Approval Details

Valid E.O.

Validity

This Executive Order approved the specified parts on on March 26, 1974.
As of Tuesday, October 15th, 2019 this Executive Order has not been overturned or superceeded.

Approved Parts

Models
1966-1970 with engines > 50 CID

This Executive Order may be listed as:
  • C.A.R.B.E.O. D-8-2
  • Executive Order 8-2 / D8-2
  • ARB # D-8-2
  • Executive Order No: D-8-2
  • C.A.R.B. No. D-8-2
  • Resolution D-8-2
For Free CARB Executive Order Status verification, email an image of the device Executive Order label as well as the Year/Make/Model and Test Group # of the vehicle to [email protected]

Download: Executive Order D-8-2 PDF

D-8-2 Document:



                               State of California
                               AIR RESOURCES B0OARD

                               EXECUTIVE ORDER D—8—2
                   Relating to Exemptions under Section 27156
                            _  of the Vehicle Code


                               AIR QUALITY PRODUCTS
                                "66—70 PURE POWER"

Pursuant to the authority vested in the Air Resources Board by Section 27]56 of
the Vehicle Code; and

Pursuant to the authority vested in the undersigned by Section 39023 of the
Health and Safety Code;

IT IS ORDERED AND RESOLVED: That the installation of a "66—70 Pure Power" high
performance system manufactured by Air Quality Products has been found by the
Board to not reduce the effectiveness of a required motor vehicle pollution
control device on 1966 through 1970 model year vehicles with engine displacements
of over 50 cubic inches, and therefore, vehicles so equipped are exempt from
the prohibitions of Section 27156 of the Vehicle Code.

The "66—70 Pure Power" high performance system consists of a capacitive discharge
ignition circuit, electric spark retard, and vacuum spark advance disconnect at
engine speeds 3300 + 200 rpm or less.

Changes made to the design or operating conditions of the device as originally
submitted to the Air Resources Board for evaluation that adversely affect the
vehicle‘s pollution control devices shall invalidate this Executive Order.

THIS EXECUTIVE ORDER DOES NOT CONSTITUTE A CERTIFICATION, ACCREDITATION, OR
APPROVAL BY THE AIR RESOURCES BOARD OF ANY CLAIMS OF THE APPLICANT CONCERNING ANTI—
POLLUTION BENEFITS, OR ANY OTHER TYPE OF ENDORSEMENT BY THE AIR RESOURCES BOARD
OF ALLEGED BENEFITS OF THE "66—70 PURE POWER" DEVICE.

Section 17500 of the Business and Professions Code makes unlawful, untrue or mis—
leading advertising and Section 17534 makes violation punishable as a misdemeanor.

Any apparent violation of the conditions of this Executive Order will be submitted
to the Attorney General of California for such action as he deems advisable.


Executed at Sacramento, California, this   2(    day of March, 1974.




                                                WILLIAM SIMMONS
                                                Executive Officer


                       State of California

                       AIR RESOURCES BOARD

                           March 22, 1974
                          Staff Report


      Consideration of Air Quality Products‘ Request
     for Exemption of its Pure Power Device for Class
                           "A" Vehicles




Introduction
Air Quality Products, Inc. submitted an application dated December 28,

1973, for exemption of its Pure Power High Performance ignition system

for 1966—70 class "a" vehicles under the provisions of Section 27156
of the Vehicle Code.    The system comprises an emissions control system

and a capacitive dischargé ignition system identical with the Pure Power

device previously exempted for 1966—70 class "b" through "f" vehicles.

A copy of the application is attached, (Exhibit A).     The application in—

cluded system descfiption and effect on emissions which was demonstrated

with a fleet of representative vehicles.


Confirmatory tests of 2 class "a" vehicles were conducted at the Air

Resources Board Laboratory to substantiate the manufacturer‘s claims.

The device did not increase emissions and generally tended to reduce

emissions.


The device, however, costs more than the statutory $35 and cannot be

considered for accreditation as an oxides of nitrogen control device.


