in Figure 2
of the patent and used only platinum as the active catalyst
material (Attachments G, H, I, and K).
b. Description:
(1) As stated in Section 3a, the primary purpose of the
Optimizer is to improve fuel economy, increase performance,
and reduce engine maintenance while keeping emissions low.
This is in agreement with proposed theory of operation and
design of the device.
(2) The statement of the applicability of the product to
essentially all gasoline-powered passenger cars and trucks
is judged to be appropriate.
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(3) The theory of operation given in Section 3c attributes the
claimed improvement in fuel economy to be principally due
to the enhancement of the combustion process by the
platinum or other noble metals added to the fuel as it
passes through the heated substrate in the Optimizer. A
secondary effect was stated to be due to the possible
reforming of the fuel due to a low temperature catalytic
reaction in the device. However, the theory does not
address the fact that ignition timing adjustments are
performed as part of the device installation and that such
adjustments are capable of improving fuel economy levels
even without any retrofit device.
Several efforts referenced in the bibliography do show that
changing the ignition timing can cause a change in fuel
economy and emission levels to the same degree as were
observed in the test data of Section 6d(2). While this
phenomenon is well known, manufacturers must consider more
than just fuel economy when establishing a timing curve,
e.g., ambient conditions, driveability, emissions, fuel
variability, and vehicle operating conditions.
The heating of the fuel is claimed to be necessary to cause
the platinum on the inert substrate to be introduced to the
fuel. The applicant submitted data that showed that
heating of the substrate was needed to add the platinum to
the fuel and that the concentration was directly
proportional to the temperature of the fuel (Attachment
C-l). Although these data indicate that platinum is added
to the fuel, there is no evidence that the platinum will
enhance the combustion process and thereby significantly
improve fuel economy.
The catalytic engine study provided by the applicant,
Reference 6, did show that a platinum catalyst mesh
installed in the combustion chamber of an engine would
allow development of a new engine with reduced emissions
and improved fuel economy. The best of the engines
evaluated in the study showed appreciable improvements over
a conventional gasoline engine over some parts of its
operating range. However, this was for a fuel-injected
engine with a prechamber and a 12 to 1 compression ratio.
As a result, this does not demonstrate that platinum in the
fuel would reduce the emissions and improve the fuel
economy of a conventional gasoline engine.
The possible reforming of the fuel referenced in the
application cover letter and Section 3c is indicated by the
data given in Attachments C-2 and C-3. However, one test
sequence showed no change in aromatics and one test
sequence showed a change- There is also the variability of
the test methods to be considered. Therefore, these
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results are only a very weak indicator of fuel reforming*
Furthermore, the effect on fuel economy of a change in the
fuel that is this small, could only be established through
a much larger test program than was used by the applicant
to evaluate the device.
(A) The description of the device given in Section 3d covered
two configurations of the Optimizer heating chamber,
alternative catalyst materials, and at least two different
plumbing installations for the Optimizer model 1150G
(previously identified as 500G or 1500G). The model was
later identified to be the single catalyst bed
configuration (Figure 2 of the patent), using only platinum
as a catalyst on an alumina substrate, and having no return
flow to the fuel tank (Attachments G, H, I, and J).
The heating element is designed to be self-regulating. It
is designed to operate between 150 and 170°F (Attachment
H). In the event of an overload, the heating element relay
will protect the device but would need to be replaced to
restore the system to proper order (Attachments G, H, I,
and K).
(5) In Section 3e, the applicant correctly noted that ambient
conditions, operating variables, and the vehicle would all
influence the vehicle fuel economy and any fuel economy
benefit. However, the test results cited do not establish
that the user might reasonably expect to get a five to
fifteen percent improvement in fuel economy. The data from
Automotive Testing Laboratories showed no fuel economy
improvement for one vehicle. In no case was an improvement
greater than six percent. Also, the emission testing cited
showed significant increases in emissions in many cases.
(The percentage changes in HC and CO emissions for the
highway cycle occur at very low emission levels and are
therefore not as significant as the NOX levels.) These
data and the road test data are further discussed in
Section 6d(2).
The increase in vehicle performance was not formally
evaluated in this testing. The applicant stated that the
drivers felt the vehicles performed better (Attachments G,
H, I, and K).
The claims for reduced maintenance were based on the
expectation that the spark plugs would last longer since
deposits were less than expected. However, they may
deteriorate quicker due to the higher temperatures. Also,
this was largely based on their experience with other
vehicles. Since vehicle emission control technology has
been changing yearly, such maintenance assessments need to
be based on comparisons with vehicles of similar technology.
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The maintenance claims do not address the need for the
inline fuel filter to be changed every 7,000 to 10,000
miles as prescribed in the installation instructions. This
is at least twice as frequently as most manufacturers
recommend.
(6) The cost of the device plus installation would probably be
at least $460 for those users who have the device installed
by a mechanic. This is based on a retail price of $390.00,
ilO.OO for miscellaneous parts, and installation requiring
approximately two hours at $30.00 per hour.
Installation, Operation, Safety and Maintenance;
(1) Installation - Instructions, Equipment and Skills Required;
The instructions are judged to be adequate for the
installation of the device. We agree with the statement of
the applicant in Section 4a that an automotive mechanic
would be able to install the device with the standard
complement of tools. Persons of average mechanical skills
should also be able to install the device although the
necessary hoses, fittings, and wiring are not provided with
the device.
The installation instructions specify that the ignition
timing is to be advanced five degrees unless the vehicle
exhibits spark knock. In this event, the timing is to be
retarded one or two degrees until the knock disappears.
This was subsequently clarified to require advancing the
timing one or two degrees after the 1,000 mile break-in
period and has been incorporated in the instructions
(Attachments B, G, H, I, and K). The instructions are not
consistent with Section 4d in that they do not state that
the timing should be periodically checked after
installation.
The additional electrical load may lower the engine idle
speed, especially on the smaller displacement engines. The
installation instructions do not specify checking the idle
speed when the device is operating.
(2) Operation;
The operation of the device is automatic. If the device
fails to function, the instructions contain enough
information to allow a mechanic to check out the system.
However, although the applicant noted in Section 4b that
the operator should have the device checked if he feels the
device is not functioning, no specific information is
provided to indicate to the operator that the device is not
functioning properly. Also, the instructions neither
describe engine knock nor alert the operator to knock as
noted in Section 4d.
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Although the heating element is not "On" when the ignition
switch is in the "Off" or start position, the appreciable
electrical load could adversely affect vehicles with
marginal electrical capacity or under some operating
conditions, e.g., idle or heavy usage of electric power
accessories.
(3) Effects on Vehicle Safety:
The device is judged to be able to be built and installed
so that it presents no safety hazard to the vehicle or
operator.
(4) Maintenance;
The claims of a potential reduced maintenance for spark
plugs as stated in Section 4d are based on limited
preliminary data and, as noted in Section 6b(5), require
verification. Also the suggestions given in Section 4d to
recheck timing, to be alert for engine knock, and to check
device operation are neither given in the installation
instructions nor provided separately to the operator.
d. Effects on Emissions and Fuel Economy;
(1) Unregulated Emissions;
The applicant submitted no data on unregulated emissions.
Since the installation of the device is claimed to alter
the combustion process, there is a potential for
unregulated emissions to be affected.
The device with the advance in ignition timing did alter
the combustion process as evidenced by higher NOX, an
indicator of higher peak combustion temperature and
pressure. However, it is judged that this change is
unlikely to appreciably affect unregulated emissions.
(2) Regulated Emissions and Fuel Economy;
The applicant did 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 requirement for test data following these procedures is stated in
the policy documents that EPA sends to each potential applicant. EPA
requires duplicate test sequences before and after installation of the
device on a minimum of two vehicles. A test sequence consists of a cold
start FTP plus a HFET or, as a simplified alternative, a hot start LA-4
plus a HFET. Other data which have been collected in accordance with
other standardized procedures are acceptable as supplemental data in
EPA's preliminary evaluation of a device.
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(a) LA-4 and Highway Test Results
Table I
Summary of Test Results Submitted by Applicant**
Emissions in grams per mile, fuel economy in miles per gallon
Hot LA-4
HFET
Vehicle
1980 Chevrolet Baseline .19 .82 .88 17.3
4.4 liter V-8 Optimizer after .38 .28 1.10 17.8
Vehicle #7957 500 miles
Average Change
.06 .16
.11 .01
1981 Oldsmobile Baseline
3.8 liter V-6 Optimizer after
Vehicle #8982 500 miles
Average Change +35% +10% +28% -1% +30% -34% +51%
1980 Chevrolet
4.4 liter V-8
Vehicle #0267
Baseline
Optimizer after
1000 miles
Average Change
.07 .22
.09 .22
.66 17.4
.86 18.0
.02 .04
.03 .00
1980 Oldsmobile Baseline
4.3 liter V-8 Optimizer after
Vehicle #2430 1000 miles
Average Change
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Configuration H£ C0_ NOx MPG HC C£ NOx MPG
1.04 22.7
1.33 23.6
+101% -67% +25% +3% +77% -91% +27% +4%
.17 .61 2.69 20.5 .07 .23 1.45 26.2
.23 .67 3.44 20.4 .10 .15 2.19 26.1
.88 21.9
.91 23.3
+26% -3% +30% +3% +26% -98% +3% +6%
.11 .04 1.36 19.2 .06 .03 1.54 24.4
.11 .05 1.63 20.1 .03 .00 2.34 25.7
+1% +36% +20% +5% -42% -100% +52% +5%
Note: The underlined values are statistically significant at a 90%
confidence level. However, due to the overall low level of HC and CO
emissions for the HFET, the impact of these changes on vehicle emission
levels, even where statistically significant, would be minimal.
These data were analyzed by several statistical
methods (student's "t" test, paired "t" test, and
two-factor analysis of variance) to determine if the
changes were statistically significant for either an
individual vehicle or a group of vehicles.
**Summary of the laboratory test results from Attachments C-4 through
C-7. This summary includes only the baseline tests and the Optimizer
tests with the timing adjusted as prescribed in the device installation
instructions. Vehicles #7957 and #8982 were tested with a fuel return
line to the tank. Vehicles #0267 and #2430 were tested without a return
line per the latest installation configuration.
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The student's "t" test is used to compare the sample
means of two populations* It is useful when there are
only a few data samples. It allows the data to be
readily compared at a given confidence level. The
individual test results given in Attachment C were
compared (i.e., Chevrolet #7957 LA-4 baseline tests to
Chevrolet #7957 LA-4 Optimizer tests, Chevrolet #7957
HFET baseline test to Chevrolet #7957 HFET Optimizer
tests, etc.). This analysis showed that:
HC emissions -
Installation of the Optimizer
caused statistically significant
increases and decreases in HC
emissions for some of the
vehicles. LA-4 HC emissions
increased for three vehicles;
however, the change was minimal
for one of these three. HFET HC
emissions both increased and
decreased. This would have
minimal impact due to the low HC
emission levels for the HFET.
CO emissions -
NOX emissions
Installation of the Optimizer
caused statistically significant
decreases for two vehicles. LA-4
CO emissions decreased for one of
the four vehicles. HFET CO
emissions decreased for two
vehicles but this would again have
minimal impact due to the low CO
emission levels for the HFET.
Installation of the Optimizer
caused large and statistically
significant increases in NOX
emissions for all vehicles. LA-4
NOX emissions increased for all
vehicles.
HFET NO,
emissions
increased for three of the four
vehicles. NOX emissions
increased an average of 30%. This
would have an appreciable adverse
effect since the NOX emission
levels are considerably higher
than the HC or CO levels.
MPG -
Installation of the Optimizer
caused small but statistically
significant increases in mpg for
three of the four vehicles for
both the LA-4 and the HFET.
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The student's "t" test of paired data is used to
sample means of paired observations. It is a more
specialized usage of the "t" tests and has the same
features as the "t" test. The emission and fuel
economy averages given in Table I were compared for
both the LA-4 (baseline vs. Optimizer for the four
vehicles as a group) and the HFET. This paired "t"
test data analysis showed that there was no
statistically significant change in emissions and fuel
economy due to the Optimizer device for the group of
four vehicles for both the LA-4 and the HFET. Since
these data have different emission levels, the
percentage changes were also similarily compared to
determine the relative effect of the device. This
analysis showed that the only statistically
significant change due to the device for the group of
four vehicles was the 20 to 30 percent increase in
NO emissions for the LA-4.
The two-factor analysis of variance (two-factor ANOVA)
is used to compare the means when there are several
test variables (i.e., for the LA-4 with or without
device for several vehicles). It can be used to test
if there is or is not a significant interaction
between test variables. Only NOX emissions and fuel
economy for both the LA-4 and HFET were analyzed since
the preceding analysis had indicated these items were
most affected. The two-factor ANOVA showed that:
NOX emissions - Optimizer caused a large (percent-
age) and statistically significant
increase in NOX emissions for both
the LA-4 and HFET.
MPG - Optimizer caused a small (percent-
age) but statistically significant
increase in vehicle fuel economy for
both the LA-4 and HFET.
(b) Discussion of Test Results
As was noted in the preceding analysis of the test
results, the overall expectation is that the use of
the Optimizer would cause NOX emissions to sharply
increase, fuel economy to increase to a smaller
degree, and hydrocarbon emissions to tend to
increase. Thus, there is a need to distinguish
between the effects attributable to the device alone
and the effects attributable to the ignition timing
adjustments performed when installing the device.
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The references in the bibliography (1-5, 7, 8) clearly
show that the results to be expected from the
prescribed five degree advance in ignition timing are
a sharp percentage increase in NOX emissions, a
small percentage increase in fuel economy, and a small
increase in hydrocarbon emissions.*
The tests conducted without the device Installed, but
with the timing advanced five degrees (Attachments C-4
and C-5), show the same trends in emissions and fuel
economy> However, the tests conducted with the device
installed but without the timing advance (Attachments
C-6 and C-7), showed an increase in NOX emissions
for both the city and highway cycles and an increase
in fuel economy for the highway cycle. After the
timing was advanced, NOX tended to further increase
and fuel economy increased for the city cycle only.
Thus, based on the data and references, it appears any
changes are due principally to the ignition timing
change performed when installing the device.
EPA has tested other devices that caused emissions to
increase. Our enforcement office determined that
installation of these devices by the aftermarket and
repair industry would be considered tampering.
Therefore, they are prohibited from installing the
devices.
(c) Road Test Results
The applicant supplied road test results for eleven
light-duty vehicles (Attachment C-8). For five of
these, the device was installed without the return
line in accordance with the instructions of the
applicant.
These were relatively well-controlled road tests. The
vehicles traveled several hundred miles over a
prescribed highway road route. The test vehicle was
tested both with and without the device. There was
mileage accumulation with the device for break-in. An
identical chase vehicle was used as a control.
*Ignition or spark retard, which is the opposite of ignition advance, is
an emission control technique that has been extensively used to reduce HC
emissions. Ignition retard will also reduce NOX emissions and fuel
economy.
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These tests showed an increase in fuel economy for the
vehicles using the Optimizer. This change is in
agreement with our expectations for the effect of the
ignition timing adjustment (done when installing the
device) and the trends observed in the lab data..
(d) Cost Effectiveness
Since most purchasers would buy the Optimizer to save
on fuel expenses, the cost of the device should be
compared to its benefits. As noted above, the overall
expectation is that the Optimizer itself would not
provide a fuel economy benefit although the
recommended timing adjustments done when installing
the device could slightly improve the fuel economy of
some vehicles. If a particular vehicle should benefit
by 5%, it would take over 170,000 miles before the
device would pay for itself.*
7. Conclusions
EPA fully considered all of the information submitted by the
applicant. The evaluation of the Optimizer device was based on that
information and our engineering judgment. The overall conclusion is
that, for most vehicles, the device and the prescribed ignition
timing adjustments of the engine will cause a small improvement in
fuel economy and a large increase in NOX emissions. These changes
are attributed to be due principally to the five degree advance in
ignition timing rather than the device itself.
Despite improvements in fuel economy, other devices evaluated by EPA
that have increased exhaust emissions have been considered tampering
by the EPA's Field Operations and Support Division.
ADDENDUM
After the completion of the evaluation, the applicant informed EPA
that the device which was evaluated would not be marketed. He
stated that the device had undergone considerable changes and that
they intended to submit a new application on this new model that they
expected to market. However, since no application has been
submitted, EPA is unable to judge if the new device has any emission
or fuel economy benefits.
EPA knew when the application was submitted that there were
differences between the device being evaluated and the device tested
(both hardware and installation differences). However, since the
applicant stated that the test data were still valid and applicable,
they were used for evaluating the device.
*Assumes the cost of the model 1200G or 1500G of $390 plus $60 for
installation, with baseline fuel economy at 25 miles per gallon and
gasoline costs of $1.40 a gallon.
-------
18
This additional correspondence between the applicant and the
government has been added to this report to complete the package of
information on the device.
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.
-------
19
BIBLIOGRAPHY
1. Miles, Donald L. and George W. Niepoth, "Optimizing Engine and Car
Design for Fuel Economy and Emissions", SAE Paper 760855.
2. Whitmyer, Alan, "The Effect of Ignition Timing Modifications on
Emissions and Fuel Economy", Environmental Protection Agency;
Technology Assessment and Evaluation Branch, Report 76-4.
3. Novak, J. M. and P. N. Blumberg, "Parametric Simulation of
Significant Design and Operating Alternatives Affecting the Fuel
Economy and Emissions of Spark-Ignited Engines", SAE Paper 780943.
4. Currie, James H., David S. Grossman, and James J. Gumbleton, "Energy
Conservation with Increased Compression Ratio and ELectronic Knock
Control", SAE Paper 790173.
5. Trella, Thomas, "Spark Ignition Engine Fuel Economy Control
Optimization - Techniques and Procedures", SAE Paper 790179.
6. Thring, R. H., "The Catalytic Engine," Platinum Metals Review, Vol.
24, No. 4, October 1980. A copy of this paper was provided with
Attachment I.
7. Honig, G., H. Decker, and S. Rohde, "Electronic Spark Control
Systems, Part I: Microcomputer-Controlled Ignition System, Part II:
Bosch Knock Control", SAE Paper 810059.
8. Trella, Thomas J., "Fuel Economy Potential of Diesel and Spark
Ignition-Powered Vehicles in the 1980s", SAE Paper 810514.
-------
20
Attachment A
Attachment B
Attachment C
Attachment D
Attachment E
Attachment F
Attachment G
Attachment H
Attachment I
Attachment J
Attachment K
Attachment L
Attachment M
List of Attachments
Patent Application (provided with 511 Application)
Installation instructions (provided with 511
application)
Laboratory and road test results (provided with 511
application)
Letter of May 4, 1982 from EPA to Ms. Vera Anderson of
Optimizer Co. responding to her May 3, 1982 letter for
information on the 511 application and evaluation
process. Similar letters were sent on June 23 and
October 6 in response to requests in June and October
for additional packets of 511 information.
Letter of July 20, 1982 from EPA to Dr. Leon I. Rosky
of Optimizer, Ltd. providing an EPA recommended test
plan for the Optimizer device.
Letter of December 6, 1982 from Dr. Rosky requesting a
511 evaluation of the enclosed application.
Letter of December 28, 1982 from EPA to Dr. Rosky
acknowledging receipt of 511 application and
requesting clarification and additional information.
Letter of January 18, 1983 from Dr. Rosky to EPA
responding to EPA request.
Letter of Febraury 7, 1983 from EPA to Dr. Rosky
summarizing recent conversation and requesting
additional clarification.
Letter of February 8, 1983 from Dr. Rosky to EPA
providing various pieces of information about the
Optimizer.
Letter of February 18, 1983 from Dr. Rosky to EPA
responding to EPA request.
Letter of March 14, 1983 from Dr. Rosky to EPA
discussing the March 4, meeting and EPA data analysis.
Letter of
March 28, 1983 from EPA to Dr. Rosky
responding to Optimizer letter of March 14, 1983.
On March 4, 1983 the applicant also provided a booklet of information
about the Optimizer. Since this information was essentially the same as
that provided with the application, a copy of it is not attached.
-------
21
The following attachments are correspondence between the applicant and
the government that occurred after the report had been written and
reviewed. They are Included to Incorporate the additional discussions
that occurred between writing and publication of this report.
ATTACHMENT N
ATTACHMENT 0
ATTACHMENT P
ATTACHMENT Q
ATTACHMENT R
ATTACHMENT S
Letter of May 12, 1983 from Dr. Rosky to
discussing the previous testing of the device.
EPA
ATTACHMENT T
ATTACHMENT U
Letter of May 20, 1983 from Dr. Rosky to EPA further
discussing the prior testing of the device and
requesting changes to report.
Letter of June 9, 1983 from Senator Donald W. Riegle,
Jr., to EPA requesting that EPA review its evaluation
of the device and meet with the applicant.
Letter of June 14, 1983 from EPA to Dr. Rosky
responding to Optimizer letters of May 12 and 20, 1983.
Letter of July 14, 1983 from EPA to Senator Donald W.
