EPA-AA-TEB-511-81-5A
Evaluation of the Paser Magnum/Paser 500/Paser 500 HEI
Under Section 511 of the Motor Vehicle Information
and Cost Savings Act
May, 1981
by
Edward Anthony Barth
Test and Evaluation Branch
Emission Control Technology Division
•Office of Mobile Source Air Pollution Control
U.S. Environmental Protection Agency
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6560-26
ENVIRONMENTAL PROTECTION AGENCY
[40 CFR Part 610]
[FRL
FUEL ECONOMY RETROFIT DEVICES
Announcement of Fuel Economy Retrofit Device Evaluation
for "Paser Magnum, Paser 500, and Paser 500 HEI"
AGENCY; Environmental Protection Agency (EPA).
ACTION; Notice of Fuel Economy Retrofit Device Evaluation.
SUMMARY; This document announces the conclusions of the EPA evaluation
of the "Paser Magnum, Paser 500, and Paser 500 HEI" devices
under provisions of Section .511 of the Motor Vehicle
Information and Cost Savings Act.
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BACKGROUND INFORMATION: Section 5H(b)(-l) and Section 511(c) of the
Motor Vehicle Information and Cost Savings Act (15 U.S.C. 2011(b))
requires that:
(b)(l) "Upon application of any manufacturer of a retrofit device (or
prototype thereof), upon the request of the Federal Trade Commission
pursuant to subsection (a), or upon his own motion, the EPA Administrator
shall evaluate, in accordance with rules prescribed under subsection, (d),
any retrofit device to determine whether the retrofit device increases
fuel economy and to determine whether the representations (if any) made
with respect to such retrofit devices are accurate."
(c) "The EPA Administrator shall publish in the Federal Register a
summary, of the results of all tests conducted under this section,
together with the EPA Administrator's conclusions as to —
(1) the effect of any retrofit device on fuel economy;
(2) the effect of any such device on emissions of air
pollutants; and
. (3) any other information which the Administrator determines to
._ be relevant in evaluating such device."
..EPA published final regulations establishing procedures for
conducting fuel economy retrofit device evaluations on March 23, 1979
[44 FR 17946]
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ORIGIN 0? REQUEST FOR EVALUATION: On July 30, 1980, the EPA received a
request from Amerlmex Industries, Inc. for evaluation of fuel saving
devices termed "Paser Magnum, Paser 500, and Paser 500 HEI". These
Devices are claimed to "... promote efficiency in an internal combustion
engine by discharging induced electrical pulses into the firing chamber
to promote chemical activity before the interception of and during
combustion of the fuel."
Availability of Evaluation Report: An evaluation has been made and the
results are described completely in a report entitled: "EPA Evaluation
of the Paser Magnumj Paser 500, and Paser 500 HEI Device Under Section
511 of the Motor Vehicle Information and Cost Savings Act." This entire
report is contained in two volumes. The discussions, conclusions and
list of all attachments are included in EPA-AA-TEB-511-81-5A,, which
consists of 21 pages. The attachments are contained in EPA-AA-TEB-511-
81-5B, which consists of 180 pages. The attachments include patent
information, correspondence between the Applicant and EPA and all
documents submitted in support of the application.
Copies of this report may be obtained from the National Technical
Information Service by using the above report numbers. Address requests
to:
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National Technical Information Service
U.S. Department of Commerce
Springfield, VA 22161
Phone: Federal Telecommunications System C'7TS) 737-4650
Commercial 703-487-4650
Summary of Evaluation
The Paser Magnum, Paser 500, and Paser 500 HEI are add-on ignition
devices that are claimed to improve vehicle emissions and fuel economy by
discharging induced electrical impulses into the combustion chamber
before and during the engine's combustion cycle. :
EPA fully considered all of the information submitted by ..the Device
manufacturer in the Application. The evaluation of the "Paser Magnum,
Paser 500, and Paser 500 HEI" devices was based on that information and
results of the previous EPA test program.
The Applicant submitted no valid data to support the claim for increased
fuel economy. The Applicant was advised by letter on several occasions
of EPA's requirement that Applicants submit valid test data following the
proper EPA Test procedures.
Test data subaitted by the Applicant did not prove that use of the "Paser
Magnum, Paser 500, or Paser 500 HEI" would enable a vehicle operator to
improve vehicle fuel economy or reduce emissions.
