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DEFLECKTOR . COM 425 

# j1"\J ,_ HALL AVENUE ST . PAUL

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**~** -l8 28 800 . 4 29 . 7768My name is.Jonathan Fleck. I live in Minnesota. My company, A de 

### F, Ltd., brought the DeflecktorAerodynamic Wheel Cover, made of fabric, to the market. Ourproduct is standard equipment on the Freightliner Cascadia Evolution model long haul truck, which receives credits from EPA under the Phase I framework. The smart folks at Freightliner made a series of tweaks - many like ours in the area of aerodynamics - to their existing 201 0 EPA certified Cascadia and created the 2014 Cascadia Evolution, which is a full 7% more efficient. Ourproduct on that truck is visually quite impactful, as it covers approximately l0 sq feet of wheel cavity area - it's a wheel cover... We have sold hundreds of thousands of these simple wheel covers, and I want to applaud EPA on incentivizing small, incremental, innovative technologies that ultimately addvalue in the big picture. A lot of times we underestimate the incremental, and when that incremental is scalable we may very well miss meaningful opportunities that move us to our ultimate goal; in this case, C02 mitigation. Today ourproduct can be seen approximately 12 times an hour on trucks in freight lanes across America on any given day, that numberwill more than double by this time next year based on deliveries. Ourfirst customer, SchneiderNational, a charter member of EPA's Smartway Transport Partnership, has deployed ourproductfleet-wide. In a press release, in March of 2010, Schneider National announced fleet-wide use of our product on their 12,000 trucks, statingfuel savings of 150 gallons per truck per year based on their average fleet speed. This savings, approximately 1%, equates to 40 million fewer pounds of C02 each year forjust that fleet alone. The weight of our product is saved in fuel within ten days of typical use on trucks in the long haul segment. Regardless of how we monetize things, I'm quite proud of that fact as a DEFLECKTOR.COM 425 HALL AVENUE ST. PAUL, MN 55110-1828 800.429.7768true measure of value. Schneider did extensive fuel economy testing over many years and determined through exhaustive replication of these tests on tractors and trailers that ourinexpensive, simple, patented approach made huge economic sense. Whenwheel covers were placed on trailers as well as tractors, fuel savings proved to be significant, a number that grows to approximately 2% when both tractor and trailer are equipped on all eight wheel ends. Schneiderknows the fuel savings are double for a combination tractor-trailer, yet given the ratio of trailers to tractors, the actualreturn on investmentis less because trailers sit idle most of the time and often out-number tractors by a factor of three. We applaud EPA's focus on vigilantly bumpingefficiency of long haul tractor-trailer combinations through this new Phase 2 as it will bring further fuel savings through trailer efficiency. EPA, it appears, took the approach to carve up the combination tractor-trailer into two regulatory phases. In the first phase a tractor manufacturer offers a coefficient of drag ( cd) for their tractor, which in the case of our product is buriedwithin that number and notquantified, yet itis known to be a significant contributor in lowering drag. In the second phase a collection of various products, largely aerodynamic, are encouraged to be incorporated into a trailer to reach the desired increase in efficiency. The truck and the trailer do not operate independent of the other. Makingthem more "incorporated" as a single efficient unit is the ultimate goal: however, EPA collects a coefficient of drag from the manufacturer for their tractor and then relies on Smartway and its certification methodology for trailers. When measuring the increases in efficiency ofwheel covers on trailers and tractors independent of each other, the fuel savings get lost in the margin of error of the testmethodology. With no enmity suggested, it is ourbelief that a hugely scalable opportunityis beingmissed. We suggest a remedy that wouldpermit testing of both tractor and trailer in combination for the purposes of aerodynamic components thatcan be fitted to both. We believe current testing methodology is suflicient, albeit misapplied to either tractor or trailer and not the combination.The market opportunities of aerodynamic wheel covers have gained momentum with many new entrants salivating at the commercialprospects. An aerodynamic wheel cover is the only aerodynamic componentthat is functional onboth tractor and trailer, and yet because of this regulatory process that splits tractor from trailer in testing, it is lost in the noise. The addition of a single sentence to this regulation that would embrace testing of tractor-trailer combinations for aerodynamic components found on both would be helpful to permit aerodynamic wheel covers to scale in a marketplace that is worldwide. Thankyou for the opportunity to make these public comments, and I hope that consideration be given to the subject matterpresented. Jonathan E Fleck President, A de 

### F, Ltd. 425 HallAve St Paul, MN 551101828 m 651 270 9148 jon@deflecktor.com

# Copyrighted page(s) removed. Copyrighted material is not available in Regulations.gov since it may not be reproduced without consent of the copyright holder. Removed pages can be viewed at the USEPA Docket Center, Public Reading Room. Address: 1301 Constitution Ave, NW Room 3334 Washington, DC 20004 Telephone: 202-566-1744 Email: docket-customerservice@epa.govJONATHAN FLE C K M : 65 1. 270 .9148 I 425 HALL AVE_ ST. PAUL, MN 55110-1828 L......__

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