EPA-AA-TEB-511-82-15
       EPA Evaluation of  the  Fuel Economizer  Device  Under
Section 511 of the Motor Vehicle Information and Cost Savings Act
                               by

                         Stanley L.  Syria
                         September 1982
                   Test and Evaluation Branch
               Emission Control Technology Divison
                    Office of Mobile Sources
              U.S. Environmental Protection Agency

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EPA Evaluation  of the  Fuel Economizer  Device  Under  Section 511  of  the
Motor Vehicle Information and Cost Savings Act

The Motor Vehicle  Information and  Cost  Savings Act  requires  that  EPA
evaluate  fuel  economy  retrofit  devices  and publish a  summary  of  each
evaluation in the Federal Register.

EPA evaluations  are  originated upon  the  application of  any manufacturer
of a  retrofit device,  upon the request  of the  Federal  Trade Commission,
or upon the motion of  the EPA Administrator.   These  studies are designed
to determine  whether the  retrofit device  increases  fuel economy  and  to
determine whether the representations made  with respect  to the device are
accurate.  The  results  of such  studies are  set  forth  in  a  series  of
reports, of which this is one.

The  evaluation  of  the   Fuel  Economizer   device   was   conducted  after
receiving  an  application  for the   evaluation  by   an   importer  of  the
device.   The  device is  claimed  to  improve  fuel   economy and  exhaust
emission  levels,  vehicle  performance,   and  also  the   life  of  certain
ignition  components.   Because  this  device  is  attached into  the  coil
secondary lead  and  is intended to change  the  ignition  secondary voltage
characteristics, it is classified  by EPA as an ignition control device.

The following is  a  summary of the information  on the device  as supplied
by the Applicant and the resulting EPA analysis and conclusions.

1.  Title; '

    Application  for  Evaluation of Fuel  Economizer Under Section  511  of
    the Motor Vehicle Information  and Cost Savings Act

2.  Identification Information;

    a.   Marketing Identification  of the Product;

         "Choice left to Agamco, Inc."

    b.   Inventor and Patent Protection;

         (1)  Inventor

              Mr. P.P. Dhahanukar, 508 Gundecha  Chambers,  Nagindas Master
              Road, Fort, Bombay-400 023.

         (2)  Patent

              "Patent for India only."  (Copy of patent not submitted.)

    c.   Applicant;

         (1)  Name and address

              Agamco, Inc. 2125 Center Avenue, Fort Lee,
              New Jersey 07024, U.S.A.

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         (2)  Principals

              Mr. Martin M. Shapiro

    d.   Manufacturer of the Product;

         (1)  Name and address

              Mr.  P.P.  Dhahanukar,  508,   Gundecha   Chambers,   Nagindas
              Master Road, Fort, Bombay-400 023.

         (2)  Principals

              Mr. P.P. Dhahanukar

3.  Description of Product (as supplied by Applicant);

    a.   Purpose:

         "More  complete combustion  of  the  fuel,  thereby  improving  the
         fuel economy."

    b.   Theory of Operation;

         "The Fuel Economizer unit converts  the High  Tension  D.C.  current
         given  by the  ignition coil into  High Frequency  A.C.  current.
         This A.C.  current  of  20,000 cycles  per second  gives  multiple
         sparks at  various points on the  spark plug.  Being  independent
         of  the ohmic  resistance  it fires  the plugs  even  if  they  are
         fouled.  This  in effect gives cleaner exhaust  and fuel  economy
         as much  as  7 to 14% depending on the  vehicle,  even in  the  case
         of electronic ignition system."

    c.   Construction and Operation;

         Circuit Diagram:
                                            Circuit
                                      Dbtrlbuior

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    d.   Specific Claims for the Product;

        "*Prevents air pollution
         *Reduces fuel consumption from 7 to 14% through complete
          combustion.
         *Increases horsepower.
         *Gives easier starting.
         *Increases life of plugs and Delco points.
         *Gives smoother acceleration, without flat-spot. (Other details
          to be decided by Agamco.)"

    e.   Cost And Marketing Information (as supplied by Applicant);

         "According to marketing strategy of Agamco, Inc."