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EPA tested the Paser Magnum ten years ago. This testing showed that the
Paser Magnum (which the Applicant stated is equivalent to the Paser 500
and Paser 500 HEI) showed no significant effect on either exhaust
emissions or fuel economy.
Thus, there is no technical, basis to support any claims for a fuel
economy improvement due to the use of the "Paser Magnum, Paser 500, or
Paser 500 HEI" device-
FOR FURTHER INFORMATION CONTACT; Merrill W. Korth, Emission Control
Technology Division, Office of Mobile Source Air Pollution Control,
Environmental Protection Agency, 2565 Plymouth Road, Ann Arbor, Michigan
48105, 313-668-4299.
Date Edward F. Tuerk
Acting Assistant Administrator
for Air, Noise, and Radiation
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Evaluation of the Paser Magnum, Paser 500 and Paser 500 HEI Devices under
Section 511 of the Motor Vehicle Information and Cost Savings Act
The following is a summary of the information on the device as submitted
by the Applicant and the resulting EPA analysis and conclusions.
1. Marketing Identification of the Devices;
A. "Paser Magnum or Paser 500 (for engines with standard distrib-
utor caps)"
B. "Paser HEI (for engines with non-standard distributor caps)"
2. Inventor of the Devices and Patents;
A. Inventor
Eugene Irvin, Jr.
8720 Empress Row
Dallas, TX 75247
B. Patent
Patent No. 3613653 (see Attachment A)
Patent Application No. 2118G (see Attachment B)
3. Manufacturer of the Devices:
Amerlmex Industries
8720 Empress Row
Dallas, TX 75247
4. Manufacturing Organization Principals;
"95% of stock owned by Eugene Irvin, Jr."
5. Marketing Organization in U.S. Making Application;
Amerlmex Industries
8720 Empress Row
Dallas, TX 75247
6. Applying Organization Principals;
Eugene Irvin, Jr. - owns 95% of stock."
"Contact Person: Eugene Irvin, Jr."
7. Description of Devices:
A. Purpose of the Devices (as supplied by Applicant); "To increase
combustion efficiency in multi-cylinder ignition equipped inter-
nal combustion engine."
B. Theory of Operation (as supplied by .Applicant)^ "See Exhibit
No. 3" (see Attachment C)
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C. Detailed Description of Construction and Operation (as supplied
by Applicant:); "See patent specifications - Exhibits 1 and 2."
(see Attachments A and B)
8. Applicability of the Devices (as supplied by Applicant):
"All ignition equipped multi-cylinder internal combustion engines.
This includes not only cars, trucks, buses, and motorcycles, but also
tractors, forklifts, marine engines, compressors, generators, and any
other mechanism in which a multi-cylinder Ignition equipped internal
combusion engine is used."
9. Device Installation (as supplied by Applicant);
A. "Paser 500 - See Exhibit No. 4" (see Attachment D)
B. "Paser 500 HEI - See Exhibit No. 5" (see Attachment E)
10. Device Operation (as supplied by Applicant);
A. "Paser 500 - See Exhibit No. 4" (see Attachment D)
B. "Paser 500 HEI - See Exhibit No. 5" (see Attachment E)
11. Device Maintenance (as supplied by Applicant):
"None"
12. Effect on Vehicle Emissions (non-regulated) (as supplied by Appli-
cant) :
"Effects on Vehicle Emissions (non-regulated): See analysis of test
data (procured from both General Testing Laboratories — Exhibit No.
6, and from Dr. Mel Adams of MIT - Exhibit No. 7) which indicates
that the installation of the Paser 500 results in an increase in
combustion efficiency, which means that the chemical reaction of the
burning of the fuel proceeds further to the right. The emissions
measured after installation of the Paser indicate a reduction in
carbon monoxide and hydrocarbon." (Attachment F is Applicant's
Exhibit 6, Attachment G is Applicants Exhibit 7)
13. Effects on Vehicle Safety (as supplied by Applicant):
"None"
14. Test Results - Regulated Emissions and Fuel Economy (submitted by
Applicant);
"See Exhibit 6" (Attachment G is Exhibit 6)
15. Analysis;
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A. Marketing Identification of Devices:
In Section 1, Amerlmex stated the "Paser Magnum or Paser 500
(for engines with standard distributor caps)". Since it
appeared to EPA that the Paser Magnum and Paser 500 were
basically the same device, EPA requested clarification (See
Attachment K).