Air Quality Products, Inc.                                  March   22, 1974




II.    Device Description

       The Air Quality Products device combines an emission control sy;tem

       with a capacitive discharge ignition system.    The two systems are con—

       tained in a single housing which is installed in the vehicle engine

      " compartment, with the exception of the Volkswagen, where it is installed

       underneath the rear seat.


       The emission control system controls emissions by electronic retard of

       the ignition timing and, in some vehicles, a solencid valve is employed

       to regulate the vacuum advance mechanism.     The electronic retard provides

       a fixed amount of retard to the basic timing below 1400 rpm; a fixed

       selectable amount of retard between 2° and 10° depending on the particu—

       lar vehicle — between 1400 rpm and 3300 rpm; restoration of normal timing

       above 3300 rpm.   The amount of retard below 1400 rpm is approximately half

       of that above 1400 rpm.     The solenoid vaive controlled vacuum advance is

       disconnected at engine speeds above 1400 rpm and reconnected at 3300 rpm

       {approximately 57 mph vehicle speed).


       No mechanical adjustments are made to manufacturer‘s specified spark

       timing or carburetor specification.


III. Emission Testing

       The applicant submitted supporting test data to demonstrate the effec—

       tiveness of the "Pure Power" device.. Hot start CVS and steady state (at
       55 mph) tests were conducted at the Olson Laboratories on a fleet of 5

       vehicles supplied by Air Quality Products, Inc.    Olson Laboratories


Air Quality Products, Inc.                                  March   22, 1974




       affirmed the vehicles were tested in accordance with California appli—

       cable procedures using Indolene — 30 test fuel.     Air Quality Products

       stated the vehicles were adjusted to manufacturer‘s specifications for

       timing, air fuel ratio, and idle speed.     The timing control module and

      . vacuum advance arrangement appropriate to the vehicle were installed

       according to the installation table in the application.


       The emissions of the three pollutants, hydrocarbon, carbon monoxide,

       and oxides of nitrogen were determined for each vehicle with and with—

       out the device.   The results are tabulated in Table I.


       The same tests were conducted on    two   vehicles at the Air Resources

       Board Laboratory, the results of which are shown in Table II.


       The average emissions of both fleets of vehicles were determined, and

       were the basis of acceptance of the device.     Based on staff experience

       of vacuum spark disconnect, there is no expected increase in aldehydes

       or hydrocarbon reactivity.     Staff evaluations of capacitive discharge

       ignition systems have shown them to have a negligible effect on exhaust

       emissions.


IV.    Comments

       The applicant staies that actual testing established satisfactory

       durability and driveability.    Customer satisfaction with equipped

       class "b" through "f" vehicles is cited as further evidence.


       The application describes the marketing, cost and maintenance of the

       system.


Air Quality Products, Inc.                                   March      22, 1974




      Summary

      The results of the vehicle tests are as fq]lows:


      a)   Fleet Average Reduction — Air Quality Products (Olson Laboratories)
                                                   HC             co        NOx

           Hot CVS Test Reduction Average — %          9.3        9.6       44

           Steady State Reduction Average — %     39             27         46


      b)   Fleet Average Reduction — Air Resources Board (El1 Monte)
                                                       HC         CO        NOx

           Hot CVS Test Reduction Average — %      8.7           31          41

           Steady State (55 mph)                  20             20          44


VI.   Recommendation

      Based on the Air Resources Board criteria for determining compliance

      with Section 27156 of the Vehicle Code, it is the staff‘s conclusion

      that the use of the Air Quality Products Pure Power High Performance

      Ignition system for 1966—70 class "a" vehicles will result in emission

      levels that comply with existing State regulations for the appropriate

      model year.


      Therefore, the staff recommends that this system be exempt from the

      prohibitions of Section 27156 of the Vehicle Code.


