FINDING OF NO SIGNIFICANT IMPACT (FONSI) for COMMERCIAL OFF-THE-SHELF VEHICLE ACQUISITIONS

Transcription

1 Commercial Off-the-Shelf Vehicle Acquisitions Finding of No Significant Impact FINDING OF NO SIGNIFICANT IMPACT (FONSI) for COMMERCIAL OFF-THE-SHELF VEHICLE ACQUISITIONS The (Postal Service) prepared a Programmatic Environmental Assessment (PEA) to examine and evaluate the physical and cultural environmental impacts of implementing proposed Commercial Off-the-Shelf Vehicle Acquisitions consisting of the purchase of 26,000 vehicles to stabilize its delivery fleet (Proposed Action). An Alternative Action consisting of leasing the vehicles and a No Action Alternative were also considered. The PEA has been prepared in accordance with NEPA, the Council on Environmental Quality (CEQ) regulations for implementing NEPA (40 Code of Federal Regulations [CFR] ), and the Postal Service s regulations for NEPA compliance described in 39 CFR Part 775. This PEA also addresses other federal environmental regulations and Executive Orders relevant to the Proposed Action. Description of the Proposed Action The Postal Service is considering the outright purchase of approximately 26,000 new commercial off-the shelf (COTS) delivery vehicles to stabilize its delivery fleet pending the development of a longer-term solution to its vehicle needs and in furtherance of its statutory Universal Service Obligation (39 U.S.C. 101), the President s Council on Environmental Quality Regulations (40 CFR parts ) and the Postal Service s regulations for NEPA compliance described in 39 CFR Part 775. Specifically, the new vehicles are needed as an interim action to accommodate route growth and to replace accidentdamaged, aged and high-maintenance cost vehicles. The Proposed Action would accommodate an increase in delivery points and routes anticipated over each of the next three years through the purchase of approximately 7,000 new delivery vehicles and establishment of new delivery routes. The Proposed Action would also replace approximately 19,000 accident-damaged and high-maintenance cost delivery vehicles, and aged minivans with new COTS vehicles. The actual type, number and timing of the COTS delivery vehicles purchased will be contingent upon Postal Service final needs and supplier availability. Alternatives Considered The Postal Service analyzed an Alternative Action that would accommodate the expected increase in routes through the lease of additional vehicles, and provide for replacement of high-maintenance cost and aged vehicles with leased vehicles. The number and type of vehicles leased would be the same as under the Proposed Action. Under the No Action Alternative, the Postal Service would not implement the COTS vehicle acquisitions. The existing delivery fleet would be maintained at the status quo; existing delivery vehicles would continue to be used and incur increasingly higher maintenance costs as the vehicles continued to age; existing delivery routes would be expanded to address annual city and rural delivery growth, incurring additional mileage and corresponding increased costs for maintenance and repair of existing vehicles. Environmental Analysis This PEA evaluates the potential nationwide environmental impacts related to the Proposed Action. The Draft PEA concluded that the Proposed Action would not result in significant adverse impacts on the physical, biological, cultural, and socioeconomic environments. Comments received from stakeholders

2 Commercial Off-the-Shelf Vehicle Acquisitions Finding of No Significant Impact on the Draft PEA were incorporated into the PEA and did not change the conclusion of the Draft PEA. The one public comment received, from Region IX of the United States Environmental Protection Agency, recommended the Postal Service consider alternative fuel vehicles for a portion of or all of the vehicle acquisition. However, Postal Service-issued Request for Proposals (RFPs) for vehicles that would meet the Purpose and Need did not specify vehicle fuel type, which was intentional to allow suppliers to propose all types of vehicles, including alternative fueled vehicles; and none of the suppliers offered alternative fuel vehicles. Future after-market vehicle conversions could occur; however the PEA assumed no conversion to alternative fuels in order to evaluate potential worst case environmental impacts based on gasoline consumption. The Proposed Action would result in beneficial impacts to current air quality nationwide, as the new vehicles would have better emission controls than the vehicles being replaced, and therefore decrease emissions as compared with the No Action Alternative, and at a significantly lower cost than the Alternative Action. Adverse impacts to other aspects of the environment such as biological, water, and cultural resources; energy resources; waste management; and community services would be minor to insignificant. The Proposed Action would also have an insignificant but beneficial socioeconomic impact nationwide, as new hires and additional related material purchases would produce beneficial economic results. The Postal Service has not identified any mitigation measures that are necessary to reduce the impacts of the Proposed Action to a less than significant level. Conclusion Based on the findings of the PEA, the Proposed Action of the Commercial Off-the-Shelf Vehicle Acquisitions will have no significant adverse impact to the physical and cultural resources or quality of the human environment. Therefore, preparation of an Environmental Impact Statement (EIS) is not required. Notice of Availability Copies of the PEA are available for review by contacting: Mr. Thomas G. Day, Chief Sustainability Officer, U.S. Postal Service, , 475 L Enfant Plaza SW, Washington, DC Thomas G. Day Chief Sustainability Officer U.S. Postal Service August 21, 2017 Date

3 Commercial Off-the-Shelf Vehicle Acquisitions Office of Sustainability 475 L'Enfant Plaza SW Washington DC

4 This page intentionally left blank. 2

5 EXECUTIVE SUMMARY The (Postal Service) is considering the purchase of an estimated 26,000 new commercial off-the-shelf (COTS) delivery vehicles over the next three years to stabilize its delivery fleet pending the development of a longer-term solution to its vehicle needs and in furtherance of its statutory Universal Service Obligation (39 U.S.C. 101). The actual type, number and timing of COTS delivery vehicles purchased will be contingent upon Postal Service final needs and supplier availability. At this time, the Postal Service anticipates new vehicles are needed to accommodate route growth over the next three years, estimated as requiring an estimated 7,000 vehicles, and to replace an estimated 19,000 accident-damaged, aged and high-maintenance cost vehicles. The Postal Service has prepared this Programmatic Environmental Assessment (PEA) pursuant to the National Environmental Policy Act (NEPA) to identify and assess the potential environmental impacts of the vehicle purchases, the Proposed Action as defined under NEPA. The PEA has been prepared in accordance with NEPA, the Council on Environmental Quality (CEQ) regulations for implementing NEPA (40 Code of Federal Regulations [CFR] ), and the Postal Service s regulations for NEPA compliance described in 39 CFR Part 775. This PEA also addresses other federal environmental regulations and Executive Orders relevant to the Proposed Action. The PEA also assesses the leasing of vehicles as an Alternative Action, and the No Action Alternative as defined under NEPA. The Proposed Action would accommodate an increase in delivery points and routes anticipated over each of the next three years through the purchase of an estimated 7,000 new delivery vehicles and establishment of new delivery routes; and replace an estimated 19,000 accident-damaged and high-maintenance cost delivery vehicles, and aged minivans with new COTS vehicles. The Alternative Action would accommodate the expected increase in routes through the lease of additional vehicles, and provide for replacement of high-maintenance cost and aged vehicles with leased vehicles. Under the No Action Alternative, the Postal Service would not implement the COTS vehicle acquisitions. The existing delivery fleet would be maintained at the status quo; existing delivery vehicles would continue to be used and incur increasingly higher maintenance costs as the vehicles continued to age; existing delivery routes would be expanded to address annual city and rural delivery growth, incurring additional mileage and corresponding increased costs for maintenance and repair of existing vehicles. The Postal Service assessed the significance of the environmental impact based on the requirements in 40 CFR Four types and levels of impact were considered i

