On Monday the Postal Service will publish the “Notice of Availability of Updated Record of Decision for Next Generation Delivery Vehicles Acquisitions” in the Federal Register.
Issuance of the Record of Decision (ROD) completes the environmental impact review and finalizes the Postal Service’s decision to purchase 106,000 delivery vehicles, with 62 percent of them battery-powered electric vehicles (BEVs). The ROD also means that the lawsuits against the Postal Service may resume.
According to the ROD (and both the draft and final SEIS), the Postal Service will be purchasing a mixed fleet of 106,000 vehicles, with another 60,000 later. The mix on the first 106,000 is as follows (the mix on the other 60,000 is yet to be determined):
- 60,000 Next Generation Delivery Vehicles (NGDV) to be built by Oshkosh Defense, of which 75 percent will be battery electric vehicles (BEVs);
- 14,500 right-hand-drive (RHD), commercial off-the-shelf (COTS) vehicles with internal combustion engines (ICE); and
- 31,980 left-hand or right-hand drive (LHD/RHD), either COTS or NGDV, of which 66% would be BEVs.
That adds up to about 65,000 BEVs and 40,000 ICE vehicles. That’s a lot more EVs than the Postal Service initially committed to, but those 40,000 ICE vehicles will continue to be a source of contention and probably cause the lawsuits to resume shortly. There’s more about the Final SEIS and the issues in the lawsuits in this previous post.
(Update: On Dec. 11, 2023, the Postal Service and Plaintiffs in CleanAirNow v DeJoy and California v Postal Service submitted a Joint Case Management Statement reviewing their respective arguments. It provides an excellent overview of the issues and the arguments on both sides.)
The long road to the ROD
The environmental review on the new fleet has been going on for over two years and nine months.
The announcement of an intent to do an environmental impact study was made on March 4, 2021, the Draft EIS on the first purchase plan came out in August 2021, the final FEIS came out December 2021, and the first ROD was issued on March 15, 2022.
A few days after the first ROD came out, the Postal Service announced a purchase order of 50,000 Next-Gen Delivery Vehicles from Oshkosh Defense, 10,000 of them electric, thus increasing the BEVs to 20 percent of the first phase of NGDVs.
Within a few weeks, three lawsuits were filed against DeJoy and the Postal Service contesting the decision to buy so many vehicles with internal combustion engines and to have the NGDVs built in South Carolina by non-union labor.
The plaintiffs in CleanAirNow v. DeJoy include Sierra Club, Earthjustice, the Center for Biological Diversity. This suit has been merged with a second, California v DeJoy, which includes the Attorneys General of fifteen states and the District of Columbia. NRDC v. DeJoy includes the Natural Resources Defense Council and the United Auto Workers as plaintiffs, with the UAW focusing on the use of non-union labor.
In June 2022, the Postal Service announced that it would increase its order of electric delivery vehicles to about 40 percent. A month later it announced that it would increase the number of BEVs to at least 50 percent. The Postal Service also said that it would supplement the NGDV order with a purchase of 34,500 commercial off-the-shelf vehicles so that the combined purchase would be at least 40 percent BEV. The Postal Service also announced that it would conduct a Supplemental Environmental Impact Statement (SEIS) about the new mix of vehicles.
The Postal Service then requested a stay on the three cases while it prepared the SEIS. Plaintiffs opposed the request, but on August 1, 2022, the court granted the motion, and the cases were put on hold. In October 2022, the plaintiffs asked for the stay to be lifted, arguing that extending it would unjustly allow the USPS to evade judicial review of the ROD. In February 2023, the court ordered for the stay to remain in place in light of the supplemental NEPA review that was underway.
In December 2022, the Postal Service announced that it would expand its order of delivery EVs and buy over 66,000 BEVs by 2028 (but that turned out not be a firm commitment, as indicated later in the SEIS).
In February 2023, the Postal Service announced that that in addition to the NGDVs it was buying from Oshkosh Defense, it would purchase 18,500 off-the-shelf vehicles. Half of them will be Ford E-Transit Electric Delivery Vans, manufactured in Kansas City. The other 9,250 vehicles would be ICE vehicles, but the announcement did not indicate who would be building them.
In a July 2023 Joint Status Report on the lawsuits, the plaintiffs noted that the purchase contracts for these off-the-shelf vehicles were awarded before completing the environmental review. They also noted that the Postal Service expected to begin receiving the ICE COTS vehicles only two months after the expected date of the ROD, which indicated that the purchase was not contingent on the environmental review.
The plaintiffs also indicated that once the ROD is issued, they “will likely seek an expedited briefing schedule to allow the court to address the alleged NEPA violations before a significant number of gas-powered off-the-shelf vehicles are delivered.”
Now that the ROD is out, the lawsuits are expected to resume.