      The applicant‘s system meets the criteria established for the accredi—

      tation of an oxides of nitrogen device with the exception of Section

      39177.3(a) relating to the cost limit of $35.         Therefore, it is the


Air Quality Products, Inc.                            March   22, 1974




     staff‘s recommendation that 1966—1970 class "a" vehicles equipped with

     the Pure Power High Performance Ignition System be exempted under the

     provisions of Section 39177 of the Health and Safety Code.


  .                        *                   TABLE I (a)
                    EMISSION DATA — AQP TEST FLEET (OLSON LABORATORY)




                                       Basetine                                   With Device

                      CYVS—gms/mile       Steady State—ppm!      CVYVS—gqms/mile              Steady State—ppm

                      HC   C0   [NOx      HC      1C0 (%)|NOx    HC         CO   [NOx         HC   |CO (%]    NOx


      Volkswagen     [4.13134.6]3.131306           234     |387814.10134 .41 2.111172               .30      1657

      Volkswagen     |3.72]43.912.87]1338         1(1.60   }(3320}4.40]43.611.601172               11.00     1638

      Datsun         2.06124.315.481137            .58     13406]1.26(22.613.591              74     A7      12754

      Opel           2.38|37.8]4.48]132           11.00    13878]1.75135.6]1.81{118                 .83      1938

      Toyota         2.15]31.4}3.231      70       .63     12490]1.58{19.3}1.74]              64    47       §1281


©®@   averege         |2sofams|ansafior            es      |ssoelzsezlsna|zar| 120 <|               cer fisse



                                               TABLE I (b)

                       EMISSIONS REDUCTION — AQP TEST FLEET (OLSON LABORATORY)



                                                           HC          60               NOx
             CYS Test Reduction Average — %                9.3         9.6              44

             Steady State Reduction Average — % 39                    27                46


                                         TABLE II (a)

                   EMISSION DATA — ARB TEST FLEET (EL MONTE)




                                 Baseline                                      With Device

             CYS—gms/mile           Steady State—ppm|           CVS—gms/mile              Steady State—ppm

              HC     CO   [NOx      HC      1C0 (%)]     NOx|   HC        CO   NOx        HC    |CO (¥)]    NOx




Volkswagen   4.25] 22.7|2.71 {130            58         (2383]3.86120.7 1.80|             109    .72       (1634

Toyota       1.74}39.2]3,25         78       «60        j2782]1,.61}22.2] 1.74            57     .22       11277


Average      3.00j 31.0|2.98 [104            .59        12583]2. 741 21.51 1.77           83     47        11456




                                         TABLE II (b)

             EMISSIONS REDUCTION — ARB TEST FLEET (EL MONTE)




                                                       HC             cCO            NOx
   CYS Test Reduction Average — %                      8.7           31              41

   Steady State Reduction Average — % 20                             20              44


                                                                     EXHIBIT A

                 AIR QUALITY PRCDUGTS INC.
                               950 NORTH MAIN STREET
                              ORANGE, CALIFORNIA 92667

                                    (714) 532—6727

                               December 28, 1973




Mr. William Simmons, Executive Officer
AIR RESOURCES BOARD
1025 "P" Street
Sacramento, CA      95814

SUBJECT:   APPLICATION FOR AN EXPANSION OF THE EXEMPTION OF THE PURE POWER
           "HIGH PERFORMANCE IGNITION SYSTEM"‘IN LIEU OF AN OXIDES OF
           NITROGEN CONTROL DEVICE FOR 1966 THROUGH 1970 MODEL YEARS TO
           INCLUDE CLASS "A" VEHICLES.


Dear Mr. Simmons:


Air Quality Products, Inc. is herein applying for an expansion of its
exemption for the PURE POWER High Performance Ignition System, in lieu
of an oxides of nitrogen control device, for 1966 through 1970 model
years to include Class "A" motor vehicles.           Testing has been accomplished
per Air Resources Board Accreditation Test Procedures.           Test results on
a fleet of five (5) such vehicles show a system NOx emission reduction
capability of 43.5% using the hot CVS cycle and indicates compliance
with the general standards.


