Coltura Comments on USPS SEIS re Next Generation Delivery Vehicle (NGDV) Acquisitions

Mr. Davon Collins

Environmental Counsel

United States Postal Service

475 L’Enfant Plaza SW, Office 6606

Washington, DC 20260-6201

Re: Coltura Comments on USPS SEIS re Next Generation Delivery Vehicle (NGDV)Acquisitions

Dear Mr. Collins:

Coltura hereby submits the following comments regarding USPS’s SEIS re Next Generation Delivery Vehicle (NGDV) Acquisitions in response to an invitation from Jennifer Beiro-Réveillé, USPS Sr. Director, Environmental Affairs and Corporate Sustainability. This comment supplements the joint comment that Coltura submitted with the National Resources Defense Council, the Union of Concerned Scientists, and the Zero Emission Transportation Association. This comment focuses narrowly on maximizing emission reductions and cost savings impacts by prioritizing electrification of those USPS vehicles which use the most gasoline.

Background

Coltura is a 501(c)(3) nonprofit moving America beyond gasoline. In 2021, Coltura developed the “Gasoline Superusers” approach, a data-driven method of prioritizing the biggest users of gasoline (“Superusers”) for the switch to EVs to reduce gasoline use faster. Coltura’s research on Superusers has been published in the Environmental Law Reporter, presented to the National Academy of Sciences, and featured in many publications.

Prioritize Vehicles Using the Most Gasoline for Electrification

The principal purpose of the electrified NGDV program is to avoid GHG and criteria pollutant emissions caused by gasoline combustion. The implementation of the NGDV program should therefore be designed to minimize gasoline consumption. To do this, the USPS should prioritize the replacement of those vehicles using the most gasoline with battery electric vehicles (BEVs). Generally, this will mean that BEVs should be prioritized for longer routes and for facilities with a preponderance of longer routes. This approach will result in substantially more gasoline, carbon, and criteria emissions reduction as compared to replacing existing delivery vehicles with BEVs without regard to gasoline reduction.

While individualized data on the gasoline use of USPS vehicles is not presently available, the following graph illustrating gasoline consumption of governmental vehicles in California by decile is instructive. It shows that the top 10% of government vehicles in terms of gasoline consumption burn 41% of all the gasoline used by government vehicles in California.

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It is likely that an analysis of gasoline consumption of USPS vehicles by decile based on gasoline use would show a similar pattern.

The USPS Should Prioritize BEV Solutions for Its Longest Distance Routes

The SEIS indicates that the USPS intends to avoid deploying BEVs on routes longer than 70 miles. While routes longer than 70 miles constitute fewer than 10% of USPS routes, they constitute a much larger share of USPS gasoline use because distance traveled is the primary driver of gasoline use. Rather than purchase new ICE vehicles for these routes, the USPS should purchase BEVs that offer a range sufficient to complete these routes. In cases where a BEV of sufficient range is not available, arranging for charging en route could be a viable option.

The USPS Should Set More Aggressive Targets for Fleet-Wide Gasoline Reduction

The SEIS notes that the USPS delivery fleet consumed 189 million gallons of gasoline in FY 2022 for delivery operations. It projects that the delivery vehicles proposed for replacement consume between 83-89 million gallons of gasoline per year, or roughly 45% of all USPS gasoline. Given that the USPS proposes replacing 62% of its vehicles with BEVs under Alternative 1 and projects gasoline reduction of around 45%, the USPS could substantially increase its gasoline reduction potential by optimizing its vehicle assignments for gasoline reduction.

The USPS should aim to achieve reductions in gasoline use significantly higher than the percentage of BEVs in its fleet. While a lack of data on USPS operations does not allow for the recommendation of a precise target, the USPS should aim to reduce its gasoline consumption by at least 80% over the eight-year replacement period, provided that it prioritizes BEVs for its longer routes. Such an approach will not only lead to a decrease in GHG emissions but will also result in decreased operating costs.

Coltura favors the maximum feasible electrification of the entire Postal Service vehicle fleet. Its suggestion that longer routes that consume more gasoline should be prioritized for BEVs should in no way be construed as a recommendation that fewer vehicles be electrified.

Conclusion

We appreciate the opportunity to provide feedback on the SEIS. Significant public health and climate benefits, as well as cost savings, will be realized from the deployment of BEVs in a manner that maximizes gasoline reduction.

Sincerely,

COLTURA