EPA420-B-98-003
    	m^  UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
  :,,  f^ \      NATIONAL VEHICLE AND FUEL EMISSIONS LABORATORY
  "*         ^                  2565 PLYMOUTH ROAD
            i               ANN ARBOR. MICHIGAN 48105
              OFFICE OF AIR AND RADIATION/OFFICE OF MOBILE SOURCES


 EPA Motor Vehicle Aftermarket Retrofit Device Evaluation Program

Introduction

The Environmental Protection Agency (EPA) conducts a program to evaluate aftermarket
retrofit devices which are intended to improve automobile fuel economy and/or reduce
their air emissions. "Automobiles" is defined as any four-wheeled vehicle manufactured
primarily for use on public streets, roads, and highways and is rated at 6,000 pounds gross
vehicle weight or less.1 Unless ordered by the Federal Trade Commission (FTC) or the EPA
Administrator (or EPA delegate) participation in the program is voluntary. The program is
managed by EPA's Office of Mobile sources (OMS) at its National Vehicle and Fuel Emis-
sions Laboratory (NVFEL) located in Ann Arbor,  Michigan.

"Retrofit device" or "device" means any component that is designed to be installed in or on
an automobile (as an addition to, as a replacement for, or through alteration or modifica-
tion of, any original component, equipment, or other device); and that any manufacturer,
dealer, or distributor of the device represents will provide higher fuel economy than would
have resulted with the automobile as originally equipped, as determined under regulations
of the Administrator of the Environmental Protection Agency. The term also includes fuel
additives for use in an automobile. The term retrofit device or device excludes flow mea-
suring instruments or other driving aids, and lubricants and lubricant additives.2

All fuel additives require registration with EPA's Fuel and Energy Division (FED). It
should also be noted that many of the fuel line devices and liquids sold and associated with
vapor bleed devices may be considered additives for the purpose of registration.

The role of the program is the generation, analysis and dissemination of technical data, and
is not an approval or certification of retrofit devices. Through engineering and/or statisti-
cal analysis of data from vehicle tests, the evaluation program will determine the effects on
fuel economy, exhaust emissions, durability and drive ability of the applicable vehicles due
to the installation or use of the device. Data generated in an evaluation are public informa-
tion and will be published in the Federal Register and elsewhere for use by the FTC and the
public.3
1. 40 CFR 610.11
2. 40 CFR 610.11 (i); 49 USC Sec 32918
3. 40 CFR 610.10
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This document is intended to assist inventors desiring to apply for an EPA evaluation of
their product. It outlines the application format, describes essential independent laboratory
test data submission requirements, explains test policy and basic test sequences and de-
scribes EPA test cost estimates. Applicable regulations for the program are found in:
42 USC 7525, 49 USC 32918 and 40 CFR 610.

EPA will not comment on the merits, or lack of them, of any device without a formal appli-
cation. Applications must contain complete independent test laboratory test reports which
demonstrate a statistically significant improvement in fuel economy and/or emissions
reduction (see the application discussion for details).

EPA will provide technical assistance in designing the test program to be performed at an
independent laboratory. For confirmatory testing at its laboratory, EPA develops the test
program in coordination with the applicant, analyzes the test results, and writes an official
report summarizing the results in the Federal Register. Reports are available to the general
public through the National Technical Information Service (NTIS), the Federal Trade Com-
mission (FTC) and elsewhere. All tested devices are recorded in the "EPA Listing of Fuel
Economy Devices" found in the appendix of this document.

General Comments

EPA recommends that device manufacturers carefully consider all the following elements
when applying for evaluation:

Test Laboratory Independence - 40 CFR 610.11 (a) (20)  of Federal Regulations states that test
laboratories "shall have no financial interests in the outcome of these tests other than a fee
charged for each test performed", and that "independence of the testing agent" will be
considered in determining the validity of manufacturer furnished test data. Applicants
must confirm that the selected laboratory has no vested financial interest in the outcome of
the tests prior to the start of testing. (A list of laboratories is provided in the appendix.)

Acceptable Test Formats

The only acceptable test procedures are the Federal Test Procedure (FTP), the simulated
city drive trace used for emissions testing, and the Highway Fuel Economy Test (HFET),
the simulated highway drive test for fuel economy calculation. Inspection and Maintenance
(I/M) test data as used in state programs or any other test formats are not acceptable and
should not be included with an application.

Minimum Test Requirements - Although some devices may require more complex test
plans, the minimum for fuel economy effect  requires two vehicles with triplicate test se-
quences in each configuration for each vehicle. The vehicles should be selected from differ-
ent manufacturers and should be representative of the largest selling engine/transmission
combinations in the United States.  Each vehicle must be set to its manufacturer's tune-up
specifications for baseline tests. Baseline emissions and fuel economy should be near the
levels at which the vehicles were certified.

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Test sequences are conducted in "back-to-back" fashion. Minimum testing requirements
are as follows: (a) If device installation does not involve adjustment of original vehicle
manufacturer specifications (e.g., timing, fuel-air mixture, choke or idle speed, etc.), then
conduct triplicate tests with the vehicle in baseline condition, and triplicate tests with the
device installed with no vehicle adjustments between tests,  (b) If installation of the device
also involves adjustments (e.g., timing, fuel-air mixture, choke or idle speed, etc.), then
conduct triplicate tests with the vehicle in baseline condition, triplicate tests with the ad-
justments and the device  installed, and then conduct triplicate tests with only these adjust-
ments. If mileage accumulation is necessary to realize the full benefit, or to determine
whether the vehicle meets emission standards, the same number of miles that were accu-
mulated before the tests with the device must also be accumulated before baseline tests
without the device. In addition, the method of mileage accumulation should be kept
constant. In all test sequences three more baseline series must be performed after the de-
vice has been removed to confirm there are no post-use negative effects on performance.

Confirmatory tests performed by EPA will include the complete FTP (40 CFR Part 86). This
is the only valid test used to evaluate devices for emission effects. As a final requirement,
the personnel of the independent laboratory selected for screening tests should perform
every element of the applicant's test plan including preparation of the test vehicle,  adjust-
ment of parameters, and installation of the device.

Submission of Data - Section 610.16(b)(5) of Federal Regulations requires all test data ob-
tained from the independent laboratories in support of the application be submitted to
EPA including any results declared void or invalid by the laboratory. We also ask that,
prior to the screening tests, applicants provide EPA with the name  of the laboratory, test
date schedule, and tests to be conducted. Applicants should allow EPA to contact the
laboratory during testing, and allow them to directly answer any EPA questions about the
test program.

Complete test reports from the independent test laboratory must be included with any
application. All test vehicle information must be furnished; this  includes the manufacturer
name,  model year, car line, vehicle identification number (VIN), engine family code,  and
evaporative family code.  The inertia weight, road load horsepower with corresponding
dynamometer setting, fuel used, method for loading the evaporative canister, any special
test requirements from the original vehicle certification (e.g., auxiliary cooling), and the
vehicle prep information  must also be included in the report.

Test Costs - Minimum testing at EPA's laboratory requires three tests in baseline configura-
tion, three with the device and three baseline configuration tests after removal of the de-
vice. The minimum cost for two different vehicles in this test format is $27,000. Additions
to the minimum test plan, such as providing test vehicles, mileage accumulation, param-
eter adjustment, or additional testing, etc. will increase cost. EPA will provide a specific
cost based on the test requirements for individual device evaluations. EPA, however, does
not charge applicants for  consultation or report writing time.

Applicants should consult an independent test laboratory for their respective cost esti-
mates.