The device involved herein is the PURE POWER High Performance Ignition
and Emission Control device which is currently accredited and exempted,
in production, and being installed on 1955—1970 vehicles throughout the
State of California.    The Volkswagen system uses a different cable than
the normal PURE POWER System and the kit includes a ballast resistor
instead of vacuum hose.     The only other variation in the system is the
color of the timing control module that is used, and a stepped electronic
retard.


                                    — —.\_\7—\ —._

 Mr. William Simmons, Executive Officer                                   Page 2
 December 28, 1973


 It is requested that approval of the application be granted at the
 January 9th meeting of the Air Resources Board.     This action will atlow
 Air Quality Products to distribute Class "A" ‘66—‘70 PURE POWER devices
 throughout California in time for the annual vehicle re—registration
 period which terminates the first week in February 1974.


 SYSTEM DESCRIPTION


 The Air Quality Products, Inc. NOx Emission Control System for 1966—1970
 Class "A" vehicles is included in its "PURE POWER" High Performance
 Ignition and Emission Control device for 1966—1970 vehicles (VW System
 slightly different).   The "PURE POWER" device includes two distinct
 systems.   The "Emission Control System" controls emissions through
 selective control of ignition timing, which includes control of the
 vacuum spark advance mechanism, on some vehicles, and electronic timing
 regulation.   The "High Performance Ignition System" is a high voltage
 capacitive discharge ignition system which is designed to improve
 performance and fuel economy and increase the durability of vehicle
 spark plugs and ignition points.   These two systems, the "Emission
 Control System" and the "High Performance Ignition System" are packaged
 in a single housing, which is installed in the vehicle engine compartment,
 with the exception of Volkswagen which is installed in the well adjacent
 to the battery underneath the rear seat.


 The "Emission Control System" includes a solenoid valve which is employed
 to selectively regulate the vacuum advance on some vehicles.     In operation,
 the valve causes the vacuum advance mechanism to be disconnected at
engine speeds above 1400 RPM, and reconnected at vehicle speeds above
 approximately 3300 RPM (57 MPH) on 4 cylinder vehicles.     Electronic
 retard is employed in control of all vehicles.    This function provides
 a fixed amount of retard to the basic timing below 1400 RPM, a Targer
_fixed, selectable, amount of retard between 1400 RPM and 3300 RPM and is
completely inhibited above 3300 RPM.   The electronic retard between 1400
RPM and 3300 RPM is between 2° and 10° depending on the timing control
module inserted for that particular vehicle.      Electronic retard below
1400 RPM is approximately one—half of the amount of retard above 1400 RPM.


 Mr. William Simmons, Executive Officer                                      Page 3
 December 28, 1973


 The "High Performance Ignition System" includes a high voltage transformer
 which increases available output voltage under starting, high speed and
 high load conditions to enhance vehicle performance in those operating
 modes.   The enhanced rise time of the ignition pulse provides more
 positive firing, more complete combustion and extended plug life over
 conventional systems.


— SYSTEM INSTALLATION


 The system is installed on Class "A" vehicles, except YVolkswagen, in
 the same manner as on Classes B—F for 1966—1970 vehicles, as described
 in the printed installation instructions with each PURE POWER kit now
 being sold.     That is, it is installed in the engine compartment, mounted
with two self tapping screws to the fender wall, or other accessible
mounting surface, in as cool a place as possible.           The provided ground
 strap should be terminated under an engine bolt or other electrical
 ground connection in the engine compartment.


On Volkswagen, the unit is mounted in the well under the rear seat,
adjacent to the battery, with two self tapping screws, to the vehicle
frame.    The ground strap is secured to the frame under one of the
existing bolts on the frame.      A 1/4" hole is then drilled through the
firewall to provide access for the cable from the device to the engine
compartment.      (See Enclosure I — Installation Instructions for Volkswagen.)
Additional installation instructions will be provided for any vehicles
whicfi connect electrically in a different manner than the Class B—F
vehicles.      The only differences in electrical connections which exist
from one vehicle to the next revolve around whether the baseline vehicle
has a ballast resistor or not, and if so, whether it is on the positive
or negative side of the cofl.      The only other differences in installation
on Class "A" vehicles will be whether or not the vacuum advance mechanism
is routed through "PURE POWER" and the color of timing control module to
be employed.     Table I defines the physical and functional requirements
for installation of PURE POWER on Class "A" vehicles.