6 during the analysis, beneficial impact, no or negligible impact, moderately adverse impact and significant impact. The PEA examined the impacts of the Proposed Action, Alternative Action and No Action Alternative to socioeconomics, transportation, noise, air quality, community services, utilities and infrastructure, energy requirements and conservation, and solid and hazardous wastes. The PEA also examined the cumulative impacts of the Proposed Action and other related, ongoing Postal Service actions when viewed in combination with the Proposed Action. The Draft PEA concluded that the Proposed Action would not result in significant adverse impacts on the physical, biological, cultural, and socioeconomic environments. The Proposed Action would result in beneficial impacts to current air quality nationwide, as the new vehicles would have better emission controls than the vehicles being replaced, and therefore decrease emissions as compared to the No Action Alternative, and at a significantly lower cost than the Alternative Action (with no commensurate environmental benefit). Adverse impacts to other aspects of the environment such as biological, water, and cultural resources; energy resources; waste management; and community services would be minor to insignificant. The Proposed Action would also have an insignificant but beneficial impact nationwide to the socioeconomic environment, as new hires and additional related material purchases would result in beneficial economic impacts. Comments received from stakeholders on the Draft PEA are incorporated herein and do not change the conclusion of the Draft PEA; hence, the Postal Service has finalized the PEA and issued a Finding of No Significant Impact (FONSI). An Environmental Impact Statement (EIS) is not required. The Postal Service is bound by a Universal Service Obligation and shall have as its basic function the obligation to provide postal services to bind the Nation together through the personal, educational, literary and business correspondence of the people. It shall provide prompt, reliable and efficient services to patrons in all areas and shall render postal services to all communities (39 U.S.C. 101). The Proposed Action, as compared with the Alternative Action and No Action Alternative, allows the Postal Service to fulfill its core statutory directive in a more cost-effective manner without significant adverse impacts on the physical, biological, cultural and socioeconomic environments. ii

7 TABLE OF CONTENTS 1 INTRODUCTION National Environmental Policy Act Regulatory Background Postal Service Fleet Management Evaluation and Decision-Making Process Scope and Use of this Programmatic Environmental Assessment Limits of this Programmatic Environmental Assessment Actions Not Included in the Proposed Action Public and Stakeholder Involvement Organization of the Programmatic Environmental Assessment PURPOSE OF AND NEED FOR ACTION Purpose of Proposed Action Need for Action DESCRIPTION OF PROPOSED ACTION AND ALTERNATIVES No Action Alternative Proposed Action Alternative Action AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES Introduction Existing Vehicle Fleet Existing Postal Facilities Existing Workforce Resources Not Studied in Detail Socioeconomics Socioeconomics - Affected Environment Socioeconomics - Environmental Consequences Transportation Transportation - Background and Regulatory Compliance Transportation Affected Environment Transportation Environmental Consequences Noise Noise - Background Information and Regulatory Setting Noise - Affected Environment Noise - Environmental Consequences Air Quality Air Quality Background and Regulatory Setting Air Quality - Affected Environment Air Quality Environmental Consequences Community Services Community Services - Background Information and Affected Environment iii

8 4-7.2 Community Services - Environmental Consequences Utilities and Infrastructure Utilities and Infrastructure - Background Information and Affected Environment Utilities and Infrastructure - Environmental Consequences Energy Requirements and Conservation Energy Requirements and Conservation - Background Information and Affected Environment Energy Requirements and Conservation - Environmental Consequences Solid and Hazardous Materials and Wastes Solid and Hazardous Materials and Wastes - Background Information and Regulatory Setting Solid and Hazardous Materials and Waste - Affected Environment Solid and Hazardous Materials and Waste - Environmental Consequences Summary of Potential Environmental Impacts CUMULATIVE IMPACTS Introduction Geographic Extent and Time Frame Past, Present, and Reasonably Foreseeable Projects and Actions Considered Discussion of Potential Cumulative Impacts Resources Not Studied in Detail Socioeconomics Transportation Air Quality Noise Environment Community Services Utilities and Infrastructure Energy Requirements and Conservation Waste Generation and Disposal Conclusion MITIGATION MEASURES LIST OF PREPARERS REFERENCES iv

9 LIST OF TABLES Table Existing Postal Service Delivery Fleet Vehicles Table Annual Delivery Route Requirement Projections (Estimated) Table Delivery Vehicle Requirements (Estimated) Table Estimated Current Maintenance Costs for Vehicles Proposed for Replacement Table Annual Vehicle Miles by Existing Delivery Fleet Vehicles Table Annual Vehicle Miles by Existing Delivery Fleet Vehicles Associated with the Proposed Action Table Annual Vehicle Miles Associated with Proposed Action (and Alternative Action) Table Net Air Emission Changes from Nationwide Action (Tons per Year) Table Applicability Analysis for General Conformity for Worst-Case Area Table Annual Bulk and Commercial Fuel for Delivery Fleet Vehicles (FY 2016) Table Potential Environmental Impacts Summary Matrix LIST OF FIGURES Figure 1 - Example of Aged LHD Minivan Figure 2 - Example of High-Maintenance Cost RHD LLV Figure 3 - LLV Maintenance Cost Distribution (FY 2016) Figure 4 - Example Replacement COTS Vehicle Figure 5 - Postal Service Mail Processing & Transportation Process LIST OF APPENDICES Appendix A Glossary of Postal Service Terms Appendix B Notice of Intent Federal Register Publication: NOI to Prepare PEA NOI Letters Sent to Stakeholders NOI Stakeholder Letter Mailing List Appendix C Notice of Availability Federal Register Publication: NOA of Draft PEA NOA Letters Sent to Stakeholders NOA Stakeholder Letter Mailing List Comments Received Postal Service Response Appendix D Noise Background Information Appendix E Air Quality Background Information v