EPA met with Amerlmex on January 6, 1981 at a meeting held at
Amerlmex1s request. When asked about the differences between
the models, Amerlmex stated:
(1) there was no functional difference between the Paser Magnum
and Paser 500.
(2) the only differences between the Paser Magnum and Paser 500
were changes in materials and manufacturing specifications
to improve durability and reliability (see also Attachments
H and J).
(3) that the Paser Magnum has been withdrawn from the market.
(4) that the Application should have stated the Paser 500 was
for engines with standard ignition systems rather than
stating the device was "for engines with standard
distributor caps."
(5) that the Application should have stated the Paser 500 HE1
was for engines with electronic ignition systems rather
than stating the device was "for engines with non-standard
distributor caps."
B. Description of Devices;
(1) Purpose of the devices as stated in the Application,
Section 7, is to increase combustion efficiency.
(2) The theory of operation for the Paser 500 is described in
section III of Attachment C.
(a) "The Paser 500 promotes combustion efficiency in an
internal combustion engine by discharging induced
electrical pulses into the firing chamber to promote
chemical activity before the inception of and during
combustion of the fuel. The Paser 500 accomplishes
this through the attachment to the secondary circuit
of the ignition system of an additional capacitive
circuit which is charged and discharged by employing
the principle of electro-magnetic induction. Basi-
cally, the operation of the Paser 500 proceeds in the
following manner in a multi-cylinder engine:
"a. When any spark plug fires, the electrical current
moving through the spark plug wires radiates an elec-
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tro-magnetic field. Without the Paser 500 installed,
this energy simply radiates from the spark plug wire
and is wasted.
"b< With the Paser 500 installed, the electro-mag-
netic field radiated by the current flowing to the
firing spark plug charges a circuit inside the Paser
500 induction sleeve by the process known as electro-
magnetic induction.
"c. The Paser 500 circuit which has been charged by
induction from the firing cylinder spark plug wire is
in electrical series with like circuits connected to
the non-firing cylinder spark plug wires. Hence, when
one of the Paser 500 circuits is charged, all are
charged.
"d. The Paser 500 circuits connected in series with
the non-firing cylinder spark plug wires induce elec-
trical fields through the spark plugs into the non-
firing cylinders.
"e. The result is that when any cylinder fires, an
induced electrical field, which is of high intensity
but not high enough to pre-ignite the fuel/air mix-
ture, is discharged in all the remaining cylinders.
This action occurs not only prior to ignition of the
fuel/air charge in the normal manner, but also during
combustion. This electrical discharge into the
gaseous mixture enhances chemical activity of fuel and
air prior to and throughout the combustion process.
"The effect is a more complete combustion in the fuel/
air mixture. In more technical terms, the Brake
Specific Fuel Consumption is reduced; that is, less
fuel is required to produce a given measure of horse-
power. "
(b) Since the Application did not specify the theory of
operation for the Paser Magnum and Paser 500 HEI, EPA
requested the Applicant submit the theory of operation
for these two Devices (see Attachment K). Amerlmex
stated "The theory of operation for all versions of
the Paser is the same." (see Attachment M).
(c) Since the Paser 500 HEI patent application (Attachment
B) indicated the Paser 500 HEI developed 40% more
potential than the Paser 500, EPA requested the
Applicant clarify this apparently substantial
difference and provide data (Attachment K). The
Applicant responded (Attachment M):
"The Paser- 500 induces -approximately -1/3- of- the
firing voltage into the non-firing cylinders.
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The Paser 500 induces approximately 7/15 of the
firing voltage into the non-firing cylinders.
The relative voltages result from the inductive
relationship designed into the unit's circuits."
(d) Because the Applicant's response (Attachment M) to
EPA's December 24, 1980 letter (Attachment K) made
several apparently conflicting statements about the
Paser Device's theory of operation, EPA requested
(Attachment P) the Applicant to clarify the
information previously provided:
"Your January 13, 1980 (1981?) letter makes
several apparently conflicting statements about
the Paser Devices. The letter claims in effect
that the Paser 500 and Paser 500 HEI give the
same performance. However, the letter also
states the Paser 500 induces 1/3 the firing
voltage while the Paser 500 HEI induces 7/15 the
firing voltage. Therefore, the operation of
these devices in a vehicle is clearly different -
unless the observed effects on emissions or fuel
economy are the same. Please clarify these
points by March 31, 1981."