                                              se cmmmamms


            Mr. William   Simmons, Executive Officer                                 Page 4
            December 28, 1973



        f                                               VAC. ADVANCE
        ©    ventele make/moper       THMING_CONTROL
                                       MOOULE COLOR
                                                        poutep TturU   INSTALLATION COMMENTS
                                                         PURE POWER
             Audi                           Red               Yes      Disconnect and Plug
                                                          ‘            Retard Diaphragm

             Fiat                           Black             No       Ballast Resistor must|
                    '                                                  be in series with Red
                                                                       Lead — Baseline
                                                                       vehicle has resistor
                                                                       on — Coil.

             MG Midget                  _   Black             No

             Opel? {1968—1970)              Blue              Yes .    Disconnect and Plug
                                                                       Retard Diaphragm

             Peugeot                        Black             No

             Toyota — 3RB, KC,              Blue              Yes
    ,          M&F Engines

    .        Volkswagen                     Black             No       Special Unit.— See
                                                                       Enclosure I

             All Others           [         Red               Yes


               TABLE I — INSTALLATION OF PURE POWER ON 1966—70 CLASS "A" VEHICLES


            The same pre—installation procedure is recommended with AQP NOx device
            as with PURE POWER in that the absence of misfires is verified and the
            vehicle timing and carburetion is adjusted to manufacturer‘s specifica—
            tion before the system is installed.       Detailed installation instructions
            are being prepared.


            COMPLIANCE WITH EMISSION STANDARDS


            Vehicles were tested in accordance with the applicable test procedures.
,           TABLE Il and TABLE Il (enclosed) delineate the emission data measured
.           before and after installation of PURE POWER on a fleet of vehicles of


                             0.

Mr. William Simmons, Executive Officer                                  Page 5
December 28, 1973


engine displacement Class "A", representétive of the vehicle population
for which exemption application is being made.     Five vehicles were
evaluated, the test data sheets for which are included in ENCLOSURE II.


The vehicles were adjusted to manufacturer‘s specification for idle C0,
dweil and timing.     The absence of mis—fires was verified.   The vehicles
were then emission tested by the 1972 CVS federal hot—cycle at baseline
and a diluted mass sample was taken at 55 MPH cruise.     The PURE POWER
device was then installed and the CVS and 55 MPH cruise tests were again
run.   Emission data from the baseline and equipped vehicles are given
in TABLE III. The CVS emission tests are measured in grams per mile,
while the 55 MPH cruise results are given in parts per million.      TABLE 11
shows the percentage reduction of each emission, for each test, by test
vehicle, and for the fleet.     Fuel Consumption of the Class "A" test fleet
ahd % Improvement of Consumption is given in Table IV.


Application for exemption is made for all vehicles in engine Class "A"
{140 cubic inch engine displacément or smaller), with the following
vehicles   not included:


             (1)    All vehicles with six volt ignition systems.
             (2)    All vehicles with positive ground electrical systems.
             (3)    All vehicles with engines which include factory installed
                    distributors containing a magnetic or optical pick—up
                    primary timing pulse for ignition initiation.
             (4)    All vehicles with engines using fuel injection systems.