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Test Results - EPA confirmatory tests will only be performed on devices which have dem-
onstrated statistically significant fuel economy or emissions benefits based on the indepen-
dent laboratory test report. From our experience, most of the products in this program are
designed to improve fuel economy. For a minimum test plan to evaluate the impact on fuel
economy, a fleet of two cars should be tested in triplicate. If a minimum five percent differ-
ence in average fuel economy is shown, one may usually conclude with reasonable confi-
dence that a real improvement exists.  (Analysis by EPA for potential fuel economy effects
will be based on actual test results and test variability, not these guidelines.)

If the device is primarily intended to reduce one or more of the EPA regulated exhaust
emissions (e.g., carbon monoxide, oxides of nitrogen and hydrocarbons), then the number
of tests needed to prove a reduction is heavily dependent on the amount  of the reduction
and other factors. The test variations for these compounds are usually greater than those
for carbon dioxide which is the primary constituent in the fuel economy calculation. In
such cases, EPA will work with the applicant on a per situation basis to develop an appro-
priate test plan.

Submitted data and information labeled confidential or proprietary must be justified on a
case-by-case basis by the applicant. EPA can not treat test results, including those con-
ducted by independent or other laboratories, as confidential since applicable laws (42
U.S.C. 7525 and 49 U.S.C. 32918) require disclosure of such information.  (EPA may not
perform an evaluation of a  device if it judges it cannot develop a technically sound final
report because an applicant declares information is confidential.)

EPA will request further information for incomplete applications. If confirmation tests are
required, EPA will advise applicants of costs and provide applicants with the opportunity
to review the test plan. Once testing is completed, an evaluation report will be written on
the  basis of independent test data submitted, EPA test data, and EPA engineering analysis.

EPA does not acknowledge the receipt of applications but attempts to respond with full
comments to the applicant  within thirty days. The EPA confirmatory test program requires
very precise scheduling,  and is dependent on the applicant's prompt response to requests
for further information. Failure to respond in a timely manner will delay the process.
Furthermore, scheduling device evaluation tests may be delayed due to higher priority test
programs at certain times of the calendar year (e.g., certification of new model year ve-
hicles, etc.).

If the applicant does not  complete requested independent lab tests and submit data to  EPA,
or does not respond to requests for further information within a six month period (180
days) after EPA develops the test program, it will be considered a withdrawal from the
program. A flow chart outlining the steps in the evaluation process is found in the appen-
dix.

Once a test pain has been signed by the applicant and the receipt of test cost funds have
been confirmed EPA will schedule tests. Completion of all tests and the issuance of the final
report may take up to twelve months.

In October 1994, EPA issued a final rule setting interim and final standards for detergent

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use in gasoline. To maintain the integrity of the rule, EPA requires that applicants for
aftermarket fuel additive evaluation must provide information demonstrating that the
additive has no adverse effect on the deposit control properties of gasoline, EPA will not
accept applications for fuel additive evaluation program without this information.

Applicants are cautioned that the installation of an aftermarket retrofit device, or use of a
fuel additive (Applicants should contact EPA's FED at 202-564-9755 to register fuel addi-
tives), raises the issue of tampering liability and the potential for civil fines of up to $25,000
(see page 19). In the past, one approach for a device or additive manufacturer to address
the tampering issue was to demonstrate by durability, aging, and FTP tests that the device
did not increase vehicle emissions over its useful life. However, beginning with 1994 mod-
els, vehicle manufacturers must provide an onboard emission diagnostic capability for
their vehicles. As a consequence, applicants must insure that, besides not adversely affect-
ing vehicle emissions, their device or additive must not render inoperative, degrade, or
defeat the operation of vehicle onboard diagnostic systems.

EPA trusts that this information will aid in the preparation of an acceptable application for
evaluation of a device. The Device Evaluation Team will be the contact in the application
process and  any subsequent EPA evaluation. Our address is:
            Device Evaluation Program
            EPA, National Vehicle and Fuel Emissions Laboratory
            2000 Traverwood Drive
            Ann Arbor, Michigan 48105
            Telephone: (734) 214-4925
            Internet: banush.russell@epamail.epa.gov
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           DEVICE EVALUATION APPLICATION FORMAT

Applications for EPA evaluation of retrofit and aftermarket fuel additives devices should
use the following format (There is no application form as such.):

1.     Title:

      Application for Evaluation of (Name of Product) in the EPA Motor Vehicle
      Aftermarket Retrofit Device Evaluation Program.

2.     Identification Information:

      a.  Marketing Identification:

      Trade name, marketing name, trade mark, or other methods which are (or will be)
      used to identify the product.  Include model numbers and/or other designations
      where appropriate.

      b.  Inventor and Patent Protection:

        (1) Name and address of the inventor.
        (2) One complete copy of the patent or patent application.

      c. Applicant:

        (1) Name and address of the individual or corporation applying for this
      evaluation.
        (2) Principal officers and/or owners of this organization.
        (3) The person(s) who are authorized to represent the organization in
            communications with the EPA.  Include name, mailing address, FAX, e-mail
            address, and telephone number.

      d.  Manufacturer:

        (1) Name and address of the individual or corporation who is (or will be)
            manufacturing the product.
        (2) Principal officers and/or owners of this organization.

3.     Description:

      a.  Purpose:

            Purpose and/or objective of the product.

      b.  Applicability:

        (1)  Provide a statement indicating which types or groups of vehicles for which

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            the product is, or is not, applicable.  The statement should include make,
            model and year, engine size, ignition type, fuel delivery, and transmission
            type. If the product is (or will be) marketed in different sizes and/or
            calibrations, identify which models correspond to which type of vehicle.

        (2)  Provide a statement describing other conditions for which the product is, or is
            not, applicable. The statement should address weather conditions, types of
            driving, topographical differences, etc.

      c. Theory of Operation:

      Provide a detailed description of the theory and principles of operation for the
      product in sufficient detail to permit technical personnel at EPA to understand the
      theory of operation.

      d. Construction and Operation:

      A detailed description of the product itself, including drawings and/or schematics,
      should be included.

      e. Specific Claims:

      Specific claims made in advertising, sales literature, packaging and installation
      instructions as they relate to improvements in fuel economy, emissions, driveability,
      etc., should be provided. Test data to support these claims must be included with
      the application.

      f. Cost and Marketing:

      Provide suggested retail price and methods used to market the product. This
      discussion should also identify the stage of the development of the product or state
      that it is in production or is ready for production.

4.     Installation:

      a. Equipment:

      Provide installation instructions for the product to include those for general and
      special applications. Indicate tools, equipment and skills required. Advise
      adjustments required to the vehicle or the product upon installation.

      b.  Operation:

      Furnish a copy of the consumer's operating instructions with details on maintenance
      procedures, service intervals, and basic diagnostics.
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      Provide ail available information regarding use of the product which could result in
      unsafe conditions for the vehicle, its occupants, or persons or property in close
      proximity. This information should also address situations where the product is not
      in use or has malfunctioned in some way.

      d. Maintenance:

      Include maintenance procedures and scheduled maintenance required to ensure the
      correct operation of the product.  List tools, equipment, and skills required to
      perform maintenance.  Also, describe how the use of the product will affect the
      normal maintenance schedule for the vehicle.