Riegle, Jr., responding to his letter of June 9, 1983.
Letter of July 18, 1983 from EPA to Dr. Rosky
providing draft copies of final report and Federal
Register notice for EPA evaluation of the Optimizer
device.
Letter of July 28, 1983 from Dr. Rosky to EPA
discussing the evaluation report of the Optimizer
device.
Letter of August 25, 1983 from EPA to Dr. Rosky
responding to Optimizer letter of July 28, 1983.
-------
ATTACHMENT A
22
Our lUf. OPL-100-A
DBVICB FOR IMPROVING FUEL EFFICIENCY
AND METHOD OF USE THEREFOR
ABSTRACT OF THE DISCLOSURE
^^^^^^^fmMfm^mfm^m^m^mmV^M^W^M^^»^m ,
A device for increasing the fuel efficiency in
an internal combustion engine having a fuel supply con-
duit connecting a fuel supply and a carburetor, a hollow
housing disposed in fluid communication with the fluid
supply conduit between the fuel supply and the carburetor
or firing chambers. A heat source, such as a heating
element is mounted within the tubular member for heating
the fuel flowing through the hollow housing. While
flowing through the housing, the fuel is in intimate con-
tact with metallized pellets of a metal, such as a noble
metal deposited on a substrate. The pellets are disposed
within the housing. In an alternate embodiment, hereof,
two types of catalyst are disposed within the housing,
one richer in metal content than the other. In prac-
ticing the present invention, the fuel passes through the
housing and issues therefrom at a temperature less than
100'C.
-------
23
BACKGROUND OP THE INVENTION
Field of the Invention!
Thii Invention relates, in general, to internal
combustion engine* and, more specifically, to fuel/air
mixing systems for internal combustion engines.
Description of the Pr^or Arti
Among the growing concerns of today's motorists
are an adequate supply of fuel for vehicles and the
rising costs thereof. Coupled with these concerns are
the enhanced awareness of the ecological damage resulting
from the emission of pollutants from fuel-burning, inter-
nal combustion engine powered, motor vehicles. In an
internal combustion engine, the pollutants include oxides
of nitrogen, carbon monoxide and unburned hydrocarbons.
In addition to creating an ecological problem, the
unburned hydrocarbons also contribute to inefficient
engine of the engine. Further, in existing internal com-
bustion engines, a measurable portion of the fuel
supplied to the engine remains unburned and is discharged
into the atmosphere. This not only pollutes the
atmosphere, but it also results in uneconomical engine
operation and poor engine performance.
Many attempts have been made to ensure a more
complete combustion of the fuel in internal combustion
-2-
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24
engines. Many of these Attempts have involved the utili-
sation of a vaporising apparatus to vaporise the fuel/air
mixture before it if patted to the combustion chamber* of
the engine. It is also well known to provide suitable
heating apparatus within the carburetor to heat the
fuel/air mixture to a temperature more conductive to
complete combustion prior to its entry into the com-
bustion chambers. Such vaporizing and heating apparatus
are typically mounted between the carburetor and the
intake manifold of the engine so as to vaporise and/or
heat the final fuel/air mixture passing therebetween.
Other attempts known in the prior art include
the introduction of adjuvants to the fuel/air mixture
prior to its introduction into the combustion chamber.
However, such attempts at improving engine efficiency and
performance by heating or vaporizing the fuel/air mixture
prior to its entry into the combustion chambers have met
with limited success at reducing engine pollutants.
Apart from the techniques used to improve engine
performance by more completely burning the fuel/air
mixture, additional pollutant control devices, such as
the now prevalent catalytic converter, have come into use
to reduce the amount of pollutants issuing from vehicle
exhaust systems.
Such catalytic converters, while greatly
reducing the amount of gaseous contaminants issuing from
-3-
-------
25
tht vehicle exhaust systems, are quite costly and require
modification of the vehicle for their installation. A
large part of the cost is due to the quantity of platinum
based materials used in their construction. Such conver-
ters also require specific types of fuel and, ifiwrong
fuel is used, become clogged. This not only reduces
their effectiveness in reducing air pollutants issuing
from the vehicle but also severly impairs the engine
performance.
Thus, the prior art has utilised separate devi-
ces to either improve engine performance or reduce pollu-
tants issuing from the vehicle exhaust system. Such
devices, while functioning satisfactorily to a certain
extent in achieving the intended purpose, i.e., fuel
efficiency improvement or pollutants reduction - then do
little or nothing at reducing the engine concomitant for
which they are not intended.
Thus, it would be desirable to provide a
fuel/air mixing system for use with internal combustion
engines which overcomes the problems with prior art devi-
ces in improving engine efficiency, i.e., decreasing the
amount of fuel utilized per distance driven, as well as
reducing the quantity of air pollutants issuing from the
vehicle exhaust system. It would also be desirable to
provide a fuel/air mixing system which is constructed as
-4-
-------
26
tlnglt device and which functions to both improve
engine performance and reduce pollutant levels. It would
also be desirable to provide a fuel/air mixing system
which can be easily incorporated in existing internal
combustion engine designs without extensive modification
thereof. Finally, it would be desirable to provide a
fuel/air mixing system which is economical in cost.
SUMMARY OF THE INVENTION
There is disclosed herein a device for
increasing the fuel efficiency of an internal combustion
engine and a method of use therefor. The device is
interposed a fuel supply and a combustion chamber. In
gasoline engines, the device is interposed a fuel supply
and a carburetor. The device includes a hollow housing
disposed in fluid communication with the fuel supply con-
duit intermediate the fuel supply and the combustion
chamber.
Disposed within the housing are a plurality of
metallized pellets. The pellets, generally, comprise a
noble metal deposited on an inert substance and are used
to activate or "catalyze" the fuel passing through the
housing.
Optionally, a heat source, such as a heating rod
or element is disposed within the housing for elevating
the temperature within the housing. Where used, the
heating element is energized by the vehicle battery. A
time-delay switch can, also, be incorporated into the
-5-
-------
27
yttam to regulate the temperature created by the heating
element.
In en alternate embodiment hereof, the pellets
disposed within the housing comprise two classes having
different levels of metal deposited thereon. In !this
embodiment, the housing comprises at least two internal
chambers in fluid communication. In one chamber is
disposed a first class of pellets with the second class
of pellets being disposed in the second chamber. The
fuel passes through both chambers before being fed to the,
combustion chamber.
In practicing the present invention, the fuel
enters the housing as a liquid and exits as a liquid
therefrom. The temperature within the housing varies
from ambient conditions to less than about 100'C.
The device of the present invention overcomes
many of the problems of similar prior art devices in
improving engine performance and efficiency; while, at
the same time, significantly reducing the levels of
pollutants issuing from the vehicle exhaust system. In
addition, the pressure regulator of the present invention
achieves both desired features in a single unit as com-
pared to prior art attempts which maximized engine effi-
cient or reduced pollution levels by use of separate
devices installed on the vehicle.
-6-
-------
28
Furthermore, the device of the present invention is both
economical in cost and easy to install on conventional
internal combustion engines without requiring modifica-
tions thereto.
BRIEF DESCRIPTION OF THE DRAWING
The various features, advantages and other uses
of the present invention will become more apparent by
referring to the following detailed description and
drawing in whioht
FIQ. 1. is a flow diagram showing the deployment
of the device of the present invention.
FIQ. 2. is a cross-sectional view of the device
of the present invention;
FIQ. 3. is a cross-sectional view of an alter-
nate embodiment of the device of the present invention,
and
DESCRIPTION OP THE PREFERRED EMBODIMENTS
Throughout the following description and
drawing, identical reference numbers are used to refer to
the same component shown in multiple figures of the
drawing.
Referring now to the drawing, and to Figure 1 in
particular, there is illustrated a device generally indi-
cated at lo, in accordance with the present invention.
-7-
-------
29
Although the present invention will work with
equal efficacy for both gasoline and diesel fuel engines,
the present invention for purposes of clarity will be
described with reference to a gasoline-burning internal
combustion engine. Furthermore, the invention will work
in connection with boats, motorcycles, etc. Again,
however, for facility, the ensuing 'description will be
made with reference to an automobile.
In a conventional vehicle, the fuel supply 12 is
connected to the carburetor 14 of the engine via a fuel
r
supply conduit, shown generally by reference number 16.
A fuel pump IS is disposed in fluid communication with
the fuel supply conduit 16 to pump fuel from the fuel
supply 12 to the carburetor 14.
As is conventionally known, the carburetor 14
functions to mix fuel and air in a proper ratio and to
deliver the fuel/air mixture to the intake maniford 20 of
the engine wherein the fuel/air mixture is transferred to
the combustion chambers in the cylinders of the engine,
not shown, and ignited to produce the explosive forces
for driving the pistons of the engine which propel the
vehicle.
According to the teachings of the present
invention, the device 10 includes a housing 22 disposed
in fluid flow comnunication with the fuel supply conduit
16 between the fuel supply 12 and the carburetor 14.
-8-
-------
30
Preferably, the device 10 it disposed in fuel supply con-
duit 16 between the fuel pump 18 and the carburetor 14.
A cheek valve 24 is disposed between the fuel pump 18 and
the device 10 to provide one way fuel flow therebetween.
The hollow housing 22 is of substantially
cylindrical configuration, and is formed of a metallic
material, such as steel or the like. The housing may be
formed of any other material which is not reactive with
the fuel. Likewise, the housing may be heat conductive
or insulative, as required. The housing includes end or
top and bottom wall members 25 and 26 respectively
secured to opposed ends thereof to completely seal the
interior of the housing 22. Inlet and outlet ports 28
and 30, respectively, are formed therein. The inlet port
28 is preferably formed in the side wall or bottom wall
of the housing 22. A segment 32 of the fuel supply con-
duit 16 is secured to the port in fluid tight sealing
relationship. The outlet port 30 is preferably formed in
the end wall member 25. Another segment 31 of the fuel
supply conduit 16 is secured to the outlet port, as
shown.
It is contemplated in the practice of the pre-
sent that the interior of the housing be heated. The
heating can be achieved either from the ambient, i.e.,
the engine compartment or the atmosphere or from a
heating element incorporated into the device. The heat
-9-
-------
31
source maintains the interior of the housing at a tem-
perature ranging from about the ambient to a temperature
of leu than 100'C. Preferably, the temperature in the
housing is maintained at a temperature of from about 25*C
to about 90*C. Henee in cold climates, and without a
heat source incorporated within the device, the housing
is heat conductive. Likewise, in extreme heat, the
housing should demonstrate some insulative properties.
Preferably, however, the heat source is incor-
porated into the device. Where used, the internal heat
source comprises a heating element 34.
The heating element 34 is securely mounted
within the housing 22,. Preferably, the heating element
is in the form of a high watt density heater having an
incoloy sheath material disposed about the exterior
thereof.
The heating element 34 is mounted to the housing
22 by any suitably means, such as external threads 36
formed adjacent the first end of the heating element 34
which thrcadingly engage an opening 38 formed in the
housing 22. In this manner, the heating element 34 may
be inserted and secured within the housing 22 as well as
removed for repair or replacement. As shown in Figure 2,
a pair of electrical connections or wires extend outward
from the heating element 34 and are adapted to be con-
nected to a suitable power source, such as the automobile
-10-
-------
32
battery (not shown), or the like, for providing electri-
cal current to the hotting element 34.
A suitable temperature sensing means (not shown)
may be mounted in the housing 12 for controlling the tera-
i
perature generated by the heating element. Suitable
electrical connecting means, not shown, extend from the
sensing unit to a conventional temperature control means
so as to control the connection of electrical current to
the heating element 34 to thereby maintain the tem-
perature of the heating element 34 within the desired
temperature range.
Likewise, because of the energy required by the
heating element is quite high, a time-delay 40 is inter-
posed the heating element and the battery. The time-
delay 40 is a conventional relay switch which interrupts
power flow to the heating element when the engine of the
vehicle started.
As shown in the drawing, disposed within the
housing are a plurality of pellets 42.
The pellets 42 generally comprise a metallized
pellet of a metal deposited on an inert support or
substrate. The metal deposition techniques for making
such pellets are well known and do not form part of the
present invention.
The metals which are employed herein include for
example, noble metals, carbides and the like, as well
-11-
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33
Biiture* thereof. Representative noble metals include
platinum, niekel, palladium, rhenium, ruthenium, and tha
ilka* Useful oarbidaa include titanium carbide, tungsten
carbide, as well aa mixtures thereof. Preferably, the
metal is a noble metal and, in particular, platinum.
The inert or non-fuel reactive support or
substrate are those conventionally deployed, such as
silica, alumina, clays and the like. Preferably, the
support of substrate is alumina.
The pellets 42 ordinarily have a mesh size
ranging from about 1/32" in diameter to about 1/8* in
diameter, and are tightly compacted within the housing.
In deploying alumina-supported platinum pellets,
the purity of the platinum will range from about 0.1% to
about 10%, in accordance with general manufacturing
techniques. Preferably, the purity or concentration of
platinum will range from about 0.1% to about 1.0%.
In practicing the present invention, liquid fuel
is pumped into the housing 22 through which it passes.
Within the housing, the fuel contacts the pellets and
issues from the housing as a liquid. Although not
wishing to be bound by any theory, it would appear that
at the temperatures employed that some metal is solubi-
lized and entrained into the fuel flow. The presence of
the noble metal within the hydrocarbon fuel effectively
-12-
-------
34
increases tn« total combustion thereof. Hence the fuel
efficiency of the internal combustion engine is improved.
It should, also, be noted with respect hereto,
that as the fuel contacts the metallized pellets or
"bubbling" effect occurs, wherein gases appear to be
liberated from the fuel. These gases remain in the fuel
and are released at the carburetor.
Referring now to Figure 3 there is shown therein
an alternate embodiment of the present device, generally,
indicated at 110. The device 110 includes a housing 112
fabricated similarly to the housing 12. The housing 112
has a hollow interior and is substantially cylindrical in
nature. A member 114 is disposed within the housing 112
and as concentric therewith. The housing 112 and member
114 cooperate to divide the device 110 into two chambers
116, 118, respectively, interiorly thereof. The member
114 has ports 120 formed therein which provide fluid com-
munication between the chambers.
A fuel inlet 121 opens into the inner chamber
118 and a fuel outlet 122 communicates with chamber 116
to permit fuel to exit therefrom. A heating element 124,
where used, is disposed within the interior chamber, as
shown.
In accordance with this embodiment of the pre-
sent invention, each chamber is packed with metallized
-U-
-------
35
pellets I19t 128, respectively. However, the metal con-
centration of the pellets within chamber 118 is higher
than the metal concentration of the pellets in the
chamber 116. The metal concentration of the metal
1 i
pellets in the chamber 118 is about twice that of the
pellets in the outer chamber 116. .For example, assuming
alumina-supported platinum pellets are employed, pellets
containing about 0.6% platinum are disposed in the
exterior chamber and pellets having a platinum con-
centration of about 0.3% are disposed in the outer
chamber 116.
The present invention further contemplates a
switching device 130 for contracting the heating element
124. The switching device 124 is in electrical com-
munication with the wires extending from the heating ele-
ment to the power source. The switching device is a
multi-positioned switch for varying the electrical load
to the element over a range from "off to full energy
flow. The switch is manually operable and conveniently
located, such as on the dashboard of an automobile.
Having, thus, described the invention, what is
claimed is:
-14-
-------
TO BATTERY
CARBURETOR
'i
//*
-3 ₯
TO BATTERY
FUEL
SUPPLY
00
-------
ATTACHMENT B 37
A-l.
INSTALLATION INSTRUCTIONS
Models No. 1150G and No. 1200G (Patent Pending)
1. Mount the Optimizer on the fender well on the same side
of the engine as the fuel pump. The Optimizer should be in
the vertical position. Be careful not to bend the wires at
the base of the unit.
2. Mount the condenser in the horizontal position in front
of the radiator in order to receive as much air flow as
possible.
3. Connect a high quality gas line material (preferably with
nylon cord reinforcement) from the outlet of the Optimizer to
the inlet of the condenser.
a. The top hole on the condenser must be the inlet.
b. The bottom hole of the condenser must be the outlet.
4. Cut the gas line near the carburetor. Connect the line from
the fuel pump to the inlet of the Optimizer.
5. Install the inline filter between the outlet of the
condenser and the carburetor.
a. Filter should be changed every 7,000 to 10,000 miles.
6. Install the relay on the fire wall or the fender well near
the Optimizer.
a. The white wire (post "B") on the bottom of the relay
is the ground wire and should be connected to one of
the wires from the Optimizer, and then to a good
ground.
Optimizer Center, 220 Lynn Street, Flushing, Michigan 48433 313 659-2000
-------
38
A-2,
6. (Con't)
b. The brown wire (post "5") on the bottom of the
relay should be connected to the other wire on
the Optimizer using the connector provided.
c. The red wire (post "7") on the bottom of the
relay goes to a battery source (the battery
itself, or to the back of the alternator where
the battery wire is found).
d. The yellow wire (post "A") on the bottom of the
relay should be connected to an ignition source
which only comes on when the car is operating.
No current should flow when the "accessories"
side of the ignition switch is on. The fuse box
usually contains an ignition plug. This would be
a good source.
e. Using an amp meter, check to see that there is
approximately 13 to 15 amps being initially drawn
by the heating element, which should decrease to
10 amps or less when the device and engine are in
normal working order.
7. Check the wire and hose clamps to make sure that all are
properly connected and make sure that no kinks or sharp bends
are present in the gas line. Start the engine and, while it
is warming up, check for leaks in the gas line.
8. Now that the engine is warmed to operating temperature,
advance the timing 5 degrees. In some cases, a spark knock
may be heard. If so, move the timing back 1 or 2 degrees until
the spark knock disappears. In those vehicles where knock is
heard within the 5 degrees advance, it is recommended that an
attempt be made to increase to the full 5 degree advance after
the 1,000 mile break-in period.
9- The Optimizer is now installed. A break-in period of
1,000 miles is necessary to see the maximum effects from the
device. A well tuned engine will insure the greatest benefit
from the Optimizer.
-------
39
A-3.
MODEL #11500 and HM200G - GasoliM Uniti (Patent Pending)
(Automobile and 4/6/8 Cylinder Light Duty Trucks)
CONDENSING UNIT
Carburetor
To Optimizer wire (Brown)
To potitive tide of battery (Red)
To ignition source (Yellow)
To Optimizer wire (White)
RELAY - (Bottom Side)
White relay wire
connected to a good
ground source
"battery" side.
-------
MODEL #22000 Gasoline Unit (Patent Pending)
(Heavy Duty Trucks)
The Condensing Unit should be
mounted in the horizontal position
To Optimizer wire (Brown) \
To positive tide of battery (Red)
To ignition source (Yellow)
7
T
r-
6
B^
^
\
ToC
r
2.
7
5
B
«^»
Optimizer wire (White)
connected to a good
RELAY - (Bottom Side) ground source
Note: This is a double unit; "battery" side.
it requires two relays.
*»
o
-------
ATTACHMENT C-l
41
Q -
p-Pt. -
25 50 7? i or..
/as i£o
-------
42
ATTACHMENT C-2
Explanation of Fuel Sample Tests from Research and Control Laboratories
A-2
B-2:
C-2
A-3
B-3:
Sample removed from fuel tank at gas station.
(480 cc sample)
Sample after exiting Optimizer with no heat.
(480 cc sample)
Sample exiting Optimizer with heat. (480 cc
sample) The hydro carbon composition done at
the same time showing increase in aromatics
and a decrese in saturates was done on this
sample.
Sample removed from fuel tank. (3840 cc sample)
Sample exiting Optimizer with heat. (3840 cc
sample)
It must be noted that there was no pump sample taken at the
time of A-3 and B-3.
"A" Group of Tests:
"B" Group of Tests:
Summer Fuel
Winter Fuel
Note: A direct flow rate of 3840 cc in 15 minutes is faster
than any automobile uses fuel and does not allow
sufficient time for treatment within the Optimizer.
Optimizer Center, 220 Lynn Street, Flushing, Michigan 48433 313 659-2000
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43
ATTACHMENT C-3
Research and Control Laboratories, Inc.
(313) 538-2367
Dr. Marvin Weintraub
Innovative Technologies, Inc.
Southfield, Michigan
Dear Sir:
27145 BENNETT ST.
DETROIT, MICH. 48240
Dec. 6, 1982
Re: Optimizer
The analytical results obtained on the samples you submitted
are listed below. Platinum was determined by flameless atomic
absorption and the gasoline characterization was done by the standard
ASTM method.