4.  Product Installation,  Operation,  Safety and Maintenance  (as supplied
    by Applicant);

    a.   Applicability;

         (1)  "All types of petrol engines.

         (2)  Universal application."

    b.   Installation - Instructions, Equipment, and Skills Required;

         "Installation  is  very  simple.   No  special  tools  or  skills  or
         adjustments are required."

    c.   Operation;

         "No maintenance procedure required.
         Recommended to be replaced after 12 to 15 months."

    d.   Effects on Vehicle Safety;

         "Would not result in any unsafe condition."

    e.   Maintenance;

         "The normal  maintenance schedule  for the vehicle  is in no  way
         affected."

5.  Effects on Emissions and Fuel Economy (submitted by Applicant);

    a.   Unregulated Emissions;

         "Not  applicable   since  this  device  is  not  for use on  diesel
         vehicles."

    b.   Regulated Emissions and Fuel Economy;

         "Tests as may be required by E.P.A."

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6.  Testing by EPA;

    EPA did not test the device  for  this  evaluation because the test data
    submitted by the applicant did not  adequately support the claims made
    for the device.

7.  Analysis

    a.   Identification Information;

         (1)  Marketing Identification;

              The  marketing  identification  was  not  stated.   However,
              elsewhere within the  application the device  is  referred to
              as  the  "Fuel  Economizer".   In  supporting  test  reports
              (Attachment  A) submitted  by  the  applicant,  reference  is
              made  to  "Petrol  Saver" and  also  "Maruti".   Although  not
              stated, it  is assumed  that Petrol  Saver, Maruti,  and Fuel
              Economizer are  one and  the same device.   For  purposes  of
              this evaluation, the device will  be referred  to  as the Fuel
              Economizer.

         (2)  Inventor and Patent Protection;

              Although the application states  the device  is patented only
              in India, a  copy  of the patent was not  submitted.  Because
              patents  often  aid  EPA  in  trying  to  understand  how  a
              particular device  functions,  the  applicant  was  requested
              (Attachment  B) to  provide  the  Agency  with  a  copy.   The
              applicant did not respond to EPA's request.

    b.   Description;

         (1)  The  primary  purpose  of  the  device,  as  stated  by  the
              applicant, is  to  cause a "more  complete combustion  of  the
              fuel,  thereby  improving  the  fuel  economy".   The  Agency
              finds no problem with the statement.

         (2)  The applicant's theory  of operation states that,  "the Fuel
              Economizer converts the  High  Tension D.C. current  given by
              the ignition  coil  into High  Frequency A.C.  current.   This
              A.C.  current  of  20,000 cycles  per  second  gives  multiple
              sparks at  various  points on  the spark  plug."  It was  not
              stated how  the device manages to  cause  the  high  frequency
              current to occur.   Also not stated was why multiple  sparks
              should occur at other than  the normal  gap which  is the path
              of least  resistance.   Additionally,  the  impact  the  device
              has on secondary  resistance,  capacitance, rise  time,  spark
              duration, and  available voltage  were  not  addressed.   EPA
              requested  (Attachment  B) that  the  applicant provide  more
              details.   Although  the  applicant responded (Attachment  A),
              the explanations provided were still  inadequate.   Again  EPA
              requested  additional  information  (Attachment C),  however,
              the applicant did not provide  any.