5.  Effects on Emissions and Fuel Economy:

      a. Regulated Emissions and Fuel Economy:

      Furnish all information related to the product and its effects on regulated emissions
      and fuel economy* obtained through screening tests at an independent laboratory
      which conforms with applicable regulations for emissions and fuel economy testing.
      Regulated exhaust emissions include unburned hydrocarbons, carbon monoxide,
      oxides of nitrogen, and particulate (diesel vehicles only).  Unburned hydrocarbons
      in the form of evaporative emissions are also regulated. This information may be
      obtained through testing or as a result of an engineering evaluation of the product.
      It should also address the effects of the product when it is not in use or during
      typical modes of failure.

      b. Unregulated Emissions:

      Provide all information related to the effect of the product on types of pollutants
      other than those regulated by EPA.

6. Testing

      The actual test plans required to properly evaluate the worth of a product vary
      widely although the basic premise of any plan is that it is able to accurately define
      benefits due solely to the product. In some cases, this requires only duplicate tests
      on two vehicles with and without the product. For products which require
      adjustments of engine parameters, such as timing or mixture, a third set of tests with
      only these adjustments is also required. In any case, an acceptable test plan can be
      developed in consultation with EPA before or after the remainder of this application
      is submitted.

*Thc FTP (40 CFR Part 86) is the primary test for vehicle emissions. The FTP and the Highway Fuel Economy
Test (HFET, 40 CFR Part 600) are the only tests recognized by EPA for evaluating fuel economy of light-duty
vehicles.  Data which have been collected in accordance with other standardized procedures may be used to
supplement results from the FTP and HFET and will be considered in EPA's evaluation of the product.

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EPA RETROFIT AND EMISSION CONTROL DEVICE EVALUATION TEST POLICY

General

Applicants must provide EPA with all information necessary to describe and explain the
functioning of the device or engine.  The information must include the theory of operation,
drawings and schematic diagrams. In addition, any standard test data performance on the
device that demonstrate the emission and fuel economy performance of the system should
be provided. The FTP is the only test which is recognized by EPA for the evaluation of
vehicle emissions; data generated in accordance with the FTP are essential for the
evaluation of a device. The HFET will be used for all fuel economy improvement claims.

EPA engineering staff will make a preliminary evaluation of a device based on information
supplied in the application. If testing has  not been performed when the application is first
filed, EPA will determine if testing of the device is needed or warranted. If the conduct of
testing would not, in the professional judgment of EPA engineers, support the claims for
the device and its cost would represent an unprofitable drain on the applicant's resources,
EPA will so advise. However, if the applicant elects, EPA will proceed with the
development of a test program, i.e., a program for testing by an independent laboratory.
The applicant will select a technically competent independent laboratory to test the device
in accordance with the EPA developed test program at the applicant's expense. A list of
laboratories is provided in the appendix of this document.

If further testing beyond that initially performed by an independent laboratory is needed to
make an evaluation, EPA engineering staff will work with applicants to design a test
program to be performed by EPA to validate the device's effectiveness.

Size of Test Sample

Sample size is one major determinant of testing cost. It may range from two vehicles to 100
vehicles, depending upon the type and variability of the effects that are being measured,
and on the accuracy and applicability of the final conclusions which are necessary. EPA
provides specific cost information for the required tests to be conducted at its laboratory.

Conclusions drawn from small samples have limited applicability. A complete evaluation
of the effectiveness of devices on the many different types of vehicles that are in actual use
requires a  large sample. The conclusions from small tests may be quantitatively valid only
for the specific test cars  used. However, it is often possible to extrapolate test results to
other vehicle types to suggest that similar results may be expected.

Applicants must pay the costs for the device, vehicle procurement and other costs incurred
by the testing laboratory. There is no charge for EPA's preliminary evaluation and
subsequent analyses, but the applicant must provide funds to cover the cost of any
confirmatory testing deemed necessary in the EPA lab. EPA will not conduct confirmatory
tests without having adequate screening test results from an independent laboratory, and
confirmation that funds to cover EPA testing costs have been received by the appropriate
EPA accounting office.

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Conduct of Tests

Test vehicles will be evaluated in at least three configurations: one with the vehicles
adjusted to the original manufacturer's specification, one with the device installed on the
vehicles, and one with the device removed and returned to baseline.  If any test vehicle
engine parameters (such as ignition timing or idle mixture) are different from manufacturer
specification when the device is installed, the vehicle will also need to be tested with the
equivalent changes to engine parameters without the device installed. If a prototype
engine rather than a device for retrofit to existing engines is tested, the vehicle is adjusted
to the design specifications.

Emission tests will be run by a laboratory using the equipment specified in 40 CFR Part 86
for the FTP. As a minimum requirement, a laboratory must have a chassis dynamometer
capable of reproducing road load and vehicle inertia weight,  a constant volume sampling
system and the following types of analyzers for measurement of exhaust emissions:

                   Hydrocarbon - flame ionization detector
                   Carbon monoxide and carbon dioxide - nondispersive infrared
                   Oxides of nitrogen - chemiluminescence

Any intrusion into the fuel delivery system to install a device also requires the diurnal
portion of the FTP.

Evaluations conducted in the EPA test program are for the purpose of demonstrating the
effectiveness of developed devices and are not to be construed as development testing.
All development work must precede EPA evaluation. The applicant will not be permitted
to make adjustments to the test vehicle or to the device except to repair malfunctions. Such
repairs will be permitted at the discretion of the EPA test engineer.

EPA engineering staff will prepare a draft report on the evaluation of the device for
applicant review to ensure accuracy of the information describing the device. The
developer should transmit comments to EPA promptly. Final test reports are distributed
upon request to technical personnel in federal and state governments, private industry,
universities and are also available to the general public through the National Technical
Information Service (NTIS).

Applicants may cite final EPA reports (but not draft reports) to indicate the exhaust
emission and fuel economy levels attained with the device, but the developer may not
claim that the EPA report constitutes approval, certification, endorsement or registration.
Cases of misrepresentation of EPA evaluation reports will be referred to the Department of
Justice and/or the Federal Trade Commission, as appropriate.
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            BASIC TEST PLANS AND TESTING SEQUENCE

General

Device and engine evaluation tests conducted by EPA generally include measurement of
two, or more, of the following items:

      1. gaseous emissions
      2. particulate and other emissions

      4. power/acceleration/driveability

Regulated gaseous emissions are unburned hydrocarbons (HC), carbon monoxide (CO),
oxides of nitrogen (NOx) and particulate. Other emissions currently unregulated by EPA
may be recorded for investigative purposes.

Other emissions include such things as sulfates, aldehydes and smoke from diesei-powered
vehicles. These emissions are generally not measured as part of a routine device
evaluation. They may be measured if the control system or engine being tested contribute
to such emissions.

Exhaust emissions are measured in the FTP where vehicles are driven on a chassis
dynamometer to simulate urban driving (see Figure 1).  This is the same test used for the
certification of all light duty vehicles.

Fuel economy is measured on a chassis dynamometer reproducing typical urban and
highway driving speeds and loads. Urban fuel economy is measured during the FTP, and
highway fuel economy is measured during the HFET. The fuel economy of the test vehicle
is calculated from the exhaust emission data using a carbon balance method (see page 18).

Engine power may be measured on a chassis dynamometer. Power is usually not
measured  unless a device is expected to have a significant effect on engine power output.
Engine power may also be measured to substantiate power output claims made for
prototype  engines.

