October 3, 2002		2002-R-0808
EPA EVALUATION OF FUEL ADDITIVES
By: Paul Frisman, Associate Analyst

The Department of Environmental Protection (DEP) has asked a fuel additive manufacturer to submit his product to the federal Environmental Protection Agency (EPA) for testing before DEP decides whether to use it in a pilot project. You asked if EPA tests the effectiveness of fuel additives as well as aftermarket “add on” devices.

SUMMARY

EPA has two different programs to evaluate aftermarket products designed to reduce engine emissions or improve fuel economy. One program, the Motor Vehicle Aftermarket Retrofit Device Evaluation Program, is meant for vehicles weighing 6,000 pounds or less (primarily passenger cars). This program includes fuel additives, but not oil additives and lubricants.

The second program, the Voluntary Diesel Retrofit Program, is meant to address emissions from construction equipment and heavy-duty vehicles. EPA says it is putting the finishing touches on a protocol to test fuel additives for these vehicles, and has begun accepting applications for that program.

AFTERMARKET RETROFIT DEVICE EVALUATION PROGRAM

At the request of a manufacturer, EPA will evaluate aftermarket fuel additives and devices intended to reduce pollution or increase fuel economy for passengers cars and other vehicles weighing 6,000 pounds or less. EPA's definition of aftermarket devices for this program includes fuel additives, but not oil additives and lubricants.

EPA will conduct the tests, at the manufacturers expense, after an independent laboratory has conducted preliminary tests that show a statistically significant improvement in fuel economy or emissions reduction. EPA does not endorse, approve, or certify a product it has tested. However, it does publish the test results in the Federal Register and elsewhere for use by the Federal Trade Commission and the public.

Application Process

A manufacturer who wants EPA to evaluate his product must submit a formal application. EPA does not acknowledge receipt of applications, but tries to respond with comments within 30 days.

Applicants must demonstrate that the product (1) has no adverse effect on the deposit control properties of gasoline, and (2) will not adversely affect vehicle emissions or render inoperative, degrade, or defeat the operation of a vehicle's diagnostic systems.

The application also must contain the findings of required independent laboratory tests that demonstrate a statistically significant improvement in fuel economy or emissions reductions. The applicant is considered to have withdrawn from the process if he does not complete the independent lab tests and submit the data to EPA, or does not respond to EPA requests for additional information within 180 days.

Independent Laboratory Testing

EPA will provide technical assistance in designing the test program to be performed at the independent laboratory. It will not accept routine inspection/maintenance test data (data from routine annual auto emissions testing).

Applicants must provide EPA with the laboratory's name, the tests to be conducted and the dates the test will take place. EPA asks that applicants allow it to contact the lab during testing, and allow the lab to answer EPA questions about the test program.

The only test procedures EPA will accept are the Federal Test Procedure (FTP), which tests emissions, and the Highway Fuel Economy Test (HFET), which tests fuel efficiency. These tests are conducted in controlled conditions on cars representing the typical vehicle for which the product is designed. They involve controlled driving patterns on a laboratory test machine during which exhaust gases are collected and analyzed. The applicant must furnish EPA with all test vehicle information and test data obtained from the independent laboratory, including any results declared void or invalid.

If the independent lab tests show the additive has made a statistically significant improvement in fuel economy or emissions reduction, EPA will conduct its own round of tests at its National Vehicle and Fuel Emissions Laboratory. EPA will schedule these tests once the applicant signs a test plan and has paid for the tests. It may take 12 months to complete all testing and issue a final report.

EPA Testing

Minimum EPA testing requires three tests of two different cars in their baseline configuration, three tests with the device or additive added; and three more baseline tests after the additive has been removed. The minimum cost for testing two cars is $ 27,000. The applicant may also incur additional costs, depending on the test protocol. EPA will provide a specific cost based on the test requirements. It does not charge for time spent on consultation or report-writing.

Once testing is completed EPA will prepare an evaluation report based on (1) the independent test data, (2) EPA's test data and (3) EPA's engineering analysis. EPA cannot keep test results confidential, and will not evaluate a product if an applicant refuses to release necessary information.

More information on the testing process can be found on EPA's web site at http: //www. epa. gov/otaq/consumer/devices. pdf

RETROFIT TECHNOLOGY VERIFICATION PROCESS

EPA's Office of Transportation and Air Quality (OTAQ) has devised a testing process to verify the performance of aftermarket emissions-reducing products for heavy-duty diesel-powered vehicles, such as school buses. Testing under this program is done either by EPA or, under certain conditions, directly by the manufacturer. The manufacturer pays for the tests in either case.

OTAQ will place successfully tested products on a verified technology list, and continue to monitor them in the field to ensure they achieve the expected reductions. OTAQ can remove products from the list if they do not meet these standards.

Interested applicants should contact OTAQ staff to begin the verification testing process. We have attached additional information about the process, and staff contacts. The information also is available on-line at http: //www. epa. gov/otaq/retrofit/verif-process. htm and http: //www. epa. gov/otaq/retrofit/basic-info. htm.

PF: eh