Pt, ppb
Aroma tic/I
Olefin
A-2
0.0
26.0%
10.2
Saturates % 63.8
Samples
B-2 C-2 A-3 B-3
6.5 29.3 0.0 23,0
28.9 31.4 26.9 26.7
9.4 9.7 9.7 9.0
61.7 58.7 63.4 64.3
-------
AA
ATTACHMENT C-A
TEST SUMMARY & RESULTS
1980 CHEVROLET MONTE CARLO V-8, VEHICLE # 7957
DATE
8/19/82
8/19/82
8/19/82
8/19/82
9/02/82
9/02/82
9/02/82
9/02/82
9/02/82
9/02/82
9/02/82
9/02/82
9/08/82
9/08/82
9/08/82
9/08/82
9/10/82
9/10/82
9/10/82
9/10/82
ODO
5AA90
5AA98
5A519
5A526
55691
55699
5572A
557AA
55783
55790
55811
55819
56372
56380
56AOO
56A08
56957
56965
56993
56998
TEST
City
Hwy
City
Hwy
City
Hwy
City*
Hwy
City
Hwy
City
Hwy
City
Hwy
City
Hwy
City
Hwy
City
Hwy
DESCRIPTION
Baseline
Baseline
Baseline
Baseline
Device *
After
500
Miles
Parameter
Only
Parameter
After
500
Miles
Final
Baseline
it
ii
HC
.206
.063
.167
.06A
.361
.11A
.389
.111
.A32
.121
.A06
.115
.283
.115
.26A
.113
.228
.075
.255
.07A
CO
.922
.189
.725
.133
.3AA
.011
.206
.017
1.A06
.059
vA87
.121
.107
.02A
.A8A
.071
.667
.168
.922
.176
NOx
.897
1.057
.872
1.025
1.123
1.3A8
1.082
1.305
1.39A
1.763
1.A57
1.895
1.270
1.A76
1.329
1.A95
.893
1.125
.910
1.08A
MPG
17.15
22.61
17. A5
22.76
17.81
23.39
17.85
23.82
18.75
2A.60
19.25
2A.5A
19.03
2A.83
19.17
2A.92
17.55
22.87
17.80
23.10
FLUIDYNE
_
-
-
17.80
23.79
17.66
2A.06
18.62
25.02
18.89
2A.99
19.61
25.11
19.27
25.17
18. OA
23. AA
18.03
23. A8
* Vehicle No. 7957 was tested with a fuel return line to the tank. The timing
was adjusted as prescribed in the device installation instructions.
-------
45
ATTACHMENT C-5
TEST SUMMARY & RESULTS - continued
1981 OLDSMOBILE CUTLASS V-6, VEHICLE // 8982
DATE
8/19/82
8/19/82
8/19/82
8/19/82
8/25/82
8/25/82
8/25/82
8/25/82
9/02/82
9/02/82,;.
9/02/82
9/02/82
9/07/82
9/07/82
9/07/82
9/07/82
9/15/82
9/15/82
9/15/82
9/15/82
ODO
63952
63960
63981
63989
64528
64535
64555
64563
64605
64613
64633
64641
65187
65195
65215
65223
66010
66018
66038
66046
TEST
City
Hwy
City
Hwy
City
Hwy.v
City
Hwy
City
Hwy
City
Hwy
City
Hwy
City
Hwy
City
Hwy
City
Hwy
DESCRIPTION
Baseline
Baseline
Baseline
Baseline
Device *
After
500
Miles
Parameter
Only
.'-*
Parameter
Plus
500
Miles
Final
Baseline
ii
ii
HC
.172
.074
.174
.074
.243
.098
.225
.095
.214
.090
.198
.088
.231
.090
.235
.086
.200
.082
.215
.080
CO ,
.457
.180
.764
.273
.469
.162
.879
.136
.508
.187
.626
.218
.630
.115
.623
.238
.352
.121
.753
.301
NOx
2.627
1.427
2.743
1.477
3.519
2.189
3.366
2.184
3.175
2.130
3.216
2.150
3.061
2.252
3.121
2.103
2.597
1.703
2.433
1.556
MPG
20.53
26.55
20.56
25.85
20.54
26.18
20.26
26.07
20.72
25.95
21.15
26.13
20.73
26.35
20.74
26.29
20.48
26.36
20.34
26.05
FLUIDYNE
_
-
-
-
_
-
-
20.60
26.42
20.93
26.28
20.80
26.58
20.88
26.45
20.77
26.79
20.80
26.53
*Vehicle No. 8982 was tested with a fuel return line to the tank. The timing
was adjusted as prescribed in the device installation instructions.
-------
EVALUATION OF OPTIMIZER DEVICE ATTACHMENT46C.6
VEHICLE NO. 0267
1980 CHEVROLET MONTE CARLO 4.4L V-8
DATE * ODO * TEST * DESCRIPTION * HC * CO * NOX * MPG
11-08-82
11-08-82
11-08-82
11-08-82
*
*
*
*
43049
43058
43077
43084
* CITY * BASELINE
* HWY * AFTER
* CITY * 1000 MILES
* HWY * FACT. SPECS
AVERAGE CITY RESULTS:
AVERAGE HWY RESULTS:
*
*
*
*
*
*
0
0
0
0
0
0
.071
.024
.073
.019
.072
..022
0.
0.
0.
0.
0.
0.
163
037
279
052
221
045
*
*
*
*
*
*
0.649
0.853
0.678
0.910
0.664
0.882
17.38
21.73
17.42
22.08
17.40
21.91
11-11-82
11-11-82
11-15-82
11-11-82
NOTES 1,
*
*,
*
*
2
44132 * CITY * OPTIMIZER
44140 * HWY * AFTER
44207 * CITY * 1000 MILES
44167 * HWY * FACT. SPECS
AVERAGE CITY RESULTS:
AVERAGE HWY RESULTS:
*
*
*
*
*
*
0.082
0.022
0.078
0.023
0.080
0.023
*
*
*
*
*
*
0.
0.
0.
0.
0.
0.
235
007
260
182
248
095
0.
1.
0.
1.
0.
1.
753
009
708
038
731
024
*
*
*
*
*
*
17.84
22.77
17.75
23.03
17.80
22.90
11-15-82;
11-15-82
11-15-82
11-15-82
NOTES 1.
**..
-;*
*
*
3
44243
44250
44270
44278
* CITY * OPTIMIZER
* HWY * PARAMETERS
* CITY * ADJUSTED
* HWY * (NO MILES)
AVERAGE CITY RESULTS:
AVERAGE HWY RESULTS:
*
*
*
*
*
*
0.090
0.027
0.092
0.027
0.091
0.027
*
*
*
*
*
*
0.
0.
0.
0.
0.
0.
066 <
000
364
002
215
001
' 0.843
0.890
0.877
0.921
0.860
0.906
*
*
*
*
*
*
17.85
23.22
18.15
23.33
18.00
23.28
11-16-82
11-16-82
11-16-82
11-16-82
NOTES 1,
*
*
*
*
2
44324
44331
44352
44359
* CITY * OPTIMIZER
* HWY * BACK TO
* CITY * FACT. SPECS
* HWY * (NO MILES)
AVERAGE CITY RESULTS:
AVERAGE HWY RESULTS:
0.
0.
0.
0.
0.
0.
193
058
208
080
201
069
*
*
*
*
*
*
0.
0.
0.
0.
0.
0.
091
016
492
072
292
044
1.553
1.438
1.577
1.737
1.565
1.588
*
*
*
*
*
*
16.37
20.56
16.70
21.61
16.54
21.09
The final set of tests, Optimizer back to factory specs (no miles), is included
here for information purposes only. It was found that one, possibly two, spark plug
wires failed on this vehicle during the final set of tests. This explains the extreme
variance from the other set of tests where Optimizer was operated at factory specs.
Vehicle No. 0267 was tested without a fuel return line according to the then
current installation configuration.
Vehicle was tested without the timing advance prescribed in the instal-
lation instructions.
Note 3. Vehicle was tested with the timing advance as prescribed in the instal-
lation instructions.
Note 1.
Note 2,
AUTOMOTIVE TESTING LABORATORIES, INC.
EAST LIBERTY, OHIO
-------
47
EVALUATION OF OPTIMIZER DEVICE
VEHICLE NO. 2430
ATTACHMENT C-7
1980 OLDSMOBILE CUTLASS 4.3L V-8
.WWMW«WWM«MMWW«M»M»W»_WW«««V4l»MW»W*WM«»~*~*»«l»W«W*~~Wa»W~~M»~~~M«*M»«B«W~W«W«a
DATE * ODD * TEST * DESCRIPTION * HC * CO * NOX * MPG
11-09-82
11-09-82
11-09-82
11-09-82
*
*
*.
*
39683
39690
39711
39719
* CITY * BASELINE
* HWY * AFTER
* CITY * 1000 MILES
* HWY * FACT. SPECS
AVERAGE CITY RESULTS:
AVERAGE HWY RESULTS:
0.108
0.055
0.107
0.063
0.108
0.459
*
*
*
*
*
*
0.
0.
0.
0.
0.
0.
044
006
034
063
039
035
1.
1.
1.
1.
1.
X
348
521
364
557
356
539
*
*
*
*
*
*
19.27
24.34
19.16
24.45
19.22
24.40
11-1
11-1
11-1
11-1
1-82
1-82
1-82
1-82
NOTES 1,
11-1
11-1
11-1
11-1
5-82
5-82
5-82
5-82
NOTES 1,
11-1
11-1
11-1
11-1
6-82
6-82
6-82
6-82
NOTES 1,
* 40755
* 40763
* 40783
* 40790
2
* 40837
* 40845
* 40865
* 40872
3
* 40925
* 40932
* 40953
* 40961
2
* CITY *
* HWY *
* CITY *
* HWY *
OPTIMIZER
AFTER
1000 MILES
FACT. SPECS
AVERAGE CITY RESULTS:
AVERAGE HWY RESULTS:
* CITY *
* HWY *
* CITY *
* HWY *
AVERAGE
AVERAGE
* CITY *
* HWY *
* CITY *
* HWY *
AVERAGE
AVERAGE
OPTIMIZER
PARAMETERS
ADJUSTED
(NO MILES)
CITY RESULTS:
HWY RESULTS:
OPTIMIZER
BACK TO
FACT. SPECS
(NO MILES)
CITY RESULTS:
HWY RESULTS:
* 0.
* 0.
* 0.
* 0.
* 0.
* 0.
* 0.
* 0.
* 0.
* 0.
* 0.
* 0.
* 0.
* 0.
* 0.
* 0.
* 0.
* 0.
134
037
119
037
127
037
102
034
116
034
109
034
115
036
107
037
111
037
0.
0.
0.
0.
0.
0.
* 0.
* 0.
* 0.
* 0.
* 0.
* 0.
* 0.
* 0.
* 0.
* 0.
* 0.
* 0.
023
001
184
001
104
001
018
000
088
000
053
000
047
001
099
000
073
001
1.
1.
1.
2.
1.
1.
* 1.
* 2.
* 1.
* 2.
* 1.
* 2.
* 1.
1.
1.
1.
1.
1.
427
740
488
046
458
893
549
333
714
353
632
343
345
861
444
906
395
884
19.41
25.34
19.06
25.92
19.24
25.63
20.19
25.58
20.03
25.77
20.11
25.68
19.28
25.48
19.13
25.83
19.21
25.66
Note 1. Vehicle No. 2430 was tested without a fuel return line according to the
current installation configuration.
Note 2. Vehicle was tested without the timing advance prescribed in the instal-
lation instructions.
Note 3. Vehicle was tested with the timing advance as prescribed in the instal-
lation instructions.
AUTOMOTIVE TESTING LABORATORIES, INC.
EAST LIBERTY, OHIO
-------
.uThose vehicl|g;>with £he- three items o.f the return
J3ijjin.e: system rnsfcaJLl^d^Juring the test are designated
Ivby a red check ( *r). xiaisk.
,.,,11 ___!_.. .,.. . . i^iiiain i j i i , » I,, ^i i. ,,- - .,,,, -_ ^^_- --
48
C-8
Device* Optimizer G-500 (Patent Pending)
Conditions: Highway, at 55 MPH.
Vehicle
'80 Olds Cutlas
77 Buick LaSabre
'76 Buick LaSabre
'82 CMC Suburban
/81 Pontiac
^X'76 Pontiac
'82 CMC Pick Up Truck
'76 Chevrolet PU Truck
y^'78 Chevy Station Wagon
'76 Cadillac
/'81 Chevrolet Citation
v t
Titan Motor Hone
Winnebago Motor Hoae
Miles Driven
969.5
780.0
2,409.0
2,409.0
381.0
381.0
381.0
381.0
381.0
500.0
700.0
296.0
296.0
MPG-Base
24.70
21.99
20.46
14.57
.27.79
17.10
13.60
19.60
22.40
16.50
26.60
7.50
8.50
MPG-Device
29.83
24.55
23.48
17.46
30.27
19.20
14.80
22.00
27.40
18.87
31.03
8.30
10.40
Improvement 1
18 %
11 %
13 %
17 I
8 I
11 %
8.8 %
11 %
19 %
12.5 t
14.2 %
10 %
18 %
AVERAGE %t
14 I
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY ATTACHMENT D
ANN ARBOR. MICHIGAN 48105
May 4, 1982
OFFICE OF
AIR. NOISE AND RADIATION
Ms Vera Anderson
Optimizer Company
220 Lynn Street
Flushing, MI 48433
Dear Ms. Anderson
This letter is in response to your inquiry on May 3, 1982, regarding an
EPA evaluation of the Optimizer. The Environmental Protection Agency is
charged by Congressional mandate to evaluate fuel economy and emission
control devices. While the EPA does not actually "approve" such devices,
it does conduct evaluations for the purpose of increasing the common
knowledge in the area. For this reason, the outcome of any testing by
EPA becomes public information. It is this information which may be
cited, although no claims can be made that any EPA findings constitute
"approval" of the device or system.
Enclosed with this letter is a packet of materials which you will need to
apply for an EPA evaluation of your device. This packet consists of
1) an application format, 2) a document entitled "EPA Retrofit and
Emission Control Device Evaluation Test Policy", 3) "Basic Test Plans and
Testing Sequences", and 4) a copy of the applicable Federal Regulations.
Engine oils, oil additives, and other lubricants do not fall under the
provisions of Section 511 of the Motor Vehicle Information and Cost
Savings Act. Recently, there has been confusion over the wording in the
regulation that gives EPA the authority to evaluate fuel additives.
Until we are able to eliminate this confusion by modifying the regula-
tion, we cannot accept applications for evaluations of fuel additives.
If you wish to improve the credibility of your oil or fuel additives by
performing tests on your own, we will try to help by commenting on your
test plans.
In order for the EPA to conduct an evaluation of your device, we must
have an application. Once you have reviewed all the documents in the
packet, you should prepare an application in accordance with the guide-
lines of the application format. A critical part of the application is
the substantiating test data. The required test results will have to be
obtained at a laboratory of your choice. Such testing would be conducted
at your expense. A list of laboratories, which are known to have the
equipment and personnel to perform acceptable tests, has been included in
the enclosed packet. The laboratory list is revised periodically, so be
certain that the list you are using is current. Please allow EPA to
comment on your test plan before beginning testing at an independent
laboratory. If you desire, we can assist in the development of a satis-
factory test plan.
-------
50
There are, however, several aspects concerning testing at an outside
laboratory which I would like to bring to your attention at this time:
Minimum Test Requirements - Although different types of devices may
require a more complex test plan, the minimum we require involves two
vehicles and two test sequences run in duplicate. The vehicles
should be selected from those listed in Table 1; if possible. Each
vehicle is to be set to manufacturer's tune-up specifications for the
baseline tests.
The tests are conducted in a "back-to-back" manner, once with the
vehicle in baseline condition, and again with the device installed
with no vehicle adjustments between tests. If installation of the
device also involves some adjustments, e.g. timing, fuel-air mixture,
choke or idle speed, another test sequence with only these adjust-
ments should be inserted between the first and last. If mileage
accumulation is necessary in order to realize the full benefit, the
same number of miles that are accumulated before the test runs must
also be accumulated before baseline runs. In addition, the method of
mileage accumulation should be kept constant. Also, as a minimum,
the test sequence shall consist of a hot-start LA-4 portion (bags 1
and 2) of the Federal Test Procedure (FTP) and a Highway Fuel Economy
Test (HFET). The details of these tests are contained in the
enclosed packet. Although only a hot-start FTP is required to
minimize the costs to you, you are encouraged to have the entire
cold-start test performed, since any confirmatory testing and evalua-
tion performed by EPA will be based on the complete FTP, and you may
wish to know how a vehicle with your device performs over this
official test. As a final requirement, the personnel of the outside
laboratory you select should perform every element of your test
plan. This includes preparation of the test vehicle, adjustment of
parameters, and installation of the device.
Submission of Data - We require that all test data obtained from the
outside laboratories in support of your application be submitted to
us. This includes any results you have which were declared void or
invalid by the laboratory. We also ask that you notify us of the
laboratory you have chosen, when testing is scheduled to begin, what
tests you have decided to conduct, allow us to maintain contact with
the laboratory during the course of the testing, and allow the test
laboratory to directly answer any questions at any time about the
test program.
Cost of the Testing - The cost of the minimum test plan (two
vehicles, two test sequences in duplicate) described above should be
less than $3000 per vehicle and less than $6000 for the total test at
any of the laboratories on the list. It should be recognized that
additions to the minimum test plan (such as mileage accumulation,
parameter adjustment, or additional testing) will result in addi-
tional costs. In any case, you will have to contact them individ-
ually to obtain their latest prices.
-------
51
Outcome of the Tests - In order for EPA to best utilize our facil-
ities, confirmatory testing will be performed only on those devices
that demonstrate a statistically significant improvement in fuel
economy or emissions based on data from an EPA-recognlzed independent
laboratory. We have established some guidelines which will help you
determine whether the test results with your device should be consid-
ered encouraging. These values have been chosen to assure both of us
that a real difference in fuel economy exists, and that we are not
seeing only the variability in the results. The table below presents
the minimum number of cars that need to be tested for varying degrees
of fuel economy improvement, assuming a typical amount of variability
in fuel economy measurement. For a minimum test plan which was con-
ducted on a fleet of two cars, the average improvement should be at
least 6%. If at least a 6% difference in average fuel economy can be
shown, then we would be able to say statistically at the 80% con-
fidence level that there is a real improvement.
Similarly, we would expect a minimum of 3% improvement for a fleet of
5 vehicles. Test results which display a significant increase in
emission levels should be reason for concern.
Minimum Fuel Economy Improvements versus Size of Test Fleet
Fleet Size Average Improvement Required
2 6%
3 5%
4 4%
5 3%
10 2%
Once we receive your application, it will be reviewed to determine if it
meets the requirements listed in the format. Please do not submit con-
fidential, trade secret, or proprietary information as EPA cannot assure
that such information can be protected in all situations. If your
application is not complete, we will ask you to submit further informa-
tion or data. After any missing information has been submitted, your
application will be reconsidered, and once it meets our requirements, you
will be advised of our decision whether or not EPA will perform any con-
firmatory testing. You must provide funds to cover the cost of any
testing in the EPA laboratory. You will be given the opportunity to
concur with our test plan. Once this testing is complete, an evaluation
report will be written. If no further testing is required, the report
will be written solely on the basis of the test data submitted and our
engineering analysis.
EPA intends to process your application in as expeditious a manner as
possible. We have established a goal of twelve weeks from the receipt of
a complete application to the announcement of our report. The attainment
of this objective requires very precise scheduling, and we are depending
on the applicant to respond promptly to any questions, or to submit any
requested data. Failure to respond in a timely manner will unduly delay
the process. In the extreme case, we may consider lack of response as a
withdrawal of the application.
-------
52
I hope the information above and that contained in the enclosed documents
will aid you in the preparation of an acceptable application for an EPA
evaluation of your device. I will be your contact with EPA during this
process and any subsequent EPA evaluation. My address is EPA, Motor
Vehicle Emission Laboratory, 2565 Plymouth Road, Ann Arbor, Michigan,
48105. The telephone number is (313) 668-4299. Please contact me if you
have any questions or require any further information.
Sincerely,
Merrill W. Korth
Device Evaluation Coordinator
Emission Control Technology Division
-£_
Enclosures
-------
53
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY ATTACHMENT E
ANN ARBOR. MICHIGAN 48105
July 20, 1982
OFFICE OF
AIR. NOISE AND RADIATION
Dr. Leon Rosky
Optimizer Ltd.
Optimizer Center
220 Lynn Street
Flushing, MI 48433
Dear Dr. Rosky:
After our meeting on July 19 and our telephone conversation later that
day, I suggested that you evaluate the Optimizer device by following EPA
recommended test plan D-l. This would eliminate one of the 500 mile
accumulation increments that you listed in your preliminary test plan
that we discussed during our meeting. As a result, the recommended plan
may be itemized as follows:
1. Obtain and prepare vehicles
2. 500 mile accumulation period
3. Baseline testing sequences (city and highway test)
4. Install device and perform the following vehicle parameter
changes.
a. Advance timing five degrees
b. Install return line as per instructions
c. Adjust fuel line pressure to the carburetor to 3.5 to 4
p.s.i. at idle.
5. 500 mile accumulation period
6. Test sequence (city and highway) test
7. Remove device
8. Test sequence (city and highway) without device leaving vehicle
parameters at same conditions as in Item 6 test sequence. (If
vehicle does not perform properly during this sequence due to
low fuel pressure, shut off the Optimizer return line restoring
fuel pressure to normal levels and perform test with timing
advance only.)