Acceleration times (0-60, 30-50 mph, etc.) may be measured either on the road or on a
chassis dynamometer. Driveability may be evaluated by the test engineer based on the
behavior of the test vehicle during the dynamometer testing or under actual road
conditions.
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                                                       Figure 1. - Vehicle on a
                                                                Dynamometer
Driving Schedules

City Driving Cycle (FTP) - The Urban Dynamometer Driving Schedule, or LA-4, is the
result of more than 10 years of effort by various groups to translate the Los Angeles
smog-producing driving conditions to dynamometer operations. The LA-4 is derived from
data taken from a vehicle driving under actual city traffic conditions, so it is typical of a
vehicle operating in an urban environment (see drive cycles in the appendix). It is a
nonrepetitive driving cycle covering 7.5 miles in 1372 seconds at an average speed of about
20 mph. During the FTP, the first 505 seconds of the LA-4 are rerun following the hot start
of the engine so the distance traveled during a full FTP is 11.1 miles, and the average speed
is 21.6 mph. However, the emissions collected during the 11.1 mile trip are mathematically
reweighed to represent the results of two 7.5 mile trips made from hot and cold starts with
average speeds of about 20 mph. The maximum speed attained during the LA-4 cycle (or
FTP) is 56.7 mph.

EPA Highway Cycle (HFET) - Since the LA-4 does not represent the type of driving done in
nonurban areas, especially on highways, a driving cycle to assess highway fuel economy
was developed by the EPA. The EPA Highway Cycle was constructed from actual
speed-versus-time traces generated by an instrumented test car driven over a variety of
nonurban roads, and preserves the nonsteady-state characteristics of real-world driving.
The average speed of the cycle is 48.2 mph, the maximum speed is 59.0 mph, and the cycle
length is 10.2 miles, close to the average nonurban trip length.

Steady-States - Constant speed, road load tests are not routinely conducted on prototype
systems. Many vehicle operation surveys conducted by EPA and others have clearly shown
that true steady-state  operation rarely occurs in customer use. If steady-state data are
collected, they must be interpreted cautiously because the vehicle is being exercised in an
unrepresentative manner.
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October, 1998

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Testing Procedures

A chassis dynamometer is employed to reproduce vehicle inertia and road load. Inertia,
representing the vehicle weight, is simulated either by flywheel or electric generator, and it
is selected in 125-pound increments between 1000 pounds and 4000 pounds, in 250-pound
increments between 4000 pounds and 6000 pounds, and in 500-pound increments between
6000 pounds and 8500 pounds (vehicles greater than 6000 pounds are not tested in this
program; see reference 1.). Roadload represents rolling resistance and aerodynamic drag
and is simulated either by a water brake or electric generator.

The vehicle's exhaust is collected, diluted and thoroughly mixed with filtered background
air to a known constant volume flow using a positive displacement pump or a critical flow
venturi. This procedure is known as Constant Volume Sampling (CVS). A proportional
sample of the diluted exhaust is collected in a sample bag for analysis at the end of the test.

On the day prior to the scheduled FTP, the test vehicle is prepared by driving over the
urban driving schedule (LA-4) on a dynamometer. This "prep" drive is performed to insure
that all vehicles have been driven in a similar manner on the day preceding the exhaust
emission test. After the prep drive, the vehicle must be  parked for at least 12 hours  in an
area where the temperature is maintained between 68 and 86 degrees F. This period is
referred to as the "cold" soak.

The FTP is a cold start test in which the test vehicle is pushed onto the dynamometer
without starting the engine. After placement of the vehicle on the dynamometer, the
emission collection system is attached to the tailpipe, and a cooling fan is placed in front of
the vehicle. The emission test is run with the engine compartment hood open.

The emission sampling system is started immediately prior to starting the engine of the test
vehicle so that emissions are collected during engine cranking. After starting the engine,
the driver follows the Urban Dynamometer Driving Schedule (UDDS) or LA-4. The driving
schedule is displayed to the driver of the test vehicle who matches the vehicle speed to that
displayed on the schedule. At the end of the driving cycle, the engine is stopped, the
cooling fan and sample collection system are shut off, and the hood is closed. The vehicle
remains on the dynamometer and soaks for 10 minutes. This is the "hot" soak preceding
the hot start portion of the test. At the end often minutes, the vehicle and CVS are again
restarted and the vehicle is driven through the first 505 seconds (3.59 miles) of the LA-4
cycle. (EPA drive cycle graphs are found in the appendix.)

Exhaust emissions measured during the FTP cover three regimes of engine operation.  The
exhaust emissions during the first 505 seconds of the test are the "cold transient" emissions.
During this period, the vehicle gradually warms up as it is driven over the LA-4 cycle.  The
emissions during this period will show the effects of any fuel enrichment associated with a
"cold" start and vehicle warm-up characteristics. When the vehicle enters the remaining
867 seconds of the LA-4 cycle, it is considered to be fully warmed up.  The emissions
during this portion of the test are the "stabilized" emissions. The final period of the test,
following the hot soak, is the "hot transient"  section, and shows the effect of the hot start.
A sample of the emissions from each of the three portions of the test are collected in
separate bags.
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After completion of the FTP, the vehicle is tested in the HFET. A warm-up Highway Cycle
is run before the actual HFET to insure that the vehicle drivetrain is at full operating
temperature.

If intrusion into the fuel delivery system is necessary to install the device, the diurnal
portion of the FTP may be required. A complete description of this procedure can be found
in 40 CFR Part 86 and 40 CFR Part 600. Evaluation tests made by EPA usually do not
include measurement of evaporative emissions.

Sample Collection and Analysis

A Constant Volume Sampler (CVS) is used to collect exhaust emissions. Vehicle exhaust is
transported from the tailpipe to a dilution box where it mixes with filtered background air.
After passing through the heat exchanger, a sample of the exhaust mixture is drawn off and
collected in a bag constructed of an impermeable, chemically inert substance. A sample of
the background air is taken concurrently with the exhaust sample. Most sampling systems
presently use a critical flow venturi to control the flow rate of the exhaust mixture (see the
CVS diagram in the appendix).

The driver of the test vehicle operates the CVS using a remote control unit with which he
can start sampling at the beginning of the FTP, switch from the cold transient to the
stabilized sample bag at 505 seconds, and stop sampling at the end of the test.

After a sample has been collected, it is taken to an analyzer where the concentrations of
HC, CO,  CO2 and NOx in the sample bag are determined. The analytical system provides
for the determination of hydrocarbon concentrations by flame ionization detector (FID)
analysis,  carbon monoxide and  carbon dioxide concentrations by nondispersive infrared
(NDIR) analysis and oxides of nitrogen concentrations by chemiluminescence (CL)
analysis.

Calculations

To correct for background levels of HC, CO, COz, and NOx in the dilution air, the
concentrations in the background bags are subtracted from the concentrations in the
sample bags.  The resultant values are referred to as corrected concentrations.  The mass of
each pollutant (HC, CO and NOx) is calculated from the corrected concentration and the
total volume flow during each of the three test phases and the density of each compound.

Once the mass emissions for each test phase are known, the emissions in grams per mile
are calculated using the following formula:

      Ywrri = 0.43 (Yet + Ys) / (Dct + Ds)  +  0.57 (Yht + Ys) / (Dh + Ds)
Where:
      Ywm = weighted mass emissions of each pollutant, i.e., HC, CO, or  NOx in grams
      per vehicle mile.
                                   14                                 October, 1998

-------
      Yet  = mass emissions as calculated from the "transient" phase of the cold start test,
            in grams per test phase,

      Yht = mass emission as calculated from the "transient phase of the hot start test, in
            grams per test phase.

      Ys  = mass emission as calculated from the "stabilized" phase of the cold start test,
            in grams per test phase,

      Dct  = The measured driving distance from the "transient" phase of the cold start
            test, in miles.

      Dht  = The measured distance from the "transient" phase of the hot  start test, in
            miles.

