The following list of changes is not exhaustive and attempts only to identify those that seemed significant. The Draft SEIS is here. The Final SEIS is here. The Notice of Availability is here. (The Draft and Final versions were compared using Adobe Acrobat’s Compare Files extension.)
Executive Summary
[Text inserted in Final] The Postal Service is an independent federal establishment, mandated to be self-financing and to serve every American community through the affordable, reliable, and secure delivery of mail and packages to nearly 165 million addresses six and often seven days per week. The Postal Service is steadfastly committed to the fiscally responsible and mission-capable roll-out of electric-powered vehicles for America’s largest and oldest federal fleet. The Preferred Alternative (described below) accounts for the Postal Service’s operational needs, including the roll-out of new vehicles in a manner that will not disrupt our service mission; market realities, including the supplier capability and vehicle availability for both purpose-built and COTS vehicles; and the financial condition of the Postal Service. We are grateful for the $3 billion in Inflation Reduction Act funding that represents the confidence that Congress and the Administration have placed in us to build and acquire what has the potential to become the largest electric vehicle fleet in the nation, but it is also important to note that most of the electric vehicle funding to support this approach will continue to come from Postal Service revenues. For the reasons described in this SEIS, we are confident that the approach proposed in the Preferred Alternative is the correct approach.”1-1 Public and Stakeholder Involvement
[Text inserted in Final] The Postal Service’s Notice of Availability (NOA) of the Draft SEIS was published in the FR on June 30, 2023 (88 FR 42401), and the NOA and Draft SEIS were made available on the project website. In addition, the Postal Service mailed and emailed the NOA directly to various stakeholders, including governmental agencies and non-governmental organizations and individuals that were sent the NGDV SEIS NOI or that provided scoping comments on the NGDV SEIS. The Postal Service advertised on the project website and hosted a second virtual public hearing, on July 26, 2023, to present findings of the Draft SEIS, and discuss next steps. In total, 43 entities or individuals registered for this public hearing, 28 unique entities called in to attend the hearing, and 11 entities provided comments (American Lung Association; Center for Biological Diversity; Coltura; Earth Justice; Interfaith Power and Light; Natural Resources Defense Council; Pedal Bikes; Sierra Club; Save the Post Office/Americans for Financial Reform; Union of Concerned Scientists; and an interested citizen). A video recording of the hearing was subsequently published on the project website, which has been viewed over 3,000 times. The comment period for the Draft SEIS ended on July 14, 2023. During the Draft SEIS comment period, including the public hearing, the Postal Service timely received 45,127 comments from interested parties, including the EPA; California Air Resources Board; United Automobile, Aerospace and Agricultural Implement Workers of America; multi-State and other entity Attorneys General; U.S. Representatives Emanuel Cleaver II (MO-5) and Sharice Davids (KS-3); Union of Concerned Scientists; Natural Resources Defense Council (including 10,694 petition comments); Sierra Club (including 6,027 petition comments); and others. These comments were carefully considered by the Postal Service during preparation of this Final”3-2.2 Route Suitability
[Draft]: Postal Service drive cycles requiring constant starting, stopping, and idling while carriers open mailboxes, complete scanning, and complete mail deliveries. This testing also accounted for battery use in all climates where the batteries will be used for heat, ventilation, air conditioning, and defrosting while doors and windows are opening and closing repeatedly throughout the operational day as well as for powering electronics and vehicle accessories (lights, strobes, flashers). [Final]: … drive cycles unique to the Postal Service which require a repeated and sustained series of abrupt starts, short forward motion (house to house), and abrupt stops, occurring on average 500 to 600 times per day, over a sustained driving period of between eight to twelve hours, at least six days per week. In contrast, according to the Census Bureau, an average commuter in the United States commutes 55 minutes per day, for 41 miles, requiring approximately 15 to 20 