10 This page intentionally left blank. vi

11 List of Acronyms and Abbreviations ABS AQCR CAA CAAA CEQ CFC CFR CH 4 CO 2 CO CO 2 e COTS db db(a) DNL DOT EISA EPAct FFV FHWA FONSI FY GHG HCFC ITE LHD LLV LMI MOVES mpg MT NAAQS NEPA N 2 O NO 2 NO x NOA NOI Anti-lock Braking System Air Quality Control Regions Clean Air Act Clean Air Act Amendments Council on Environmental Quality Chlorofluorocarbons Code of Federal Regulations Methane Carbon Dioxide Carbon Monoxide Carbon Dioxide Equivalent Commercial Off-the-Shelf Decibels A-Weighted Decibel Day-Night Average Sound Level Department of Transportation Energy Independence and Security Act Energy Policy Act Flexible Fuel Vehicle Federal Highway Administration Finding of No Significant Impact Fiscal Year Greenhouse Gas Hydrochlorofluorocarbon Institute of Transportation Engineers Left-Hand Drive Long-Life Vehicle Low and Moderate Income MOtor Vehicle Emission Simulator Miles Per Gallon Metric Ton National Ambient Air Quality Standards National Environmental Policy Act Nitrous Oxide Nitrogen Dioxide Nitrogen Oxide Notice of Availability Notice of Intent vii

12 O 3 OEM OSHA P&DC Pb PEA PEIS PM 2.5 PM 10 Postal Service POV ppm RCRA RFP RHD SIP SO 2 TPY µg/m 3 U.S. U.S.C. USEPA USGCRP USPS VMF VOC Ozone Original Equipment Manufacturer Occupational Safety and Health Administration Processing and Distribution Center Lead Programmatic Environmental Assessment Programmatic Environmental Impact Statement Particulate Pollution Measured as Less than 2.5 Microns in Diameter Particulate Pollution Measured as Less than 10 Microns in Diameter Privately Owned Vehicle Parts per Million Resource Conservation and Recovery Act Request for Proposal Right-Hand Drive State Implementation Plan Sulfur Dioxide Tons per Year Micrograms per Cubic Meter United States United States Code United States Environmental Protection Agency United States Global Change Research Program Vehicle Maintenance Facility Volatile Organic Compound viii

13 1 INTRODUCTION The (Postal Service) has prepared this Programmatic Environmental Assessment (PEA) pursuant to the National Environmental Policy Act (NEPA) to identify and assess the potential environmental impacts of the Proposed Action the purchase and deployment of an estimated 26,000 new Commercial Off-the- Shelf (COTS) vehicles in late Fiscal Year (FY) 2017 through FY The goals of the Proposed Action are to replace high-maintenance and end-of-life vehicles, ensure continuity of service, and address an increase in delivery points pending a future procurement decision regarding the replacement of the Postal Service s delivery fleet. This PEA also assesses the leasing of vehicles as an Alternative Action, and the No Action Alternative as defined under NEPA. 1-1 National Environmental Policy Act Regulatory Background The proposed operational change has nationwide scope and will be addressed programmatically under NEPA. The Postal Service has conducted a NEPA assessment and prepared this PEA to assess the proposed nationwide operational change. The PEA has been prepared in accordance with NEPA, the Council on Environmental Quality (CEQ) regulations for implementing NEPA (40 Code of Federal Regulations [CFR] ), and the Postal Service s regulations for NEPA compliance described in 39 CFR Part 775. This PEA also addresses other federal environmental regulations and Executive Orders relevant to the Proposed Action. Due to the Postal Service s unique mission and status as an Independent Establishment of the Executive Branch of the United States Government, these Executive Orders do not apply to the Postal Service. However, the Postal Service does seek to fulfill the spirit of nonmandatory environmental, socioeconomic, energy and transportation goals, and it is in that spirit that the Postal Service voluntarily reports on those categories. 1-2 Postal Service Fleet Management Evaluation and Decision-Making Process The Postal Service has begun the long-term process of identifying and evaluating options for replacing various vehicles currently within its fleet in numerous locations nationwide. In the interim until a final procurement decision is made, the Postal Service has developed the Proposed Action to address the fleet needs, which include replacing an estimated 19,000 aged and high-maintenance cost vehicles; and adding an estimated 7,000 vehicles to accommodate an anticipated increase over three years in routes. These needs combined total an estimated 26,000 vehicles. The actual type, number and timing of COTS delivery vehicles purchased will be contingent upon Postal 1

14 Service final needs and supplier availability. The proposed locations for vehicle replacements are based on the existing locations of aged and high-maintenance cost vehicles, and the proposed locations for additional vehicles are based on delivery route growth needs in both rural and city areas. This PEA focuses on the broad programmatic actions to address Postal Service vehicle fleet needs nationwide and its potential environmental impacts rather than on individual area-specific or city/county-specific procurement actions that could be implemented as part of the action. The PEA evaluates acquisition of vehicles as the Proposed Action, leasing of vehicles as an Alternative Action, and the No Action Alternative Scope and Use of this Programmatic Environmental Assessment The scope of this PEA includes an evaluation of the range of potential environmental impacts associated with the process of acquiring (through purchase or lease) approximately 26,000 new vehicles to fulfill immediate fleet needs. The PEA evaluates the environmental effects of the Proposed Action, as fully described in Section 3. The Proposed Action addresses the following: Accommodate an increase in routes anticipated each FY. Replace high-maintenance cost vehicles. Replace aged minivans that have exceeded their scheduled life expectancy. The PEA focuses on the issues specific to the Proposed Action, the Alternative Action and the No Action Alternative, in accordance with CEQ regulations (40 CFR (i), , and ). The PEA analyses are based on the current Postal Service need to acquire an estimated 26,000 new vehicles, with the actual number and timing of COTS delivery vehicle acquisitions to be contingent upon Postal Service final needs and supplier availability. 1 The Postal Service is using this PEA and its associated documents to integrate the NEPA process with other fleet management planning activities at the earliest phase 1 The Proposed Action's type and number of vehicles to be acquired and the timing of their deployment are based on the best current information available as of the preparation of this PEA. The ultimate number and timing of COTS delivery vehicles purchased would be based on the final needs of the Postal Service and supplier availability. Any significant deviation from the type, number or deployment timing of the vehicles analyzed herein, with the potential to cause a significant impact on the environment, shall be undertaken in accordance with NEPA, including, if necessary, through the preparation of a Supplemental Environmental Assessment. 2