      Ds  	The measured driving distance from the "stabilized" phase of the cold start
            test, in miles.

The cold start and hot start portions of the test are weighted 0.43 and 0.57 respectively.

Detailed explanations of the calculations can be found in the Federal Register,

Fuel Economy (see the appendix for the calculation formula)

Fuel economy is measured by a carbon balance method. The carbon  balance procedure for
measuring fuel economy relates the carbon products in the vehicle exhaust to the amount
of fuel burned during the test. The major factors in using this technique are:

1. Carbon from HC, CO, and CC>2 is the only significant carbon source considered in the
exhaust (minor amounts from other compounds are insignificant). Other carbon containing
compounds, such as oxygenated hydrocarbons (undetected by flame ionization) and
carbonaceous particulates, are ignored for gasoline and diesel fuels.  The use of alternative
fuels (ethanol, methanol, etc.) would dictate the analysis of oxygenated hydrocarbons.

2. All of the carbon that is measured in the exhaust in the form of HC, CO and CO2 comes
from the fuel; there are no other sources of carbon.

3. All of the fuel consumed during the test can be accounted for by the carbon in the
exhaust. This means that all of the fuel leaving the tank is assumed to pass  through the
engine and that no carbon leaks out of the exhaust system before being analyzed or
evaporated from the vehicle.

Since the carbon weight fraction of the fuel is known, it is a simple matter to calculate the
amount of fuel consumed during the test. Agreement between the carbon balance method
and direct fuel consumption measurement is normally within two percent.
                                      15                                October, 1998

-------
Test Fuels

EPA testing uses a specially formulated standard test fuel having a minimum research
octane of 96 . The fuel specifications must fall within certain limits set by the EPA. Tight
control of fuel quality eliminates fuel as a source of test variability in certification tests.
There is no reason to expect that the emission characteristics from a vehicle running on this
test fuel would be significantly different from those obtaine from running on a summer
grade of commercial pump gasoline.

Other Emissions

Occasionally, it is necessary to test vehicles for emissions other than those that have
already been discussed. Emissions that may be measured include oxygenated compounds
and specific reactive and nonreactive hydrocarbons.

Power. Driveability. Durability

Relative engine power output can be measured on a chassis dynamometer. Power output
can be determined for any engine speed including the maximum engine power point.

Driveability is evaluated by the test engineer. Items to be considered include acceleration,
cold start performance, tendency to stumble or hesitate, surge, and hot start performance.

Comments about the expected durability of a device or prototype engine will be based on
several considerations. Among these are exposure of the control system to severe
operating conditions and previously demonstrated durability of similar systems.

Narrative Description - Sequence of Evaluation

Obtain and Prepare  Vehicles - At least two vehicles are to be tested. They should represent
the models for which the device or additive is to be advertised and sold. Each vehicle must
be in proper operating condition and safe to operate on the dynamometer. The vehicles
must be adjusted to  the manufacturer's specifications before beginning the test sequence.
A complete tune-up (including oil and filter change) is recommended before beginning a
program which includes mileage accumulation.  Vehicle preparation consists of installing
the tailpipe adapter (s), inflating tires and removing wheel covers.

Mileage Accumulation - This is a type of preconditioning which may be an important part
of the evaluation. It  must be conducted in exactly the same manner at each point in the test
plan. Mileage may be accumulated on the road or in the laboratory, but it should
approximate  typical driving.

Device Test

Installation - The device or additive is to be installed (or introduced) in accordance with the
printed instructions  which accompany the product. Parameter adjustments may be made
as directed. Applicants may observe the process, but the actual effort is to be either carried

                                      16                               October, 1998

-------
out by laboratory personnel or by an independent person under the supervision of
laboratory personnel. Any problems with the installation should be noted,

Remove Device - At this point, the device is to be removed, but parameters which were
adjusted are not to be changed. The purpose of this portion of the sequence is to address
the effect of only parameter adjustments on the levels of emissions and fuel economy.

De-Prep Vehicles - Once the testing is complete and all tests have been validated, the
vehicles may be restored to their original condition. Deflate the tires to the appropriate
pressure, install the hubcaps and remove the tailpipe adapter.

Assemble Data - Gather all the results and other documents together into one package.
Prepare a concise report which summarizes the conduct and results of the project.

Narrative Description - Sequence of Testing

Check Basic Parameters - With the vehicle at normal operating temperature, measure and
record values for basic timing, idle  rpm, idle HC and idle CO. Emissions measurements
should be made in both neutral and drive. The fuel tank should be filled to approximately
40% capacity.

Perform Cold Start FTP - This step begins with preconditioning on the dynamometer, or on
the road, and is followed by a 12 to 36 hour soak before the FTP. Except in special cases
where evaporative emission control may be affected, the Sealed Housing for Evaporative
Determination (SHED) phase of the test need not be conducted. However, all portions of
the test procedure at each point must be as close to identical as possible.  This includes the
type of preconditioning and soak time as well as the more obvious parameters such as
driver, test cell, dynamometer setting and starting procedures.

Precondition (HFET or LA-4 "hot start" Cycle) - A single driving cycle is used to precede a
Hot Start sequence. The test vehicle is to be at normal operating temperatures before-this
cycle. For this type of evaluation, the test vehicle itself may be used to warm up the
dynamometer and to set the horsepower.
                                     17                                October, 1998

-------
Perform Hot Start LA-4 - This test is 1372 seconds long and is to be run into two bags. It is
preceded by a 10 minute soak period.

Perform HFET - This is a single cycle which can be run immediately after the FTP or LA-4.
If a soak period is required, up to 20 minutes is allowed.  In this case, three minutes at 50
mph must be used for preconditioning.

Calculate Results - Assemble all strip charts, driver's traces, computer outputs and other
documentation into a single package.  Review the packet to ensure validity of the test.
Calculate and record the results in grams per mile and miles per gallon.
Fuel Economy Calculation
To calculate fuel ecomomy, in miles per
gallon (MPG), from an emission test, the
following equation applies:
Miles
gms carbon/gal of fuel  (A-l)
Gallon    gms carbon in exhaust/mile


The carbon in the fuel is:

grains Cfbel =

grams fuel    molecular weight C  (A-2)
	 x 	
gallon       molecular weight fuel

        - (2798) x (.866) - 2423
where 2798 is the mean density of EPA test
gasoline, in gnis/gallon, and 0.866 is the
weight fraction of carbon in the fuel.
The carbon in the exhaust is contained in the
unburned fuel hydrocarbons (HC), carbom
monoxide (CO), and carbon dioxide (CO2), as
follows:
                  mol. wt. C  (A-3)
grams CHC = gms 11C x
                  mol. wt. 1IC
                                = gms HC x (.866)
                                                     mol. wt. C  (A-4)
                                   grams Ceo = gra CO x
                                            mol. wt. CO
                               - gms CO x (.429)
                                             mol. wt C (A-5)
                          grams CcOz = gms CQz x .
                                             mol. wt. CO2
                                - gms CO2 x (.273)
                                   So. we have :
                                   Miles
                                   Gallon
                                         2423 /
                                   (.866 gm I1C - .429 gms CO + .273 gms CO2)

                                               / miles traveled
                                                                      MPG -
                                                                    2423 x miles traveled
                                                                                        (A-6)
 (.866 gm HC ~ .429 gm CO -I- .273 gm CO2)


Example:

In a 10 mile test, a car's exhaust emission
measurements show the following amounts of
carbon compounds:

        HC  - 9 grams
        CO  = 124 grams
        CO2  = 3641 grams

Using equation A-6, the fuel economy is:

MPG -

           2423 x10

   (.866)(9) - (.429)(124) + (.273)(3641)

           24.230
                                                                    7.8 + 53.1 +993.7
                                                                               23.0 MPG
                                                                                        October, 1998

-------
Potential Tampering Liability Associated with Fuel Economy Retrofit Devices
The federal tampering prohibition is contained in section 203 (a) (3) of the Clean Air Act
(Act), 42 U.S.C. 7522 (a) (3). Section 203 (a) (3) (A) of the Act prohibits any person from
removing or rendering inoperative any device or element of design installed on or in any
motor vehicle in compliance with regulations under Title II of the Act (i.e., regulations
requiring certification that vehicles meet federal emissions standards).  The maximum civil
penalty for a violation of this section by a manufacturer or dealer is $25,000; for any other
person, $2,500.