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To determine  whether the  device could alter  the secondary
voltage  characteristics,  a  sample device  provided  by the
applicant   was  subjected   to   some  preliminary   tests.
Specifically,  a  recent  model  vehicle was  tested,  with and
without   the   device,   using  a   Sun  Diagnostic  Analyzer
equipped  with an  oscilloscope.   The  oscilloscope patterns
showed  there  were no  changes in  the primary  voltages and
that  the  secondary voltage  spark lines were  either raised
or lowered  slightly  depending on which side  of  the device
the  scope pickup  leads were  attached.   The  difference in
observed  voltages  represent  a  voltage  drop  across  the
device   and   therefore   suggests  the   secondary  circuit
resistance/impedance was  changed as  a result  of  using the
device.   No other changes were  observed in  the secondary
scope  patterns.  Also  noted was an increase  in temperature
of the  device over that noted during  installation.   It was
attributed  to operation of  the  device and not  to elevated
engine compartment temperatures.

The  Royal  Automobile   Club  (RAG)  of England  tested  the
device  in a  similar manner.   Their   report  (Attachment A)
states  that,  "from the initial  tests carried out  using an
oscilloscope,  we  are of  the opinion  that  with  the  use of
the device,  the  high tension spark intensity  is increased,
naturally  improving  combustion   within   the   engine,   and
leading   to   better  performance   and  thus  fuel  economy.
However,  the  oscilloscope  trace  for   the  secondary  circuit
is unchanged  [emphasis  added]  whether the  device  is fitted
or not."   The RAG report does  not  define spark intensity
nor does  it explain how it  can state  the  spark intensity is
increased   (based   on   oscilloscope   tests)   when   the
oscilloscope   trace   is  unchanged   when  the   device   is
installed.   The  main point  to be made  by referencing  the
RAG report  is that their  scope patterns, as well as EPA's,
showed  the  device  has  minimal  impact on  secondary  voltage
characteristics.  Admittedly, the  oscilloscopes  used by RAG
and   EPA   have    their   limitations   and   perhaps   more
sophisticated  equipment might be  required  to show any other
changes within the ignition system.

EPA  asked  the  applicant   (Attachment  B)  if  the  device
consisted   of   capacitors,   resistors,    diodes,   or   a
transformer,  and  if  so,   what  were   their  specifications.
The applicant  responded (Attachment  A)  that  there  were no
capacitors,  resistors,  transformers,  or  diodes.   However,
the narrative  description in conjunction  with  the schematic
of the device, both of which were  submitted  in  that  same
letter, suggest  the  device is indeed  a capacitor  in series
with the  other components,  i.e.,  coil and  secondary cables,
which  contribute  to   the   capacitance   of   the  secondary
circuit.  Because  of the  open  distributor rotor  and  spark
plug  gaps,   one   side   of   the  capacitor  is  not  actually
grounded  (as   it normally is with  other capacitors)  until
the  secondary  voltage  reaches  a  value  high  enough  to

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     overcome  the  combined  resistance/impedance  of  the  mica
     discs within the device  and the rotor and  spark plug gaps.
     At  that  instance,  current  flow  is  established,  thereby
     causing a spark  to  occur across the spark  plug  gap.   Thus,
     although  the  device seems  to  be  a capacitor,  its use  is
     unlike most others  in  that  it  is not truly  grounded  at all
     times, and also  that  the mica  discs contained  therein are
     intended to be  inadequate in coping with the high  voltage
     and thereby, by  leakage,  allow  current flow to  exist.   The
     current  flow  combined  with   the   high   mica  resistance/
     impedance should  cause a  voltage drop  across  the  device.
     This  energy  loss   should  also   result  in   heat   being
     generated.  Both  a voltage  drop and  heat  generation  were
     observed during  the oscilloscope tests  discussed earlier.