15 possible to ensure that planning decisions reflect environmental values and to avoid potential conflicts and delays. The Postal Service published a Notice of Intent (NOI) to prepare a PEA in the Federal Register, and after completion of the Draft PEA, published a Notice of Availability (NOA) in the Federal Register. After the public notices were completed, and comments received on the Draft PEA and incorporated therein, the Postal Service determined that the context and intensity of the environmental effects of the Proposed Action would not be significant as defined by Section of the CEQ regulations, and based on the conclusions of the PEA, has prepared a Finding of No Significant Impact (FONSI). 1-3 Limits of this Programmatic Environmental Assessment This PEA does not cover any action that Section 3 does not describe as part of the Proposed Action Actions Not Included in the Proposed Action The Postal Service is continuously assessing its fleet of delivery vehicles, identifying and replacing vehicles that have reached or exceeded their scheduled life expectancy and also identifying and replacing high-maintenance cost vehicles due to major accident repair or significant mechanical repair. As a result of this ongoing fleet management process the Postal Service has made other minor acquisitions for replacement of fleet vehicles. These vehicle replacements are regular, ongoing minor activities that have continued over many years and are not considered part of the Proposed Action. The Proposed Action is an action specifically designed to address the need to maintain an adequate fleet of delivery vehicles during the period while a final, long-term procurement option for the wider Postal delivery fleet is decided, and includes both replacement and additional vehicles for delivery growth until January This PEA focuses only on Postal Service operations-related actions associated with the Proposed Action, as defined above. If currently unanticipated future exterior alterations or expansions of Postal Service facilities are required as a result of the Proposed Action, the Postal Service Facilities Department will conduct appropriate environmental review at the local level per Postal Service Handbook RE-6 (2014b). Operational Environmental Checklists, screening analyses, other NEPA Checklists such as Facilities Environmental Checklists, Supplemental Environmental Assessments, and stand-alone, project-level Environmental Assessments could be needed on a facility-specific basis to assess the 3

16 extent of impacts from any currently unanticipated exterior alterations or expansions of Postal Service facilities. 1-4 Public and Stakeholder Involvement The Postal Service s Notice of Intent to Prepare a Programmatic Environmental Assessment for the Purchase of Commercial Vehicles was published in the Federal Register on March 17, 2017 (84 Federal Register 14238). As part of this public notice, the Postal Service provided a public and agency scoping and comment period through April 3, In addition, the Postal Service mailed the NOI directly to various stakeholders, including the United States Environmental Protection Agency (USEPA), and Postal Service union representatives. During this scoping and comment period, the Postal Service received one inquiry from a potential supplier, which is unrelated to this PEA and therefore not included herein. Copies of the NOI, an example NOI letter, and a list of the NOI letter recipients, are included in Appendix B. Upon completion of the Draft PEA, the Postal Service s Notice of Availability: Draft Programmatic Environmental Assessment for Commercial Off-the-Shelf Vehicle Acquisitions, Nationwide, was published in the Federal Register on July 19, 2017 (137 Federal Register 33167); and NOA letters were mailed to the same stakeholders who received the NOI. The NOA announced the availability of an electronic copy of the Draft PEA for review on the Postal Service s website, provided a contact for further information, and offered a 15-day comment period. One stakeholder (USEPA Region IX) provided a response during the comment period; a summary of the USEPA comment, and Postal Service response is as follows: Comment: Response: USEPA recommends acquisition of alternative fueled or hybrid vehicles The Postal Service issued Request for Proposals (RFPs) for vehicles that would meet our Purpose and Need (Section 2). The RFPs did not specify a requirement for a fuel type; it was intentionally left open to allow suppliers to submit any and all types of vehicles (including alternative fuel vehicles) which would satisfy postal operational requirements. None of the Original Equipment Manufacturer (OEM) suppliers offered E-85, electric, compressed natural gas or hybrid vehicles in their responses, which is consistent with USPS market research on the types of vehicles that meet the purpose and need for this COTS purchase. While E-85 capability may have been available in certain models, it was not included in the OEM responses. Lastly, while future after-market vehicle conversions to alternative fuel types could occur, this PEA 4

17 does not evaluate alternative fuels and assumes no conversion to alternative fuels, in order to evaluate potential worst-case environmental impacts based on gasoline consumption. Although no suitable alternative fuel vehicles were offered for this particular acquisition, the Postal Service remains committed to having a diverse fleet and reducing its impacts on the environment. In fact, the Postal Service owns approximately 48,000 alternative fuel vehicles and continues to purchase more each year. In FY 2017 alone the Postal Service purchased over 1,100 hybrid vehicles for use and six electric vehicles for research and development. The Postal Service incorporated relevant additional information in the final PEA. Copies of the NOA, NOA letters to stakeholders, list of NOA letter recipients, comment letter received from USEPA, and the Postal Service s response are presented in Appendix C. 1-5 Organization of the Programmatic Environmental Assessment In addition to describing the Purpose and Need for Action (Section 2), this PEA describes the Postal Service s alternative actions that have been evaluated (Section 3); describes the Affected Environment that provides a basis for measuring the impacts of actions, and the Environmental Consequences of implementing the alternative actions (Section 4); discusses the Cumulative Impacts that the Proposed Action could have on relevant resources (Section 5); summarizes Mitigation Measures associated with specific resources or issues (Section 6); and provides a list of Preparers (Section 7) and a list of References (Section 8). Appendices provide a glossary of select Postal Service terms used in this PEA, copies of various public and stakeholder outreach documentation and responses; and various technical background information. 5

18 This page intentionally left blank. 6

19 2 PURPOSE OF AND NEED FOR ACTION 2-1 Purpose of Proposed Action The Postal Service has as its basic function the obligation to provide postal services to bind the Nation together through the personal, educational, literary and business correspondence of the people. It shall provide prompt, reliable, and efficient services to patrons in all areas and render postal services to all communities. (Universal Service Obligation [39 United States Code (U.S.C.) 101]). The Postal Service has been a self-supporting Independent Establishment 2 of the Executive Branch of the United States Government since 1971 when Congress assigned the Postal Service the general duty to maintain an efficient system of collection, sorting, and delivery of the mail nationwide (39 U.S.C. 403(b)). In order to carry out this obligation, the Postal Service has the specific powers to: provide for the collection, handling, transportation, delivery, forwarding, returning, and holding of mail, and for the disposition of undeliverable mail (39 U.S.C. 404(a)(1)); and determine the need for post offices, postal and training facilities and equipment, and... provide such offices, facilities, and equipment as it determines are needed (39 U.S.C. 404(a)(13)). The purpose of the Proposed Action is to provide replacement vehicles for aged and high-maintenance cost delivery vehicles, and add vehicles to the delivery fleet for anticipated route growth pending a final procurement decision for the wider Postal Service delivery fleet. After years of extensive field testing, Postal Service has determined that the best COTS vehicles for meeting that purpose are light-duty trucks and Class 2 trucks (e.g., minivans and delivery vans). New purchases of these vehicles would provide increased vehicle capacity, more consistent and reliable operations, and improved public view of the Postal Service. 2-2 Need for Action In FY 2016, the Postal Service delivered to more than million delivery points (addresses) in every state, city and town in the country, year-round, six days a week (and even on Sundays primarily driven by e-commerce needs); this represents an increase of 1.1 million delivery points from FY A total of billion mail pieces 2 The Postal Service receives no tax dollars for operating expenses and relies on the sale of postage, products and services to fund operations. 7