                                         e2                                                                               222   0

 Mr. William Simmons, Executive Officer                                                                  Page 6
  December 28, 1973




                                                                  EXHAUST EMISSION % REDUCTION
    TEST
  VEHICLE     YEAR          MAKE          DISP.             HOT CVS CYCLE                55 CRUISE MODE
    NO.                                                    HC       CO     NOX       HC           CO          NOX
                                                                                                                     «[
    503           70   Volkswagen             91           0.7       0.7   32.6     43.8      11.8            57.3}

    507           69   Volkswagen             91          —18.3      0.7   44.3     49.1      37.5            50.7

    508           69   Datsun                 97          38.8      7.0    34.5     46.0      19.0            19.1

    509           70   Opel               112             26.5      5.8    59.6     10.6      17.0            50.0

    510           70   Toyotav            112             26.5     38.6    46.1      8.6      25.4            48.6
                  FLEET AVERAGE                            9.3      9.6    43.5     39.0      26.0            45.4


          TABLE II      —     CLASS "A" TEST FLEET PERCENT EMISSION REDUCTION




  TEST              BASELINE _                       PURE_POWER
VEHICLE __CVS—GRAM/MILE _| 55. CRUISE—PPM  CVS—GRAM/MILE     §55_CRUISE—PPM
  no.   ue    co     }mox l e |co(w»] nox e     co    nox mc co(¥) nox
  so3 f4.13 |34.63]3.13 306| 0.34 sa7s l4a.10|34.39 2.11 172| 0.30 1657
 5o7      |3.72 4a3.93|2.87            33s 1.60 3320 |4.40l43.63 1.60                      172| 1.00 1638
 sosg     |2.06 24a.34 [s.4as          137| 0.58 3406 |1.26]22.63 3.59                       74| 0.47 2754
 509      |2.38    37.76|4.48          132|        1.00    3878    |1.75)}35.58   1.81     118         0.83     1938

 510      |2.15    |31.40}3.23          70|        0.63    2490    |1.58]19.27    1.74      64         0.47     1281

 AV.      2.89     34.41]3.84          197|        0.83    3394    2.62]31.10     2.17     120|        0.61     1854


                   TABLE III       —    CLASS "A" TEST FLEET EMISSION DATA


Mr. William Simmons, Executive Officer                                    Page 7
December 28, 1973




                   TEsT       BASELINE     PURE POWER    y
                  "Ho |       insrams       inGurme IMPROVEMENT
                     503          894         904       — 1.12
                     507          980         210         7.14
                     508          992         871        12.20
                     509          912        1049       —15.02
                     510         1089        1109       — .30

                    AV.          973          968         0.50

TABLE IV     —   CLASS "A" TEST FLEET FUEL CONSUMPTION AND PERCENT IMPROVEMENT


COMPLIANCE WITH GENERAL STANODARDS


1.   Noxious or Toxic Emissions/Safety
     A.    The device, in its operation, will not cause the emission of any
           noxious or toxic matter into the ambient air that is not emitted
           by the motor vehicle engine without the device.
     B.    Safety.— The device does not have operational or failure modes
          which would result in any unsafe condition which would endanger
           the motor vehicle, its occupants or persons or property in close
           proximity to the vehicle, beyond those which may occur in an
           unequipped vehicle.


2.   Mydrocarbon, Carbon Monoxide, Aldsehydes, orHydrocarbon Reactivity
     A.    Hydrocarbon, Carbon Monoxide.    There is no increase in HC, CO
          emissions resuiting from operation of the device.      Tests con—
          ducted on five vehicles using CVS hot—start procedures indicate
          an average of 9.3% reduction of HC and a CO reduction of 9.6%.
          Measurements at 55 MPH cruise conditions on the same vehicles
          showed an HC reduction of 39.0%, and a reduction of CO of 26.0%
     B.   Aldehydes/Hydrocarbon Reactivity.


                           000

Mr. William Simmons, Executive Officer                                 Page 8
December 28, 1973


    Adverse Effects on Vehicle Performance
    Driveability testing was accomplished on selected vehicles repre—
    sentative of the vehicles for which exemption is being applied
    for.   Federal driveability evaluations were performed on test
    vehicles 503 and 507 (Volkswagens) and on the Datsun (TV508).     The
    evaluations indicate no adverse effects on vehicle performance.
    The other Class "A" vehicles driven were also found to have no
    adverse driveability effects.