Section 203 (a) (3) (B) of the Act prohibits any person from manufacturing or selling, or
offering to sell, or installing, any part or component intended for use with, or as part of,
any motor vehicle or motor vehicle engine where a principal effect of the part or
component is to bypass, defeat, or render inoperative any device or element of design
installed on or in a motor vehicle or motor vehicle engine, and where the person knows or
should know that such part or component is being offered for sale or is being installed for
such use. The maximum  civil penalty for a violation of this section is $2,500.

Installing any device, system or part(s) which affect the fuel delivery rate or the
combustion process would be expected to affect elements of design of the emissions control
system. Accordingly, any change from the original certified configuration of a vehicle such
as adding a system or parts that affect the fuel delivery rate or the combustion process,  or
the manufacture, sale of, or installation of, aftermarket parts or systems which are not
equivalent to the original equipment could be considered violations of section 203 (a) (3) of
the Act. However, EPA has established an enforcement policy, Mobile Source Enforcement
Memorandum No. 1A (Memorandum  1A), to provide guidance to the public to reduce  the
uncertainty regarding potential liability under section 203 (a) (3) of the Act for using or
selling aftermarket parts or systems, or making adjustments or alterations to parts or
system parameters.

Basically, Memorandum 1A states that EPA will not consider any modification to a
certified emissions control configuration to be a violation of the tampering prohibition if
there is a reasonable basis for knowing that emissions are not adversely affected. In many
cases, durability aging and emissions testing according to the FTP would be necessary to
make this determination.

There are two different methods for establishing a reasonable basis for knowing that
emissions are not adversely affected by the installation of a retrofit device: 1) the installer
knows of, or the manufacturer of the device represents in writing, that FTP emission tests
have been performed as prescribed in 40 CFR 86 showing that the device does not cause
similar vehicles to fail to meet 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 to the geographic area over which
that agency has jurisdiction. Some states, such as California, have additional reuirements.

If the results of EPA emission testing of a retrofit device show that any of the regulated

                                     19                                October, 1998

-------
emissions increase (even though other regulated emissions may have decreased), EPA will
publish a Federal Register Notice (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.

EPA does not have a mandatory, formal program to evaluate and make determinations of
compliance of aftermarket parts with Memorandum 1 A. Although EPA has informally
evaluated compliance information in the past, because of current budget cuts and resource
constraints we are not routinely reviewing information showing compliance with
Memorandum 1A . While compliance with Memorandum 1A is required, submission of
the information to us is not required unless we request the information to verify
compliance. We emphasize, however, that our lack of review of the information does not
relieve any one from responsibility to comply with Memorandum 1A or liability for
violations of section 203 (a) (3) and Memorandum 1A.

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 the durability of the emission control systems.

The EPA's National Vehicle and Fuel Emissions Laboratory does not make decisions as to
whether the installation of a particular retrofit device constitutes tampering with the
emission control system of a vehicle.  Questions regarding tampering or requests for
copies of Memorandum 1A are handled by:

            Steve Albrink            202-564-8997 (Washington, DC)
                                      20                              October, 1998

-------
                               Appendix
Subject                                                                         Page







I. Device Evaluation Process Flow Chart                                               22




II EPA Test Drive Cycles                                                           23




II. Constant Volume Sampler                                                         24




IIIList of Test Laboratories                                                          25




IV.List of EPA Evaluated Devices                                                    26
                                        21                               October, 1998

-------
 Manufacturer
 contacts EPA
      I
/[EPA
|k        Process Flow     Jj
EPA sends device
   package to
  manufacturer
   Application
    received
         Yes
EPA preliminary
    analysis
         Yes
 Send proposed
   test plan to
    applicant
         Yes
                     Yes
                     No
     Information
     .received.
 Reminder sent...
No response gets
cancellation letter
                     No
                                 EPA Requests
                                  information
                     No

Reminder sent...
No response gets
cancellation letter
I
No
k
                         Testing
                        conducted
                    Prepare report &
                     Federal Register
                         notice
                    Send report through
                    application process
                                                  Incorporate valid
                                                 applicant comments
                                                 Publish report &
                                                 Federal Register
                                                       notice
                      Completion
                    22
                                   October. 1998

-------
      EPA
          LA4 Drive Schedule
             (505)
(Sample Bags I & 3)
(Sample Bag 2)
  I	1	I  "I "I" I • I" I' fl
  HFET  Drive  Schedule
                    (See Page 17)
                                       o   o
                                       CO   C\J
                                       CD   r-~
                   23
                                         October. 1998

-------
               Ambient Air
                 Inlet
  Vehicle
  Exhaust
  Inlet
                                                          To Dilution Air
                                                          Sample Bag
                                                          To Exhaust
                                                          Sample Bag
                                         *~ Absolute Pres-
                                           sure Transducer
                                                     nubbelMptlhann1 Sample

                                                           " Formaldehyde Sample
   Critical Flow
   Venturi
                          Sensor
^
                                          t
CVS Compressor


          Blower
                                        Discharge v
               ^
Symbol Legend
    Flow Control
    Participate Filter
    Pump
 f   Flowmeter
©  Pressure Gauge
                     Figure 2  Constant Volume Sample Unit
                                   24
                                     October, 1998

-------
                                                         Test Laboratories
       Name of Laboratory
                                              Street
                                       Citi
St.
ZIP
Telephone
to
Ul
o
cr
o
   Alternative Fuels Laboratory-
   Auto. Club of Southern California
   Auto. Testing & Developm't Servs.
   Automotive Testing Labs.,Inc.
   Automotive Testing Labs.,Inc.
   Autoresearch Laboratories, Inc.
   California Analytic Instalments Inc.
   California Environmental Engring.
   Certified Emission Testing Laboratory Inc.
   Clean Air Vehicle Tech. Center
   Colorado School of Mines
   Colorado State University
   Compliance and Research Sendees
   Crane Emissions Laboratory
   Echlin Automotive Test Center
   EG&G Automotive Research. Inc.
   Environmental R & D Corp.
   Environmental Testing Corp.
   General Motors Corporation
   GM - LA Vehicle Emission Laboratory
   Mercedes-Benz Sendee Corp.
   Mich. Automotive Research Corp
   Nat. Inst.  for Petrol, Energy Res.
   NGV Development Company
   NGV Southeast Tech. Center
   Northern  California Diagnostic Laboratories
   NYC Dept of Envir. Protection
   Roush Emissions Laboratory-
   Siemens/Bendix Automotive Electronics
   Southwest Research Institute
   Testing Sendees Inc.
   Wallace Environmental Testing Lab