The EPA letter and USPS reply
The revised ROD, it should be noted, was published four months after the Postal Service said it would be ready. The original publication date was August 2023, and it was then postponed to October, and then to December. (Note: An earlier version of this article incorrectly stated the expected publication date for the ROD was originally May 2023.)
The only new information in the ROD that wasn’t already in the Final SEIS is the Postal Service’s response to a letter submitted on Oct. 30, 2023, by the EPA. The letter consists of several questions and recommendations regarding the Postal Service’s decision to go with 62 percent electric.
EPA recommended that the fleet purchase include a higher percentage of BEVs because they have lower adverse environmental impacts than ICE vehicles. The Postal Service disagreed for various reasons, including its view that the more EVs it buys, the longer the acquisition and implementation process will take, and during this time, more of the older vehicles will be on the road, which will have adverse impacts on the environment and postal operations.
The EPA also contested the way the Postal Service calculated the costs for ICE vehicles compared to BEVs. The Postal Service respectfully disagreed with the EPA and GAO on this issue, and it reiterated its view that its costing model was appropriate.
The EPA also recommended that the Postal Service provide more transparency about the factors used to make its purchase decision. The Postal Service replied that more detailed disclosures “would necessarily entail the disclosure of commercially sensitive information such as model preference,” which would not “be prudent.”
Test driving the C250
It’s possible that some of the off-the-shelf vehicles will be the same one chosen by Canada Post for its new fleet: the C250 step van built by Morgan Olson in Virginia.
In October, the Postal Service informed unions and management associations that it was launching a pilot to test the C250. The pilot runs from Nov. 13, 2023, to Feb. 16, 2024, in six cities. It’s not yet clear which cities, but according to a Facebook posting, one of them is Castle Rock, Colorado, near Denver.
The C250, which is built on the Ford F-150 chassis, is available with both a traditional gas engine and electric model. Canada Post has been testing the ICE vehicle. The electric version will not roll out until late 2024. According to an article in the NALC’s Postal Record (Dec. 2023), the C250 being tested by the Postal Service is also the ICE model.
The NALC article has a detailed, first-hand description of the C250. The vehicle has all sorts of modern features, like a key fob to unlock the doors and to start the engine, a heated driver’s seat, LED lighting for the cabin and cargo areas, a control for switching the vehicle between two-wheel drive and four-wheel drive, a monitor above the steering wheel with video feeds from cameras installed above the passenger side cargo and rear doors of the vehicle as well.
It’s a right-hand drive model, the same height as the current Long Life Vehicle but four feet longer, so it has more than twice as much storage space as the LLV. The cabin area has a jump seat that also folds down into a tray for mail handling. There is no interior door connecting the cabin area to the cargo section, so carriers need to enter through roll-up shutter doors on the side and rear. (There are more details here.)
According to the USPS notification, as part of the pilot city and rural carrier employees will be provided a survey form to offer their input and suggestions. It asks employees to rate the vehicle on various factors, including noise and vibration; maneuverability going forward, backing up, and turning; the instrument panel, lighting in the cargo area, driver side visibility, the heater and AC, safety systems, and shelving and capacity.
The notification doesn’t say this, but the Postal Service may also be testing the Canoo LDV 130 and 190 electric cargo vans, both of which were apparently spotted at the USPS Research and Engineering site in Fairfax, Virginia, along with some C250s. There’s more in this post on canooers.com.
Canada Post goes electric
In March 2023, Canada Post announced that it would be purchasing the new electric Morgan Olson C250 for its new fleet. Canada Post currently has about 14,000 LLVs. It expects to replace half of them with the all-electric C250 by 2030, and by 2040 the entire last-mile fleet will be zero-emission.
Canada Post has already been testing the ICE version of the C250. “We have been deploying the ICE version of this vehicle to some of the most rural and remote parts of Canada and the feedback from drivers, mechanics, postmasters, and customers alike has been overwhelmingly positive,” says Canada Post’s fleet management director. “Everything from the functional development of the vehicle, including the overhung side mirrors that allow drivers to clear mailboxes on approach to the layout of the cab and operators console…. Many drivers will drive all day long with the window down so the heated seat, heated mirrors and heated steering wheel is like winning the lottery and the temperature of the cab isn’t nearly as important as it was years ago.”
The electric C250 will be charged by AC overnight charging. Range in cold weather will not be an issue since the average daily trip is 40 miles, says the fleet director. “They’re typically seven-hour routes and then they come back in and they’re there all night, so it’s a perfect fit for electric.”
While Canada Post’s fleet of 14,000 vehicles is small compared to the Postal Service’s, one has to ask: If Canada can go 100 percent electric, why can’t the USPS buy a new fleet that’s at least 90 percent electric? That’s the question that will be on the table when the lawsuits against DeJoy and the Postal Service resume.
— Steve Hutkins