     Since the device  apparently is  a  capacitor in  series  with
     other capacitors, and remembering that capacitors  in  series
     result in reduction of  the  overall capacitance,  the  device
     in effect  reduces  the secondary capacitance.    Should  this
     indeed be  the  case, then  the  secondary  voltage  rise  time
     would  also  decrease  with  a   consequential   increase  in
     available voltage  and a  decrease in  spark duration.   The
     rate  of  energy   transfer  across the  spark  plug electrodes
     would also  be  expected  to increase.  While  these  changes
     are beneficial with respect  to  the establishment  of a  good
     spark at the spark plugs, it is  not  known without  test  data
     whether  the  changes  would  have a  significant  impact  on
     exhaust emissions or  fuel economy.  It  must  be remembered
     that  EPA's  understanding  of  the  device  is  based  upon
     limited   information.     Should   the    applicant   provide
     additional information/test  data,  then  EPA may  develop  a
     different understanding as to how  the  device  functions and
     its associated  benefits.

(3)  The description of  the device given in the  application was
     determined by EPA to not be adequate.  The  construction and
     operation were  not  discussed  and   the   schematics  of  the
     device in Section 3(c) of the application were not detailed
     enough.  EPA requested (Attachment B) additional details  on
     the  device.   The  applicant's  response   (Attachment   A)
     included  a  narrative   description  and a  schematic  of  the
     device.  While  these were considered helpful toward gaining
     a  better  understanding of  the   device,  EPA was  still not
     sure   how   the    device   functions  without   additional
     information  from   the   applicant.    The   applicant  was
     requested (Attachment C)  to  submit additional  information,
     but none was  provided.

(4)  The applicant makes  several claims  for  the device.   Based
     on EPA's  understanding of  the   device,  the general  claims
     made with respect to easier  starting and increased life  of
     spark plugs and  ignition  contact points,  are  considered  to
     be reasonable.    The applicant  did not specify,  nor did  he
     provide  data   in  support   of,   specific   changes   that

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     purchasers of  the  device may realize.  With  respect to the
     other  claims  made  for   exhaust  emissions,  fuel  economy,
     horsepower, and acceleration, the applicant  did not provide
     adequate details about,  or test results in  support  of, the
     claims  made  for  the  device.    Thus,  without  additional
     information  and test  results,   EPA does  not  know if the
     claims are reasonable.

(5)  The cost  of  the device  was  not stated in  the  application.
     EPA  requested  (Attachment B)  the   tentative  cost  of the
     device,  however,   the applicant  responded   (Attachment  A)
     that it could not  be  commented  on as he was  unaware of the
     American production  cost.  EPA  estimates  the  device  would
     sell  for  under $20.   For most  purchasers  of   the  device,
     this would  be the only  cost involved  as most individuals
     could easily  install  it  themselves.  Even if the purchaser
     had the device  installed at  a commercial  service facility,
     the cost  of  labor would  be  minimal as  only a  few minutes
     would be required.

Installation, Operation, Safety and Maintenance;

(1)  Applicability;

     The  applicability   of   the   product   as   stated   in   the
     application  is  judged  to  be   appropriate  (assuming  the
     applicant defines  "petrol" engines  as  being  spark-ignition
     gasoline-fueled engines).

(2)  Installation - Instructions,  Equipment and Skills Required;

     The  applicant's  statement  that,   "installation  is   very
     simple" and that  "no  special tools, skills,  or adjustments
     are  required"  appear   to  be   correct.     EPA  requested
     (Attachment  B)  a  copy  of  the  installation  instructions
     which will  be provided  to purchasers  of  the  device.   The
     applicant  provided   a   copy   (Attachment   A)    which   EPA
     considered adequate.   Based  on  the design  of   the  device,
     EPA does  not  expect purchasers  to  experience  difficulty
     when installing the device.

(3)  Operation;

     The applicant  states, "no maintenance  procedure  required"
     and further,  "recommended to be replaced  after  12 to  15
     months".   These   statements   do   not   actually   address
     operation of the device but rather  maintenance.   Therefore,
     they will  be  commented  on later in Section  7c(5)  of  this
     report.   With  respect   to  operation  of  the  device,   EPA
     judged that the device is  capable  of functioning without  a
     controlling action from  the  driver  and that  it  should not
     affect the operation  of  the vehicle  in any  way.