Updated 10/1997
6111HWY290East
2601 S. Figueroa St.
400 S. Etiwanda Ave.
263 S Mulberry St
P.O. Box 289
6735 S. Old Harlem Ave
1238 W. Grove Ave.
3231 S. Standard
15 Trade Zone Drive
26233 Executive Place

Dept. of Ind. Sciences
2 Garficld St
530 Fentress Blvd.
2155 StateSt.
5404 Handera
9607 Dr. Pern' Rd.
1859 Jasper Street
GM Proving Grounds, M/C 483-331-000
144 HCabrito Road
3953 Research Park Dr.
1254 N. Main
220 N.  Virginia
2250 Cherry Industrial Cir.
616 Highway 138
2748 Jefferson St.
75 Frost Street
12257 Market Street
2400 Executive Hills Dr.
6220 Culebra Road
200 W. Fifth St.
2140 Wirtcrest
Austin
Los Angeles
Ontario
Mesa
East Liberty
Chicago
Orange
Santa Anna
Ronkonkoma
Hayward
Golden
Fort Collins
Linden
Day tona Beach
Hamden
San Antonio
Ijamsvillc
Aurora
Milford
Panorama City
Ann Arbor
Ann Arbor
Bartlesville
Long Beach
Rrverdale
Napa
Brooklyn
Livonia
Auburn Hills
San Antonio
Lansdale
Houston
TX
CA
CA
AZ
OH
IL
CA
CA
NY
CA
CO
CO
NJ
FL
CT
TX
MD
CO
MI
CA
MI
MI
OK
CA
GA
CA
NY
MI
MI
TX
PA
TX
78723
90007
91761
85202
43319
60638
92665
92705
11779
94545
80401
80523
07036
32114
06517
78238
21754
80011
48380-3726
91402
48104
48107
74005
90805
30274
94558
11211
48150
48321
78284
19446
77055
(512) 452-1776
(213)741-3378
(909) 390-1100
(602) 649-7906
(513) 666-4351
(708) 563-0900
(714) 974-5560
(714) 545-9822
(516) 588-9666
(510)785-3100
(303) 273-3967
(303) 491-7240
(908) 925-5533
(904) 252-1151
(203) 777-7444
(210) 523-4603
(301) 607-4416
(303) 344-5470
(810) 685-5497
(818) 997-5500
(313) 995-3066
(313) 995-2544
(918) 337-4464
(310) 630-5768
(770) 907-5213
(707) 258-1753
(718) 388-4994
(313) 591-4310
(810) 253-1000
(210) 522-2646
(215) 362-1194
(713) 956-7705
    Note: EPA does not endorse, rate, or certify individual vehicle emission laboratories. It is the responsibility of the individual customer to evaluate a laboratory's current test capabili-
    ties and quality. Although this list is updated as we receive new information, other laboratories may exist that can perform emissions testing. For further information call the EPA
    National Vehicle and Fuel Emissions Laboratory at 313-668-4343.

-------

                 NAME
   ACDS Automotive Cylinder Deactivation System (2)
   ADAKS Vacuum Breaker Air Bleed
   Air-Jet Air Bleed
   Analube Synthetic Lubricant
   Aquablast Wyman Valve Air Bleed
   Atomized Vapor Injector
   Auto-Miser
   Autosaver
   AUTOTHERM (1) (circulates coolant for heater)
   Ball-Matic Air Bleed
   Basko Enginecoat
   Baur Condenser
   Berg Air Bleed
   BIAP Electronic Ignition Unit
   BRAKE-EZ
   Brisko PCV
   Bycosin
   Cyclone-Z
   Dresser Economizer
   Dresser Economizer
   Dynamix
   Econo Needle Air Bleed
   Econo-Jet Air Bleed Idle  Screws
   Econo-Mist Vacuum Vapor Injection System
   El-5 Fuel Additive
   Electro-Dyne Superchoke
   Energy Gas Saver
   Environmental Fuel Saver
   Filtron Urcthane Foam Filter
   Frantz Vapor Injection System
   Fuel Conservation Device
   Fuel Economizer
O  Fuel Max (2)
to
ON
O
cr
o
    Fuel Maximiser
    Fuelon Power
    FuelXpander
    Gas Meiser I
    Gas Saving Device
REPORT                 SOURCE
  PBS 1228 256                 NTIS
  PB 220 005                    NTIS
  PB 220 002                    NTIS
  PB 80 181 985                 NTIS
  PB81 113001                  NTIS
  PB 83 214 684                 NTIS
  EPA-AA-TEB-511-80-1         EPA
  PB 81 220 840                 NTIS
  PB 85 233 310                 NTTS
  PB 80 159 429                 NTIS
  PB 82 123 837                 NTIS
  EPA-AA-TEB-511-81-18        EPA
  PB 218 574                    NTIS
  PB 218 647                    NTIS
  EPA-M-TEB-511-82-10         EPA
  PB 218 398                    NTIS
  EPA-AA-TEB-71-24            EPA
  PB 83 227 587                 NTIS
  EPA-AA-TEB-511-82-6         EPA
  PB 84 155 936                 NTIS
  PB 83 159 384                 NTIS
  PB 218 638                    NTIS
  PB 81 012 931                 NTIS
  PB 80 190 952                 NTIS
  EPA-AA-TEB-76-28            EPA
  EPA-AA-TEB-76-11            EPA
  EPA-AA-TEB-511-82-7         EPA
  EPA-AA-TEB-511-80-3         EPA
  EPA-AA-TEB-74-23            EPA
  EPA-AA-TEB-72-5             EPA
  PB 82 124 215                 NTIS
  PB 83 181 149                 NTIS
  PB 81 229 866                 NTIS
  PB 84 129 881                 NTIS
  PB 93 236 693                 NTIS
  PB 80 140 809                 NTIS
  PB 81 219 032                 NTIS
  PB 83 181 123                 NTIS
    TYPE
Internal Engine Modifier
Air Bleed Device
Air Bleed Device
Oil/Additive
Air Bleed Device
Vapor Bleed Device
Air Bleed Device
Ignition Device
Driving Habit Modifiers
Air Bleed Device
Mixture Enhancer
Ignition Device
Air Bleed Device
Ignition Device
Miscellaneous
Air Bleed Device
Fuel/Additive
Air Bleed Device
Internal Engine Modifier
Mixture Enhancer
Miscellaneous
Air Bleed Device
Air Bleed Device
Vapor Bleed Device
Fuel/Additive
Mixture Enhancer
Mixture Enhancer
Mixture Enhancer
Mixture Enhancer
Vapor Bleed Device
Driving Habit Modifiers
Ignition Device
Air Bleed Device
Miscellaneous
Fuel/Additive
Fuel Line Device
Fuel Line Device
Air Bleed Device
                                                                                                                         SUB TYPE
                                                                                                                           Other
                                                                                                                           Other
                                                                                                                           Other
                                                                                                                           Under Carb
                                                                                                                           Under Carb
                                                                                                                           Other
                                                                                                                          Heat/Cool
                                                                                                                          Heat/Cool