The Applicant did not respond to these questions in
the Applicant's response (Attachment R) to this
request and the Applicant was so advised (Attachment
S).
(e) Although it is true that the spark plug wires radiate
an electromagnetic field when the spark plug fires,
EPA is unable to judge:
(i) whether the device is able to efficiently
interact with the electromagnetic field of
the firing plug.
(ii) whether any electromagnetic field induced in
the firing plugs is able to materially
affect the combustion process-
(f) Therefore, since the Applicant did not provide
sufficiently detailed information, EPA is unable to
properly assess the claimed theory of operation.
(3) Detailed Description of Construction and Operation:
The mechanical Description of the Devices given in the
patent and patent application (see Attachments A and B) are
judged to be an adequate physical description of the
Devices.
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C. Applicability of the Devices;
The applicability of the Devices, as stated in section 8, to
"all ignition equipped multi-cylinder internal combustion
engines" is judged to be valid. However, the specific
applicability of the individual devices is not clear.
(1) In section 1 the Paser 500 was identified as being for
engines with standard distributor caps and the Paser
500 HE1 was identified as being for engines with
non-standard distributor caps.
(2) During the meeting at EPA on January 6, 1981, Amerlmex
stated, 15(A)(4) and 15(A)(5), that the Paser 500 was
for engines with standard ignition systems and the
Paser 500 HE1 was for engines with electronic ignition
systems.
(3) Amerlmex's January 13, 1980 (1981?) letter (Attachment
M) replying to EPA's December 24, 1980 letter
(Attachment K), did not sufficiently clarify the
applicability and usage of the Paser Devices.
(4) EPA therefore requested, March 3, 1981 (Attachment P)
that Amerlmex respond and clarify.
"Your January 13, 1980 (1981?) letter replying to
EPA's December 24, 1980 letter stated "The Paser
500 HEI can be used with both female and male
connectors on the distributor cap. It can be
used with either point - condenser and electronic
ignition systems." This conflicts with the
information provided in the discussion of the
device during your January 6, 1981 visit to EPA.
At that meeting, AMERIMEX stated that the Paser
500 was for conventional ignition systems and the
Paser 500 HEI was for electronic ignition
systems. Therefore, in order to resolve these
seeming inconsistencies, please answer the
following questions by March 31, 1981.
1. For conventional ignition systems with
sockets in the distributor cap, which is the
recommended Device, Paser 500 or Paser 500
HEI?
2. For conventional ignition systems with
sockets in the distributor cap, would there
be any benefit to using the Paser 500 HEI
instead of the Paser 500?
3. For electronic ignition systems with sockets
in the distributor cap, which is the
recommended Device, Paser 500 or Paser 500
HEI?
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4^ For electronic ignition systems with sockets
in the distributor cap, would there be any
benefit to using the Paser 500 HEI instead
of the Paser 500?"
The Applicant did not respond to these questions in
the Applicant's response (Attachment R) to this
request and the Applicant was so advised (Attachment
S).
(5) Therefore, since the Applicant did not provide
sufficiently detailed information after repeated
requests, EPA is unable to properly identify to which
ignition systems (conventional or electronic) and
distributor caps (standard or non-standard) the Paser
500 and Paser 500 HEI are applicable.
D. Costs
"The suggested retail price of the Paser is $49.95." (Attachment
M) It is assumed this price applies to both the Paser 500 and
Paser 500 HEI since the Applicant did not specify any difference.
E. Device Installation - Tools and Expertise Required:
«. • ,
(1) The Paser 500 and Paser 500 HEI instructions/warranty
information are judged to be complete for the physical
installation of the device.
(2) The installation of the Paser devices appears to be within
the mechanical skills of many vehicle operators. The
checkout of the engine to insure ". . . that the engine is
in normal good running order." will require some mechanical
skills, common tools, and working knowledge of the engine*
Amerlmex recommends ". . . that installation be performed
by a qualified mechanic, who insures that the engine is in
good running order."
F. Device Operation;
The Applicant requires that the oil and oil filter be changed
1000 miles after the installation of the Paser 500/Paser 500 HEI
and to adjust the idle speed, if required, to the normal setting.
G. Device Maintenance;
The Application specifies that no maintenance is required for
the Paser 500/Paser 500 HEI device. Although this is true in
the general usage of the word maintenance, the Paser 500/Paser
500 HEI caps would require the normal, periodic inspection
accorded the spark plug wires to insure -the distributor caps,
Paser, and spark plug wires are properly connected.