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         (4)  Effects on Vehicle Safety;

              Based on the description  of  the  device,  EPA judges that the
              applicant's statement regarding safety is appropriate.

         (5)  Maintenance;

              The applicant  states,  "the normal maintenance  schedule for
              the vehicle is in  no way  affected."   However,  in Section 4c
              of the application,  the  applicant states  the  device should
              be replaced every  12 to 15 months.   EPA asked the applicant
              (Attachment  B) how  the  optimum replacement  interval  had
              been  determined.   The  applicant responded  (Attachment  A)
              that,  "the  device  normally works   on  Indian  make  of  4
              cylinder engines for 3 to 4  years.   In American cars having
              6 to  8  cylinder  engines   the  safe optimum life  would  be 12
              to 15  months".  The applicant did  not elaborate as  to how
              this  conclusion  was reached.  Considering  that many  four
              cylinder engines are being sold in the U.S.,  it seems the 3
              to 4 year life expectancy should also apply to them.

    d.   Effects on Emissions and Fuel  Economy;

         (1)  Unregulated Emissions;

              Based on the description  of  the device,  EPA does not expect
              the  device  to  have  an adverse   affect  on  unregulated
              pollutants.

         (2)  Regulated Emissions and Fuel Economy;

              The applicant  did  not  submit test data in  accordance  with
              the  Federal  Test  Procedure   and  the  Highway  Fuel  Economy
              Test.   These  two  test   procedures   are   the  primary  ones
              recognized  by  EPA  for   evaluation  of  fuel  economy  and
              emissions  for  light  duty  vehicles.*   The  applicant  was
              notified by telephone, and- in  two  letters  (Attachments  B and
              C)  to submit  test  results   using  appropriate  procedures.
              However, the only  test results  submitted  (Attachment A)  to
              EPA were  obtained  using  on-road  test procedures.   Because
              the control of variables  was inadequate, EPA could  not use
              the data in lieu of  that  required using  the EPA recommended
              procedures.  Thus,  the applicant  did  not  submit acceptable
              data from which EPA could  evaluate the effectiveness  of the
              device with respect to  the claims made for it.
*The requirement  for test  data  following these  procedures  is  stated  in
the policy  documents that  EPA  sends  to each  potential applicant.   EPA
requires duplicate  test sequences  before  and after  installation of  the
device on a minimum  of  two  vehicles.   A test sequence consists  of a cold
start FTP plus  a  HFET or, as a  simplified  alternative,  a hot  start  LA-4
plus a  HFET.   Other  data which have  been  collected  in accordance  with
other  standardized  procedures  are  acceptable  as  supplemental  data  in
EPA's preliminary evaluation of a device.

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                                                                             10
8.  Conclusions

    EPA  fully  considered  all  of   the   information  submitted  by  the
    applicant.  The evaluation of  the  Fuel Economizer device was based on
    that information  and  EPA's engineering experience.   Appropriate data
    was not  submitted showing the  device  could significantly  change the
    ignition  characteristics  or  that  it  could  achieve  the  benefits
    claimed.   Thus,  there is no  technical basis  for EPA to  support the
    claims made for the device or to perform confirmatory testing.

FOR  FURTHER  INFORMATION  CONTACT;   Merrill  W. Korth,  Emission  Control
Technology Division,  Office of  Mobile Sources, Environmental  Protection
Agency, 2565 Plymouth Road, Ann Arbor, Michigan 48105, (313) 668-4299.

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                                                                              11
                           List of Attachments

Attachment A      Copy of a letter from Agamco,^ Inc. to EPA, June 1, 1982.

Attachment B      Copy  of  a letter  from EPA  to  Agamco,  Inc.,  April 29,
                  1982.

Attachment C      Copy  of  a letter  from  EPA to  Agamco,  Inc, .  June 17,
                  1982.