-------

to
o
cr
o
              NAME

Gas Saving/Emission Control Improvement
Gastcll
Glynn-50
Goodman Engine System, Model 1800
Grancor Air Computer
Grcer Fuel Prehcater
Gyroscopic Wheel Cover
Hot Tip
Hydro-Catalyst Pre-Combustion Catalyst System
Hydro-Vac
ID ALERT (1)
Jacona Fuel System
Johnson Fuel Additive
Kamei Spoilers (i)
Kat's Engine Heater
Larnkin Fuel Metering Device
Landrum Mini-Carb
Landrum Retrofit Air Bleed
Lcc Exhaust and Fuel Gasification EGR
Magna Flash Ignition Control System
Malpassi Filter King (fuel pressure)
Mark II Vapor Injection System
Mesco Moisture Extraction System
Mini Turbocharger Air Bleed
Moleculetor (metallic)
Monocar HC Control Air Bleed
Morse Constant Speed Accessor}' Drive (i)
MSU Cylinder Dcactivation(2)
NRG #1 Fuel Additive
Optimizer
P.A.S.S. KIT(i)
P.S.C.U. 01 Device
Paser Magnum/Paser 500/Paser 500 HEI
Pass Master Vehicle Air Conditioner (i)
Peterman Air Bleed
PETRO-MIZER
PETROMIZER SYSTEM
Platinum Gasaver
REPORT                 SOURCE

  PB 83 181 123                 NT1S
  PB 81 215 899                 NTIS
  EPA-AA-TEB-511-81-28        EPA
  EPA-AA-TEB-511 -80-4         EPA
  PB 82 215 899                 NTIS
  PB 82168 949                  NTIS
  PB 84 143 577                 NTIS
  PB 83 181 156                 NTIS
  PB 81 153 827                 NTIS
  PB 84 144 088                 NTIS
  PB 84 154 111                 NTIS
  PB 83 159 301                 NTIS
  EPA AA-TEB-74-26            EPA
  PB 83 211243                 NTIS
  PB 83 165 548                 NTIS
  PB 80 177 272                 NTIS
  PB 82 142 100                 NTTS
  PB 82 142 100                 NTIS
  EPA-M-TEB-74-14             EPA
  PB 218 570                    NTIS
  PB 83 214 700                 NTIS
  EPA-AA-TEB-76-13            EPA
  PB 84 148 014                 NTIS
  EPA-AA-TEB-76-12            EPA
  PB 81 247 942                 NTIS
  PB 218 685                    NTIS
  PB 80 159 601                 NTIS
  EPA-AA-TEB-75-11            EPA
  PB 80 226 558                 NTIS
  PB 84 154 194                 NTIS
  PB 83 194 381                 NTIS
  PB 84 146 166                 NTIS
  PB 82 183 567                 NTIS
  PB 82 178 534                 NTIS
  EPA-AA-TEB-74-16            EPA
  PB 83 181 115                 NTIS
  PB 81 227 043                 NTIS
  PB 92 104 413                 NTIS
    TYPE

Mixture Enhancer
Driving Habit Modifiers
Mixture Enhancer
Liquid Injection
Air Bleed Device
Fuel Line Device
Miscellaneous
Air Bleed Device
Mixture Enhancer
Vapor Bleed Device
Driving Habit Modifiers
Fuel Line Device
Fuel/Additive
Miscellaneous
Miscellaneous
Mixture Enhancer
Air Bleed Device
Air Bleed Device
Miscellaneous
Ignition Device
Fuel Line Device
Vapor Bleed Device
Miscellaneous
Air Bleed Device
Fuel Line Device
Air Bleed Device
Accessory Drive Modifiers
Internal Engine Modifier
Fuel/Additive
Fuel Line Device
Accessory Drive Modifiers
Miscellaneous
Ignition Device
Accessory Drive Modifiers
Air Bleed Device
Fuel Line Device
Mixture Enhancer
Vapor Bleed Device
                                                                                                                          SUBTYPE
                                                                                                                            Under Carb

                                                                                                                            Under Carb


                                                                                                                            Heat/Cool


                                                                                                                            Under Carb


                                                                                                                            Heat/Cool



                                                                                                                            Other
                                                                                                                           Other
                                                                                                                           Other
                                                                                                                           Heat/Cool
                                                                                                                           Magnet
                                                                                                                           Under Carb

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                                                      DEVICE AND ADDITIVE TEST LIST
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             NAME

POLARION X
POLARION X (second evaluation)
Pollution Master Air Bleed
POWERFUEL
QEI400 Fuel Additive
Ram-Jet
Rolfite Upgrade Fuel Additive
Russell Fuelmeiscr
Sav-A-Mile
SCATPAC Vacuum Vapor Induction System
Smith Power and Deceleration Governor
Special Formula Ignition Advance Springs
Spritzer
Sta-Power Fuel Additive
Stargas Fuel Additive
Super-Mag Fuel Extender
SYNeRGy 1
Teclinoi  G Fuel Additive
Tephguard
Treis Emulsifier
Turbo Vapor Injection System
Turbo-Carb
Turbo-Dyne G.R. Valve
Turbocarb
ULX-15/ULX-15D
V-70 Vapor Injector
VareblO Fuel Additive
VEECD (Now EVEC™) (3)
Waag-Injection System (2)
Wickliff Polarizer (fuel line and air intake)
XRG #1  Fuel Additive
REPORT                 SOURCE

   PB 83 175 752                 NTIS
   PB 86 127 107                 NTIS
   PB 218 43 8                    NTIS
   PB 84 148 543                 NTIS
   EPA-M-TEB-76-8              EPA
   PB 80 170 657                 NTIS
   PB 80 190 960                 NTIS
   PB 83 181 131                 NTIS
   PB 82 197 417                 NTIS
   PB 81 153 819                 NTIS
   PB 80 173 867                 NTIS
   EPA-AA-TEB-75-13            EPA
   EPA-AA-TEB-74-15            EPA
   PB 218 567                    NTIS
   P8 218 568                    NTIS
   PB 82 194 937                 NTIS
   PB 82 122 169                 NTIS
   PB 219 396                    NTIS
   no number report               EPA
   PB 82 109 711                 NTIS
   EPA-AA-TEB-73-22            EPA
   PB 83 159 939                 NTIS
   PB 285 381                    NTIS
   PB 84 156 462                 NTIS
   PB 81 226680                  NTIS
   PB 84 163 062                 NTIS
   EPA-M-TEB-74-30             EPA
   PB 97 193 999 INF             NTIS
   EP A-AA-TEB-511-80-6         EPA
   PB 82 117 898                 NTIS
   PB 80 180 672                 NTIS
   TYPE

Fuel Line Device
Fuel Line Device
Air Bleed Device
Vapor Bleed Device
Fuel/Additive
Air Bleed Device
Fuel/Additive
Fuel Line Device
Mixture Enhancer
Vapor Bleed Device
Mixture Enhancer
Ignition Device
Mixture Enhancer
Fuel/Additive
Fuel/Additive
Fuel Line Device
Fuel/Additive
Fuel/Additive
Oil/Additive
Miscellaneous
Vapor Bleed Device
Mixture Enhancer
Air Bleed Device
Mixture Enhancer
Fuel/Additive
Vapor Bleed Device
Fuel/Additive
Air Bleed Device
Liquid Injection
Fuel Line Device
Fuel/Additive
                                                                                                                            SUBTYPE

                                                                                                                               Magnet
                                                                                                                               Magnet
                                                                                                                               Heat/Cool
                                                                                                                               Under Carb

                                                                                                                               Other

                                                                                                                               Under Carb


                                                                                                                               Magnet
                                                                                                                                Under Carb

                                                                                                                                Under Carb
                                                                                                                               Magnet
     (1) Indicated a statistically significant improvement in fuel economy without an increase in exhaust emissions although cost effectiveness must be determined by the consumer for his particular application.
     (2) Indicated a statistically significant improvement in fuel economy but with an increase in exhaust emissions. According to Federal Regulations, installation of this device could be considered tampering.
     (3) Reduced carbon monoxide and hydrocarbons on older emission control technology vehicles.

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