Despite Potential to Electrify 90 Percent of Routes, USPS Still Plans to Deliver Pollution with the Mail
I came across this article on Steve Hutkins’ “Save the Post Office.” There has been a political effort to redefine the USPS into more of a business model and something it was never meant to be. Right now, the USPS is beginning to reimage its model and existence as led by Postmaster Louis Dejoy. There is much wrong with this effort. Both Mark Jamison and Steve Hutkins have been defining the issues with Dejoy’s plan in their articles at Save the Post Office.
As you read Sam Wilson’s report you will see the concern for not specifying more electric vehicles. The belief is the USPS should order more.
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Despite Potential to Electrify 90 Percent of Routes, USPS Still Plans to Deliver Pollution with the Mail, Union of Concerned Scientists, Sam Wilson
With over 250,000 vehicles in service, the United States Postal Service (USPS) has one the world’s largest truck fleets. Over the past several years, the USPS worked to plan the replacement of its aging delivery truck fleet with a mix of both electric and combustion vehicles. If electric delivery vehicle deployment is maximized, this transition could have significant positive impacts on both air quality and the larger adoption of commercial electric vehicles.
I’ve blogged in detail about this effort, focusing mainly on the severe analytical shortcomings in the Postal Service’s 2021 study of air quality, climate, economic, and technological aspects of the new fleet of vehicles, known as the Environmental Impact Statement (EIS). Quite a bit has happened since the EIS was published and, thanks in part to our strong advocacy on the issue, a handful of lawsuits, and significant funding through the Inflation Reduction Act, the Postal Service announced it would increase the share of zero-emission vehicles (ZEVs) in their new delivery fleet from 10 percent to 62 percent. A few weeks back, the Postal Service released an updated analysis supporting this increase, called the Draft Supplementary Environmental Impact Statement (SEIS), which examines the environmental and economic impacts of several potential fleet replacement strategies.
From a high level, the updated plan seems significantly improved: the percentage of ZEVs in the fleet has increased substantially, they’ve signaled that they plan to focus the deployment of ZEVs in communities experiencing environmental injustices, and they’ve committed to purchasing only ZEVs after 2026. This is all great news.
However, there are still several unaddressed flaws in their analysis that lead to undervalued benefits and overinflated costs of fleet electrification. If properly addressed, a more accurate analysis would likely show clear evidence for a plan that maximizes ZEV deployment within the fleet given the massive lifetime cost savings of ZEVs and the fact that, according to the USPS, 90 percent of routes could be served by electric delivery vehicles. A USPS fleet that maximizes electrification potential would not only help to reduce climate warming and air pollution but would help to make electric vehicles more commonplace in every community across the nation.
Still room for improving the analysis
I’ve tracked the Postal Service’s fleet replacement efforts for some time now and am consistently alarmed by the poor quality of their analysis and data inputs. One of the highlights of my year so far was reading a report published by the Postal Inspector General (somewhat akin to an independent auditor for the Postal Service) that stated they had serious concerns, “related to the evaluation of reasonable alternatives, total-cost of ownership cost inputs, and environmental emissions that the Postal Service should address as it prepares its SEIS (Special Education Information System).” How’s that for an affirmation?
It’s a hopeful sign to see a significant increase in the number of ZEVs the USPS plans to deploy, but there are still major flaws in the design, methods, and data inputs of their analysis in the SEIS. That said, I believe they could be easily addressed. Here are several keyways.
The need to include a maximum feasible electrification alternative
Environmental Impact Statements, including this draft SEIS, are built around analyzing different options, courses of action, or choices that governmental entities are considering to meet the purpose and need of proposed actions.
These options, referred to as “alternatives” in an EIS, should reflect the most likely, reasonable, and feasible potential courses of action. The objective of any EIS should be to provide an accurate and rigorous look at potential outcomes, but cherry-picking alternatives that fit or omitting feasible alternatives that do not fit an agency’s agenda can result in a biased analysis.
Unlike the original EIS, the SEIS did include at least one feasible alternative, but it still did not analyze an alternative including the maximum technically feasible ZEV deployment. The Postal Service noted in the SEIS that around 90 percent of all routes could be serviced by electric vehicles but did not analyze the costs and benefits of a 90 percent ZEV fleet. This major omission is disappointing as it potentially leaves additional fiscal and environmental benefits on the table, compared to their “preferred alternative” of a 62 percent ZEV fleet.
In the SEIS, the Postal Services suggests several reasons for not choosing a 100 percent electrification alternative that makes good sense, however, they do not make a reasonable case for not analyzing a 90 percent ZEV fleet and should include such an analysis in their final SEIS. While I do think it’s technically reasonable that, in the near term, some gasoline delivery vehicles may be needed for niche routes and situations, the Postal Service should be diligently pursuing electrification wherever feasible.