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                                                                    Cc
12
     V
                                                                  ATTACHMENT A
                                                            2125 Center Avenue
                                                            Fort Lee, New Jersey 07024
                                                            U.S.A.
                                                            TEL (201) 592-6670
                                                            TLX:135130

                                                           June 1,  1982
Mr. Merrill W. Korth
Device Evaluation Coordinator
Emission Control Technology Division
U.S. Environmental Protection Agency
Ann Arbor, Michigan 48105

Dear Mr. Korth,

Further to your letter of April  29th and subsequent phone conversation,
we have today received the  following responses  to the questions  you
raised in your aforementioned letter as  follows: •

     EPA para 2:  For better understanding how  the device functions,
     we would like to give  the construction details.   It consists  of
     four brass discs on one side  separated by  mica insulator discs
     and one brass disc on  the other side.   These sub assemblies are
     held appart by metallic spring which also  acts as a conductor
     of electric current.   The brass end plates on both sides are
     directly in contact with the  terminals housed in the melamine
     housing.  We are pleased to enclose a sectional  drawing showing
     the construction.  There is no capacitor,  resistor,  transformer
     or diode.  The simplicity of  the construction makes  the device
     fail proof and completely reliable.

     EPA para 3:  The theory of operation for the device  is  as follows:
          (a)  In conventional coil ignition system the intermittent
               high tension DC current is converted into  High Frequency
               AC current
          (al) In additiion there  is a voltage  surging effect.   Multiple
               sparks are a result of AC current.
          (b)  Where the original  ignition  system has  secondary  alternating
               current of 30 megacycles  as  stated in  the  EPA letter, the
               advantage gained may be on account of  the  surging effect
               which will raise the voltage.  A party in  California had
               mentioned in their  letter that it  could be also used in
               electronic ignition system.

     EPA para 4:  In view of the para 3b  above  the claims  can be
                  substantiated only by  actual  performance tests on
                  American  cars.

     EPA para 5:  Cannot be commented on, as we are not aware of the American
                  production costs,

     EPA para 6:  Method of installation is  given  in our printed leaflet.

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                                                                              13
                                                            2125 Center Avenue
                                                            Fort Lee, New Jersey 07024
                                                            U S A
                                                            TEL:; 20 ^; 592-5670
                                                            TLX:135130
                                    (  2  )

     EPA para 7:  The device normally works on Indian make of  4  cylinder
                  engines for 3 to  4  years.  In American  cars  having
                  6 or 8 cylinder engines the safe optimum life  would  be
                  12 to 15 months.

We are also enclosing copies of the test reports performed by  the Royal
Automotive Club in the U. K. and the  Automotive Association  in West Africa.
We trust that the attached will further assist you in your evaluation.

We would be very grateful if you could  test the fuel economizer  sample
which was already forwarded to you, and convey to us your findings.

Thanking you for your kind and continuous attention, we remain,

                                          Sincerely,
                                          AGKMCQ, INC.
 MS:hs
Martin Shapiro    "
Director of- Sales

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                                                                               14
The  Royal Automobile  Club  and  the Automobile  Association  Reports  on
Petrol Saver:

EPA  could  not  obtain  legible  copies  of  the  subject  documents  and
therefore, they have not  been made part of  this  attachment.   Individuals
may  request  copies of  these  documents  from:  Merrill W.  Korth,  Emission
Control  Technology Division,  Office  of  Mobile  Sources,  Environmental
Protection  Agency, 2565  Plymouth  Road,  Ann Arbor,  MI   48105.   (313)
668-4299.