20 were processed and delivered in FY 2016, including 5.2 billion packages, representing no change in total mail pieces but an increase of 700 million packages from FY 2015 (USPS 2017a). To transport and deliver this mail volume, the Postal Service currently has a combined delivery fleet of 203,853 vehicles composed of a variety of delivery vehicles as shown in Table Table Existing Postal Service Delivery Fleet Vehicles Vehicle Type RHD Long- Life Vehicles (LLVs) RHD Flexible- Fuel Vehicles (FFVs) COTS LHD Minivans / Delivery Vans COTS LHD Mixed Delivery Total Vehicle Count 141,380 21,140 32,000 9, ,853 RHD = Right-Hand Drive LLVs = Long-Life Vehicles FFVs = Flexible Fuel Vehicles COTS = Commercial Off-the-Shelf LHD = Left-Hand Drive Mixed Delivery = Walk-in one- and two-ton vans As described further below, an estimated 26,000 new vehicles are needed over the next three years to meet the aged vehicle replacement and future route growth demands, including: 1) Approximately 7,000 additional vehicles for future route growth, 2) replacement of approximately 11,000 accident-damaged or high-maintenance cost vehicles, and 3) replacement of approximately 8,000 end-of-life vehicles. Route Growth The number of delivery points served by the Postal Service grows by almost a million every year, driving an increase in routes. In FY 2015, 226,777 delivery routes were needed, while in FY 2016, 229,104 delivery routes were needed, an increase of about 1 percent of the total. Of the total routes, 144,395 were city routes at the end of FY 2016, and 84,709 were rural routes (not all serviced by Postal Service-owned motor vehicles). As a result of the route growth in both city and rural locations, the Postal Service delivery fleet today is severely strained to meet requirements of both quantity of vehicles and capacity. An immediate plan is needed for additional vehicles to meet growth demand over the next three years. The Postal Service forecasts that the 8

21 number of city and rural routes will grow by an estimated 7,000 over the next three years, as shown in Table Table Annual Delivery Route Requirement Projections (Estimates) Year Total Rural Routes* 340 1, ,000 City Routes 1,666 1,667 1,667 5,000 Total 2,006 2,692 2,302 7,000 *Rural Route Counts only include Routes Requiring Vehicles Each new route added would require a new vehicle, requiring expansion of the fleet by an estimated 7,000 vehicles over the 2017 to 2019 time frame to satisfy route growth demands. Replacement Vehicles The Postal Service replaces vehicles when they reach end-of-life and/or when the cost of maintaining the vehicles becomes excessive. Typically, the expected life of a minivan is 10 years, while Long-Life Vehicles (LLVs) were purpose built for Postal Service carrier operations with a life expectancy of 20 years. Examples of an aged Left- Hand Drive (LHD) minivan and high-maintenance cost Right-Hand Drive (RHD) LLV are shown in Figures 1 and 2, respectively. Figure 1 - Example of Aged LHD Minivan Figure 2 - Example of High-Maintenance Cost RHD LLV An estimated 8,000 minivans will meet or exceed their expected end-of-life within the next three years. The steadily increasing maintenance costs and reduced reliability associated with these vehicles warrant their replacement within the next three years. Additionally, while the entirety of the RHD fleet is due to be replaced beginning in 2020, the cost to maintain many of these vehicles until the start of that replacement is financially prohibitive. Many LLVs were manufactured over 20 years ago, with some of the highest maintenance-cost vehicles up to 30 years old. 9

22 As shown in Figure 3 below, most LLVs incur average maintenance costs between $2,000 and $4,000 a year. However, a significant portion of the RHD vehicles require more than $10,000 in maintenance costs, each year, due to major accident repair or significant mechanical repair work necessary to keep them operational. Generally, a little over 6,000 vehicles reach this level of maintenance annually. In addition to the direct costs associated with this maintenance, it also reduces the time available for Postal Service fleet mechanics to spend on critical preventative maintenance to keep other vehicles in top condition. Figure 3 LLV Maintenance Cost Distribution (FY 2016) Addressing these needs will require an estimated 19,000 replacement vehicles for an estimated 8,000 aged minivans and 11,000 accident-damaged and high-maintenance cost LLVs, as shown in Table This table also shows the vehicle requirements needed for the anticipated route growth. Table Delivery Vehicle Requirements (Estimated) Year Total Route Growth 2,006 2,692 2,302 7,000 Rural Route Vehicles* 340 1, ,000 City Route Vehicles 1,666 1,667 1,667 5,000 Aged Minivan Replacement Vehicles 0 7, ,000 Accident-Damaged and High-Maintenance Cost LLV Replacement Vehicles *Rural Route Counts only include Routes Requiring Vehicles 3,667 3,667 3,666 11,000 Total 5,673 13,609 6,718 26,000 In total, an estimated 26,000 new vehicles are needed over the next three years to meet the aged vehicle replacement and future growth demands, including an estimated 7,000 additional vehicles for future route growth, 8,000 end-of-life (aged) minivan replacement 10

23 vehicles, and 11,000 accident-damaged and high-maintenance cost replacement vehicles. 11