Sincerely,
Merrill W. Korth
Device Evaluation Coordinator
Test and Evaluation Branch
Enclosure
-------
54
ATTACHMENT F
timizeriiM
December 6, 1982
Environmental Protection Agency
Motor Vehicle Emission Laboratory
25C5 Plymouth Road
Ann Arbor, Michigan 48105
Attention: Mr. Merrill W. Korth
Device Evaluation Coordinator
Emission Control Technology Division
Dear Mr. Korth:
Enclosed you will find our application for evaluation of
the Optimizer under section 511 of the Motor Vehicle Information
and Cost Savings Act. Included are test reports from laboratories
relative to composition of the fuel, both before and after the
device.
I believe some comments are necessary at this point in order
to clarify the test results and some questions that may come up
relative to the test programs. You will note that two test pro-
grams have been done. The first program was done according to
the agreed upon test procedure as stated in your letter dated
July 20, 1982. On that test you will note the following: one
vehicle, the Oldsmobile, gave no results at all; car number two,
the Monte Carlo, showed results both on the urban and highway
cycles. You will note that the sequences wherein the device was
removed (parameters only, without an accummulation of 500 miles),
improvement was seen over device plus parameters. The sequence
immediately following this, where 500 miles were accummulated
(with no device, only parameters), gave a further increase,
which may lead one to believe the device had no effect. However,
in all of our testing, both that which was done at Optimizer, Ltd
and also at Automotive Testing Laboratories, Inc, we saw that the
Optimizer required an accummulation of miles both for "heating"
and "wearing-off" effects within the combustion chamber. Until
recently, we were not sure how many miles had to be accummulated
for the break-in and the wearing-off periods. Consequently, it
is apparent to us that the increase in miles per gallon figures
without device (both with and without accummulation of miles) is
due to deposits of noble metals on the walls of the combustion
Optimizer Center, 220 Lynn Street. Flushing, Michigan 48433 313 659-2000
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55
chamber from fuel previously treated within the Optimizer.
These results are consistent with all the tests that we have
done up to this point.
In the second program, we were concerned about knowing
exactly what the device alone would do on two other vehicles.
It was set up for a base line test after an accummulation of
1,000 miles, and a device only test after an accummulation
of 1,000 miles. The results are appended. After the device
only test, we did an immediate timing advance of 5 degrees,
followed by timing back to specs with device. The results
show the effect of the timing. We found that the vehicles ran
more efficiently with the timing advanced and were better able
to utilize the chemically treated fuel. After thousands of
miles of road testing, we found no detrimental effects to
valves and no detonation problems on vehicles that had
Optimizers and advanced timing. In addition, there did not
seem to be any increase in exhaust emissions due to the timing
advance.
You will note on the fuel analysis reports that platinum
is found in the fuel exiting from the Optimizer, and that in
the F.I.A. test there is a suggestion also of what might be a
hydro-cracking effect due to the increase in aromatics.
We have observed some problems with the use of a return
line which was previously a part of the. Optimizer system.
Therefore, we have stopped using the return lines and have
found the results improved. Also added as a parameter during
all the testing (both programs) is a condensing unit which
cools the fuel prior to entering into the carburetor. You will
note the placement of the unit on the drawing of the installation
procedure. Because of the emission findings in these tests,
which are well within EPA guidelines, I do hope that when EPA
tests this device, vehicles without a catalytic converter will
also be used.
Test results verify that the "Optimizer System" does work
and is a marketable item. I must stress that much time and effort
has been put into this project, not to speak of the cost factor.
This company will only market a device that does work. We are at
that stage presently, and are looking to market this to fleets in
both gasoline and diesel. While we have not had independent
testing done on the diesel, our own tests appear to be even better
than on the gasoline engine. It should be noted that platinum is
also found in the diesel fuel treated by the Optimizer. We are
now considering a diesel testing program at an independent labor-
atory to verify our results.
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Hoping to hear from you soon and looking forward to
discussing the EPA testing of our product, I remain
Sincerely yours,
Dr. Leon I. Rosky
President
LIR:va
Enclosures
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57
\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY ATTACHMENT G
°
ANN ARBOR. MICHIGAN 48105
December 28, 1982 OFF)CE
AIR. NOISE AND RADIATION
Dr. Leon I. Rosky, President
Optimizer, Ltd.
220 Lynn Street
Flushing, MI 48433
Dear Dr. Rosky:
We received your letter of December 6 in which you applied for an EPA
evaluation of the Optimizer device as an emission and fuel economy
retrofit device.
Our Engineering Evaluation Group has made a preliminary review of your
application and has determined that there are several items that require
clarification or additional information prior to further processing of
your application. Our comments below address these items.
1. Section 2a - Marketing Identification. Six models of the
Optimizer are identified - two for light-duty vehicles and four
for heavy-duty vehicles. Our program for the evaluation of
emission and fuel economy devices does not include heavy-duty
vehicles. We will therefore assume that the application does
not apply to the 1200G, 2150G, 2200D, and 4200D model and that
the information and data supplied for these models was for back-
ground information purposes only. Devices for heavy-duty
vehicles are evaluated by DOT. The person to contact is:
Sam Powell, Chief
Heavy Duty Research Division
DOT - NHTSA
400 7th Street
Washington, DC 20590
(202) 426-2957
2. Section 2a. - Marketing Identification. Are the optimizer
models 1150G and 1200D presently manufactured and sold or are
they prototypes?
3. Section 3c. - Construction and Operation. Your application
described several variations in the construction of the device
and the components used. For the models 1150G and 1200D:
a. What is the catalyst material?
b. Does the Optimizer have a temperature sensor or limit
switch to prevent overheating. If so, what are the off /on
set points?
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58
c. What are the dimensions of the units?
d. What is the delay time of the relay?
e. These devices do not appear to incorporate a check valve,
pressure regulator, or fuel bypass line. Is this correct?
4. Section 3d. - Specific Claims.
a. From the information provided, it appears that you claim
that some benefits are achieved immediately with full
benefits achieved at 1000 miles. Is this correct?
b. To maintain the benefits attributable to the device, it
must remain in active use. The benefits will cease after
1000 to 2000 miles without the device. Is this correct?
c. You claim a minimum improvement in fuel economy of 5%.
d. What is the "... increase in performance of the vehicle."?
How is it measured?
5. Section 4b. - Installation.
a. Are the relay and condensor included with the device?
b. Are all necessary hoses, fittings, and wiring included with
the device?
c. Several versions of the instructions were provided with the
application. We assume the only applicable instructions
were those labeled "Installation Instructions - Model
#1150G and Model //1200D. Is this correct?
d. These instructions require advancing the timing 5 degrees
or until knock is heard. Under what conditions - idle or
at road load?
e. For those vehicles whose timing is advanced less than 5
degrees due to knock, do you expect to be able to advance
the timing the full 5 degrees after 1000 miles? Do you
recommend attempting to advance timing to the full 5
degrees after 1,000 miles?
6. Section 4c. - Operation. Do you anticipate any problems if the
vehicle is not running but the ignition key is left in the on
position?
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7. Section 4e. - Maintenance. Since the active catalyst material
is to be leached out of the substrate by the heated fuel, how
long is it before the device is ineffective (miles and gallons
of fuel)?
8. Section 5b. - Regulated Emissions and Fuel Economy.
a. Which model was tested by ATL in August and September? It
appears to have been a G-500 which incorporated a pressure
relief valve and flow return line.
b. Which model was tested by ATL in November?
c. Do you claim that these test results are representative of
the results to be expected from the model 1150G Optimizer?
d. How was the mileage accumulation conducted for these tests?
e. Why do you expect ambient conditions (other than tempera-
ture) or driving habits to alter the benefits of the
device? In what manner are the benefits changed?
f. You state that "... I do hope that when EPA tests this
device, vehicles without a catalytic converter will also be
used". I assume by this you mean vehicles on which the
manufacturer did not install a catalyst. Is this correct?
Why non-catalyst vehicles?
g. You state that the benefits of the device on a 4 cylinder
vehicle may be less. Typically how much less?
h. You gave the results of the road testing conducted by
Optimizer Ltd. on the model 1500G. For these tests:
(1) What was the difference between this model and the
1150G?
(2) What were the number of miles driven, both baseline
and with device for each vehicle?
(3) Briefly describe the test route, fuel measurement
methods and techniques for quality control.
The application covers both gasoline and diesel engines. Because these
fuels are different and the device acts on the fuel, it will be necessary
also test the model 1200D. We are prepared to work with you in
developing a test plan. We may be able to devise a simplified test plan
for the diesel model after the preceding questions on the gasoline model
are answered.
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We will be able to perform a detailed review of your application after
you have responded to the preceding items. In order that we may
efficiently process your application, I request that you respond to this
letter by January 21, 1983. If I can be of any additional assistance,
please contact me at (313) 668-4299
Sincerely,
> x , ....... -^ XT*.
Merrill W. Korth
Device Evaluation Coordinator
Test and Evaluation Branch
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ATTACHMENT H
January 18, 1983
. Mr. Merrill W. Korth
Device Evaluation Coordinator
Test and Evaluation Branch
Environmental Protection Agency
2565 Plymouth Road
Ann Arbor, Michigan 48105
Dear Mr. Korth:
Enclosed you will find our answers to the questions which
you submitted on December 28, 1982. We hope that they are
clear and make a thorough review of our application possible.
Item 1. As to the model numbers of the Optimizer referred to in
this question, the 2150G, 2200D and 4200D models are to
be used on heavy duty vehicles. This application,
according to what you are saying would not then apply to
the above models, but would definitely apply to the 1150G,
1200G and 1200D. Thank you very much for the reference to
Mr. Sam Powell, Chief, Heavy Duty Research Division of
DOT - NHTSA.
Item 2. The Optimizer model 1150G, 1200G and 1200D are presently
manufactured for sale and are not prototype units. The
units tested by Automotive Testing Laboratories, Inc. were
prototype units in that the exterior design of the unit is
different than that which is presently being manufactured.
The interior contents of the Optimizer, both those tested
at Automotive Testing Laboratories and those now being
manufactured, are similar, but certain refinements were
made to improve the heating capabilities in colder weather,
It should be noted that the identification of the original
prototype model evolved from G-500 to 1500G to the present
designation of 1150G. (Reference to any of these desig-
nations indicates one model only, the 1150G).
Optimizer Center, 220 Lynn Street, Flushing, Michigan 48433 313 659-2000
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62
- 2 -
Item 3
A.
Catalyst used is a substrate of alumina oxide impregnated
with platinum metal.
B. The temperature is controlled by a cartridge heater using
a Belco resistance wire. The "on" point is 150 degrees
and the "off" point is 170 degrees. There is no over-
heating seen due to the condenser, which cools the fuel
prior to entering the carburetor.
C. See drawing below.
n
T
> ,
7" 8-5/8"
9-3/4"
Circumference: 7-15/16"
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- 3 -
Item 3. (Con't):
D. The relay we are presently using can be used in a system
that draws up to appcoximately 20 amps of current, and will
cease to function if more than that power is called for.
The delay is part of the relay and works in conjuntion with
the power source of the car. As you will note on the wiring
diagram, the relay is connected to the ignition side of the
fuse box, thereby giving no power to the relay until after
full ignition.
E. You will note that there were two separate tests done at
Automotive Testing Laboratories. The first test incorporated
a pressure regulator, check valve and fuel by-pass line. The
second test had none of these three items. We found that we
could maintain better heat (which is crucial to the working
of the Optimizer) and more adequately utilize the platinum
effect upon the fuel within the combustion chamber by
eliminating those three items. It should be emphasized that
the units used in both the first and second tests were the
same but, between those two tests, we changed the model
numbers.
Item 4,
A.
B.
C.
D.
Our tests demonstrate that within the 1,000 mile accumulation
there is a constant increase in the curve showing improvement
in miles per gallon.
As noted in the application, immediately upon removing the
device, the same increase in miles per gallon will still be
realized on a decreasing curve until approximately 1,000 miles
have been accumulated.
As you will note, by virtue of the tests done at Automotive
Testing Laboratories, a minimum of 5% improvement was obtained,
In addition, the test results on different vehicles tested by
Optimizer display percentages of up to 20% improvement.
Optimizer has tested many units on different vehicles with
varied drivers. Subjectively, improved handling of the
vehicle and increased power were noted by the drivers.
Item 5.
A.
B.
Yes.
No.
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64
- 4 -
Item 5
(Con't):
C. Please include the Installation Instructions for Model 1200G
in this statement.
D. Instructions require advancing the timing a minimum of
5 degrees, or until knock is heard (within that 5 degrees
advance). This timing advance is at idle condition.
E. Our experience shows that due to the chemical change of the
gasoline, a 5 degree advance is possible initially. In
- those vehicles where knock is heard within the 5 degrees
advance, it is recommended that an attempt be made to
increase to the full 5 degree advance after the 1,000 mile
run-in with the device.
Item 6. No problems are anticipated if the vehicle is not running
but the ignition key is left in the "on" position other
than the draining of the battery. This would happen
whether there is or is not an Optimizer on the vehicle.
Item 7. At this point, our tests indicate the life of the catalyst
to be in excess of 150,000 miles (automobiles, gasoline and
diesel) and approximately 350,000 miles on gasoline and
diesel heavy duty trucks.
Item 8
A. Automotive Testing Laboratories in August, September and
November tested the same unit. In August and September,
& that unit was known as the G-500, but due to a change in
stock numbering procedures, the device used in November
B. was changed to Model 1150G. The August-September test
incorporated the pressure relief valve and the fuel return
line. The November test did not include these items.
C. The test results from all Optimizer units presently
manufactured are seen to be higher than previously noted.
This relates to a slightly different design within the
Optimizer having to do with the heating mechanism, which
allows for improved heat. Being that the rate of
dissolution of the platinum from the substrate is directly
proportional to the heat (within a specific range), we are
able to see a greater improvement in miles per gallon.
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65
- 5 -
Item 8. (Con1t);
D. Mileage accumulation at Automotive Testing Laboratories
was done on a test track using test track drivers.
E. Benefits of the device will not be changed assuming that
the same driver is driving the same vehicle under both
baseline and device conditions. In a situation where
baseline is driven by driver A and device testing would
be driven by driver B, then the results may vary in
accordance with the individual driving habits of each
driver. The same would be true of testing the vehicle
on a relatively flat expressway for baseline and a
mountainous terrain for device test.
F. This statement relates to cars that have a catalytic
converter installed by the manufacturer. We feel that
if all anti-pollution mechanisms on a car (for instance,
catalytic converters, EGR valve, and so forther) were
removed from the car and testing was done for emissions
just with the Optimizer, we may see a level of emissions
which falls within the EPA guidelines.
G. As you can see in the original application, the important
words in this statement are "may be less". Because we
hav.e not done adequate testing on 4 cylinder vehicles, and
because of the high number of miles per gallon obtained
by some of these vehicles, it is not known at this point
how the Optimizer will benefit this class of vehicles.
Preliminary results indicate a positive response in many
of these 4 cylinder vehicles within the same percentage
increase range of other vehicles.
H. 1} It should again be noted that the Optimizer models
G-500, 1500G and 1150G refer to the same unit, now
known solely by the designation of 1150G. Due to the
design of the G-500 (also known as the 1500G) unit, it
is considered a prototype as opposed to the 1150G,
which is a production model.
2) You will note that on the tests done at Automotive
Testing Laboratories in August and September, a
break-in period of 500 miles was used. This 500 mile
break-in was decided on after extensive testing by
Optimizer on a number of vehicles. You will further
note that between September and November (after further
extensive testing by Optimizer), it was seen that an
accumulation of 1,000 miles was necessary. The test
results related to on the application as having been
done by Optimizer were on vehicles driven prior to
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- 6 -
Item 8. (Con1t):
H. 2) August of 1982. In all cases, except for the two
vehicles which ran 2,400 miles each, the numbers on
this sheet relate to miles driven with Optimizer
attached after having approximately 250 mile accumu-
lations on each vehicle. Two vehicles on this list '
which show 2,400 miles (total miles driven) break
down to approximately 50% baseline and 50% with device.
-- 3) Test route included interstate highways in Michigan
(1-75 and 1-69), 1-75 to Florida (vehicles driven
2,400 miles), and Ohio Turnpike. It should be noted
that on each vehicle, the base test and the device
test were driven on the same highway between the same
two points in order to control the results obtained.
Furthermore, the measuring method was by tank fill-up
with the same individual filling the vehicles to the
same point with great care and taking sufficient time.
A calibrated barrett was used on most of these tests
in order to determine accurately the miles per gallon
obtained. These figures were compared with the miles
per-gallon obtained through the tank test and the results
obtained (tank test versus barrett) were very close
using this comparison method. In order to further
obtain quality control, a "bogey" vehicle was utilized.
The bogey was a vehicle similar to that used in the test
and driven closely to the test vehicle. The purpose of
the bogey was to see the effect of wind, temperature,
driving conditions, terrain and so forth on this vehicle
so that corrections could be made in the results of the
test vehicles in direct proportion to that of the bogey.
The bogey vehicle similarly was tested by tank and
barrett methods as described above.
Thank you very much for being so prompt in your response to
our original application presented. As per our conversation on
January 17, you stated that within two weeks of the time you
received our reply to your questions we would hear from you
regarding the further disposition of this application.
We are prepared to meet with you at any time in order to
discuss this application as it relates to your assessment of
the Optimizer.
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- 7 -
Thank you very much for your assistance in this matter,
We appreciate your efforts in our behalf.
Sincere
Dr. Leon Rosky
President
LIR:va
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY ATTACHMENT I
! ANN ARBOR. MICHIGAN 48105
February 7, 1983
OFFICE OF
AIR, NOISE AND RADIATION
Dr. Leon I. Rosky
Optimizer, Ltd.
220 Lynn Street
Flushing, MI 48433
Dear Dr. Rosky:
The purpose of this letter is to confirm the items discussed in our
telephone conversation of January 27 and clarify several remaining
issues. The items discussed and your responses are given in the
enclosure.
As a result of that discussion, we feel that the following changes to the
application were also implied.
1. Item 2a of the application is now to read "1200G - Gasoline
Units - passenger vehicles with large engines and heavy duty
trucks" instead of "1200G - Gasoline Units - Heavy Duty Trucks".
2. Since the models being evaluated are single bed catalyst, all
are the single chamber design shown in Figure 2; none are the
two chamber design shown in Figure 3.
3. If there is excessive current draw and the relay "ceases to
function" it must be replaced. There are no fuses or circuit
breakers to protect the relay.
The following questions were either unanswered or raised as a result of
that conversation, and therefore still require a reply.
1. In discussing paragraph No. 2 of the enclosure, you said that
there were some small differences in these units that enabled
some of these models to provide more heat. Which models? How
much more heat? Under what operating conditions and ambient
temperatures do these differences have an effect? What is the
fuel economy improvement for each of these models at these
ambient conditions?
2. In discussing paragraph No. 3 of the enclosure, you stated that
the catalyst loading was 250 grams of active material, of which
0.9% is platinum. What is the composition of the remaining
99.1% of the active material? Is there any inactive catalyst
substrate?
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69
3. In discussing paragraph No. 8 of the enclosure, you stated that
your own experience had shown a greater Improvement for the
device in city driving than in highway driving. Please provide
the results of these tests. Describe the driving cycle and test
procedures and provide a copy of these results.
You and I further discussed the need for diesel testing. Our position is
that since the device functions by enhancing the combustion process,
since the combustion processes are different for diesel and gasoline
engines, since the fuels are appreciably different, and since the
application covered both fuel applications, substantiating test data were
required for both gasoline and diesel vehicles. Further processing of
the application would therefore be suspended pending diesel testing by
Optimizer. In lieu of this, EPA agreed to permit Optimizer to withdraw
the diesel device from the application. You thereupon requested that the
application be modified by withdrawing the only diesel model, the 1200D,
from the application. Therefore, we shall now consider that the
application applies only to the gasoline models 1150G and 1200G. All
information regarding diesel versions of the device will now be
considered to have been supplied for background information purposes only.
In order that we may proceed with the processing of your application, I
request that you respond to this letter by February 25. If I can be of
any further assistance, please call me at (313) 668-4299.
Sincerely,
Merrill W. Korth
Device Evaluation Coordinator
Test and Evaluation Branch
Enclosure
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70
The following draft of a letter to Optimizer Ltd., was discussed with Dr.
Leon I. Rosky of Optimizer on January 27, 1983.
We received your letter of January 18 in which you responded to our
request for additional information on the "Optimizer" device.
Our Engineering Evaluation Group has reviewed your response and has
determined that there are still several items which require clarification
or additional information prior to further processing of your
application. Our comments below address the referenced items in your
letter. Our understanding of your responses to these questions follows
each item.
1. Item 1. You stated that the application "... would definitely
apply to the 1150G, 1200G, and 1200D." As we stated in our
letter "Our program for the evaluation of emission and fuel
^_ economy devices does not include heavy-duty vehicles. We will
therefore assume that the application does not apply to the
1200G..." which was identified in your application as being a
gasoline unit for heavy duty trucks. Therefore, our position
still is that the application does not apply to the model
1200G.