stops. Moreover, even other delivery organizations use vehicles in much more of an “urban” drive cycle, where the vehicle traverses much greater average distances between stops and, often, requires several hundred fewer stops per day. The drive cycle that the Postal Service delivery vehicles experience and must support is much harsher and more demanding than that required of personal vehicles and other commercial delivery organizations. This harsher drive cycle exacts a toll on battery usage as well, since there is significantly less opportunity to reap the benefits of regenerative braking. The Postal Service’s vehicle testing also accounted for battery use in all climates where the batteries will be used for heat, ventilation, air conditioning (HVAC), and defrosting while doors and windows are opening and closing repeatedly throughout the operational day (for mail and package delivery) as well as for powering electronics and vehicle accessories (lights, strobes, flashers). In short, even if a BEV’s energy demand for propulsion to drive an average Postal Service delivery route was similar to that of a BEV for a typical commuter or commercial delivery vehicle – which it is not – the HVAC and accessory demand for a Postal Service delivery vehicle would significantly differentiate the Postal Service’s usage given the fact that windows and doors are constantly opening and closing as we make deliveries. Approximately 60 percent of battery usage on a Postal Service drive cycle would be for HVAC and accessories alone in average climates. In severe weather, particularly severe cold, HVAC and accessory usage could be up to one-third higher.Same section, text added: “to ensure a mission-capable rollout”….
3-3.3 Additional COTS Vehicle or NGDV Acquisition
[Text inserted in Final] Additionally, to better take advantage of rapid changes in the COTS market and to better ensure access to either RHD or LHD COTS delivery vehicles capable of meeting the Postal Service’s demanding operational requirements, the Postal Service is clarifying that Alternative 1 allows for the ICE and BEV COTS specified in Tables 3-3.2 to be replaced with equivalent or superior COTS delivery vehicles. Alternative 1’s total BEV percentage of 62 percent would not be changed by any such replacements. In the event of any COTS replacements, a Record of Environmental Consideration, analyzing any changes to the air emissions analysis, will be prepared and published in the Federal Register. However, if any COTS replacement would result in a substantial adverse effect – for example, due to a significant difference in vehicle specifications or a significant change in the LLV replacement rate – such replacement would only occur following completion of an additional supplement to the EIS, in accordance with 40 CFR 1502.9(d).4-6.3 Environmental Consequences, Section on Social Cost of Greenhouse Gases
In section 4-6 there are a tables and summaries showing the estimated total Social Cost of Greenhouse Gases (SC-GHG). For some reason, the calculations were revised.
Table 4-6.4: SC-GHG of Alternative 1 from 2023-2050 (click to enlarge)
Table 4-6.8: SC-GHG of Alternative 2 from 2023-2050 (click to enlarge)
Table 4-6.12: SC-GHG of No-Action Alternative from 2023-2050 (click to enlarge)
4-12.2 Selection of Preferred Alternative
[Draft] Additionally, using the most conservative SC-GHG scenario (i.e., IWG’s 5 percent discount rate), Alternative 1 would increase savings in climate change impacts by at least $6 million by 2050 compared to Alternative 2 and by at least $168 million by 2050 compared to the No-Action Alternative. As Alternatives 1 and 2 would incur at least $160 million more in climate savings than the No-Action Alternative, both action Alternatives are significantly better than the No-Action Alternative. [Final]: Additionally, using the most conservative SC-GHG scenario (i.e., IWG’s 5 percent discount rate), Alternative 1 would increase cumulative present value savings in climate change impacts by at least $12 million by 2050 compared to Alternative 2 and by at least $86 million by 2050 compared to the No-Action Alternative. As Alternatives 1 and 2 would incur at least $74 million more in climate savings than the No-Action Alternative, both action Alternatives are significantly better than the No-Action Alternative. [Text inserted in Final] Furthermore, as noted in Section 3-3.3, Additional COTS Vehicle or NGDV Acquisition, under Alternative 1 the Postal Service would retain the option to replace COTS vehicles with equivalent or superior COTS vehicles to ensure an adequate vehicle supply and to achieve its BEV percentage commitment.