24 This page intentionally left blank. 12

25 3 DESCRIPTION OF PROPOSED ACTION AND ALTERNATIVES The Postal Service considered various alternatives to meet the projected delivery fleet needs over the next three years. Various studies completed thus far concluded that the Proposed Action, the outright purchase of approximately 26,000 new vehicles, is the most attractive option. An alternative action considered is the leasing of an estimated 26,000 new vehicles. Previous studies for the acquisitions examined the cash flow (cash outlay) over a multi-year period. The following sections describe the alternatives assessed, and include the No Action Alternative, the Proposed Action, and the Alternative Action. 3-1 No Action Alternative Under the No Action Alternative, the Postal Service s delivery fleet would be maintained at the status quo; existing vehicles such as those shown in Figures 1 and 2 (Section 2) would continue to be used. The fleet would continue to operate at its current level, with no new vehicles for replacement of aged, accident-damaged, and high-maintenance cost vehicles; and no additional vehicles to address the delivery route growth anticipated over the next three years. The Postal Service would incur increasingly high maintenance costs by operating minivans past their life expectancy and repairing/maintaining and operating LLVs involved in accidents and those with high maintenance costs. Maintenance costs of the most expensive LLVs currently in the fleet would continue to rise with decreased availability of adequate parts. This would contribute to costly breakdowns and, potentially, service failures, which in turn could erode the Postal Service s customer base as consumers lose faith in the Postal Service s ability to provide on-time and effective delivery services. Existing routes would need to be expanded to address the annual city and rural delivery growth, incurring additional mileage and corresponding increased costs for maintenance and repair of existing vehicles. The existing Postal Service personnel complement would continue to operate and maintain the delivery fleet, and deliver the mail. The No Action Alternative is not expected to result in new construction, real property disposals or purchases, or facility renovations or alterations. 13

26 3-2 Proposed Action The Proposed Action has two primary components, summarized as: 1) Acquisition of an estimated 7,000 additional delivery vehicles to accommodate future route growth. 2) Acquisition of an estimated 19,000 COTS replacement vehicles for an estimated 8,000 aged minivans and estimated 11,000 accident-damaged or highmaintenance cost LLVs. As discussed in Section 2 and shown on Table 2-2.3, these two components would provide Delivery Operations the estimated 26,000 vehicles needed to maintain the current readiness of the fleet with extra capacity to accommodate anticipated route growth in city and rural areas. An example COTS vehicle that is typical in size and configuration of the new vehicles proposed for acquisition is shown below: Figure 4 - Example Replacement COTS Vehicle The Postal Service would purchase an estimated 26,000 light-duty trucks and Class 2 trucks. The actual number and timing of COTS delivery vehicles purchased and deployment would be based on the final needs of the Postal Service and supplier availability. These vehicles would provide increased vehicle capacity, more consistent and reliable operations, and improved public view of the Postal Service. All of the approximately 7,000 new route growth vehicles are anticipated to use gasoline; all of the approximately 19,000 new vehicles are also anticipated to use gasoline, replacing vehicles that already use gasoline. Gasoline usage is anticipated based on potential supplier responses to the Postal Service-issued RFPs for vehicles that would meet the Purpose and Need (Section 2). While future after-market vehicle conversions to alternative fuel types could occur, this PEA does not evaluate alternative fuels and 14

27 assumes no conversion to alternative fuels, in order to evaluate potential worst-case environmental impacts based on gasoline consumption. Of the replacement vehicles, primarily to 2010-model year minivans would be replaced, and primarily to 1994-model year LLVs would be replaced. The acquired vehicles would be up-fitted and postalized (painting, decals, etc.) to meet Postal Service delivery vehicle requirements. Vehicle-maintenance technicians (mechanics) at vehicle maintenance facilities (VMFs) would receive training on maintenance of the new vehicles. As compared to the vehicles being replaced, the additional and replacement vehicles would have improved safety equipment, including driver airbag, four-wheel anti-lock braking system (ABS) brakes, height adjustment safety belts, low-tire pressure signal, stability control, traction control, and emergency braking assistance. The Postal Service expects to hire or reassign approximately 7,000 Postal Service mail carriers for the new routes, one per each additional vehicle. No additional Postal Service personnel are expected to be hired for the replacement vehicles, as the Postal Service mail carriers for the replaced vehicles would deploy to the new vehicles. Personnel would be given up to 3.5 hours of driver training for the new COTS vehicles. The Postal Service vehicles being replaced would be sold or scrapped, based on their residual value. The Headquarters Office of Vehicle Maintenance would determine their disposition as operable vehicles, parts-only vehicles, or scrap. If deemed operable, vehicles would be sold. Prior to sale, the Postal Service would clean the vehicles inside and out and perform basic service (tire pressure, fluids, etc.) as needed. If scrapped, various materials from the vehicles (metal, batteries, oil, coolant, and tires) would be removed and reused or recycled to the extent reasonably feasible. The remainder of the vehicle parts would be disposed of appropriately. The Proposed Action Alternative is not expected to result in new construction, real property disposals or purchases, or facility renovations or alterations. 3-3 Alternative Action The Alternative Action is the leasing of an estimated 26,000 route growth and replacement vehicles between 2017 and The actual number and timing of COTS delivery vehicles leased will be contingent upon Postal Service final needs and supplier availability. The leased vehicles would be COTS, and then up-fitted and postalized to 15

28 meet Postal Service delivery vehicle requirements prior to first use, the same as under the Proposed Action. The Postal Service anticipates that all the lease vehicles would use gasoline as their fuel source, the same as the vehicles being replaced. An estimated additional (7,000) Postal Service mail carriers are expected to be hired or reassigned for the new routes using the leased vehicles. As compared to the vehicles being replaced, the Postal Service anticipates that the lease vehicles would have improved safety equipment similar to that described for acquired vehicles under the Proposed Action. The Postal Service would provide initial operator/driving training on the operation of the lease delivery vehicles; and initial training of mechanics for each VMF where the lease vehicles are being deployed, similar to the Proposed Action. Leasing costs exceed the new vehicle acquisition scenario by more than five times based on a recent financial analysis. In addition, leasing the vehicles removes any flexibility the Postal Service might have should it elect to maintain the vehicles over a longer period of time. The Alternative Action is not expected to result in new construction, real property disposals or purchases, or facility renovations or alterations. 16

29 4-1 Introduction 4 AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES This section describes the affected (existing) environment for each resource and then describes the potential environmental consequences due to implementation of the No Action Alternative, the Proposed Action and the Alternative Action. It is important to note that the Proposed Action is national in scope, with vehicles to be distributed across the operations network. The PEA does not assess the site conditions or environmental impacts of any particular facility action. Rather, the PEA focuses on the broad, programmatic impacts and regulatory implications of the Proposed Action and its Alternatives in a national context. For each resource addressed, the baseline ( existing ) conditions are described. The discussion then provides information regarding the assessment of impacts from the No Action Alternative, the Proposed Action, and the Alternative Action. This section s discussion of potential impacts for the No Action Alternative, Proposed Action, and Alternative Action focuses on direct and indirect impacts and whether the impacts are significant. Direct Impacts are caused by the action and occur at the same time and place. Indirect Impacts are caused by the action and are later in time or removed in distance, but are still reasonably foreseeable. The Environmental Consequences are addressed for each resource in terms of the significance of potential impacts from the No Action Alternative, Proposed Action, and Alternative Action. A determination of significance as defined by Section of the CEQ regulations requires consideration of both context (such as society as a whole [human, national], the affected region, the affected interests, and the locality) and intensity. Significance varies with the setting of the proposed action and both short- and long-term effects are relevant. The Proposed Action, being national in scale and scope, has the potential to impact resources throughout the U.S. The specific actions that the Postal Service would take as part of the initiative are located in geographically diverse areas (urban, suburban, and rural). Because of the wide variety of natural and manmade environments and the complexity of resources potentially affected, this section characterizes resource impacts in general terms. For the purpose of this PEA, the Postal Service examined potential impacts in terms of the severity of the impact. The assessments included: 17

