Letters from White House and EPA criticize USPS’ ‘flawed’ EV plan

The contract has stood ever since Oshkosh received a $6 billion contract from the United States Postal Service to develop a new mail delivery vehicle drawn controversy. Oshkosh’s plan primarily envisages gas-powered vehicles and has prevailed another plan for pure electric vehicles. Now the White House is asking the Postmaster General to live up to his responsibility and speed up the modernization of the delivery truck fleet.

History of the USPS NGDV

The current postal vehicle fleet is showing its age and modernization is long overdue. The most common postal vehicle today is the Grumman LLV (Long Life Vehicle). With its production from 1987 to 1994, it lived up to its name. However, as the LLV’s heater is susceptible to fire and maintenance costs increase, an environmentally friendly replacement is required.

The USPS began searching for this replacement NGDV (Next Generation Delivery Vehicle) back in 2015. A case study pointed out that the history of the postal service with electric vehicles dates back to 1899, when the electric vehicles competed with horses and not with gas cars. But somewhat inexplicably Oshkosh won the contract in February 2021, not for a fleet of electric vehicles, but for a fleet of mostly petrol.

congress didn’t seem too happy with this idea:

In response to this announcement, Rep. Jared Huffman of California says he will introduce legislation to ensure the USPS contract consists of at least 75% electric or zero-emission vehicles.

Another representative, Mary Kaptur of Ohio, says she will introduce a bill that intends to pause the treaty while questions about corruption and compliance with Biden’s executive order are answered. She, Ryan, and Ohio Senator Sherrod Brown all sent a letter to Biden asking for the Oshkosh treaty to be halted.

Kaptur refers to Biden’s plan for the complete electrification of the federal vehicle fleet.

Oshkosh NGDV at CES 2022. By Seth Kurk.

The White House turns to Postmaster General Dejoy

Now the Biden administration appears to be pushing the USPS to more fully electrify the fleet. In a letter sent Feb. 2 by Brenda Mallory, chair of the White House Environmental Quality Council, to Postmaster General Dejoy, the White House urges the Postal Service to “fulfill its obligations under the National Environmental Policy Act (NEPA) improve its competitiveness, address the climate crisis and combat environmental injustice by accelerating the modernization and electrification of its delivery vehicle fleet through the procurement of its Next Generation Delivery Vehicle (NGDV).”

The letter goes on to identify the Environmental Protection Agency’s “serious concerns” about the environmental review conducted in the process of procuring the NGDVs. Some of the concerns raised can be addressed, such as using up-to-date EV information to address the “deficiencies in the environmental impact statement”.

The letter also raises concerns that cannot be addressed as easily as a $480 million commitment to design and build a factory ahead of an environmental review of the Postal Service’s procurement decision.

… Through NGDV, USPS has the option to achieve 70 percent electrification of its delivery vehicle fleet by the end of this decade … at a time when our international competitors are rapidly electrifying their transportation systems, and leading US companies, including large delivery companies, are bringing American competitiveness moving fast by electrifying their fleets and showing how the US is leading by example.

This transition to a modern, clean, and efficient USPS vehicle fleet is a top priority for the Biden administration. To address the climate crisis, President Biden has urged us to seize the unique economic opportunity we have to create and sustain jobs, including well-paying union jobs; supporting a just transition to a more sustainable economy for American workers; Empowering American Communities; protection of public health; and promote environmental justice.

… We will continue to do everything we can to support the USPS fleet electrification effort, including financial and technical assistance in addressing the issues I have discussed.

EPA concerns about NGDV plan

Also on February 2, a similar letter was sent by Environmental Protection Agency Assistant Administrator Vicki Arroyo to the USPS Senior Director of Environmental Affairs and Corporate Sustainability, detailing EPA’s specific issues with the USPS NGDV acquisitions became.

The EPA review found that “EPA’s concerns about the EIS draft [Environmental Impact Statement] were not adequately addressed and that the final EIS still has serious shortcomings.” Arroyo went on to list several “key shortcomings”.

The main shortcomings include the fact that, contrary to the requirements of NEPA, a contract for this proposal was awarded before the NEPA process, critical features of the contract are not disclosed in the EIS, important data and economic assumptions are missing in the EIS and the EIS has failed to consider a single viable alternative to the proposed measure. In particular, the final EIS fails to disclose essential information underlying the key analysis of total cost of ownership (TCO), underestimates greenhouse gas (GHG) emissions, fails to consider greener, viable alternatives, and gives insufficient consideration to impacts on communities with environmental justice concerns.