Optimizer: The model 1200G is still to be included in the evaluation.
This model is for heavy duty gasoline trucks and some cars.
2. Item 2. You stated that the 1150G, G-500, and 1500G models
were essentially identical. You also inferred that the test
results for any one of these models is directly applicable to
the other models, except possibly in cold weather, if they are
installed in a similar manner, i.e., presence or absence of
check valves, flow return line, or pressure relief valve. Is
this correct?
Optimizer: Yes, these were different model identifications used
throughout the product development process. Also the model
1200D is the same inside the unit. The only difference in
this model is the location of the fittings.
3. Item 3a. From your response it appears all models being
evaluated are a single bed catalyst. Is this correct? What
is the catalyst loading (amount of active material on
substrate)?
Optimizer: Yes. The catalyst loading (active material) is 250 grams of
platinum.
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4.
This information was subsequently corrected during a
telephone call on February 4, 1983. EPA noted that there
appeared to be an error since, at current prices for
platinum, it was unlikely the device contained 250 grams of
platinum. Optimizer corrected the previous statement. The
platinum loading on the approximately 250 grams of active
material is 0.9% platinum by weight.
Item 3d. You state that the relay "... will cease to function
if more than that power [20 amps] is called for." Please
explain what you mean by the terminology "cease to function".
Optimizer: Cease to function means the relay will burn out.
5. Item 3d. You stated that "the delay is part of the relay and
works in conjunction with the power source of the car". Since
you also stated on page 11 of the patent that "the time delay
(reference number) 40 is a conventional relay switch ..." and
gave no delay time, we assume that there is in fact no time
delay and that the heating element is energized as soon as the
ignition key returns from the start position to the run
position. Is this correct?
Optimizer: Yes.
6. Item 3e. You stated that "We found that we could maintain
better heat (which is crucial to the working of the Optimizer)
and more adequately utilize the platinum effect upon the fuel
within combustion chamber by eliminating those three items"
[check valve, return line, and relief valve]. We assume
therefore that you don't consider the August/September testing
at ATL to be representative of the device now being evaluated
since these three components were used in that test program.
Is this correct?
Optimizer: Yes. The August/September tests at ATL are not
representative. Optimizer feels the tests indicate a lower
bound of improvement. That is, the results would have been
better with the better heat employed in the November tests at
ATL.
7. Item 4a. Your reply did not fully answer our question
regarding the claimed effectiveness of your device. Is there
an immediate benefit attributable to the device? How large is
this benefit as a percentage of the full benefit? Are full
benefits seen at 1000 miles?
Optimizer: Yes, there is an immediate benefit but the size of this
benefit is unknown. Full benefits are seen at 1000 miles.
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72
8. Item 4c. You stated that the ATI tests showed at least a 5%
improvement in fuel economy. However, neither test program
demonstrated that city fuel economy was likely to improve.
Optimizer: Yes, the ATL tests do not demonstrate that city fuel economy
was likely to improve. However, Optimizer has actually found
the reverse to be true. That is, the improvement in city fuel
economy was greater than the improvement in highway fuel
economy. The statements regarding improved handling and
increased power were subjective driver comments and no attempt
was made to evaluate these comments. Optimizer has no
explanation as to how the device would improve handling.
9. Item 5e. Your response regarding the timing adjustments did
not state that the readjustment of the timing at 1000 miles
was to be incorporated in the installation instructions.
However, we assume you wish to modify item number 8 of the
installation instructions for the Model 1150G to incorporate
this adjustment. Therefore, instruction 8 is to be modified
by adding your comment from 5e. "In those vehicles where
knock is heard within the 5 degrees advance, it is recommended
that an attempt be made to increase the full 5 degree advance
after the 1,000 mile run-in with the device."
Optimizer: Yes
10. Item 8d. Please provide a more detailed description of the
mileage accumulation procedure, e.g., type of driving cycle,
average speed or speeds, stop-and-go or constant speed.
Optimizer: The mileage accumulation procedure was selected by ATL to
comply with EPA requirements. Optimizer thought it probably
was 55 mph cruise with breaks at two hour intervals.
11. Item 8H(1). You stated that the Optimizer model 1500G used
for the road tests was identical to the model 1150G. However,
you did not indicate if the vehicles which were road tested
did or did not have the auxiliary components installed (the
check valve, flow return valve, and pressure relief valve).
Optimizer: The road test data given in application was for vehicles
without the auxilary components installed.
12. Item 8H(2). Your answer was not clear. Do you mean that the
1980 Olds Cutlass accumulated about 250 break-in miles with
the device and then 969.5 test miles with the device? What
was the baseline distance?
Optimizer: Yes. The baseline distance was the same as the device test
distance. For the 1980 Olds the baseline mileage was 969.5
miles.
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13. Item 8H(3). Please describe each of the bogey vehicles and
the test vehicles to which each was matched Was the same
bogey test vehicle used for both baseline and device tests?
How were bogey results used to correct the baseline and device
test results of the test vehicles. Also, please briefly
describe the driving conditions, e.g., how the 55 mph cruise
condition was maintained.
Optimizer: The bogey vehicle was the same make and year as the test
vehicle. For a particular test vehicle, the same bogey
vehicle was used for the baseline and device tests. The
change noted for the device tests were corrected by the
percentage change in fuel consumption for the bogey vehicle
for the two test sequences. For the road tests, the drivers
tried to maintain a 55 mph cruise. The bogey vehicle was
positioned 1000 yards ahead of the test vehicle. The driver
of the Optimizer test vehicle then attempted to match the
driving pattern of the bogey vehicle.
As I stated before, it will be necessary for you to also test the diesel
version of your device. Test Plan/Test Sequence C-l with a 1000 mile
accumulation period would seem most appropriate. However, C-4 would be
equally acceptable to us and should cost less although it would not
permit you to evaluate cold start emissions or fuel economy.
Testing will require at least two vehicles and possibly more. If the
change in fuel economy is only 5%, with normal test-to-test variability,
two vehicles may be insufficient to demonstrate a significant change. In
order to minimize the potential costs, you may wish to test vehicles
sequentially rather than as a group. On this basis, you could initially
test two or three vehicles. If the test results are not conclusive, you
could schedule another complete test sequence on additional vehicles, one
at a time.
Optimizer: Optimizer had found that the diesel vehicle tests give results
similar to gasoline vehicle tests. Optimizer had found good
correlation between tests of the device on the two types of
vehicles. Therefore they make the same claims for both the
diesel and gasoline vehicles.
In response to your allusion to EPA testing of the Optimizer, further
consideration of confirmatory testing at our laboratory must await
completion of the application process.
We will proceed with the review of your application when we have received
your response to the preceding items.
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T' '*
74
ATTACHMENT J
February 8, 1983
Mr. Merrill W. Korth
Environmental Protection Agency
2565 Plymouth Road
Ann Arbor, Michigan 48105
Dear Mr. Korth:
Enclosed are the following:
1. Article from "New Scientist" magazine.
2. Article from "Platinum Metals Review".
3. Graph of temperature and platinum breakoff
in gasoline. The breakoff at the same temp-
erature always falls on the curve. A similar
curve is available on diesel.
4. Annual payback for large vehicles in dollars
and months .
5. Optimizer limited warranty.
Furthermore, we can't provide more articles because there
isn't very much information available on platinum breakoff in
gasoline or diesel in the combustion process at the temperatures
we are using. The results on our testing are constant.
Thanks again. I hope to hear from you by February 11. It
appears that the evaluation must be positive due to the informa-
tion we have provided and the testing done.
Sincerely,
LIR:va
Enclosures
Dr. Leon Rosky
President
Optimizer Center, 220 Lynn Street, Flushing, Michigan 48433 313 659-2000
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ATTACHMENT K'
February 18, 1983
Environmental Protection Agency
Motor Vehicle Emission Laboratory
2565 Plymouth Road
Ann Arbor, Michigan 48105
Attention: Mr. Merrill W. Korth
Device Evaluation Coordinator
Emission Control Technology Division
Dear Mr. Korth:
This letter is in answer to your communication of February 7,
1983. We will attempt to answer your questions as concisely as
possibly. As per our conversation of February 16, we would like
to request a meeting with you so that any further clarification
can be made in person and through direct discussion.
In reference to your letter, our answers will be given
according to your numbering sequence.
I. In reference to Model 1200G, the application should read
"Gasoline Unit - Passenger Vehicles and Light Duty Trucks".
The Model 2200G will be designated "Gasoline Unit - Heavy
Duty Gasoline Trucks. Model 1150G and 1200G are inter-
changeable depending on flow rate of vehicle and heat
required.
2. All the models being evaluated are single bed catalyst. Our
patent pending covers both single and double chamber units.
3. There are no fuses or circuit breakers to protect the relay
if there is excessive current draw. The relay itself acts
as a circuit breaker.
The following answers are to your questions which were raised
as a result of one of our prior conversations.
1. The changes in the units that are presently being manufactured
for sales involve the heating mechanism only. All the prior
units had a shorter rod length. In order to obtain greater
Optimizer Center, 220 Lynn Street, Flushing, Michigan 48433 313 659-2000
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76
1. (con't)
dispersion of the heat without changing the resistance of the
wire and the temperature limits (which were described previously
in our application), we have lengthened the heating rod, there-
by obtaining a greater surface area. This allows us more
diffuse heat throughout the unit. All models are now using the
longer heating element. We notice that at ambient temperatures
below 35 degrees we see quicker, more uniform heating of the
catalyst bed along with'the fuel flowing through it. There is
a direct relationship between the temperature of the fuel, the
amount of platinum in the fuel exiting the Optimizer, and fuel
economy.
2. Platinum metal (.9%) is coated on an inert aluminum oxide
support material similar to automotive emission catalyst.
Total catalyst weight in a single unit Optimizer is 250 grams.
Residual trace metals present in parts per million are iron,
zinc, copper, antimony and tin. Also present in much smaller
traces are calcium, potassium and sodium. Present in parts
per billion are bismuth, lead and arsenic.
3. Optimizer has tested mostly on the highway due to the desire
of keeping conditions as stable and results as accurate as
possible.
City driving cycles have not been tested as such. When the
laboratory results of platinum found in the fuel were
correlated with fuel economy on the highway, it was noticed
that as the heat allowed a greater breakoff of platinum, the
fuel economy improvement results were improved. Due to the
principle of better heat yielding more platinum breakoff, it
stands to reason that with lower speeds, less wind resistance,
better heating and more idling, the city cycle would allow
better results. Since it was difficult to count on the testing
conditions in the city always being the same, no city cycle
tests were run.
The following relates to your items numbered 1 through 13
contained in your letter of February 7.
1. Refer to the first item of this letter, which clarifies the
questions about model 1200G.
2. Model 1150G, G500 and 1500G are the same unit.
3. This has previously been answered in this letter.
4. Yes.
5. Yes.
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77
6. August/September testing at A.T.L. is still valid. We learned
that 1,000 miles accumulation with the device is necessary
for Optimizer benefits to be seen. We stopped using the
return line due to loss of heat within the system. We were
also concerned about over-heating in the warm weather. Now
that the condenser unit (to prevent vapor lock) and a longer
heating element (to improve dispersion of heat within the
Optimizer) are used, the system is viable.
We have three (3) patent applications pending on the Optimizer.
One of them incorporates the use of the return line, check
valve and relief valves. We have tested the Optimizer using
only a return line and find no appreciable difference in fuel
economy that can be attributed to the return line itself.
The check valves are only for the purpose of not allowing
fuel to flow backward through the return line, depriving the
carburetor of fuel. The relief valve is not a pressure regu-
lator, but regulates the flow back through the return line,
which has some effect on the pressure to the carburetor.
Timing adjustment is made in that system also. The results of
the August/September testing are indicative of the device even
as installed today.
As stated previously, we feel the results of the August/
September tests would have been improved with the use of the
condenser and a longer heating element with or without the
return line system.
7. Yes.
8. Answered previously in this letter, and the Optimizer answer
is also applicable.
9. Yes.
10. Yes.
11. Some of the vehicles did have the return line, check vales and
relief valve. We are appending a list with a check mark to
delineate those that were tested with the three items in the
system.
12. Yes.
13. Optimizer's answer is correct except that the bogey vehicle was
positioned 100 yards (not 1,000 yards) ahead of the test vehicles,
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78
In summary, we are sure that EPA recognizes that change is
constant throughout the research and development process. There
is no doubt that we have had certain amount of change also,
through the testing procedures at Automotive Testing Laboratories.
We have not, and we stress the word not, changed any part of the
process having to do with the theory of operation of the Optimizer.
We have refined this process by modifying the heating element. We
now have two viable options for installation, namely both with and
without the return line system. The tests that we did at Automotive
Testing Laboratories did not show the full benefit of the Optimizer
due to- the lack of adequate heat dispersion within the unit. We
are sure that, had the heating mechanism been of the type we are
presently using, the results on those tests (A.T.L. - August/
September and November) would have been better.
It is our belief that if any further questions come up, we
should meet and discuss them in order to clearly understand one
another. We have spoken with many individuals in the automotive
engineering field and they appear to be as excited as we are with
the prospect of low temperature platinum breakoff into the fuel
system (gas and diesel) . Many of the questions that may come up
from here on should be answered by the confirmatory tests which
you at EPA should elect to do. Hoping to hear from you very soon,
we remain,
Sincerely,
OPTIMIZED, LTD
Dr. Leon I. Rosky
President
LIR:va
Enclosures
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ATTACHMENT L
March 14, 1983
Environmental Protection Agency
2565 Plymouth Road
Ann Arbor, Michigan 48105
Attention: Mr. Ralph Stalhmand
Director of Test Evaluation
Dear Mr. Stalhmand:
This letter is being written as a result of a telephone
conversation between Mr. John White of EPA and myself on
Friday, March 11. Mr. White notified me that EPA had decided
not to test the Optimizer. After he was questioned as to the
reasons for this evaluation, Mr. White stated that the issues
of NOX and timing advance were questionable. I am not going
to relate to those specific items at this time, but they have
been addressed in the past through Tony Barth and Merrill Korth.
It is our feeling that there was a complete disregard for the
testing done at Automotive Testing Laboratories and at Optimizer,
as demonstrated by Mr. Whites call.
As I stated on the telephone, I will be out of the country
for at least 30 days, and upon my return would like to have a
meeting with EPA. The results of our meeting of March 4, 1983
with Tony Barth and Merrill Korth gave us the impression that
the evaluation would be positive. It is very difficult to under-
stand what happened in the interim.
There are many questions that we have relative to Automotive
Testing Laboratory's testing procedures. Tony Barth was supposed
to clarify this and notify us of his findings. We never received
his communication. That will have to be clarified at our meeting.
We began our discussions with EPA in June of 1982. Through-
out that time, we have had good rapport with Merrill Korth. Many
questions have been asked of us, and we have responded fully and
promptly. We would like to maintain that type of relationship.
Our impressions are that the feeling is mutual as far as EPA is
concerned.
Optimizer Center, 220 Lynn Street, Flushing, Michigan 48433 313 659-2000
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80
- 2 -
I have just received notification from EPA as to a change
in the policy of payment for confirmatory testing in the EPA
laboratories. It would seem incongruous that after beginning
this process in June of 1982, having submitted the application
in December of 1982, that we would be told at this date of a
change in payment policies.
As you can tell from this letter, we are quite upset at
the evaluation by Mr. White. If it were not that we know the
results of our testing and what the Optimizer can do, we would
not be in the present position of writing this letter.
We thank you very much and hope to hear from you very
soon.
Sincerely,
s~\
OPTIMIZER, LTD.
Leon I. Rosky
President
cc: Senator Donald Riegle
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ATTACHMENT M 81
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
ANN ARBOR. MICHIGAN 48105
March 28, 1983 OFRCE QF
AIR. NOISE AND RADIATION
Dr. Leon I. Rosky, President
Optimizer, Ltd.
220 Lynn Street
Flushing, MI 48433
Dear Dr. Rosky:
We received your letter of March 14 in which you raised several issues
that I will attempt to answer and clarify.
The purpose of the March 4 meeting was to give Optimizer and EPA
personnel the opportunity to discuss any unresolved questions relating to
the Optimizer device. Mr. Barth stated that he expected to shortly clear
up his minor concerns about the data (principally, which data should be
incorporated in his analysis of the data) and expected to have an
analysis done by March 8. He anticipated that EPA could make a decision
on confirmatory testing by March 10. The analysis of the ATL data showed
that there was a small improvement in fuel economy and a large increase
in NOx. We feel that this is consistent with the effects to be
anticipated when timing is advanced per the device installation
instructions. Since modifications to a vehicle which cause emissions to
rise can be considered tampering, we have no need to perform confirmatory
testing and will, therefore, complete the evaluation using the
information now available. During your telephone conversation with Mr.
White, he informed you of our course of action in advance of a formal
notification.
Your statements about the effects of the device on emissions and fuel
economy were considered in performing our analysis and reaching a
conclusion. Contrary to the statement in your letter, the testing at ATL
and Optimizer was a crucial element used in making our decision.
Also, at the meeting we did not state that our evaluation would be
positive. We stated that we were impressed by the magnitude and apparent
quality of the testing done by Optimizer, but that any conclusions about
the device or decision to test at EPA would be based on the analysis of
data which was yet to be performed.
Shortly after our meeting with you, Mr. Barth further discussed the ATL
testing with ATL. This discussion satisfactorily clarified that the
tests to be considered were those submitted with your application. He
also clarified a few minor points about the test procedures and
nomenclature which we can discuss at the meeting you requested.
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sft2
You also questioned the letter sent to you stating that there was a
change in policy regarding payment for confirmatory testing performed at
EPA. We have sent similar notices to all people we sent 511 packages to
in the recent past. We informed you of this change in policy at our
meeting. We also said that, although we did not anticipate applying it
to applicants, like yourselves, who were well along in the evaluation
process, we could not guarantee it.
As Mr. White Cold you, we are proceeding with the evaluation. However,
since completing the process will take several weeks, there is ample time
for you to meet with us in early April prior to the report being
published. Please notify me as soon as you return so that the meeting
you requested can be arranged soon. If I can be of any further
assistance, please contact me at (313) 668-4299.
Sincerely,
Merrill W. Korth
Device Evaluation Coordinator
Test and Evaluation Branch
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83
ATTACHMENT N
Optimizecmi
May 12, 1983
Environmental Protection Agency
Motor Vehicle Emission Laboratory
2565 Plymouth Road
Ann Arbor, Michigan 48105
Attention: Mr. Merrill W. Korth
Device Evaluation Coordinator
Dear Mr. Korth:
As I was out of the country until recently, no response to your letter
dated March 28 was made. In preparation for our meeting of May 17, the
following should be considered and discussed.
1. Enclosed you will find copies of two different test plans submitted
to EPA at our meeting of July 19, 1982. During this meeting,
Optimizer, Ltd requested that a timing advance sequence be done in
order to establish the effect of timing advance alone on the vehicle.
EPA subsequently rejected this request and stated they wanted the
whole system tested and then removal of the device as a second sequence.
Optimizer, Ltd made it clear at that time that there was a "run-in" and
"wear-off" period, and that there would be an effect from the Optimizer
still present after the device was removed (see pages "A", "B" and "C"
attached).
2. Fuel economy obtained in the two programs (October 7, 1982 and
December 1, 1982) is within the range as written in the guidelines
for the EPA 511 Program for Retrofit Devices and Fuel Additives.
3. In the first program, vehicle #8982 has a baseline on NOX above EPA
specifications, and therefore should not have been tested (Figure 1).
Vehicle #7957 (Figure 2), in both city and highway cycles, was slightly
above EPA specifications with the Optimizer, but only slightly below
specifications on baseline in city and above specifications in highway
on baseline.
In the second program, vehicle #0267 (Figure 3) was below EPA speci-
fications for NOX for both city and highway baseline sequences, and
remained below except on the last sequence, where spark plug wires
failed (the NOX ei3vated dramatically). It should be noted that in all
Optimizer Center, 220 Lynn Street. Flushing, Michigan 48433 313 659-2000
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84
3. (Continued)
sequences, NOX was at or below EPA specifications. Furthermore, on the
highway sequence with the Optimizer, parameters adjusted, no miles, the
NOX decreased over the previous sequence of Optimizer alone. Vehicle
#2430 (Figure 4) was above specifications in baseline on both city and
highway, and should not have been used.
We are not able to understand how the Optimizer is being faulted for
elevations in NOX when only a .024 increase has been observed in the
worst case (with Optimizer only, Figure 3), with the only vehicle that
met all NOX specifications on baseline. In fact, with parameter adjust-
ment, NOX was decreased in the highway cycle and the vehicle with the
Optimizer met all emission specifications. Enclosed are copies of the
graphs obtained from Automotive Testing Laboratories demonstrating these
points.