30 Consideration of both beneficial and adverse impacts; Effects on public health or safety; the degree to which impacts are likely to be highly controversial, highly uncertain, or involve unique or unknown risks; The degree to which the action may establish a precedent for future actions with significant effects or represents a decision in principle about a future consideration; Whether the action is related to other actions with individually insignificant but cumulatively significant impacts; The degree to which the action could adversely affect cultural resources protected by the National Historic Preservation Act or endangered or threatened species protected by the Endangered Species Act; and Whether the action would violate a Federal, State, or local law that protects the environment. To assess the significance of an impact, the Postal Service first identified the relevant context and whether the impact would be negligible, minor, moderate, or major. The Postal Service then determined if the impact was significant, based on the requirements in 40 CFR Four types and levels of impact were considered during the analysis: Beneficial Impact The impact would be beneficial in nature. No or Negligible Impact No impact is anticipated or the impact is barely perceptible or measurable. Moderately Adverse Impact An impact is anticipated, but the impact does not meet the context/intensity significance criteria for the specified resource. Significant Impact An impact is anticipated that meets the context/intensity significance criteria for the specified resource. The levels of these impacts and their specific definitions vary based on the resource evaluated. For example, a significant impact may be different for wetlands than for air quality, both in terms of the relevant context and the intensity of effects. Findings regarding the significance of the No Action Alternative s, the Proposed Action s, and the Alternative Action s impacts on the resources considered in this PEA were based on the relevant context and on the assessment of intensity, and are described herein. The Postal Service also used this approach to develop similar conclusions regarding cumulative impacts, which focus on the combined, incremental 18

31 effects of actions within a particular area and within a particular time frame, and are further defined and addressed in Section 5. Section 4-11 provides a table summarizing the potential impacts that could result from implementation of the No Action Alternative, the Proposed Action and the Alternative Action. A discussion on mitigation measures is presented in Section Existing Vehicle Fleet A breakdown of the numbers and types of vehicles in the Postal Service s existing nationwide delivery fleet is shown in Table The backbone of the delivery fleet is purpose-built RHD vehicles including 141,380 LLVs and 21,140 Flexible Fuel Vehicles (FFVs); in addition the fleet includes 32,000 light-duty delivery vans (approximately 23,000 minivans and 9,000 delivery vans) and 9,145 walk-in vans (one- and two-ton vehicles). Both the light-duty vans and the walk-in vans are COTS LHD vehicles. The total delivery fleet serviced approximately 229,000 delivery routes in FY Maintenance of the delivery fleet to ensure the fleet is adequate for operational needs is a detailed and continuous process. The Postal Service tracks individual vehicles based on age and maintenance costs to support the decision-making process for a continuous vehicle replacement program. Vehicle replacement begins when the vehicle approaches end-of-life, based on Postal Service experience, which for the LLV fleet is 20 years or more and for the fleet of minivans is 10 to12 years. Replacement decisions are also made based on maintenance costs with replacements of the RHD vehicles occurring when maintenance costs significantly exceed the average of $2,000 to $4,000 per year. Maintenance costs exceed $10,000 per year for some 6,000 of the RHD vehicles Existing Postal Facilities The Postal Service maintains its fleet of vehicles at Postal Service-owned or -leased VMFs strategically located throughout the operations area; local commercial vehicle repair and maintenance shops are also used when warranted. The existing Postal Service VMFs are currently adequately maintaining the vehicles that are being replaced and would continue to maintain the replacement vehicles. The maintenance of an additional estimated 7,000 new vehicles to an existing fleet of 203,853 vehicles represents an approximate three percent increase, an insignificant increase. Therefore, no expansion of existing VMFs or additional VMFs is anticipated, and an increase in commercial repair shop usage is not anticipated. Delivery vehicles are parked overnight at various Postal Service facilities, including Processing & Distribution Centers (P&DCs), Network Distribution Centers, Post Offices, 19

32 and VMFs. These facilities have designated parking lots and parking spots for delivery fleet vehicles, and ample parking space to accommodate additional vehicles Existing Workforce Relevant to this PEA, the Postal Service has over 173,380 delivery fleet Carriers driving LLVs and light-duty delivery vehicles, additional Carriers in 21,140 FFVs, and Carriers driving 9,195 COTS LHD mixed delivery vehicles; and over 7,760 automotive technicians, repairers, and mechanics at its 322 active VMFs. 4-2 Resources Not Studied in Detail At this time in the decision-making process, the Postal Service does not anticipate any interior or exterior facility alterations, or construction; nor new real property leasing, acquisition, or disposal as part of, or resulting from, the No Action Alternative, Proposed Action, or Alternative Action. Also, additional land at existing Postal Service facilities would not be used for storage or parking of the existing, or replacement and additional vehicles. Therefore, the Postal Service has concluded that the following resources and topics would not be affected, and were dismissed from detailed analysis: topography, geology, soils, and prime farmland; historical and archaeological resources; hydrology, water resources, floodplains, and wetlands; vegetation and wildlife; land use and planning; and coastal zone. With no new building construction or modifications, there would be no impact to historical and archaeological resources. No changes to topography and no ground disturbance would occur; therefore no impacts to soils or geology or prime farmland would occur. The existing VMFs are maintained in an environmentally compliant manner with all discharges to stormwater and sanitary treatment systems properly permitted and compliant; therefore no impacts to hydrology or water resources would occur. No impacts to vegetation and wildlife, floodplains, wetlands or coastal zone areas would occur since no new construction would be required. 4-3 Socioeconomics Socioeconomics - Affected Environment Community Economics Postal Service facilities, like any large employer, contribute positively to communities both directly through employment at the facility and expenditures to service providers and suppliers, and indirectly through jobs created in other sectors of the local economy and increased sales of local trade and service businesses, such as restaurants and gas stations. In FY 2016, the current delivery fleet of 203,853 vehicles consumed over