This is not a short list of concerns, and they “make the final EIS inconsistent with the requirements of NEPA and its implementing regulations.” As a result, the Environmental Impact Statement must be revised and reopened for public comment.

The letter is clear and tough, calling out the USPS for its flawed process, noting that “the Postal Service chose not to consider in detail even a single viable alternative to its proposal that would be more environmentally friendly, only alternatives to the Postal service itself not considered feasible (e.g. 100 percent BEV for longer rural routes).”

The letter details the proposed gas fleet, noting that the proposed ICE NGDVs deliver a modest 0.4mpg improvement over the existing fleet developed over 30 years ago, meaning the updated vehicles achieve 8.6 miles per gallon would achieve…

An updated fleet of 90 percent ICE vehicles and 10 percent BEVs would reduce “relevant emissions by 21.7 percent after ten years,” but the letter notes that these new vehicles would cause climate damage under the plan, which “900 would exceed millions of dollars.”

EPA ends the letter by recommending, “The Postal Service will first prioritize the purchase of BEVs consistent with existing contractual obligations” and requested a meeting.

NGDV at CES 2022. By Seth Kurkowski

Electrek’s opinion

In all honesty, each of these letters is worth reading – in full. It’s hard to find an excuse for the many flaws in the postmaster’s plan. Post Offices’ analysis assumed a static price for battery electric vehicles that simply doesn’t tally with the real world, where the cost of batteries, and therefore battery electric vehicles, is falling.

Expected cost reductions for batteries and thus BEVs over the course of the 10-year acquisition are not taken into account.

The EPA suggests that the Postal Service use estimates from the National Academy of Sciences as a starting point for possible projections of battery price declines, which recently concluded that “the primary cost driver for electric vehicles is the battery, which is amenable to mass battery production.” expected to drop to $90-115/kWh by 2025 and $65-80/kWh by 2030 at the package level.”6

The USPS also underestimated emissions from ICE vehicles while overestimating those from electric vehicles.

Even the ICE vehicles’ weight, a pound over the light-duty vehicle weight limit, means they are subject to less stringent emissions.

The fact that the new BEV NGDVs have a 734-pound lighter payload capacity than the ICE NGDVs (2,207 pounds versus 2,941 pounds), but still meet the relevant operational requirements, suggests that the ICE vehicles are significantly larger than required, thereby they can have much higher emissions because they are subject to less stringent standards.

Given the very short distance of most postal routes (95% are less than 70 km long), even something like that Ford E-Transit das Electreks Seth Weintraub recently checked out, with its estimated range of 108-126 miles and a mid-range price of $40,000, could go the distance. The USPS estimates that the BEV versions of the NGDV would cost $30,000 more than the ICE counterparts, which is clearly unreasonable, and the USPS should consider lower-end EVs to directly meet these requirements. Ford had submitted its bid to provide NGDV but was not selected (although it supplies the engines for Oshkosh’s fleet, given the military contractor’s lack of experience in the small consumer vehicle market in particular).

The vehicles and technology are in place to make the postal service electric, and it needs to be. Sure, there are some routes where a gas vehicle can offer some benefits, but the bulk of the fleet needs to go electric, not just a mediocre 10 percent.

Post offices have regular short routes and locations to store the delivery vehicles overnight. This is the perfect use case for electric vehicles. The usual excuses that EV naysayers like to throw around like “the range isn’t enough”, “where should I charge” and “they are more expensive” simply don’t apply here. The daily distance traveled is known and consistent, and the long-term costs of BEVs in terms of maintenance and environmental impact must be considered.

It’s hard not to blame Dejoy for all of that. He is a holdover from the Trump administration with multiple conflicts of interest (investment in UPS, Amazon and a USPS subcontractor) and has no experience as a mailman. He faced a lot of criticism during the 2020 election for taking steps that would do that Slowing down mail delivery in the name of cutting costs. The Postmaster cannot be removed by the President, only by the Board of Governors, but the best choice for the future of USPS is to remove him and replace him with someone who actually cares about the environment and the future of the Postal Service.

Letter to the USPS from the White House

Letter to the USPS from the EPA

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