Date: February 4, 2022
To: Chair Martinez and Members of the USPS Board of Governors Environmental Counsel
United States Postal Service
475 L’Enfant Plaza SW, Office 6606
Washington, DC 20260-6201
Re: Final Environmental Impact Statement (EIS) for Postal Service Next Generation Delivery Vehicle (NGDV) Acquisitions (CEQ Number 20210129)
Dear Chair Martinez and Members of the Board of Governors:
On behalf of the undersigned organizations, we write to express our concern with the recently released Final EIS for the Postal Service Next Generation Delivery Vehicle (NGDV) Acquisitions.1 The Final EIS is rife with flaws and unsubstantiated findings. We urge you to help rectify these shortcomings by holding a public hearing to inform a supplemental EIS.
As one of the largest vehicle purchasers globally, the Postal Service has both an opportunity and a responsibility to lead the way in our transition to zero-emissions vehicles. This is especially true considering that transportation is the largest source of climate pollution in the United States and air pollution from fossil fuel vehicles harms people’s health, especially in low-income communities and communities of color. By upgrading to electric vehicles, the Postal Service can bring cleaner air to almost every community in the country.
On January 27, 2021, the Biden Administration signaled its focus on implementing a government-wide approach to addressing climate change by signing an Executive Order (EO) on Tackling the Climate Crisis at Home and Abroad.2 The EO calls for decarbonizing the electricity sector by 2035 and directs the government to buy clean and zero-emission vehicles for federal, state, local, and tribal government fleets.3 Since then, President Biden has announced a plan to “use [the Federal Government’s] scale and procurement power” to purchase only carbon- free electricity, acquire only zero-emission federal vehicles and buildings, and achieve net-zero federal procurement in the coming decades.4 The targets intend to, among other things, protect the environment and improve public infrastructure and operations so that they are climate- resilient.5
The proposed NGDV acquisition undermines the Administration’s goals. And even more fundamentally, the Final EIS undermines the National Environmental Policy Act (NEPA), which seeks to ensure federal government decisions benefit from rigorous and coherent scientific analysis to support decisions.
The Final EIS that purports to support the agency’s decision to purchase up to 90% fossil fuel burning vehicles that will be on our roads beyond 2050 suffers from many of the flaws the Environmental Protection Agency identified during the Draft EIS comment period that make it “inadequate and preclude meaningful consideration of the proposed action and alternatives.”6 In fact, the EPA issued a blistering criticism of the Final EIS as well, which was supported by the Council on Environmental Quality. Several sections of the Final EIS, like the selection of alternatives, greenhouse gas emissions, environmental justice, and air quality, are especially flawed. Specific examples of flaws include:
- Significantly underestimating the price of gasoline, in addition to relying on unsupported assumptions that battery prices for electric vehicles will remain the same;
- Not quantifying air quality improvements and public health benefits for neighborhoods near staging sites for large fleets if zero-emission vehicles replace polluting fossil fuel vehicles;
- Failing to consider how many fossil fuel delivery vehicles will remain on the road in 2050 thereby interfering with the President’s national policy of transitioning the U.S. to a zero-emission economy;
- Failing to examine the socioeconomic impacts of manufacturing the NGDVs outside of Wisconsin; and
- General lack of transparency including, but not limited to, data collected during prototype testing, projected electric vehicle infrastructure costs, and delivery route electrification suitability.
These are but a few of the major flaws with the Final EIS, which also failed to meaningfully respond to public and agency comments on the draft. The Postal Service should issue a Supplemental EIS to comply with NEPA and analyze the information needed to make an informed decision on delivery vehicle acquisition.7
At a minimum, we respectfully request that the Postal Service conduct a public hearing on this highly controversial decision pursuant to the Postal Service’s NEPA regulations.8 Over 37,000 commenters took time to provide input on this EIS. The vast majority of those comments were critical of the analysis and the Postal Service decision here. They deserve a public hearing to further discuss this decision that will impact every one of their neighborhoods.
We need the Board of Governors to show real climate and clean air leadership. At a minimum, the Postal Service must ensure it actually complies with federal environmental laws prior to making a decision of this magnitude. We appreciate your consideration of these comments.
A3PCON Environmental Justice Committee
Center for Biological Diversity
Center for Community Action & Environmental Justice
Department of Population and Public Health Sciences, University of Southern California
East Yard Communities for Environmental Justice
Environmental Protection Network
Environmental Defense Fund
Moms Clean Air Force
Natural Resources Defense Council
San Pedro & Peninsula Homeowners Coalition
Union of Concerned Scientists
West Long Beach Neighborhood Association
CC: Louis DeJoy, Postmaster General, United States Postal Service
Brenda Mallory, Chair, Council on Environmental Quality
Michael Reagan, Administrator, USEPA
Richard Corey, Executive Officer, California Air Resources Board
1 See 87 Fed. Reg. 994 (Jan. 7, 2022).
2 Exec. Order No. 14,008, 86 Fed. Reg. 7619 (Feb. 1, 2021).
4 See Exec. Order No. 14,057 § 102, 86 Fed. Reg. 70,935, 70,935–36 (Dec. 13, 2021).
5 Id. at § 102.
6 Letter from Victoria Arroyo, EPA, to Ms. Jennifer Beiro-Réveillé, USPS, October 21, 2021.
7 See ibid. (EPA directing Postal Service to prepare a supplemental draft EIS); 40 C.F.R.
8 39 C.F.R. § 775.14(a)(1).