The importance of lifetime cost analysis
The angle at which the Postal Service chose to examine the potential economic costs and benefits of fleet electrification significantly limited their results. Where most economic studies of vehicle and fleet electrification look at costs over the life of the vehicle, the SEIS only looked at upfront costs. This cut out the meaningful lifetime fuel and maintenance savings that ZEVs provide, while inflating the total ZEV fleet cost estimate, given that electric vehicles tend to have higher sticker prices than their combustion counterparts.
Their original analysis did consider total costs but included ridiculous assumptions like, for example, that gasoline would cost around $2.50 per gallon in 2040. Instead of following the Inspector General’s suggestions to improve the cost inputs in the total-cost of ownership analysis and the U.S. Government Accountability Office’s suggestions to improve the credibility of its cost estimates, they cut it altogether. The Postal Service has often stated cost as a barrier to further electrification, but if they aren’t looking at the lifetime fleet costs and ignoring the significant cost and maintenance savings of battery-electric vehicles (BEVs), how can they make informed decisions related to cost?
The Postal Service claims that the electric delivery vehicles they are considering cost approximately 40 percent more than the combustion versions, however leaving it at this is simply unreasonable – they should be taking a long-term holistic look when considering updating a fleet that could be on the road for several decades. The overwhelming body of research is clear that electric delivery vans are approaching upfront price and total cost parity at rates much faster than other truck types. In fact, a January 2022 study by the International Council on Clean Transportation suggests that electric delivery vans with a 100-mile range have already reached total cost parity.
Appropriate infrastructure cost estimates
There are several other incorrect assumptions within the analysis that undervalue the benefits and overinflate the costs of BEVs. One that is particularly meaningful is the Postal Service’s assumption that each electric NDGV would need its own dedicated charger. In reality, it is highly unlikely that a ratio of 1-to-1 would be necessary. Each of the battery-electric models under consideration will have a minimum operational range of 70 miles, of which a Level 2 charger can provide a full charge to around 8 hours, and only two percent of postal routes exceed 70 miles (according to a 2022 report by the Inspector General). Why then are so many costly chargers necessary?
Sure, there will be select cases of longer routes and areas with range-impacting weather that could need a higher ratio of chargers, but the new fleet could reliably operate on both fewer chargers as well as a mix of charging options. The same Inspector General study I referenced above suggested that the Postal Service consider a mix of Level 2 and less costly Level 1 chargers. This would reduce the average cost of chargers in the fleet by around 40 percent.
Clearly, there are more options to consider when it comes to charging the fleet. Estimating that each vehicle will need a dedicated charger is an unrealistic assumption that falsely inflates the cost of BEVs, limiting the potential benefits from their increased deployment.
Each of these examples hearkens back to some of my biggest complaints with the original EIS – that they were using the study to support foregone conclusions, rather than doing real analysis to better understand their fleet replacement plan. Good, lasting, and meaningful public policy is based on – you guessed it – objective and transparent science. Decisions of policymakers and agency decision-makers must be driven by rigorous analysis.
A more realistic look at environmental justice
One notable improvement in the SEIS was the realization that this plan would, in fact, affect disproportionately impacted (DI) communities. In its original study, the Postal Service simply stated, “there would be no or negligible impacts on environmental justice.” However, the science is clear that certain neighborhoods, all too often majority communities of color, experience exposure to air pollution and resulting negative health outcomes at rates much greater than others. Given the Postal Service’s massive nationwide fleet, any plan to transition to more modern and cleaner delivery vehicles would most certainly impact these communities. Our goal here is to make sure that the most impacted communities see a fair share of the fleet electrification benefits, including air quality and infrastructure improvements.
Where the old EIS wrote off any potential impacts – good or bad – the updated SEIS includes an in-depth analysis of the locations best suited for ZEV deployment using several well-vetted tools including the Environmental Protection Agency’s EJSCREEN. The analysis examined several factors including historic economic and environmental issues, the amount of current pollution burden, and levels of economic, climate, and health risks. While environmental justice was not a factor in determining where BEVs would be deployed, it turns out that the locations best suited for electrification from an infrastructure and use case point of view are most often located in DI communities – around 85 percent in fact. This is because those sites were located in more urbanized and industrialized areas where charging infrastructure may be easier to develop.
CleanAirNow, a Kansas City-based environmental justice leader that organizes efforts around electrification, air quality, and equitable labor transitions to clean energy, has been quite instrumental in not only pushing for expanded USPS electrification but for the new electric delivery vehicles to be deployed first in communities most impacted by unhealthy air quality. In a recent conversation with Beto Martinez, the executive director of CleanAirNow, he reiterated the need to center environmental justice and the health of those most impacted. He noted that the areas the organization represents are, “high-risk zip codes where asthma, heart disease, and cancer are above the national average, which links back to environmental health hazards” from long-term exposure to breathing toxic emissions from transportation.
