USPS Has a Second Chance to Go Green

The Postal Service decided earlier this year that it would purchase gasoline-fueled engines for up to 90% of its new fleet of 165,000 Next Generation Delivery Vehicles (NGDVs). The agency based this plan on undisclosed and unsupported assumptions about the environmental impacts of gas-powered vehicles and the cost of buying and operating electric vehicles. But tremendous public pressure from NRDC and our allies have allowed us to slam the brakes on Postmaster General Louis DeJoy’s dangerous procurement plan.

Thanks to our advocacy (including the delivery of over 500,000 petitions against this action), the Postal Service finally got the message that cleaner vehicles are a win all around. Not only has the agency announced that it will conduct a supplementary environmental review to assess the true costs of its plan, but earlier this week, the agency also announced that it expects to make at least 40 percent of its new delivery vehicle fleet electric. These changes are a step in the right direction and a direct response to strong advocacy from NGOs, labor, elected officials, and regulators. However, we will keep pushing until the Post Office corrects the underlying assumptions in their original environmental review and has an electric, union-made fleet.

One way we intend to keep pushing for this is by responding to the Postal Service’s request for comments on the scope of what the agency should cover in its supplemental environmental review.

The Postal Service’s original environmental review was deficient at every step. Had the agency conducted a thorough analysis the first time around, they would have seen that EV technology is capable of meeting its needs—certainly at a ratio much higher than 10 percent. They also would have seen that the adoption of electric delivery vehicles could save the agency money in the long term. Instead, the agency chose to ignore the latest in vehicle technology advancements, made use of inflated costs, and misrepresented the benefits of EVs. Additionally, they awarded a procurement contract for the NGDVs prior to completion of the National Environmental Policy Act (NEPA) process.

Although the Postal Service’s recent announcements to electrify more of its fleet are welcome, there is still more the agency needs to do to correct the record. In addition to following through on the announcements made, it is imperative that the agency revise its original environmental review, first, by correcting the faulty assumptions and data it used as the basis for determining its original procurement plan, and second, by using these corrected data and assumptions in its supplementary environmental review.

Some of the faulty assumptions the Postal Service must address include:

• EV Battery Range: One of the gravest errors in the Postal Service’s original analysis was the assumption on EV battery range. The Postal Service asserts that the assumed range of BEVs is only 70-miles, which is incredibly false. There are multiple commercial vehicles on the market today that are similar in size to a postal delivery vehicle and are rated to reach at least 100 miles on a single charge. For example, the Ford Lightning Electric Transit Cargo Van is available with a 140-mile range and an 86-kWh battery or 170-mile range and a 105-kWh battery. Both versions can fully charge in under three hours using a DC fast charger and both are commercially available. Again, this demonstrates how the Postal Service’s original analysis was premised on questionable and incorrect data, that inaccurately represented the capabilities and benefits of battery electric vehicle technology.

• Total Cost of Ownership (TCO): The Postal Service has shared that it fully recognizes that battery electric vehicles would provide environmental benefits compared to gas vehicles and that this technology could provide long-term cost savings. Sadly, the agency has also repeatedly referred to “cost” as a major constraint – even though it has failed to quantify or make available its analysis of key considerations that actually impact overall costs, such as deployment and charger procurement strategies. Instead, the Postal Service used inflated and obsolete data to conclude that its original “preferred alternative” of procuring 90 percent gas guzzling vehicles was the more favorable option.

  For example, the Postal Service concluded that the 100 percent battery electric vehicle alternative would cost $2.3 to $3.3 billion more than its “preferred alternative,” since the EVs had a higher total cost of ownership compared to the gas-powered vehicles. But until the Postal Service completes its delivery network refinements and route optimization efforts, it is hard for the agency to appropriately gauge what the true total cost of ownership would be for this technology, especially since the total costs of deploying EVs (instead of gas vehicles) is closely tied to the length of a delivery route.