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1A
H. Effect on Vehicle Emissions (non-regulated);
(1) The Applicant infers that because the emission data
supplied in Attachments F and G proves the claims for lower
emissions, that non-regulated emissions would not be
adversely affected.
(2) Non-regulated emissions were not assessed as part of the
evaluation. However, since the device does not appear to
modify the vehicle's emission control system (although it
is claimed to modify the combustion process), it appears
reasonable to assume that the device would not signifi-
cantly affect a vehicle's non-regulated emissions.
I. Effects on Vehicle Safety:
As claimed, it is judged unlikely that the Devices would
adversely affect vehicle safety when properly installed.
J. Test Results Supplied by Applicant:
Applicant did not submit any test data per the current Federal
Test Procedure or Highway Fuel Economy Test. These are the only
EPA recognized test procedures^'. This requirement for test
data following these procedures was stated in the application
test policy documents and three subsequent letters that EPA sent
to the applicant (Attachments I, K, P, and S).
Since EPA had previously tested the Paser Magnum (see Section 15
K), the Applicant was advised in the initial July 9, 1980 letter
(Attachment I) and again in the December 24, 1980 letter
(Attachment K) that for the Paser devices to be reevaluated
(1) From EPA 511 Application test policy documents:
Test Results (Regulated Emissions and Fuel Economy):
Provide all test information which is available on the effects
of the device on vehicle emissions and fuel economy.
The Federal Test Procedure (40 CFR Part 86) is the only test
which is recognized by the U.S. Environmental Protection Agency
for the evaluation of vehicle emissions. The Federal Test
Procedure and the Highway Fuel Economy Test (40 CFR Part 600)
are the only tests which are normally recognized by the U.S. EPA
for evaluating vehicle fuel economy. Data which have been
collected in accordance with other standardized fuel economy
measuring procedures (e.g. Society of Automotive Engineers) are
acceptable as supplemental data to the Federal Test Procedure
and Highway Fuel Economy Data will be used, if provided, in the
preliminary evaluation of the device. Data are required from
the test vehicle(s) in both baseline (all parameters set to
manufacturer's specifications) and modified forms (with device
installed).
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there needed to be either (1) technological improvements in the
Devices or (2) new data. The Applicant's response (Attachment
M) was that there were no technological improvements and that
the Paser 500 and Paser 500 HEI were merely production
improvements of the Paser Magnum. The Applicant did not submit
valid data documenting an improvement for the Devices.
The test data submitted by the Applicant are listed below and
evaluated.
(1) General Testing Laboratories Vehicle Testing
The vehicle test data, contained in the General Testing
Laboratory Report Summary (Attachment F) contained fuel
economy test data for the four vehicles tested with the
Paser Magnum installed. The vehicles were tested in 1971
using the 1370 second cold start Federal Test Procedure
(FTP) then in effect. These results are summarized below:
Vehicle Fuel Economy, MPG
initial baseline
without Paser
initial with Paser
Paser after 1000 miles
Paser after 2000 miles
Paser after 3000 miles
1970
Maverick
200 CID
12.3
18.
16.
13.
16.8
1965
Oldsmobile
300 CID
11.0
12.9
14.2
11.2
10.9
1968 1968
Plymouth Volkswagen
318 CID 1500 CC
9.7
12.3
14.8
11.9
12.2
14.8
.2
.3
21.
20.
20.0
20.0
These tests show considerable unexplained variability in the
test results with the Paser Device.
The current procedure, the 1975 FTP, repeats the first 505
seconds of the cold start cycle after a 10 minute hot soak.
Therefore, data obtained using this procedure can be used for
comparison to the 1971 FTP by using the fuel economy data for
the first 1370 seconds of the current FTP.
EPA recently conducted tests on a group of 1970-71 vehicles as
part of a study on the effects of temperature on vehicle
emissions, "Effects of Ambient Temperature and Driving Cycle on
Exhaust Emissions, EPA-460/3-80-012". These vehicles selected
for testing were verified to be in good mechanical condition and
properly tuned prior to testing. A group of these vehicles
similar to the preceeding is given below with fuel economy
calculated for the same 1370 second driving cycle.
