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United States Postal Service’s Environmental Impact Statement Cooks the Books and Demonstrates A Clear Bias Against Electric Vehicles

September 1, 2021


Washington, D.C. – Last week, the United States Postal Service (USPS) released its draft environmental impact statement (EIS) regarding its plan to acquire new gas-powered next-generation delivery vehicles (NGDVs) in the coming decade. The EIS demonstrates a clear, illogical commitment to internal combustion engine vehicles (ICEVs) over battery electric vehicles (BEVs), which hinges on outdated and incorrect information. The Zero Emission Transportation Association (ZETA) views the EIS’s findings as a bad-faith analysis and looks forward to actively engaging in the USPS’s public comment process.

In its EIS, USPS proposes replacing 50,000 to 165,000 of its 218,000 vehicles over the next ten years, and it compares acquiring either 90% ICEVs and 10% BEVs or 100% BEVs. The USPS does not consider any other ICEV/BEV fleet compositions, such as the 25% ICEV and 75% BEV fleet composition proposed in the Postal Vehicle Modernization Act (H.R.1636), sponsored by Representative Jared Huffman (D-CA-02). 

The EIS report acknowledges that the 100% BEV fleet would release 200% fewer direct and indirect greenhouse gas (GHG) emissions than a 90% ICEV and 10% BEV option, but it nevertheless dismisses electrification, calling it infeasible. An environmental impact analysis that ignores such a clear advantage in emissions reduction should establish a high bar for choosing the most polluting alternative, but the EIS simply argues that the 90% ICEV and 10% BEV scenario is justified because it would release fewer emissions than the current 30-year old fleet.

Additionally, the report claims that the 100% BEV scenario is too expensive given the current financial status of the USPS. This analysis is inaccurate for several reasons. The cost calculation inexplicably uses nickel manganese batteries, which are more expensive – and less common and efficient – than EV industry-standard lithium-ion batteries. Furthermore, the USPS’s conclusions about BEVs’ financial impact did not consider its own analysis about the social cost of carbon: The USPS calculated that the 100% BEV scenario could save three times as much in social costs compared to the 90% ICEV and 10% BEV scenario. The EIS also cites the cost of charging infrastructure as a barrier to the 100% BEV scenario, but it does not list the assumptions or calculations used to make that conclusion. A report released just weeks earlier from Atlas Public Policy found that electrification could save the USPS up to $4.3 billion over the lifetime of the vehicles. The USPS’s claim that electrification is too expensive is not supported by the evidence.

The USPS also concluded that the 90% ICEV and 10% EV scenario is preferable to the 100% BEV scenario because it claims that BEVs are incapable of handling the distance, weather conditions, or charging requirements on up to 12,500 of the USPS’s 232,000 routes. This conclusion lacks credibility. After all, 12,500 routes is less than 5.4% of the USPS’s total routes. As stated previously, the USPS is not replacing 100% of its existing fleet; rather, it is replacing 22.9% to 75.6% of its fleet over the next ten years. Its remaining vehicles could easily cover these routes – if these routes truly are not a good fit for electrification. Or, the USPS could purchase a small percentage of new, fuel-efficient ICEVs to cover these routes.The USPS inexplicably argues that because 5.4% of its routes are not a good fit for electrification, it is justified in acquiring a 90% gas-powered new fleet.

Furthermore, the EIS does not present evidence that these 12,500 routes cannot be driven by BEVs, as the USPS claims. The USPS asserts that up to 12,500 routes (with no explanation for how they reached that number) have environmental or infrastructure-related barriers that limit the feasibility of BEVs. These barriers range from cold temperatures to a lack of charging infrastructure. For many of these routes, these concerns are superficial. The “hypothetical BEV” that the USPS analyzes has a range of just 70 miles, which is far lower than the range of off-the-shelf options. Despite that, a 70-mile range still exceeds the USPS’s 22-mile average route length more than three times over. The USPS also exaggerates the impact of cold temperatures on battery life, providing no analysis or calculations to support their claim. Nevertheless, even at the lowest end of their range and even if their batteries are substantially diminished by cold temperatures, BEVs could easily handle the average USPS route and the vast majority of all USPS routes. 

The USPS’s concern about the nationwide lack of charging infrastructure also fails to consider both President Biden’s plan to build at least 500,000 charging stations and the steady nationwide growth rate in the prevalence of charging stations, which will undoubtedly continue to climb in the years to come. The USPS’s next generation delivery vehicle procurement plan will unfold over the span of a decade; yet, it does not consider ongoing growth in BEV battery efficiency or charging infrastructure deployment. For these reasons, BEVs are fully capable of driving many of these 12,500 routes. It is ironic that the USPS ignores this national charging buildout when it considers the feasibility of BEVs driving these 12,500 routes; after all, they do remember to factor in this charging buildout when they calculate the cost of a 100% BEV fleet.

The USPS cherry picked their models and data in order to weave the narrative they needed to justify their decision to pursue a 90% ICEV and 10% BEV NGDV fleet. The USPS’s EIS shows a clear bias against BEVs by excluding data, relying on unrealistic assumptions, and mistaking simple facts. The USPS’s preference to pursue an overwhelmingly polluting fleet will leave Americans worse off by ignoring the crucial public health benefits and necessary GHG emissions reduction that will derive from electrification. ZETA plans to participate in the formal public comment period of the draft EIS to put these false claims to rest.  

In recent months, ZETA has strongly criticized Postmaster General Louis DeJoy’s decision to sign a $6 billion contract with Oshkosh Defense – a military defense contractor – to build USPS’s new generational delivery vehicles, which initiated the process for locking the USPS into a carbon-intensive fleet for decades to come, despite President Biden’s executive order calling for USPS electrification. ZETA also outlined a roadmap for USPS electrification and endorsed the Postal Service Vehicle Modernization Act, which would provide an additional $6 billion for the USPS should they commit to electrifying at least 75% of the delivery fleet – a feasible fleet makeup even by the USPS’s flawed assumptions. This bill would give the USPS more funding for electrification than Postmaster DeJoy has previously estimated is necessary to electrify the fleet.

About ZETA

The Zero Emission Transportation Association (ZETA) is a federal coalition focused on advocating for 100% EV sales by 2030. ZETA is committed to enacting policies that drive EV adoption, create hundreds of thousands of jobs, secure American global EV manufacturing dominance, drastically improve public health, and significantly reduce carbon pollution.

Policy Platform

Learn about our six-part strategy for electrification.

About ZETA

National policies to support 100% electric vehicle sales.

The Zero Emission Transportation Association (ZETA) is a federal coalition focused on advocating for 100% EV sales. Enacting policies that drive EV adoption will create hundreds of thousands of jobs, secure American global EV manufacturing dominance, drastically improve public health, and significantly reduce carbon pollution.