Letter to Louis DeJoy, Postmaster General and Hon. Roman Martinez, Chairman of USPS Board of Governors - Brown, Colleagues Call for USPS to Prioritize Widespread Fleet Electrification

Letter

Dear Postmaster General DeJoy and Chairman Martinez,

We write to express our strong opposition to the failure of the United States Postal Service (USPS) to plan to electrify its fleet of mail delivery vehicles and contribute to the fight against climate change. After an unjustifiable, truncated, and deficient process, it is unacceptable that the USPS intends to cling to an overwhelmingly fossil fuel-powered fleet whose emissions are endangering our planet. We urge USPS to respond immediately to requests from the Environmental Protection Agency (EPA) and Council on Environmental Quality (CEQ) to correct its flawed plan to procure an overwhelmingly gasoline-powered delivery fleet for its Next Generation Delivery Vehicles (NGDV).

USPS recently released its final environmental impact statement (EIS) assessing its plan to procure a new NGDV fleet of 50,000 to 165,000 vehicles. Electrifying the USPS delivery fleet would provide meaningful cost-savings and dramatically reduce greenhouse gas (GHG) emissions, and is consistent with President Biden's recent executive order to fully electrify the federal fleet. But under the EIS, USPS plans to procure a fleet comprising up to 90-percent internal combustion engine vehicles (ICEVs) and only 10-percent battery-electric vehicles (BEVs). Not only is this outcome bafflingly out-of-step with the Administration's goals and with private sector trends, it is also the product of a severely faulty process.

Both the CEQ and EPA have advised USPS of serious problems with its EIS. The EPA admonished the USPS that, "[c]ontrary to [National Environmental Policy Act (NEPA)] requirements, a contract for this proposal was awarded prior to 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 failed to consider a single feasible alternative to the proposed action." After ignoring the EPA's earlier criticisms, USPS persisted in "systematically and substantially [underestimating] GHG emissions from its new ICEVs, while overestimating GHG emissions from BEVs."

Throughout the EIS, USPS underestimates the cost of purchasing and maintaining a carbonintensive gasoline fleet. A recent report found that, by 2025, BEVs could replace 97 percent of USPS vehicles at a lower total cost of ownership than that of comparable gas or diesel trucks, with potential savings of as much as $4.3 billion over the fleet's lifetime. These cost savings explain why even private companies are investing heavily in electric delivery vehicles, with UPS placing a 10,000-vehicle purchase order for electric trucks, FedEx moving to achieve a fully electric fleet by 2040, and Amazon purchasing 100,000 electric delivery vehicles. While USPS is falling short in its process, it is also senselessly falling behind its delivery competitors.

Not only are BEVs cheaper to own and operate than ICEVs, electrifying the USPS fleet will also significantly mitigate the public health and environmental damages that result from GHG emissions and other air pollution. According to the EPA, new, inefficient ICEVs will produce nearly 20 million metric tons of carbon dioxide equivalent over their lifetimes, equal to the emissions of 5 new coal-fired power plants. Even the USPS EIS acknowledges that moving to 100- percent BEVs would more than double the reduction of GHG emissions than its preferred action--still a likely massive underestimation of the climate pollution differential between these two plans.

We strongly agree with the conclusions and concerns in the CEQ's recent letter to USPS, which noted the "deficiencies" of the USPS's "flawed" approach to its environmental review. We also agree with the EPA's conclusion that USPS's "ten-percent commitment to clean vehicles, with virtually no fuel efficiency gains for the other 90 percent is plainly inconsistent with international, national, and many state GHG emissions reduction targets, as well as specific national policies to move with deliberate speed toward clean, zero-emitting vehicles." Electrifying the transportation sector is among our greatest opportunities to mitigate the devastating effects of climate change, improve public health, and create good-paying American jobs.

USPS's plans for its future delivery-vehicle fleet have subverted both our NEPA regulations and our national and international climate and public health commitments. We therefore echo the EPA and CEQ's recent letters, urge USPS to conduct a supplemental environmental impact review under NEPA, and host a public hearing, and abandon this faulty procurement plan. Should USPS continue to refuse to acknowledge the serious legal concerns its current process has raised, we will urge the Administration to take any strong steps available to it, in order to remedy these issues.

We look forward to a response from USPS on how it intends to address this matter and remain in line with the Administration's climate and electrification targets.

Sincerely,