I would agree with Beto that, “we don’t want pollution to be delivered with our mail” and that the Postal Service should commit to an accelerated deployment of zero-emission delivery vehicles in areas of persistent air pollution and poverty.
https://prospect.org/politics/continued-survival-of-louis-dejoy/
The Continued Survival of Louis DeJoy
The American Prospect – November 29, 2022
By retaining their Senate majority, Democrats no longer feel the urgency to use the lame-duck session to confirm executive branch appointments, pushing off decisions on who will fill key positions until at least next year. That means that the Biden administration will likely go through 2023—as they have through 2021 and 2022—with Louis DeJoy as postmaster general, given the current makeup of the U.S. Postal Service (USPS) Board of Governors, the body that decides whether to fire the PMG and choose a successor. Currently, the board supports DeJoy, and if the members whose terms expire in December are allowed to stay on the board an extra year, that support will continue.
The terms of Democrat Lee Moak and Republican William Zollars both expire on December 8th of this year. But both can receive a “holdover year,” where they can fulfill the duties of a postal governor before leaving the board. With no nominees currently in place to replace Moak and Zollars, that scenario is likely, according to sources with knowledge of the situation. In fact, on the USPS website, Moak and Zollars are listed as currently in their holdover years, even though that technically isn’t true until December 8th. ,,,
Seen on the web:
“Lee Moak’s and William Zollars’s hold-over terms expire on Dec. 8, 2023.”
Louis DeJoy – They have got to get rid of that guy.
Would be nice if they’d start policing the mail theft problem. It’s getting so people can’t mail checks anymore.
The only thing The Constitution actually mandates: maintain the post
Roads are part-in-parcel of that
There’s no better example of a deliberate assault on The Constitution, on the United States of America than the harm, the sabotage that has been done, continues to be done and to all practical appearance isn’t going to stop being done to the postal service
Ten Bears:
Which is why we need to talk about it and for you to comment on it! Thank you.
A couple ideas. First, increasing electricity demand by systematically converting a sector such as terrestrial transportation probably isn’t that environmentally effective now and increases the risks to an aging and already somewhat inadequate distribution grid. Conversion of carbon energy to non-carbon energy distributed as electricity is going to take decades just in the US. Second is that the EV technology still has a lot of maturing to do. Third, does anyone know if a big USPS EV order increases aggregate EV adoption, or are material supply chains limiting anyway? Just today, the high temps in the eastern part of the US has the major grid operator telling folks they think they can handle it, but margins will be quite tight. So it’s possible that the “big” picture is that more EVs soon don’t change carbon emissions very much, complicate an already very difficult energy source migration with significant distribution upgrades requirements without really altering the trajectory of growth of EV ton-miles while making big investments in a technology sure to be way better in 10 or 15 years. Discretion is often the better part of valor. It would be nice if the federal government showed some leadership here, but that leadership could easily be not jumping at EVs while energy source and distribution are much more critical investments.
This is another analysis of the USPS under DeJoy that feels like it obscures the bigger headache the critics actually have. This one not quite as much as the ones about new distribution organization, but I suspect if the plan was to do 90% – but DeJoy still PM – then that would be described as poorly thought out. No, the big I think is that Congress has clearly told USPS to get the job done but generate a lot less forecast pension costs in doing it. How do you do that? Less labor input or labor inputs without pensions. That’s ugly and do not blame folks for getting nauseated by changes, but swap out DeJoy and unless Congress changes the accounting requirements reducing forward pension costs will dominate the next PM’s tenure also.
Eric
i don’t honestly know how much of your analysis is valid and how much of it comes from the gas companies. I am not entirely happy with the EV thinking right now. But the post office problem also involves a consolidation of post offices into bigger regional “centers” meaning, i think, that postal workers and postal customers will have longer to drive to work or to do post office business, which i am told could also provide banking services that might be more honest than commercial banks. meanwhile, as a former employee of a vast bureaucracy i can say, and my project manager would agree with me: the farther from the home office (top management) you can get, the better. [also, the more efficient as it turned out for us at least.]
there is something dreadfully wrong with running the post office “like a business.” unknown to a lot of people, the jub of government is not to make a profit, but to provide needed services that cannot be provided by “business” at a profit.
oh, and “local” post offices could operate with relatively low-tech, cheap, slow, limited range electric vehicles without needing ro rebuild the grid., at probably a good deal less cost than gas cars and trucks for that kind of driving.
when “private enterprise” owns everything, it will own you. the slavery people fear from “socialism” will come to you ten times over from “private” enterprise and you won’t be able to do a damn thing about it.
I see a conflict between the delivery centers and electrification goals. When they imply that all the deliveries will be made from central locations, the ability to use EV’s where I live disappears. Using the delivery centers at all is terribly inefficient for here, and maybe they will do what they do now, but I haven’t seen anything to make me think they will. It would make perfect sense to have one ICE or hybrid deliver mail from the sorting center to the local PO’s where EV’s could do the final miles. Maybe some exceptions are planned for places that are like us, but I have not seen that.
Jane:
Both Mark Jamison and Steve Hutkins have their qualms about such a plan working. The distances from a centralized delivery center to a delivery route would vary as much of the US is not ande p of cities.