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Vehicle Fuel Economy, MPG
1970 1970 1970 1970 1970
Maverick Chevrolet Dodge Plymouth Volkswagen
200 CID 307 CID 318 CID 318 CID 1500 CC
18.0 13.4 14.4 13.9 23.1
When the fuel economy of this group of vehicles is compared to
those submitted by the Applicant, the data suggests that the
baseline fuel economy for the Applicant's fleet was too low for
the vehicles to be considered representative of vehicles in
satisfactory mechanical condition and properly tuned to
manufacturer's specifications.
Since the Applicant specifies in the instructions (Attachments D
and E) that the vehicle's engine must be ". . . in normal good
running order.", the Applicant's data is judged to be
non-supportive of the conclusion that the Device improves fuel
economy.
As previously noted, the EPA also requires that valid
FTP/HFET test results be obtained by Applicants at one of
the independent laboratories currently listed on the EPA
list of acceptable laboratories and use representative
current vehicles. The four vehicles tested are not
representative of current vehicles and the Applicant was so
advised (Attachment P). The Applicant was advised of this
requirement for valid current vehicle testing in the EPA
test policy documents provided the Applicant on July 9,
1980 and again reminded in more recent communications
(Attachments I, K, P, and S).
(2) General Test Laboratories Engine Dynamometer Testing
The Applicant also submitted test data on a 1968 Oldsmobile
330 CID V-8 engine (see Attachment G) with the Paser 500.
These tests consisted of engine dynamometer tests modeled
after the EPA heavy duty engine dynamometer test cycle.
However, a post test inspection of the engine by the
Applicant revealed evidence of a ". . . substantial amount
of rust accumulation on the cylinder walls from rain and
moisture" (see Attachment G). Therefore the initial
condition of the engine was really unknown and it cannot be
considered a representative engine. Therefore this engine
data cannot be used to evaluate the Device and the
Applicant was so advised (Attachment P).
(3) During the January 6, 1981 meeting with EPA, Amerlmex
provided EPA with copies of tests of the Paser Devices
conducted by several organizations using a variety of test
methods. The tests, are discussed-below. ..
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(a) Mexican Government Environmental Protection Agency
Test of the Paser 500 (Attachment Q, pages 5, 6, and
7).
The Applicant stated the test procedures used were
identical to those required by the U.S. EPA. At that
time, EPA informed the Applicant that the data could
be of some use for evaluating the Devices if_ (1) the
Applicant provided EPA a detailed description of the
Mexican test procedures including a translation to
English, (2) the Mexican test procedures were
identical to the EPA test procedures as claimed,
(3) the test vehicles were representative of current
U.S. motor vehicles, and (4) the Applicant provided
detailed test results including the raw data.
The information provided by the Applicant in response.
to this request (Attachment Q, pages 1 thru 6) was the
information previously provided with a copy (including
translation of the Mexican Government's authorization
for the Paser 500. It did not include the necessary
information requested by EPA.
Therefore, since the Applicant failed to provide the
requested information, EPA is unable to evaluate these
test results.
(b) Mexican Government Department of Public Works (see
Attachment T. Attachment T was provided in Spanish
with an English translation. Only the English
translation is attached.)
The test data consisted of tailpipe emission
concentrations at various engine rpm (no load). These
tests cannot be used to indicate what might be
achieved, by a vehicle on a chassis dynamometer during
the EPA cold/hot start transient vehicle tests.
The test data also included what is apparently road
test fuel economy taken during extended periods of
vehicle operation. These tests represent relatively
uncontrolled tests and therefore cannot be used to
validate a fuel economy change due to the Device.
Also, it is unclear why this recently (1980) conducted
testing used the Applicant's Paser Magnum (1) since
the Applicant no longer markets the Paser Magnum (see
Section 15 A(3) of this report), and (2) since the
Applicant apparently cooperated with the testing group
by supplying detailed technical information about the
Device.
(c) Consumer's Report of Japan (magazine's tests) . Paser
500 (see Attachment U of this report).
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The test data consisted of road test fuel economy
taken over the magazine's city and highway routes.
Again, these tests represent relatively uncontrolled
tests and therefore cannot be used to validate a fuel
economy change due to this device.
Also, the test data has several anomalies. (1) The
current gas mileage data was added to previous year's
data to arrive at a baseline - why not use the
current? (2) The test without the device showed
substantially different fuel economy for the
magazine's city and highway routes, however, the tests
with the Device showed the same fuel economy for both
routes.