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                                                                                                       15
                       FUEL    ECONOMIZER
 How it works*:
 The Fuel   Economizer unit converts . the  High  Tension  0. C. current given by the ignition
 coil  into  High-Frequency A.  C. current. This  A.  C. current  of 20,000 cycles per second
 gives multiple  sparks  at various points >on the Spark Plug.  Being  independent  of the ohmic
 resistance it fires the plugs  even if they are fouled.
                                                             \

  Benefits :
  1   Reduces fuel: consumption  from 10  to 15% through complete combustion.
- 2.  Increases^Vlorse Power.   '...:.  .:?•;•                          ,           -  ..•.  •
  3.  Gives easier starting.      ;:               -                             -
  4.  Increases life of Plugs and Oelco Points,
  5.  Gives smoother acceleration,  without flat-spot.
  6.  Prevents air pollution
  7.  Life upto"4 years.         .  -

  Directions for  Installation :  '-   '
•  I           *-            ••_.•-.
  1.  Cut with-pliers the  High Tension  Cable between  Distributor  and  Coil, at a distance
     of 2 inches  from-the Distributor Cap.                         \'
 ,2.  Disconnect the cable from the- coil.                           •
  3.  Screw in the unit firmly  into tha distributor—side cable.
  4.  Screw in the unit into  the cable coming  from coil.
  5.  Connect the cable back to the  coil  as before.
              v^ ..--,!£„••
              •;« ' vi; -x-»•
                               .;.^..,,   Clgajjt Diagram
                                ••-i.-r.-jt .V »•-•
                                                  Ignition €ott
                               Olitrlbutor

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   AGAMCO INC.
2125  CENTER AVEWUt
  LEE, NEW JERSEY 07024
      U.SA
                 13513JJ

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                                                                  ATTACHMENT B 17
April 29, 1982
Mr. Martin M. Shapiro
Director of Sales
Agamco, Inc.
2125 Center Avenue
Fort Lee, NJ  07024

Dear Mr. Shapiro.:

We have received your April 12,  1982 application for an EPA  evaluation  of
the  "Fuel  Economizer",  a  fuel  economy  retrofit  device.  We  have made  a
preliminary  review  of  your  application  and  will  undertake  a  complete
review  after  all required information  has  been submitted.   Our  prelim-
inary comments are as follows:

1.  In  your transmittal   letter  which  accompanied  the  application,  you
    stated  you  would appreciate  our testing of  the  device and  providing
    you with our test results and "approval."   I would like to make clear
    that  EPA does  not either  approve  or  disapprove  devices.   We only
    evaluate the devices and make our findings available to the  public  in
    the form of a final report.

2.  Section 2(b)(2)  states the  device is  patented  in India only.  If the
    patent  is in English,  you may want to provide us with  a  copy so that
    we may develop a better understanding  of how  the  device functions.

3.  Section 3(b)  of your  application describes  the  theory  of  operation
    for the device.  Your description does  not sufficiently  detail  how
    the device manages  to  convert secondary direct  current to alternating
    current  with a frequency  of  20,000 cycles per  second.    Does  the
    device  consist  of capacitors,  resistors,  transformers,  or diodes?   If
    so,  what  are  their  specifications?   Considering  that  all  spark
    ignition  engines   possess,   even  without   your  device,    secondary
    alternating current of approximately 30 megacycles  once  the  spark is
    established at  the  spark plugs  (often referred to  as the capacitance
    component of the  spark discharge), the  20,000  cycles  per second fre-
    quency  attributable to your  device  would seem to  have  an  insignif-
    icant  effect  when  compared   to., that  obtained  from the  30  megacycle
    frequency.  Please  submit any  addditional  information you  may have
    showing  the  affect your  device has  on  secondary  resistance,  capac-
    itance,  rise  time,  spark  duration  and  available  voltage.   Also,
    provide a schematic drawing and  a sectioned view of the device.

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                                                                            18
    You also  state  the high frequency  alternating current gives  multiple
    sparks  at  "various  points"  on the  spark  plug.   Is  our  assumption
    correct that the "various  points"  you refer to are all located  within
    the combustion  chamber?   Does your statement  mean that current  paths
    are being established at  other  than the  usual gap  which is located
    between the center and ground electrode tips?  If so, and  considering
    that  electrical current generally  follows  the  path  of  least  resis-
    tance (that being  the gap  located  between the center and ground  elec-
    trode tips  for  spark  plugs),  why would  current flow be established at
    longer and more resistive  paths when your device is used?

