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DEFLECKTOR . COM 425 j 1"\J ,_ HALL AVENUE ST . PAUL ~ _ .. ~ -l8 2 8 800 . 4 2 9 . 7768 
My name is .Jonathan Fleck. I live in Minnesota. My company, A de F, Ltd., 

brought the Deflecktor Aerodynamic Wheel Cover, made of fabric, to the market. 

Our product 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. Our product on that 

truck is visually quite impactful, as it covers approximately l 0 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 add value 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 our product can be seen 

approximately 12 times an hour on trucks in freight lanes across America on any 

given day, that number will more than double by this time next year based on 

deliveries. Our first customer, Schneider National, a charter member of EPA's 

Smartway Transport Partnership, has deployed our product fleet-wide. In a press 

release, in March of 2010, Schneider National announced fleet-wide use of our 

product on their 12,000 trucks, stating fuel 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 for just 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 800.429.7768 
true 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 our inexpensive, simple, patented approach made huge economic 

sense. When wheel 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. Schneider knows the fuel 

savings are double for a combination tractor-trailer, yet given the ratio of trailers to 

tractors, the actual return on investment is 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 bumping efficiency 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 buried within that 

number and not quantified, yet it is 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. Making them 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 of wheel covers on trailers and tractors 

independent of each other, the fuel savings get lost in the margin of error of the 

test methodology. With no enmity suggested, it is our belief that a hugely scalable 

opportunity is being missed. We suggest a remedy that would permit testing of 

both tractor and trailer in combination for the purposes of aerodynamic 

components that can 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 commercial prospects. An aerodynamic 

wheel cover is the only aerodynamic component that is functional on both 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. 

Thank you for the opportunity to make these public comments, and I hope that 

consideration be given to the subject matter presented. 

Jonathan E Fleck 

President, A de F, Ltd. 

425 Hall Ave 

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.gov
JONATHAN FLE C K M : 65 1. 270.9148 

I 

425 HALL AVE_ ST. PAUL, MN 55110-1828 

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,N f. & SUSAN R. FLECK \ 

:4:25 HAll A YfNUE ~j OJ BIRCHWOOD V1lL".GE 

.E ~AA l.AKE~ MN &ll\Q 

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