(d) Japanese National Defense Acadamy's testing of the
Paser 500 (see Attachment V of this report.
Attachment V was provided in Japanese with an English
translation. Only the English translation is
attached).
The Japanese National Defense Academy testing
consisted of constant speed tests of a small single
cylinder engine on an engine dynamometer. These
results cannot be extrapolated nor inferred to
directionally indicate what might' be achieved by a
multi-cylinder, automotive engine during the EPA
cold/hot start transient vehicle tests.
(e) Auto Mechanic Magazine of Japan testing of the Paser
500 (see Attachment W of this report. Attachment W
was provided in Japanese with an English translation.
Only the English translation is attached).
The tests consisted of steady state fuel economy
tests, acceleration tests, and road tests. Although
there were changes noted, there were insufficient test
details to verify the steady state and acceleration
tests. Also, the road tests are relatively
uncontrolled tests and therefore cannot be used to
evaluate the device.
(f) Royal Autommobile Club testing of the Paser Magnum
(see Attachment X. Note this Device is no longer
marketed).
The tests consisted of road tests under relatively
uncontrolled test conditions and therefore cannot be
used to evaluate the Device.
(g) Carlos W. Coon, Jr., Ph.D, P.E. tests of the Paser 500
(see Attachment Y).
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This letter briefly reviews the GTL test results which
were previously discussed in 15 (J)(l) and 15 (J)(2).
The letter also briefly discusses steady state tests
conducted over 9 years ago using a 1968 Buick.
However, no detailed data was provided.
(h) Boyce and Hughes Engineering Associates test of the
Paser 500 device by Professor J. Martin Hughes (see
Attachment Z).
This letter summarizes the test results of chassis
dynamometer test of the Paser 500. However, since no
details of the tests were provided, these tests cannot
be used to evaluate the device.
(i) Wayland Baptist College tests of the Paser 500 device
by Professor James C. Cox, Jr. (see Attachment AA).
This letter contains results of tailpipe emission
concentration tests for two vehicles under some
unspecified standard conditions. These tests cannot
be used to indicate what might be achieved by a
vehicle on a chassis dynamometer during the EPA
cold/hot start transient vehicle tests.
K. Test Results Obtained by. EPA;
EPA tested the Paser Magnum ten years ago. (EPA\ reports 71-6
and 71-31). This testing showed that the Paser Magnum (which
the Applicant states is equivalent to the Paser 500) showed no
significant effect on either exhaust emissions or fuel economy.
During a meeting with Amerlmex on January 6, 1981, Amerlmex
requested EPA to discontinue the distribution of these two EPA
reports on the Paser Magnum and essentially disavow the
reliability of these reports. Amerlmex's primary reasons for
requesting this course of action were (1) EPA could not verify
that the ignition wire continuity had been checked, (2) only 250
miles of mileage accumulation was performed, and (3) one of the
EPA test vehicles was modified.
Since the Device manufacturer's installation instructions,
packaged with the Device, did not specify that the ignition wire
continuity check or mileage accumulation were required, EPA
judged that the test engineer had not used poor test procedures
as alleged by Amerlmex. Also, EPA judged that the vehicle
modifications would not have invalidated the test conclusions
(see Attachment N for a more detailed discussion of EPA's
decision. See Attachment 0 for Amerlmex's reply).
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16. Summary of Evaluation
EPA fully considered all of the information submitted by the Device
manufacturer in the application. The evaluation of the "Paser
Magnum, Paser 500, Paser 500 HE1" devices were based on that
information and the results of the previous EPA test program.
The Applicant submitted no valid data to support the claim for
increased fuel economy. The Applicant was advised by letter on
several occasions of EPA's requirement that Applicants submit valid
test data following the proper EPA Test procedures.
Test data submitted by the Applicant did not prove that use of the
"Paser Magnum, Paser 500, or Paser 500 HEI" would enable a vehicle
operator to improve vehicle fuel economy or reduce emissions.
EPA tested the Paser Magnum ten years ago. This testing showed that
the Paser Magnum (which the Applicant stated is equivalent to the
Paser 500 and Paser 500 HEI) showed no significant effect on either
exhaust emissions or fuel economy.
Thus, there is no technical basis to support any claims for a fuel
economy improvement due to the use of the "Paser Magnum, Paser 500,
or Paser 500 HEI" device.
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