4. Through many tests on the Optimizer device, we have found that platinum
coats the combustion surfaces in an engine, thereby improving fuel
economy. We have searched through the literature very meticulously and
have found very little information relative to any testing done anywhere
utilizing low temperature catalysis of fuel. We have sent to you an
article from Brookhaven Research Center and another about the Ricardo
catalytic engine, which shows some related work in this area. We realize
that this is a new concept, but it would appear the EPA must look at the
facts of test results in relation to the process that is used in order to
evaluate any device. In our process, as we have previously explained to
you , the device can be removed and a further increase in fuel economy
will still be obtained until the platinum effect has disappeared from the
combustion surfaces of the engine. Therefore, the increase in fuel economy
of 9.8% to 10.4% city and 8.3% to 9.7% highway (Figure 5) are solely
attributable to the Optimizer, not to any parameter change based again on
data furnished to you showing this effect.
5. The second program was done to show the effect of the device on fuel economy
both with and without timing advance. It proves that timing change is
minimal by itself (Figure 6)-. We use timing advances because it is our
contention and is documented in the literature that a timing advance helps
to utilize any improvement in combustion. Timing advance with Optimizer
provides a synergistic effect so that fuel economy is further enhanced
beyond that of Optimizer alone.
We believe that in past correspondence between Optimizer, Ltd and EPA, all
the above points were clarified. As we alluded to above, most probably the
newness of thi.~ concept and some modifications made between the first and second
program have complicated your evaluation. We hope that with this clarification,
it becomes clear that the fuel improvement is not due to the timing and that the
NOX increase is not due to the Optimizer. Your use of the word "tampering" does
not apply to our device for the reasons stated above.
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85
Furthermore, as was stated at our last meeting with you, certain
inconsistancies in the testing results and procedures at Automotive Testing
Laboratories and the use of vehicles which were out of EPA specifications
for emissions (in fact, EPA recalled some cars of this year, make and model
for being above specifications on NOX subsequent to our testing), bring
many questions to mind, and at an appropriate time will be investigated.
We thank you very much for your willingness to discuss this evaluation.
We are asking that in light of the expense incurred by us, and the vase amount
of testing done both through independent laboratories and Optimizer, Ltd that
the judging be done with an understanding of our device. There is no doubt in
our minds that fuel economy is obtained without an increase of emissions and that
this device will benefit the consumer. In that light, EPA has an obligation to
test and prove the efficiency of the Optimizer.
Sincerely,
OPTIMIZED/LTD.
C
Dr. Leon I. Rosky
President
LIR:va
Enclosures
Senator Donald Reigle
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-1.
) l
86
ATTACHMENT 0
May 20, 1983
Environmental Protection Agency
Motor Vehicle Emission Lab.
2565 Plymouth Road
Ann Arbor, Michigan 48105
Attention: Mr. Merrill W. Korth
Device Evaluation Coordinator
Dear Mr. Korth:
We wish to thank you for the time spent with us in discussing EPA's
evaluation of the Optimizer. We would also like to thank both you and
Tony Barth for your candid remarks, but many questions remain which, in
summary of our meeting, we want to put in writing at this time.
It is our contention for the following reasons that your evaluation
of the Optimizer is erroneous for the device as manufactured today.
1. In the first program of testing (vehicle #8982 and vehicle #7957), a
return line, check valves and timing advance were used. The check
valve and return line were not used in the second program (vehicles
#2430 and #0267) , and are not a part of the present Optimizer system.
Therefore, utilization of these two vehicles is seen as background
information and is not relevant to the Optimizer in its present form '
and as it will be marketed. In fact, it is not appropriate to write
an evaluation concerning a product which will never be marketed.
2. You have concluded without factual basis relative to the Optimizer
process that a timing advance will yield an increase in oxides of
nitrogen and thereby may make use of that parameter unfavorable for
the Optimizer device. If EPA objective testing per mutually acceptable
conditions factually demonstrates a relationship between timing advance
(with Optimizer) and an increase in NOX, then Optimizer (which has
demonstrated an increase in economy without timing advance) can be
marketed without a timing advance. It should be noted in evaluating
the second program (vehicles #2430 and #0267), that on the sequence
marked Optimizer after 1,000 miles at factory specifications, the NOX
does not increase over the acceptable 10% elevation allowed. Please
note that at our meeting it was stated by EPA that whenever you advance
Optimizer Center. 220 Lynn Street. Flushing, Michigan 48433 313 659-2000
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87
E.P.A. - 2 - May 20, 1983
the timing, the NOX will increase. On vehicle #0267 on highway baseline,
NOX was reported as .882 and with the Optimizer at factory specifications,
it increased to 1.024 and with.the timing advance, it decreased to .906.
This demonstrates an inconsistancy in your statement. In vehicle #2430
there was a continued increase from baseline to Optimizer at factory
specifications (NOX within the 10% error range) to Optimizer with timing
advance. However, in vehicle #0267, NOX decreased between Optimizer at
factory specifications and Optimizer with timing advance (NOX again within
the 10% error range). This proves that timing does not in and of itself,
or timing with the Optimizer, always cause NOX elevations.
3. On the units used in the second program (vehicles #2430 and #0267) a
condensing unit was used which actually is not the same as that which
we are using at the present time. The present unit is more efficient and
cools the fuel to levels as low as the temperature prior to entering the
device.
4. As we stated at the meeting, new information was supplied to us that
differed from that which we had previously received from EPA. I now
refer to information (obtained in July of 1982) as given to us by your
office relative to emissions which show the standards according to vehicle
year of manufacture for all pollutants into the air from vehicle exhaust.
As waspreviously stated, EPA made.it clear in discussions and in print
that we would be judged on the results of emissions according to the EPA
guidelines. It wasn't until our meeting of May 17, 1983 that we were made
aware that we are being judged on the percentage increase over baseline.
Neither did EPA in the meetings we had prior to testing, or in their
literature supplied to us, nor did ATL in our discussions with them as an
approved EPA laboratory, state that we would be judged in this manner.
We have evidence to show that even OEM manufacturers are not evaluated in
the manner described above. We wil-1 not accept being singled out and
evaluated by means not accepted within the automotive industry.
5. Referring to your handout entitled "Potential Tampering Liability Associated
with Fuel Economy Retrofit Devices" (copy enclosed and pertinent statements
underlined), paragraph 6 says that any devices must meet applicable emissions
standards. The Optimizer does meet those standards, and we should be judged
accordingly. This is further evidence that your evaluation at this time
is not correct and would be damaging and arbitrary utilizing irrelevant
information.
In light of the above statements, we are requesting the following:
A. We intend to market a device different from that tested. Therefore, most
of the information that you presently have at your disposal must be used
as background information only.
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88
E.P.A.
- 3 -
May 20, 1983
B. We wish to amend the July 1982 application to conform to the results of
expensive testing over six to nine months done at an EPA approved
laboratory and with EPA's help and guidance so as to reflect the accurate
results without the need for new testing.
C. We request an accurate report of the documented testing from this EPA
approved and recommended laboratory:
1. In that fuel economy is seen with the use of the Optimizer.
2. That some increase in NOX may be demonstrated with a timing advance.
3*r That without a timing advance, no increase in NOX is seen in
accordance with accepted EPA testing standards and procedure (_+ 10%)
4. That in no case did the Optimizer show an increase in NOX over
standards.
We at Optimizer wish to apologize for our part in the confusion caused
by ATL, EPA and Optimizer jointly during the testing phase of this project.
As we told you at the meeting, we are convinced that the product by itself
with no parameter changes will stand up to the test of both fuel economy
improvement and emissions scrutiny. A negative evaluation based on
insufficient data is not fair to Optimizer and in fact could be detrimental.
We do not believe that a subsequent retraction is ever as strong and as well
understood by the public as the initial rejection. We reaffirm our feeling
that we are not interested in sales based on a device which does not perform
a meaningful service for the consumer. We do not mean to attempt to "pull
the wool over the public's eyes", but at the same time, do not wish to be
judged either prematurely or with insufficient data.
Thanks again for all of your courtesies, and if there are any
questions, please feel free to contact us.
We remain,
Very truly yours,
OPTIMIZER, LTD.
Dr. Leon I. Rosky
President
LIR:va
cc: Senator Donald Riegle
Enclosure
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89
Potential Tampering Liability Associated with Fuel Economy Retrofit
Devices
Section 203 (a)(3)(A) of the Clean Air Act (Act) prohibits any person
from removing or rendering inoperative any emission control device or
element of design installed on or in a motor vehicle or motor vehicle
engine prior to its sale and delivery to an ultimate purchaser and
prohibits a dealer or manufacturer from knowingly removing or rendering
inoperative any such device or element of design after such sale and
delivery. The maximum civil penalty for a violation of this section is
$10,000.
Section 203 (a)(3)(B) of the Act prohibits fleet operators and
persons engaged in the business of .servicing, repairing, selling,
leasing, or trading motor vehicles or motor vehicle engines from
knowingly removing or rendering inoperative any emission control device
or element or design installed on or in a motor vehicle or motor vehicle
engine. The maximum civil penalty for a violation of this section is
$2,500,
Installing a fuel economy device or system may render inoperative a
device or element of design of an emisson control system, and
thereafter, could be considered tampering under section 203 (a) (-3) of
the Act.
The Act does not prohibit individuals, provided they do not fall into
one of the above mentioned regulated categories, from tampering with the
emission control devices on in-us« vehicles. Applicable state and local
laws, however, may prohibit individuals from tampering with, registering,
selling, or operating a tampered vehicle.
It is EPA's enforcement policy not to initiate enforcement
proceedings against a regulated party who installs a retrofit device if
that person has a reasonable basis for knowing that the use of chat
device will not adversely affect emission performance. This policy is
set out in Mobile Source Enforcement Memorandum No. LA.
There are two different methods for establishing a reasonable basis
for knowing that emissions are aot adversely affected by the installation
of a retrofit device: 1) Che installer knows of, or the manufacturer of
the device represents in writing, that Federal Test Procedures (TIP)
emission tests have been performed as prescribed in 40 CPR 86 showing
that the device does not cause similar vehicles to fail to aeet
applicable emission standards for their useful life; or 2) a Federal,
State or local environmental control agency expressly represents that a
reasonable basis exists. Such an agency determination is limited co the
geographic area over which the Agency has jurisdiction. The results of
the SPA sponsored vehicle emission testing which is done under the
authority of Section 511 of the Motor Vehicle Information and Cost
Savings Act can be applied to similar vehicles throughout the country.
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90
If the results of EPA sponsored emission'testing of a retrofit device
show that emissions increase, EPA will publish a Federal Register Notice
explaining the legal implications of those findings on persons engaged in
the business of servicing, repairing, selling, leasing, or trading motor
vehicles, fleet operators, new car dealers and individuals. The Notice
will alert the regulated parties that the installation of such a device
by them may be deemed to be a violation of section 203 (a) (3) of the Act.
The results of an FTP test are valid only for similar vehicles.
Therefore, the test fleet should be diverse and large enough to provide
an adequate data base from which conclusions can be drawn with reasonable
confidence. When appropriate, however, analyses based upon engineering
judgment can be used to determine the applicability of FTP test results
to other vehicles and the devices' effect on Che durability of the
emission control systems.
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DOr*Al_D W. R IEGLE. JR.
MICHIGAN
91
ATTACHMENT P
WASHINGTON. D.C. 20510
June 9, 1983
The Honorable William D. Ruckelshaus
Administrator
Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Dear Bill:
I would like to acquaint you with a situation I find most disturbing.
A Michigan based company, "Optimizer, Ltd.", has developed a device
with the potential to reduce fuel consumption in internal combustion engines.
Prior to marketing this device, Optimizer, Ltd. voluntarily contacted EPA's
Motor Vehicle Emission Laboratory in Ann Arbor, Michigan to obtain a product
evaluation. In accordance with EPA application procedures and policy
guidelines, Optimzer, Ltd. supplemented company collected test data with
tests conducted at an EPA approved independent laboratory. Furthermore,
Optimizer, Ltd.'s staff proceeded with EPA recommended testing procedures
even though they felt that the procedures they had originally suggested
would provide a more accurate assessment. These testing modifications were
agreed to by Optimizer, Ltd. because of the staff's confidence that even
these preliminary tests would result in positive EPA findings and subsequent
federally funded testing. It now appears, however, that EPA is preparing
to publish a negative evaluation based upon testing results which appear to
be both inconsistent and subject to a significant degree of technical
interpretation. In addition, since Optimizer, Ltd. has made a number of
technical improvements to their device subsequent to last summer's
testing, a portion of the data used in the EPA evaluation appears inappropriate
and out of date.
I feel that publishing any assessments of the Optimizer's performance
based upon the testing conducted last summer by the independent laboratory
would be premature. A Federal Register notice conveying a negative
evaluation based upon questionable test results may well destroy the future
market potential of what could be a valuable device. I would like to ask
that the publishing of any EPA assessments of the Optimizer be delayed
until a meeting with representatives of Optimizer, Ltd., your staff and
other interested parties can be arranged.
I am also requesting that EPA fund additional testing of the Optimizer
in order to resolve any outstanding technical questions. I am aware that
recently promulgated EPA regulations preclude federal funding for device
testing, but I feel that the Optimizer, Ltd. group warrants special
consideration. The basis for my request is twofold. First, Optimizer, Ltd.
has been working with EPA staff in good faith since May 1982 under the
assumption that federal testing would be forthcoming upon receipt of a
-------
The Honorable William D. Ruckelshaus . 92
Page Two
positive assessment. Secondly, Optimizer, Ltd. has spent over $100,000 of
company funds to date on device testing. This amount is far in excess of
that spent by other developers of similar products who have subsequently
received EPA funding. I have enclosed a recent article highlighting a
case in which EPA funding was awarded for testing a similar device with
little prior testing. Consequently, I do not think that this request is
without precedence.
In closing, it is my hope that every effort will be made to give a
fair product assessment to this small business venture which would most
probably result in new jobs and economic growth within the battered
Michigan economy.
Your attention to this matter is greatly appreciated.
Sincerely,
DWR/jev
Enclosure
cc Mr. Merrill W. Korth, EPA Ann Arbor
Dr. Leon Rosky, Optimizer, Ltd.
-------
December 20, 1982
<0 Enllie conlenli copyright, 1962. by Cnlfl Automotive Group. Inc. All rlohli (nerved.
ncproducilon 01 usi ol idilorlil content In my manner without peimlislon li tlilclly prohibited.
58th year$40 per year, $1.00 pof cop\
EPA would do the job for almost nothing
U. S. to spend $175,000 to test politico-backed fuel device
Ity Jake Kclderninn
W.ililniinn Sl«fl Wrlttr
WASHINGTON.The Federal
Government, at the behest of
two congressmen and the coun-
-cl to the Vice President, C.
loydon Grny, is about to pay as
mich ns $175,000 tor the testing
if an alleged fuel-economy clc-
.icc thai the EPA would test
or next to nothing.
Known -'as the Wcbslcr-Hcise
/nlvc, for its inventors, Shcr-
voocl Webster, Richard H c i s e
md Douglas Hcisc, the device is
'llcgcd to improve fuel cco-
iQiny by up to 20 percent, in-
crease torque by up to 40 per-
cent, decrease nitrogen oxide
emissions by up to 50 percent,
cut carbon monoxide by up to
45 percent and cut hydrocar-
bons by up to 13 percent.
Further, it is alleged to allow
cars to run on 75-octanc gaso-
line.
Among investors in the valve
are former President Gerald
Ford; Ford's former White
House Counsel, John Marsh;
Senator John Warner, Virginia
Republican, and former Senator
Carl Curtis, Nebraska Republi-
can.
That political clout and a let-
ter from Transportation Secre-
tary Drew Lewis calling the de-
vice "extremely interesting"
and a possible "breakthrough
with respect to pollution con-
trol, fuel economy and octane
ratings" may explain why the
DOT is paying for the testing of
the device.
« First brought to public atten-
tion about two years ago, the
device has had a rebirth of sorts
in the wake of a Congressional
Research Service analysis con-
cluding that it presents the "po-
tential for substantial national
benefits in fuel efficiency, re-
duced dependency on imported
oil. improved balance of pay-
ments position and reduced au-
tomotive air pollution," and the
subsequent call for further test-
ing of the valve by Reps. James
Broyhill, North Carolina Repub-
lican, and Richard Madigan, Il-
linois Republican.
The usual practice on fuel-
economy devices is for the in-
vestor to apply to the EPA's
Technology Assessment and
Evaluation Branch for confirma-
tory testing.
That office, specifically i-slah-
lishcd to assess the value of al-
Icged fuel-economy devices, will
accept a device for complete
testing at EPA's Ann Arhnr
(Mich.) Emissions Testing L;il>
free of charge to the inventor.,
provided preliminary dntn indi-
cates a reasonable potential for
fuel-economy improvement.
To get such preliminary dnt.i.
inventors typically need to
equip a vehicle with their de-
vice and have it tested on a dy-
namometer at an EPA-approvcd
test facility and over an EPA-
Conllnurd on Tite JO. Col. I
A Christmas Fantasy
Or John Z. the Snowman
'Tii'tu the night he/ore Christinas, Detroit turn quite tone;
Stiles were no better than Roger Smith's PR seme.
'1 here n>ere plenty of cars, there was no need to make 'em,
Anil ii'ith rebates ti>e had to pay buyers to take 'em.
I'.fJ'irts to sell cars ii'ere clumsy, maladroit,
Like l:ortl's Jackie Stcit'nrt at the Grand Prix-Detroit.
Anlo persons nestled nil snug in their beds,
While I'isions of jits'-hi-timc danced in their heads;
Local content and kiinhan did haunt all their sleep
and the thought of Yank soldiers driving Le Jeep.
('I he niime.1 of the men al Ilic lop seemed to shout
'I'hiil American M"lnn is as I'rcnch as Peugeot.)
And Anifrifiiii worlren tiiiftlni; "Honda over all"
IRS probes U. S. subsidiaries
of Toyota, Nissan and Honda
Uy Jake Keldcrman
Wellington Sun Writer
WASHINGTON. The In-
ternal Revenue Service is in-
vestigating the U. S. subsidiaries
of Toyota, Nissan and Honda
for possible illegal profit trans-
fers between themselves and
their Japanese parent firms that
could be depriving the U. S.
Treasury of millions in taxes.
According to information <>b-
Inincd by AUTOMOTIVE NKWS,
I h c investigation, a so-called
'Ifl?. invrslii'.tlinn w:\~-. hc-i'iin Iw
importing companies for alleged
dumping. That investigation
found the Japanese makers in-
nocent of such activity.
In the present investigation,
the IRS is scrutinizing the man-
ner in whicli the U. S. subsidi-
aries of Toyoia, Nissan and Hon-
da have chosen to determine,
for lax purposes, the so-called
"arm's length" or transfer price-
of vehicles sold to the U. S. sub-
sidiaries by their parent firms.
This price, which is an ex-
pense to the U. S. subsidiary.
plays a major role in what lli<>ir
taxable income will be fur tin-
year.
The IRS apparently suspects
Continued on P««e JO. Col. 4
news
-------
IL S.. to pay $175,000 to test valve
Continued from F»t« 1
^proved test cycle. Such lest-
ig typically costs from $5,000
' 57,000, EPA sources said.
Webster and Heise have nev-
- asked EPA to test their de-
ice and, though they have had
reliminary testing done at an
PA-approved Jab, the data re-
jlting from that testing (the
ime data the Congressional
.esearch Service used in Us as-
sssment of the Webster-Heise
alve) was deemed by an EPA
facial as being "less than the
minimal data" it -would need
a decide on whether to accept
ne device for further testing.
When asked why he had not
sked EPA to test his device, as
lany other inventors before
im had, Webster s a i d it was
ecause he "couldn't trust the
:PA," and that in any case they
vould not run the kind of tests
ie wanted.
"They don't test for perform-
nce or wide-open throttle and
hey use 97 indolino gasoline, a
asoline not representative of
-hat is on the market," he said.
"We have no intention of go-
ng there until we've completed
ur own tests," he said.
Webster's mistrust of the
-PA stems back to his involve-
ment in the early and mid-'70s.
.'ith another fuel-economy in-
ention known as the "LaForce
ngine."
Basically a 1974 AMC Hornet
ngine modified to run on a
^aner mixture while utilizing
GR, advanced timing and a
adical induction system that
;parated the fuel charge by
roplet weight, it, too, promised
reater fuel economy, enhanced
ower and reduced emissions.
EPA tested the engine and
hile it did show some of the
iprovements promised, it
idn't match what AMC man-
>ed to do with the 1975 pro-
uction version of the same en-
ne.
Webster and other members
the LaForce group charged
heating by the EPA," but a
ibsequent investigation by the
e n a t e Commerce Committee
ndicated the agency.
Later, a "blue sky" invesliga-
on by the Securities and Ex-
iange Commission led to the
dictment and conviction of
dward LaForce for selling un-
gistcred stock in firms promot-
g his invention.
The new device is said by
ebster to be a further refine-
ent of the- fuel foparntor sys-
m used in the LaForce encine.