    Restoration of the vacuum advance and/or electronic retard at 57 MPH
    precludes possible valve damage which might ensue as a result of
   employing a continued vacuum disconnect or electronic retard profile
   beyond that speed.    Vacuum advance restoration at idle (for vehicles
   without ported spark} and reduced electronic retard at idle protect
   the vehicle from overheating upon the installation of this device.


   Device Durability
   Data accumulated during accreditation testing for 1955—1965 model
   year vehicle installation, included durability data for six vehicles
   which accumulated 25,000 systemequipped test miles each.    Three
   of the test vehicles have continued in operation and have now
   accumulated approximately 60,000 miles each of system equipped
   operation.   To date, approximately 15,000 systems have been installed
   and are in operation on customer vehicles, on both the 1955—65 and
   1966—70 (Class B—F) vehicle retrofit programs in California.      Although
   no known customer owned vehicles have exceeded 50,000 miles, test
   results of 5,000 hour bench tests (approximately equivalent to
   150,000 miles) conducted in the laboratory indicate a mean mileage
   between failure of 98,000 miles.   The device has a full replacement
   warranty for six months and a warranty, on a prorata basis, for an
   additional 18 months.   It is estimated that a system in normal
   operation will have an expected useful life of at least 50,000 miles
   of operation.


                                                00 00.


    Mre. William Simmons, Executive Officer                                       Page 9
    December 28, 1973


    5.   Marketing/Distribution
\
         Air Quality Products, Inc. has established a dealer network of
         approximately 1,000 authorized installation stations.        These stations
         are served directly by Air Quality Products.        Some dealers operate
         in a jobber capacity and sell to other authorized dealers in addition
         to their normal business.     A field representative staff is main—
         tained to provide technical training and warranty service to the
         dealers.


         Device Effectiveness
         Application of accreditation test procedures reveal that a 43.5%
         average reduction in NOx is obtained with system equipped vehicles.
         This reduction demonstrates that the system is more effective than
         the 42% requirement established by the first system accredited for
         Class "A" vehicles and therefore, is in compliance with the general
         standards.     The device is also effective at 55 MPH.


         Device Costs
         Statutory Criteria — Section 39177.3{a)        Health & Safety Code.
         The Air Quality Product device which includes a "High Performance
         Ignition System" and "Emission Control System", will exceed Thirty—
         Five ($35.00) Dollars installed.


         Device Maintenance Costs
         Section 39177.3(b)     Health & Safety Code.    There is no required
         maintenance for the life of the device.


         Device Maintenance
         There is no required maintenance for the life of the device.           All
         information related to the operation and installation of the device
         is included in the installers handbook which accompanies each kit.
         The installers are instructed to leave this handbook with the purchaser.


                     ODDORIDCRN


    Mr. William Simmons, Executive Officer                                Page 10
    December 28, 1973


    10. Protection of Public Interest
.       In order to protect the public interest, Section 39177.1 Health &
        Safety Code requires an agreement by the manufacturer to cross
        license or allow the State to establish a fair and reasonable device
        price in the event that only a single device is accredited.                 to   k n ns


        The public currently has available two accredited devices for
        Class "A" vehicles from which to choose, that will cost no more than
        Thirty—Five ($35.00) Dollars.   This should adequately protect the
        public from an optional device which because of its additional
        performance features costs more than Thirty—Five ($35.00) Dollars.


        In fact, the public interest will be best served, in a mandatory
        program, by providing them with an exempted device option which
        includes additional equipment which restores vehicle performance
        and improves durability while controlling NOx to within State
        standards.


.   We hereby agree to comply with any request of the Executive Officer
    pursuant to provisions III, A, &, H, and I of the Air Resources Board‘s
    test procedures.


    Your early attention to this application is ea;gest]y requested.




                                             7   //

                                         %M#eA

                                   By William C. Lanni



Document Created: 2005-09-01 12:42:10
Document Modified: 2005-09-01 12:42:10

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