4.  In Section  3(d),  specific  claims  are made  for the  device.   On what
    technical basis are  these claims made?  Have  tests  been performed to
    substantiate the  claims?   If so,   please  provide  us  with  the  proce-
    dures used and the results.

5.  Section  3(e)  does not  include the  tentative  cost  of   the  device.
    Please provide  the omitted information, if  available,  so  that we can
    perform a cost analysis for our final report.

6.  Section 4(b) states that," installation is  very simple".   However,  no
    details  are given.   Are  any adjustments  of  the engine  parameters
    required?   Please submit   a  copy  of  the   installation  instructions
    which will be provided to  purchasers of your device.

7.  Secion  4(c) states  the device  should  be  replaced  after  12  to  15
    months.  How has the optimum  replacement interval been determined?

8.  Section 5(b) does  not include any  test results.  As  explained  in  my
    March 8 letter  to  you, test data will be required  from an independent
    test  lab  prior to EPA  performing  any  testing.   My  letter included
    details on  the  required  test  procedures  and also  stated  that  a min-
    imum of two vehicles  would need to be  tested.   I  suggest  you contact
    independent  test  labs  regarding the  testing of  your device.   I  am
    also ready to assist you in developing an appropriate test plan.

    In order  to maintain  our schedule   for  evaluating  your  device,   I ask
    that  you  respond  to  this  letter by  May 21  and  that you  submit all
    test  data by June 11.   Should  your  have   any  questions   or  require
    further information, please contact me.

Sincerely,
Merrill W. Korth
Device Evaluation Coordinator
Test and Evaluation Branch

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                                                               ATTACHMENT   C    19

       JNITED S7A~E5 E.\ . irtON'-ENTAL PROTEC~;C\  -GE\CV-

                      A.NN  AR3OR  MICHIGAN IQ'.C;-
June 17, 1982
Mr. Martin M. Shapiro
Director of Sales
Agamco, Inc.
2125 Center Avenue
Fort Lee, NJ  07024

Dear Mr. Shapiros

We  have received your letter of  June 1  in which  you  responded  to  the
questions raised in my letter of April 29.  Although you provided  some  of
the  requested information, you  did not  satisfy the  requirements  of  the
following two areas*

    1?  Your letter  did not sufficiently detail  how the devices-converts
         secondary direct  current  to alternating current with a frequency
       -  of  20,000 cycles per  second.   In fact,  your  response  merely
         reiterated  the statement  given  in the  application*  Addition-
         ally,  you did  not  submit  information showing the  affect  your
         device may have on secondary resistance,  capacitance, rise  time,
         spark  duration,  or available  voltage.   Further,  you did not
         explain why  sparks should  occur  at  other then the normal tenter
         to ground electrode  gap.

    2.   You  did not  provide the required test  data which were explained
         in my  letter of March  8.   The  road test data that you provided
         can  only  be  used  as supplementary  information.   A  prerequisite
         to EPA testing is that you provide  data  which supports the fuel
         economy claims, made for the  device.  That  data must be obtained
         from an  independent facility using the  procedures  described  in
         my letter of  March 8.

So  that  we  may evaluate your device  in a timely  manner,  I  ask that all
information and data  be submitted  by  July 19.  If  the required informa-
tion and data are not  received  by  that date,  we  will complete our evalua-
tion using all  available information.   A  copy of our final report will  be
sent to you prior to  its announcment in the  Federal Register.  Should you
have questions  regarding this course of action,  please  contact me.

Sincerely,
Merrill W. Korth
Device Evaluation  Coordinator
Test and Evaluation Branch

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