The air-fuel mixture flows
through the screen and vapor-
izes in an optimal fashion, ac-
cording to the inventors.
A large number of fuel vapor-
izing devices similar in nature
to the Webster-Heise have been
tested by EPA over the years
but none has ever been shown
to improve significantly the effi-
ciency of today's gasoline en-
gine, which burns gasoline at
about 99 percent efficiency.
According to auto engineers
familiar with vaporizing devices
and the theories behind them,
improving the vaporizing of the
air-fuel mixture helps improve
performance only at low tem-
peratures. They say there are
probably more "elegant" ways
to do it than putting a screening
device in the intake air flow.
. They mention such things as
the sonic carburetor, which
sends the air - fuel mixture
through a "standing shock wave"
or a heated ceramic honeycomb,
like that found on the Chevro-
let Chevette and other GM cars,
which heat the charge before it
reaches the combustion cham-
ber.
Today's engine, with its so-
phisticated feedback emission
control systems, modulated
EGR, high-energy ignition and,
in some cases, octane compen-
sating fuel injection (Saab), is a
pretty efficient unit, the engi-
neers say. "Improving on it
would take some doing," they
say.
The DOT, meanwhile, has
contracted to pay Sherwood
Webster and his two partners,
Richard Heise and Douglas
Heise, $41,580 for 60 to 90 days
of consultation on the testing of
their valve. Further, it will pay
$6,370 for such equipment as
may be necessary to install and
check out the device on two ve-
hicles, one owned by Webster-
Heise Corp. and one by the gov-
ernment.
It will pay $4,000 for two
Webster-Heise valves and be-
tween $9,000 and $10,000 for one
Dodge 400 equipped with a 2.2-
liter engine.
Testing-has already commenc-
ed at the Environmental Testing
Corp. laboratory in Denver, and
will consist of dynamometer
tests utilizing the EPA urban
driving cycle, the EPA highway
cycle and special idling tests to
determine fuel economy and
emissions. In the course of all
these tests, EPA-specified fuels
will be used.
There will then be a series of
road tests to determine octane
requirements, wide-open throt-
tle performance and driveabil-
ity under hot and cold condi-
tions.
A second set of tests, identical
to the first will then be run at
the Southwest Research Insti-
tute facilities in San Antonio,
Tex.
Chrysler, in addition to de-
livering the vehicles will assist
in the testing program by pro-
viding such technical help as
may be needed.
DOT will pay for the use of
the testing facilities at ETC and
SWRI, which, according to
knowledgable sources, will
likely amount to approximately
$100,000.
"If it works out, it will be the
best investment we've ever
made," said Mike Mason, associ-
ate minority counsel for the
House Health and Environment
subcommittee.
Meanwhile, Broyhill and Ma-
digan have introduced legisla-
tion that would allow the ad-
ministrator of the Government
Services .Administration, in
consultation with the Secretary
of Transportation, "to require
that at least 10 percent of new
gasoline-p o w e r e d cars in the
federal fleet be equipped with
the valve, should it prove to do
all that it promises."
AMC shifts Lepeu, Tierney;
Lawrie, MacCracken retire
American Motors last week
announced the reassignment of
two.vice presidents and the re-
tirement of two others.
Given new duties were Jean-
Marc Lepeu, now vice president
- finance, and John P. Tierney,
who was named vice president -
finance staff and controller.
Lepeu, a former Renault ex-
troller, and MacCracken had
been with the firm since 1972,
starting as corporate director of
industrial relations.
With MacCracken's retire-
ment, labor and industrial rela-
tions report directly to Richard
A. Calmes, vice president - per-
sonnel and industrial relations.
In another personnel change
Going to lengths v
O'Donovan Mercede
N. J., will convert a M
a luxury limousine "fit
eludes an extension c
necessary to limousin
price tag.
IRS probiii.
of Honda, f
the Japanese makers sot
higher than reasonable f
vehicles they sold to tlu-i
subsidiaries. That would
the taxes the U. S. firm:
lower than they should t
U. S. tax regulations r
that in determining arm's '.
price, firms must use one c
methods. These are, in di-:
ing order of priority: Tin-
parable Uncontrolled P
(CUP) method; the Rt-saK-
(RP) method; the Cost
(CP) method, or the Hy
method.
The IRS thinks the
should be using the CUP .
' od, which determines the
fer price based on the pr.
a comparable item in a s.v
tween unrelated parties.
The Japanese, on thr
hand, think the RP mrt)>
the one that should be us<-c
because the firms do not b<
sufficient similarities oxis
tween the U. S. and Jnp
markets to make comp.-,
reasonable. They also note
the RP method'takes into
sideration whether the U. S
sidiary is earning a sufT
profit.
Government sources c.>
that the investigation is i:
way, but the IRS, as is tht
torn in all tax investigation
fuses to either confirm or
its existence.
International '.ax experts
other auto firms, equally
of this subject matter, s;ii
investigations are not \n:
for multinational ro::-.p
Bui they were surprisi-d .-
length of the invcsticaiio
volving the Japr.m-se. Cu
arily these imvs'.ifa'J.:-.<.
about a y<-ar for <-ich \>
-------
95
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY ATTACHMENT Q
w
? ANN ARBOR. MICHIGAN 48105
June 14, 1983
OFFICE OF
AIR. NOISE AND RADIATION
Dr. Leon ! Rosky, President
Optimizer, Ltd.
220 Lynn Street
Flushing, MI 48433
Dear Dr. Rosky:
We received your letters of May 12 and 20 in which you raised several
issues. Although most of these were discussed in our meeting on May 17,
there are many which were not and several which still need to be
addressed. We believe a formal response is necessary to make our
position clear and prevent a misunderstanding.
In your letter of May 12, you raised several issues about the testing at
ATL. Our comments below address these items according to your numbered
paragraphs.
1. Paragraph 1 - Parameter adjustment tests. Your letter
reiterated your concern as to when the parameter adjustment only
(ignition timing) tests should be performed in a test sequence.
We feel that the best sequence is as follows:
a. Vehicles set to manufacturer's specifications.
b. Mileage accumulation.
c. Duplicate test sequences (baseline).
d. Installation of device and adjustment of parameters.
e- Mileage accumulation.
f. Duplicate test sequences.
g. Readjust parameters to manufacturer's specifications.
h. Duplicate test sequences.
We recognize the problem of carryover effects for the final test
sequence. Also, the testing could be done in a different order
and other tests and changes incorporated. However, we feel that
the above sequence should be followed to minimize both the costs
and the risk of test problems confounding the results- In any
case, the ultimate goal is to obtain a fuel economy and emission
comparison of a fully installed device to baseline results.
-------
96
2. Paragraph 2 - Fuel economy guidelines. The EPA guidelines for
fuel economy were established to allow applicants to size their
test programs and to determine if the test results should be
considered encouraging' The values were chosen to assure that a
real difference in fuel economy can be detected with normal
test-to-test variability. To determine if there is a potential
benefit, the test results from the independent lab are analyzed
to determine if any changes are statistically significant.
Thus, it is a combination of fleet size, actual change in fuel
economy, and actual test variability that determines if the
device shows improvement.
Therefore, although a fuel economy benefit is indicated for the
- device by some segments of the test program, this is not
necessarily true for each segment for all of the many ways in
which the data can be compared.
3. Paragraph 3 - Vehicle N0y levels. EPA does not have NOX
specifications* Instead, There are prescribed levels of NOX
that a vehicle cannot exceed when tested in a specific manner.
In designing a vehicle to meet the standard, a manufacturer must
seek a level sufficiently below the standard so that, when
combined with production tolerances and normal system
deterioration, the vehicle would not be expected to exceed the
standard at 50,000 miles. The test used to certify vehicles is
known as the Federal Test Procedure (FTP). This is a cold
start, three part emission test. The hot start LA-4 tests you
used are the second and third parts of the FTP. Although
emissions are measured, the principal purpose of the Highway
Fuel Economy Test (HFET) is to measure highway fuel economy.
Thus, the NOX values obtained from LA-4 and HFET tests cannot
be compared to the FTP standard.
Hot start LA-4 emissions of NOX are anticipated to be higher
than those over the FTP. Also, a vehicle which has been found
to meet the specifications of the manufacturer may exceed NOX
emission levels due to production tolerances, operating and
maintenance history, or design deficiencies. Thus, a vehicle
exceeding the standard is not necessarily unrepresentative.
Requiring FTPs and automatically rejecting vehicles exceeding a
standard would raise the costs of testing for an applicant by
adding more vehicles and more tests. Furthermore, the
independent lab testing by an applicant is used essentially to
screen devices. EPA normally performs confirmatory testing on
those devices showing emission and/or fuel economy benefits.
Therefore, because we are interested in the emission and fuel
economy effects as well as the overall emission levels, unless
the data shows there is obviously something wrong with a
vehicle, we accept the test data from an independent laboratory.
-------
97
Our comments below address your comments in Paragraph Three
about the NOX levels of the four test vehicles.
a. Vehicle #8982, the 1981 Oldsmobile V-6. The LA-4 baseline
NOX levels appear to be high for a vehicle that is
supposed to meet the 1981 NOX standard of 1.0 gm/ml.
However, for the reasons cited previously, our intention is
to include it in the Optimizer data base.
b. Vehicle #7957, a 1980 Chevrolet. The LA-4 baseline and
device NOX levels are below the 1980 NOX standard of
2.0 gm/mi. As noted previously, there is no HFET NOX
standard. We find no reason to reject this vehicle on the
basis of emissions.
c. Vehicle #0267, the other 1980 Chevrolet. The LA-4 baseline
and device NOX levels are below the NOX standard of 2.0
gm/mi. This vehicle is acceptable from an emissions
viewpoint. We agree that, due to the spark plug wire
failure, the final set of tests on this vehicle (Optimizer
back to factory specs with no miles) should not be included
in any analysis.
We agree the data do indicate a decrease in NOX emissions
for the HFET between the test with the Optimizer only and
the test with the Optimizer and the adjusted parameters.
However, this same pairing shows an increase in LA-4 NOX
emissions. Furthermore, the more important comparison is
the change in LA-4 NOX emissions between baseline and the
installed device tests (with parameter adjustments). For
this vehicle, this change is not statistically significant.
d. Vehicle #2430, the 1980 Oldsmobile. The LA-4 baseline and
device NOX levels are below the NOX standard of 2.0
gm/mi. This vehicle is acceptable from an emission
viewpoint.
Therefore, from an emission standpoint, three of the vehicles
are completely acceptable and the other, vehicle #8982, although
high in NOX emissions, is acceptable for the reasons cited
above.
4. Paragraph 4 - Fuel economy increase. The data you cite for that
Chevrolet indicate that there is a small increase in fuel
economy with the device installed and a further and larger
increase after the device is removed. If the device has a
carryover effect, one would expect tests performed immediately
after the removal of the device to be about the same as the
device tests, not to increase immediately and to increase still
further after 500 miles. Therefore, it also can reasonably be
-------
98
argued that this is a combination of test-to-test variability
and shift in vehicle fuel economy or even that the device has an
inhibiting effect and should only be used occasionally. The
other vehicle, #8982, shows no statistically significant changes
of a similar nature. Therefore, we must conclude that the data
do not support your statement.
5. Paragraph 5 - Second test program fuel economy effects due to
timing. The test data show a progressive increase in fuel
economy from baseline to device only and, finally, to device
with ignition timing advance. Forty percent of the overall
change occurs with the timing change. Thus, the data do not
support your statement that the effect of the timing change is
minimal.
6. Although, as you state, many of the items you addressed in
paragraphs number one through five of your letter were addressed
in previous communications, these items do not show that the
fuel economy improvement is not due to timing, that the increase
in fuel economy is due solely to the Optimizer, and that some of
the NOX increase is not due to the device. Also, the
modifications to the device between the first and second program
were clearly and adequately addressed in correspondence between
us prior to our analysis of the data. Thus, although the
changes in the device may have complicated the evaluation, this
did not prevent us from completing our analysis of the data.
7. Finally, you briefly discussed inconsistencies in the results
and procedures at Automotive Testing Laboratories. Based on
xfhat was discussed at the meeting and our analysis and checks on
the data, we know of no reason to reject the ATL results. The
NOX levels and potential recall of some of the test vehicles
are not cause to reject the ATL test results for the reasons
cited earlier in Section 3.
In your letter of May 20, you further discussed the applicability of the
ATL test results and raised several additional issues about our
evaluation of your device. The sections below address these issues:
1. Paragraph 1 - Appropriate tests to be used in evaluation. After
reviewing the information supplied with the application and
several clarifications, we knew that, as you state, vehicles
#7957 and #8982 were tested with a check valve and return line
installed with the device. Furthermore, we were aware that the
application was clarified to be for the device without these two
components. Therefore, we knew that it might not be appropriate
to use the tests on these two vehicles in our analysis.
However, you stated that the tests were valid and representative
and that you anticipated that the device would have shown a
greater improvement if it was installed in your most recent
-------
99
configuration. We cautioned you that our analysis would be
based on the data as supplied, not some assumed improvement over
these test results. Therefore, we feel that these results
should be considered as more than just background information
and that it is appropriate to include the test results for these
two vehicles in our analysis of the test data.
Also, contrary to your statement, it is appropriate for EPA to
evaluate products that will not be marketed, since marketing a
device is not a prerequisite for a 511 evaluation.
2. Paragraph 2 - NOV effects of device. The key comparisons are
between the baseline and device tests. Contrary to your
statement, the data do show that the Optimizer with timing
advance does increase oxides of nitrogen. Thus, there is no
need for EPA to conduct a confirmatory test program to verify
the emission increase.
Our cursory analysis of the device tests done without the
initial timing changes does show a trend of small increases in
fuel economy and large increases in NOX emissions. However,
at the meeting we did not state that a ten percent increase in
NOjj was allowed. We noted that we were concerned with both
the percentage changes in emissions and emission levels. We
stated that, with normal test-to-test variability, a ten percent
change in NOX was usually not significant. On the other hand,
the final determination of significance would be based on the
test data. Note: at our meeting, I stated that for NOX the
above number was five percent while Mr. Barth stated he thought
it was higher, perhaps ten percent. We subsequently checked and
confirmed it is five percent for NOX.
We also noted the change in NOX for the LA-4 and HFET tests of
vehicles #0267 and #2430 for the baseline, device without timing
adjustment, and device with timing adjustment tests. In three
out of four cases, an advance in timing increased NOX. The
one case where it does not increase does not disprove the
statement that timing advances increase NOX.
3. Paragraph 3 - Changes in the condenser. Your prior
correspondence does not indicate that a critical change in the
condensing units was necessary nor did you modify the
application to reflect the change in the condenser unit.
4. Paragraph 4 - Evaluation standards. The Section 511 process
mandates that we evaluate the effects of the device on emissions
and fuel economy. The percentage increase over baseline
emissions, even if emissions are still below the standard is a
valid comparison. Further, since vehicles are designed and
-------
100
targeted to be at or below a given emission standard, a device
which increases emissions, if installed on the total fleet,
would similarily bias the fleet emissions to be above the
standard.
On the other hand, changes made by the vehicle manufacturers are
designed to apply to a select group of vehicles. Through the
certification process, he can establish that any increases in
emissions of these vehicles will not cause the particular
vehicle family to exceed the standard.
5. Paragraph 5 - Tampering. The statement you reference states
that the device must not cause vehicles to fail to meet their
applicable emission standards for their useful life. For
reasons cited in paragraph 4 above, increasing emissions can be
interpreted as a cause for a vehicle to fail to meet the
applicable standards.
6. Paragraph A - Marketing intentions. The applicability of the
test data to the device being evaluated was clearly established
in our previous correspondence. Therefore, contrary to your
statement, the information in the evaluation is applicable to
the device to be marketed.
7. Paragraph B - Amendment of application. We do not consider the
request in this paragraph to be a valid and formal change of the
application previously submitted. As we stated at our meeting
on May 17, you are welcome to submit a new application
incorporating a modified version of your device. However, to
avoid confusion we insisted that it be submitted as a complete
and separate document. We feel that any information or data now
part of the current application could readily be extracted and
placed in a new application.
8. Paragraph C - Request summary. We disagree with these
statements to varing degrees for reasons previously cited in
this letter.
We feel that we have fairly considered all the information you have
provided and are proceeding with the evaluation process. Our conclusion
is still that the device, when installed according to the current
instructions, will cause a large increase in NOX emissions, a small
increase in fuel economy, and may be considered tampering.
As we indicated at our May 17 meeting, if you submit a new application
soon, we would note that fact in our present evaluation. However, as
stated above, we do not consider your letter of May 20 to be a new and
formal application. Furthermore, a subset of the present data may not,
by itself, meet the evaluation data requirements. For example, if only a
-------
101
two percent fuel economy improvement is noted, ten vehicles would need to
be tested, or if the data we discussed in responding to paragraph two of
your May 20 letter were used, no benefit is indicated.
I hope this detailed response has clarified our position. If you have
any further questions, please contact me.
Sincerely,
Merrill W. Korth
Device Evaluation Coordinator
Test and Evaluation Branch
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
102
ATTACHMENT R
1 ; * OFFICE OF
'
JUL ' 1°°^ AIR, NOISE AND RADIATION
Honorable Donald W. Riegle, Jr.
United States Senate
Washington, DC 20510
Dear Mr. Riegle:
This Is In response to your letter to Mr. Ruckelshaus
dated June 9, 1983, discussing an automotive fuel economy
device manufactured by "Optimizer, Ltd." Your letter asked
that EPA fund additional testing of the Optimizer device, and
that EPA delay publication of a technical report on the device
until further meetings can be arranged between EPA and
Optimizer, Ltd.
EPA evaluates fuel economy retrofit devices, such as the
Optimizer, under the authority of Section 511 of the Motor
Vehicle Information and Cost Savings Act (MVICSA). In order to
perform these evaluations at a reasonable cost to the
Government, it is necessary to require that applicants provide
persuasive test data substantiating their claims. We have
established precise protocols to be followed by EPA and the
device manufacturer in determining the effectiveness of a
device in improving fuel economy and in improving or degrading
air pollution emissions. These procedures require the device
to first be tested in a commercial laboratory whose proficiency
has been recognized by EPA. If the private laboratory data
indicates a likely fuel economy improvement, EPA may choose to
perform more thorough confirmatory testing at the EPA
laboratory in Ann Arbor, Michigan as part of its evaluation
process. As provided in regulations under the MVICSA, EPA
publishes the results of its evaluation in the Federal Register
and provides copies to the Federal Trade Commission and the
Department of Transportation.
Consistent with our requirements, the applicants obtained a
considerable amount of data on the Optimizer device at an EPA
recognized laboratory. In collecting and analyzing these data,
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103
both Optimizer, Ltd* and EPA have followed the procedures
specified in the EPA regulations and policy documents. EPA
analyzed the private laboratory data and fully considered all
of the information that was submitted by Optimizer, Ltd. The
overall conclusion is that, for most vehicles, the device and
the prescribed ignition timing adjustments of the engine will
cause a small improvement in fuel economy along with a large
increase in oxides of nitrogen emissions. These changes are
attributed by EPA to the five degree advance in ignition timing
rather than the device itself. Irrespective of improvements in
fuel economy, installation of devices evaluated by EPA that
have increased exhaust emissions has been considered
"tampering" by EPA's Field Operations and Support Division.
Under this situation, to perform further testing of the
device in the EPA laboratory would violate long-standing EPA
policies. The Automotive News article attached to your letter
was referenced as illustrating a precedent in which EPA
supported testing of a retrofit device which had had little
prior testing. I must point out that DOT is supporting the
evaluation of the Webster-Heise device test program, not EPA.
Had he applied to EPA for an evaluation, Mr. Webster would have
been required to supply the same type of preliminary data as
was Optimizer. A recent legal determination within EPA
requires that device manufacturers who request EPA to test
their device be held liable for all costs incurred by EPA in
conducting such testing.
Optimizer, Ltd. indicated that technical improvements to
their device have been made since they collected the data that
was submitted to EPA, which could make the EPA evaluation out
of date. However, EPA must report on the device as it existed
when the data was collected. If the device has since changed
and is now a different product that may produce different
results, then a new application for evaluation will be welcomed
but it must be accompanied by a clearly defined description of
the new configuration and it, too, must have supporting data
from a recognized laboratory demonstrating its effect on fuel
economy and emissions.
EPA has recently met with Optimizer, Ltd., and numerous
letters have been exchanged. We cannot see reasons for an
additional meeting at this time, but if Optimizer can identify
specific needs for such a meeting it certainly can be arranged.
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104
In summary, we feel that EPA is fairly evaluating the
Optimizer device using well established protocols. Our
analysis of the data at hand does not Justify further testing
in the EPA laboratory, and we believe it would be appropriate
to continue with the publication of our report on the device in
the configuration which was tested.
Sincerely yours,
Charles L. Elkins
Acting Assistant Administrator
for Air, Noise, and Radiation
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105
ATTACHMENT S
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
ANN ARBOR. MICHIGAN 48105
June 18,. 1983 OFRCE OF
AIR. NOISE AND RADIATION
Dr. Leon I. Rosky
President, Optimizer, Ltd.