  Additionally, as time passes, EV technology will continue to improve, and upfront costs will continue to decline. The agency’s procurement strategy could make use of this trend and maximize EV cost-saving benefits by incorporating a staggered deployment over the next ten years, that prioritizes the replacement of vehicles on routes already well suited for electrification and delays EV deployment for the few routes that are currently harder or more expensive to electrify.
  The Postal Service’s gas price assumptions were also incredibly low and based off stale data. In its total cost of ownership calculations, the agency used a gas price about $2 per gallon less than the current national average. Even in its furthest out cost projections for 2040, the agency only projected a cost of $2.55 per gallon.

  Another egregious deficiency in the Postal Service’s total cost of ownership calculus was its use of inflated cost estimates for charging infrastructure – a point that even the Postal Service Inspector General calls the agency out on. For example, the agency predicted a cost of $18,000 per charger. This differs from the Inspector General’s assumed costs of around $7,300 per charger and peer reviewed data that priced chargers between $2,500 to $4,900, with an outlier of $7,210. The agency also incorrectly assumed a one-to-one ratio of chargers to vehicles, when vehicles that do not require a full charge every night do not need a one-to-one ratio.

• Insufficiently Quantified Electric Vehicle Benefits: The Postal Service’s original analysis failed to analyze the emissions impact of the proposed procurement plan under its “preferred alternative.” The analysis was insufficient and only provided a basic comparison of emission reduction benefits from the proposed action and the alternatives it considered.

  For example, gas vehicles (especially trucks) emit large quantities of health-harming and smog forming pollutants, such as Nitrogen Oxides (NOx), particulate matter, and ozone. These pollutants are toxic and dangerous and exposure to them can lead to premature death and a whole host of other devastating chronic health impacts. These emissions also disproportionately impact low-income communities and communities of color, since a higher proportion of these communities tend to be situated near freeways, ports and other facilities that generate significant levels of localized vehicle exhaust. This is well understood science and public health data, yet none of these life-or-death impacts were appropriately evaluated in the Postal Service’s original review.

  A proper analysis would have focused on identifying and quantifying health benefits (such as avoided hospital visits, avoided respiratory and cardiovascular diseases, and avoided premature mortality, among other health impacts caused by this pollution). Additionally, a proper analysis would have looked at the impacts of prioritizing EV deployment on routes in areas of air quality concern. Lastly, a proper analysis would have appropriately quantified and weighed the environmental benefits related to reduced greenhouse gas (GHG) emissions from a largely electric fleet – especially given that EVs are a technology that only gets cleaner as the electrical grid continues to transition to renewable energy sources. 

  As the Postal Service undergoes its supplemental review, it is important that this time it be thorough and monetize and contextualize the air pollution reduction benefits for various vehicle acquisition scenarios. In addition, it is important that the agency fully take into account such findings in determining the final action it takes. Had a thorough analysis like this been done the first time around, it would have certainly made it harder for the agency to ignore the benefits that EVs provide relative to their gas counterparts.

Additional considerations for the Postal Service

The Postal Service’s supplemental review and resulting final action should also account for the socioeconomic and workplace impacts of its procurement actions and production location(s). The opaque manner in which the agency engaged, when it prematurely awarded its vehicle production contract made clear that there was very little (if any) consideration of the socioeconomic impacts of its acquisition plan.

A thorough analysis would have adequately evaluated how the awarded contract and resulting vehicle production plan—including the production location—would best ensure that the vehicles are produced in a manner that protects the interest of workers, their families, and their communities and provides for safe working conditions. This is a point the United Auto Workers (UAW), our partner in litigation against the Postal Service, emphasized in its initial comments to the agency but has yet to see addressed.

This fight is not over

The Postal Service’s announcement to invest in more electric vehicles pushes the envelope in the right direction, but again, this announcement alone is not nearly enough. The quality of any new analysis the agency conducts is impacted by the Postal Service’s original analysis and the data and assumptions that analysis was based on. Moving forward on any new analysis without correcting the prior analysis would be a grave oversight and would render their supplemental review to be just as deficient as their original.

Hopefully the Postal Service takes advantage of this second chance opportunity to shift gears and deliver a plan the agency deserves—one that will meet the moment and will save money while delivering cleaner air.