220 Lynn Street
Flushing, MI 48433
Dear Dr. Rosky:
This is in response to your letter of December 6, 1982 which submitted an
application for an evaluation by EPA of the "Optimizer" device under
Section 511 of the Motor Vehicle Information and Cost Savings Act.
The EPA evaluation of your product has been completed and a copy of the
draft final report is enclosed. This report, entitled "EPA Evaluation of
the Optimizer Device Under Section 511 of the Motor Vehicle Information
and Cost Savings Act", will be made available to the public. Also
enclosed is a copy of the summary which is expected to be published in
the Federal Register. If you have any questions concerning this report ,
please contact Merrill Korth of my staff at (313) 668-4299.
Sincerely,
Charles L. Gray, Darectoi
Emission Control Techno/ogy Division
Enclosures
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106
ATTACHMENT T
Optimizers!
July 28, 1983
Environmental Protection Agency i
Motor Vehicle Emission Laboratory
2565 Plymouth Road
Ann Arbor, Michigan 48105
Attention: Mr. Merrill W. Korth
Device Evaluation Coordinator
Emission Control Technology Div.
Dear Mr. Korth:
Enclosed you will find our comments relating to the EPA Evaluation
#EPA-AA-TEB-511-83-9 entitled "EPA Evaluation of the Optimizer Device Under
Section 511 of the Motor Vehicle Information and Cost Savings Act".
Our comments will be made in accordance with page numbers and paragraph
numbers used in your evaluation. It is our understanding that any comments and/or
critique made on EPA's evaluation will require a further in-depth study and
possible re-consideration of those points in your final evaluation.
In the preface to the evaluation under Section IV entitled "Summary of
Evaluation", it must be stated that,the Optimizer device used in the testing
sequences submitted to E.P.A. for evaluation is not the device intended for
marketing. This device which was tested has undergone modifications, improvements
and refinements. Optimizer, Ltd intends to submit a new application to E.P.A. on
their present Optimizer unit which will be marketed.
Your summary of evaluation does not cover those sequences which relate to
the baseline, Optimizer unit alone (no timing advances), after 1,000 miles run-in.
We believe that since those test sequences were done, a reference should be made to
their existence, evaluation and performance in this section of the total evaluation
of the Optimizer (in order so that there is no duplication of effort in commenting
on this evaluation, all critique of the sections referred to immediately above will
be made at the appropriate time in this letter).
On page £2, paragraph §3, we acknowledge that the original application we
made to E.P.A. was for a device which included a timing advance. During the
testing period, there have been numerous letters between Optimizer, Ltd and E.P.A.
in which the subject of timing advance came up many times. The entire evaluation
of the Optimizer done by EPA seems to be based on a judgement that all fuel economy
increases are due to the timing advances and not to the device itself. The reason
test sequences using an Optimizer device alone were performed was to show that with
Optimizer Center, 220 Lynn Street, Flushing, Michigan 48433 313 659-2000
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107
the Optimizer device alone (no timing advances), a fuel economy increase would
be seen. Therefore, the statement that "the device, coupled with ignition
timing advance, is claimed to improve fuel economy..." is a true statement, but
does not relate to the fact that the device alone, without timing advances, will
also give fuel economy.
Page #9, Paragraph #1 - Theory of Operation of the Optimizer.
It DOES NOT state anywhere that for the device, to perform and a fuel
economy increase to be obtained, a timing advance is needed. While we may agree
that at times improved fuel economy levels may be seen with ignition timing advance
alone, even without any retrofit device, Optimizer, Ltd maintains that a timing
advance is used to enhance the fuel economy increase received by the device alone.
Page #9, Paragraph #3.
Tests done by Optimizer, Ltd show platinum in the fuel as it exits the
vihit. There is laboratory evidence (attachment enclosed) to the effect that
parts removed from an engine (from a vehicle with an Optimizer installed for
60,000 miles) displayed a platinum coating uniform in depth with very little
carbon on the combustion surfaces. Optimizer, Ltd acknowledges that this is a
new technology and that as yet we have not learned everything there is to know
about the method of action. There are articles (some of which you were given
by Optimizer, Ltd) that show that platinum used in engines will improve combustion.
In most of those cases, the continuous introduction of the platinum was the primary
problem which had to be researched.
Page #11, Paragraph itl.
The figures as stated in our installation instructions of 7,000 to 10,000
miles for changing the in-line fuel filter have been revised. That figure is more
like every 30,000 miles.
Page # 13.
In table one, looking at the configuration column itself, the description
"Optimizer after 500 miles, both on vehicles S7957 and =?8982", is incorrect. We
notice that there is a foot-note on that page correcting the mistake, but we
believe that correction should be above, in the body of the evaluation. Anyone
scrutinizing this report may not notice the footnote and believe this to refer to
the Optimizer alone, instead of the Optimizer with parameters (return line, check
valves and timing advance). No doubt the confusion here is due to what is written
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1UO
in attachments C-4 and C-5 of the report. A.T.L. described in their test
summary and results on these two vehicles the second sequence as "device after
500 miles". This is incorrect, and not footnoted on their report. This table
shows that on the first two vehicles, the Optimizer after 500 mile sequence can
be directly compared to the Optimizer after 1,000 mile sequence on the last two
vehicles (#0267 and #2430) . The facts are that the first two vehicles (#7957
and #8982) not only had timing advance, but had return line and check valves in
place. The last two vehicles (#0267 and #2430) had timing advance only. The
parameters were not the same in these two sequences.
Page #14, Paragraph Entitled "NOX Emissions".
Your first statement, "installation of the Optimizer caused large and
statistically significant increases in NOX emissions for all vehicles", is not
a true statement. On attachment C-6 (vehicle #0267), the NOX increase from
baseline to Optimizer after 1,000 miles at factory specifications on the LA4 is
10%. On the H.F.E.T., NOX emissions were elevated 16%. On the H.F.E.T. from
baseline to Optimizer with parameter adjustments, the increase was 2.7%. I
would like to emphasize that the fact that the spark plug wires failed at this
point was detrimental to Optimizer, Ltd because we could not prove a decrease
in NOX on the sequence of Optimizer back to factory specs. It must be noted that
with the timing advanced, the NOX decreased to a level well within any error
range. On vehicle #2430, attachment C-7, the following is apparent. LA4, NOX
emissions between baseline and Optimizer after 1,000 miles at factory specs,
increased by 7.5%. In the sequence with Optimizer, parameters adjusted, no miles,
the NOX increased to 20%. But in the last sequence of Optimizer back to factory
specs, the NOX elevation was 2.8%. It is evident from this information that with
the Optimizer, no timing advance, the NOX should be considered|!basically at a zero
level. At this point, I would like to refer you to your letter .'dated June 14, 1983,
page 3, item "c", second paragraph: "we agree the data do indicate a decrease in
NOX emissions for the H.F.E.T. between the test for Optimizer only and the test
with the Optimizer and the adjusted parameters. However, this same pairing shows
an increase in LA4 NOX emissions. Furthermore, the more important comparison is
the change in LA4 NOX emissions between baseline and the installed device test with
parameter adjustments. For this vehicle, this change is not statistically signifi-
cant. We want to reiterate that the statement made in your evaluation, page 14
under NOX emissions which states that the installation of the Optimizer caused
increases in NOX emissions for all vehicles is not correct.
Page 15, Last Paragraph - Discussion of Test Results.
The statement "the overall expectation is that the use of the Optimizer
would cause NOX emissions to sharply increase" is not a true statement as proven
above. Nox emissions for certain sequences with Optimizer and timing advance
had an elevation in NOX emissions. Sequences of Optimizer without timing advance
did not have large increases in NOX emissions. In that same paragraph, it is
written "thus, there is a need to distinguish between the effect attributable to
the device alone and the effect attributable to the ignition timing adjustments
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109
performed when installing the device". Optimizer, Ltd is very interested in
doing just that. It is not noted anywhere in your summary, nor anywhere in the
body of this report, that the sequences with Optimizer alone (no timing change)
do not have increases in NOX emissions.
Page #16, Paragraph #2.
You have stated "however, the test conducted with the device installed, but
without the timing advance (attachments C-6 and C-7) showed an increase in NOX
emissions for both the city and highway cycles...". Again, we wish to reiterate
that for the reasons given above, that is not a true statement. It appears that
when looking at vehicles #2430, attachment C-7, no interest was paid to the Optimizer
back to factory specs sequence (the last sequence done on that vehicle). If it had
been looked at, it would have been noted that the NOX results were the same in that
sequence as the baseline.
We take issue with paragraphs #3 and #4 on page 16 due to what has been
described here. You can not state that all the results are due just to the timing
advance. I would like also to refer to A.T.L.'s testing material, final report
dated December 1, 1982, on vehicles #0267 and #2430. Looking at unit #2430, which
did not have a spark plug wire failure, on the highway sequence, Optimizer after
1,000 miles at factory specs, showed 5% increase over baseline. With the timing
advance there was a 5.2% increase over baseline, and with the Optimizer back to
factory specs, the percentage remained at 5.2%. In a previous communication from
E.P.A., letter dated June 14, 1983, page 4, item 5, you stated that "forty percent
of the overall change occurs with the timing change. Thus the data do not support
your statement that the effect of timing change is minimal." Had the spark plug
wires not failed on the last sequence, we maintain that the result would have been
6%, duplicating the results on vehicles #2430 where the timing was shown to have
little effect.
Page #17, Paragraph "d" - Cost Effectiveness.
Since Optimizer, Ltd will be targeting for sales in the fleet market,
your cost effectiveness is not correct. If we assume a cost of S390.00 per unit,
a baseline fuel economy of 25 miles per gallon, gasoline costs of $1.40 per
gallon, and an annual usage of the vehicle of 50,000 miles, then the payback
would be 69,000 miles. Because our tests show that this device should last for
400,000 miles, it is very cost effective.
Page #17 - Conclusions.
In this section, you must insert a statement about the device alone with
.no timing advance. That statement must reflect that indications with device alone
and no timing adjustments show fuel improvement and no emissions elevations.
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Furthermore, in your conclusions, as in the summary at the beginning of this
evaluation, it must be stated that the device as tested and evaluated is hot
the device that Optimizer, Ltd will market. A new application on the present
device with its modifications is being submitted.
Mr. Korth, if there are any questions on this critique, please contact
me. We believe that what we have stated here reflects the true evaluation of
the tested Optimizer (not ever to be marketed). Thank you very much for your
cooperation and help.
Sincerely,
OPTIMIZER, LTD.
Dr. Leon I. Rosky
President
LIR:va
Enclosure
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Optimizers.
^unr^^i.'y-fv. .». »> '.».( t-.. :-- _* . ' * . . . -...',; *,,-
118 -V Fuel filter off truck #310 frorn^
119 -V Fuel filter off truck #932 from-
May 2, 1983
120
Quart oil out oi
:ar
121
Fuel filter off
rcar.
122
BAS» from combustion chamber.
123
BAflrpieces of piston's. .
124
BAfl-of valves.
.
/V3
Carua/. 220 Lynn Sueet. rlu&vng. Michigan 48433 313 659-2000
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Research and Control Laboratories, Inc.
27145 BENNETT ST.
(313) 538-2367 DETROIT, MICH. 48240
Dr. Marvin Weintraub
Innovative Technologies, Inc. July 22, 1983
Southfield, MI
Re: Optimizer
Dear Sir:
Preliminary results for Testa 122-125 show small amounts
of platinum present-(8-10 ppb). These will be repeated after
a concentration step and the remaining samples are in process.
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OpdmizecM
The main problems in evaluating the Optimizer have been two fold:
Firstly, the Optimizer is a new and unique concept in its approach to improving
fuel economy it functions in an area of unexplored technology. Secondly, and
the most_important factor is that to properly evaluate the Optimizer, preconceived
engineering judgements regarding retrofit fuel savings devices, engine adjustments,
and existing test procedures must be disregarded.
The Optimizer functions in part by the dissolution of platinum into the
fuel with the subsequent "plating out" of the platinum on to the cylinder walls,
valves, heat risers, etc. Thus, it will take a given time frame (e.g. - 1,000
miles for certain vehicles) for the platinum to coat the engine surfaces before
observing the full benefit of the Optimizer. Conversely, if the Optimizer is
removed from the vehicle after, say 1,000 miles, a fuel economy improvement will
still exist until the platinum wears off. A detailed description of the proposed
mechanism, along with laboratory data, is attached. It should be noted, however,
that the mechanism is extremely complex and not yet fully understood.
Observations Related to Mechanism
The catalyst employed by Optimizer is stabilized platinum on an aluminium
oxide support. As the fuel is passed through the Optimizer, the platinum dissolves
at a given rate depending on the temperature of the Optimizer and the type of fuel.
At a given temperature, platinum dissolution is greater in gasoline than in diesel
fuel, which probably is related to the olefinic concentration differences between
the two fuels. Figures 1 and 2 show the dissolution of platinum as a function of
temperature in both gasoline and diesel fuel. These curves should be considered
to be proprietary.
Optimize/ Center, 220 Lynn Street. Flushing. Michigan 48433 373 659-2000
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Our latest test results on a disassembled engine (valve stems, pistons,
combustion chamber scrapings, and heat riser) all show a platinum coating in the
range of 8 - 11 parts per billion. To confirm this, a bench study was set up to
evaluate the platinum coating. A piece of low carbon steel was placed in a glass
flask, in which low lead gasoline was recycled through the Optimizer for 16 hours..
Platinum analysis showed that 280 micrograms were deposited on 20 cm2 of steel and
the amount of platinum in the fuel was less than 2 parts per billion. The coating
appeared to be uniform over the surface, but was not checked on the S.E.M.
There are indications that there is a low temperature catalytic reaction
based upon F.I.A. results with aromatic content changing from 26% to 31% and
olefinic content ranging from 10.2 to 9.4%.
The explanation of platinum entering the combustion chamber and initiating
combustion at lower temperatures has been shown in the literature (1), and may be
applicable to the Optimizer. Another explanation based on our findings is that
platinum coats the cylinder wall and combustion chamber over a period of time. The
unburned hydrocarbons which accumulate on the cylinder wall are completely oxidized
and hydrocracking of the fuel can occur within the combustion chamber.
'h
Continual independent fleet testing shows that vehicles with the Optimizer
require much lower maintenance based on decreased down time than similar vehicles
without the Optimizer. Therefore, the platinum coating probably serves as a high
temperature boundry layer lubricant (2).
Comments Regarding Emissions
The measure of emissions becomes even more complex since literature on a
catalytic engine showed that to obtain stable combustion, a slight increase in
timing was necessary at light loads only. The results were that hydrocarbons and
carbon monoxide decreased and oxide." of nitrogen increased. An increase in timing
is not necessary with the Optimizer oecause .as the platinum wears off, it is
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replenished and the literature shows that oxides of nitrogen are reduced
overall with a platinum catalytic engine. Thus, the test sequence plus the time
frames must be considered with the utmost caution in evaluating the Optimizer
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REFERENCES:
1. B. E. Engra and D. T. Thompson - Platinum Metals Review, 1979,
23 (4) 134.
2. F. Bowden and D. Tabor - Friction, An introduction to Tribology,
Doubleday, New York, New York, 1973.
3. R. H. Thring - The Catalytic Engine, Platinum Metals Review, 1980,
24 (4) 126.
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ATTACHMENT U
\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
* ANN ARBOR. MICHIGAN 48105
August 25, 1983
OFFICE OF
AIR. NOISE AND RADIATION
Dr. Leon I. Rosky, President
Optimizer, Ltd.
220 Lynn Street
Flushing, MI 48433
Dear Dr. Rosky:
We received your letter of July 28 in which you raised several issues
concerning the EPA evaluation report of the "Optimizer" device. Although
most of these items have been discussed in our prior correspondence and
meetings, there are a few items that may not have been discussed and
others for which our position was possibly not clear.
To make our response clear, we have numbered each paragraph of your
letter (copy enclosed) and will respond separately to each one.
1. Paragraph No. 2. Regarding the evaluation, we will take the
action indicated in the following paragraphs. The report and
summary in the Federal Register will be modified as noted in
this letter and then published.
2. Paragraph No. 3. A statement will be added to the Federal
Register Notice after the summary that will indicate that the
applicant does not intend to market the device evaluated. Also,
this addition will indicate that the applicant intends to submit
an application for evaluation of their present unit which they
do expect to market.
3. Paragraph No. 4. The report did cover the test "... sequences
which relate to the baseline, Optimizer unit alone (no timing
advances), after 1000 miles run-in." However, they are not
addressed in either the Federal Register summary or the
evaluation report conclusions since they do not represent the
primary test sequences for comparison. Namely, baseline and
device installed according to the instructions of the
manufacturer (for which the Optimizer includes timing advance).
Furthermore, the data in the sequence to which you refer, do not
demonstrate that the device, rather than the timing advance, is
the principal cause of the changes in emissions or fuel
economy. The comment on the effect of timing advance was
incorporated in the Federal Register summary and conclusions
since the data and literature support this as a principal effect.
4. Paragraph No. 5. The report does not state "... that all fuel
economy increases are due to the timing advances and not due to
the device itself." The report states that the small increases
in fuel economy are due principally to the timing advance rather
than the device.
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The statement "... that the device alone, without timing
advances, will also give fuel economy [benefits]..." is not
supported by the data. Although isolated test sequences may
show that the device alone, without timing advances, does
indicate a fuel economy benefit, the data in attachments C-4
through C-7 do not support the conclusion that the device alone
has a fuel economy benefit.
5. Paragraph No. 6. The installation instructions prescribe the
timing change. Also you stated that "Our tests show that in
order to utilize the improvement in the fuel mixture and obtain
complete combustion, a timing advance is necessary."
6. Paragraph No. 7. We agree that the data indicate that platinum
is added to the fuel. Also, we did not infer that the platinum
in the fuel would not coat engine surfaces. However, as noted
in paragraphs no. 3 and 4 on page 9 of the report (Section
6b(2)), there is no evidence that the platinum enhances the
combustion process and improves fuel economy. Furthermore, the
engine studies referenced that did show a benefit were for
completely different engines, e.g., a fuel injected engine with
a prechamber, 12 to 1 compression ratio, and a platinum grid in
the piston head.
7. Paragraph No. 8. The installation instructions stated that the
inline fuel filter was to be changed every 7,000 to 10,000 miles
and was not revised in subsequent correspondence.
8. Paragraph No. 9. The description "Optimizer after 500 miles"
both on vehicles #7957 and #8982 is correct since, unless noted
as an exception, it is presumed to be installed according to
the then current instructions of the manufacturer (and it was).
The footnote is quite prominent and would be readily noticed by
anyone scrutinizing the report. We agree that the labeling of
the data in Attachments C-4 thru C-7 could be clearer and
therefore we have added additional clarifying footnotes to these
four pages. Copies are attached.
9. Paragraph No. 10. You apparently are referring to only the
first sentence of the paragraph. The complete statement
"Installation of the Optimizer caused large and statistically
significant increases in NOx emissions for all vehicles. LA-4
NOx emissions increased for all vehicles. HFET NOx emissions
increased for three of the four vehicles. NOx emissions
increased an average of 30%" is a true statement. As we
discussed in our meetings and in our letter of June 14 the more
important comparison is the large change in LA-4 emissions
between the baseline and installed device tests (with parameter
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adjustments). Also, the data of attachment C-7 are insufficient
in themselves to establish that ... "the Optimizer, no timing
advance, NOx should be basically at a zero level."
10. Paragraph No. 11. As noted above, we expect the device to cause
NOx emissions to increase. The key item for the summary is the
change in emissions and fuel economy to be expected when
installing the device according to the instructions of the
manufacturer (including timing).
11. Paragraph No. 12. As noted in our paragraph No. 4 above, we did
"... not state that all the results are due just to the timing
advance."
13. Paragraph No. 14. We rechecked our calculations used to
calculate the payback period for an assumed improvement in fuel
economy by 5%. The correct payback mileage should be 170,000
miles rather than 200,000 miles and the report will be
corrected. However, this would still certainly make the device
not cost effective for passenger car fleets.
14. Paragraph No. 15. The Federal Register summary and conclusions
will be modified as indicated in paragraph No. 2 above.
15. Attachments. Figures 1 and 2 were included as part of a six
page attachment to your letter. The text stated that these two
figures should be considered to be proprietary. However, the
figure showing the temperature versus platinum dissolution rate
in gasoline was previously provided as an attachment to your
letter of February 8, and it was not claimed to be proprietary
at that time. Furthermore, since it was included in the report
as Attachment C-l and you did not take exception to its
inclusion, we will assume the data is not proprietary and will
include it in the published evaluation.
We believe we have fairly considered and addressed your concerns. The
changes we have promised will be incorporated before our report is
published. We are looking forward to receiving your new application.
I hope this response has clarified our position. If you have any
questions, please contact me.
Sincerely,
Merrill W. Korth
Device Evaluation Coordinator
Test and Evaluation Branch
Enclosure
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