33 million gallons of bulk fuel and over million gallons of fuel purchased commercially at local retail outlets, for a total of almost million gallons of fuel (see Table for details). Existing delivery fleet LLVs and minivans averaged 8.7 miles per gallon (mpg), based on 2016 data compiled by the Postal Service, while the newer delivery van models averaged 6.7 mpg based on these same data and the other delivery vehicles averaged between 6.7 mpg and 8.7 mpg. The Postal Service also pays local providers for utilities, supplies associated with operation and maintenance of the facility, and fuel for postal vehicles. Under the No Action Alternative, Proposed Action, and No Action Alternative, Postal Service facilities would not be altered and real estate transfers would not occur; hence, socioeconomic impacts associated with Postal Service facilities are not evaluated herein. Postal Service delivery vehicle maintenance costs consist of in-house parts cost, inhouse labor cost, commercial parts cost, and commercial labor cost. Most Postal Service delivery vehicles incur average maintenance costs between $2,000 and $4,000 a year. A significant portion of RHD vehicles require more than $10,000 in maintenance costs each year due to major accident repair or significant mechanical repair work necessary to keep them operational. Generally a little over 6,000 vehicles reach this level of maintenance each year, and the Postal Service has identified 9,700 vehicles already in this category. As shown on Table below, the estimated maintenance costs for vehicles proposed for replacement as part of the Proposed Action and Alternative Action (approximately 8,000 minivans, and 11,000 of the highestmaintenance cost LLVs) are over $131 million annually. Table Estimated Current Maintenance Costs for Vehicles Proposed for Replacement Type of Vehicle Replaced Number of Vehicles* Estimated In-House Parts Cost Per Vehicle Estimated Commercial Parts Cost Per Vehicle Commercial Labor Cost Per Vehicle Total Estimated Maintenance Cost Minivans 8,000 $ 1,219 $ 262 $ 710 $ 17,528,000 RHD LLVs 11,000 $ 7,357 $ 391 $ 2,603 $ 113,861,000 Total $ 131,389,000 Notes: Postal Service VMF labor costs are not factored into the above *Estimated Employment The national direct labor economic contribution from the 203,853 Postal Service carriers driving the existing Postal Service delivery fleet of 141,380 LLVs, 21,140 FFVs, 32,000 minivans and delivery vans, and 9,195 COTS LHD mixed delivery vehicles is more than 21

34 $11.4 billion annually, based on an average annual salary of $56,000 (based on internal Postal Service data) Minority and Low-Income Populations Executive Order 12898, Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations (February 11, 1994), directs federal agencies to take the appropriate and necessary steps to identify and address disproportionately high and adverse effects of federal projects on the health or environment of minority and low-income populations to the greatest extent practicable and permitted by law. Due to the Postal Service s status as an Independent Establishment of the Executive Branch of the US Government, most Executive Orders, including Executive Order 12898, do not apply to the Postal Service. However, the Postal Service does seek to fulfill the spirit of those non-mandatory requirements, and it is in that spirit that Postal Service takes into consideration such effects. The fundamental principles of Environmental Justice are to: Ensure effective public participation and access to information in the decisionmaking process; Prevent the denial of, reduction in, or significant delay in the receipt of benefits by minority and low-income populations; and, Avoid, minimize or mitigate disproportionately high and adverse human health and environmental effects, including social and economic effects, on minority populations and low-income populations. To address Executive Order 12898, agencies are required to make a determination on whether proposed actions would have a disproportionately high and adverse effect on minority and low-income populations. Disproportionately high and adverse effects are adverse effects predominantly borne or suffered by a minority or low-income population, and an effect that would be appreciably more severe or greater in magnitude than the adverse effects that would be suffered by the non-minority or non-low income population. The Postal Service delivery network is located across the United States, and services each address regardless of racial and/or socioeconomic status. It is likely that many of the new routes in urban areas would be in areas inhabited by Low and Moderate Income (LMI) persons. 22

35 4-3.2 Socioeconomics - Environmental Consequences No Action Alternative Under the No Action Alternative, no new vehicles would be added to the existing fleet and no new routes would be added to account for the new growth in business and increase in delivery points. Existing delivery vehicles would continue to be used and existing routes would be expanded; delivery miles driven and delivery time frames would therefore likely increase in order to meet the demand for additional delivery points. All customers, including Low and Moderate Income (LMI) persons, would continue to receive their mail via the existing vehicles. It is possible that mail delivery to some addresses would be at a different time than customers have grown accustomed. Fuel consumption associated with delivery operations would increase, as more miles would be driven, resulting in increased fuel purchase costs and positive economic impact to communities. As discussed later in Sections and , for purposes of this analysis an estimated 24,867,850 miles would be added to the existing routes, and approximately 2,858,374 additional gallons of fuel, an approximate 2 percent increase, would be purchased to fuel the vehicles over the expanded routes. As a result of not acquiring the estimated 26,000 new vehicles under the No Action Alternative, maintenance costs for the existing fleet of delivery vehicles would increase. As vehicles age, more parts would wear out and, with fewer safety features, would be increasingly involved in more frequent breakdowns and accidents requiring repair. Both Postal Service VMFs and commercial repair and maintenance shops would experience an increase in vehicle maintenance requests. More frequent breakdowns would also potentially result in safety concerns and traffic delays on roadways, and delays in delivery of the mail. This would adversely impact that route s residents and customers, regardless of their socioeconomic status. No additional mail carriers would be employed under the No Action Alternative. The existing complement of mail carriers would be tasked to potentially work longer hours to serve the longer delivery routes, thus increasing their individual annual income and positive direct and indirect effects on the economy. The percent increase in delivery hours has not been quantified Proposed Action The newer vehicles are anticipated to have higher fuel consumption than the existing ones, based on Postal Service existing delivery vehicle fuel data. Using an estimated 6.7 mpg for the new replacement and new additional vehicles would result in an additional purchase of an estimated 10,935,059 gallons of fuel, or an 8 percent increase 23

36 for Postal Service delivery fleet vehicles. However, manufacturer data for COTS lightduty trucks and Class 2 trucks suggest that new vehicles would be able to achieve a higher mpg than the current fleet that achieves 6.7 to 8.7 mpg (e.g., one manufacturer website lists a 2017 delivery van model with USEPA mileage estimated at 15 mpg city and 22 mpg highway, whereas Postal Service data for the older model-year delivery van indicates 6.7 mpg). Hence, additional miles driven under the Proposed Action for the new delivery routes would increase fuel purchases and the positive impact to the economy, while better fuel consumption rates for the new vehicles and more efficient routing across the network would partially offset the increases and economic impacts. The economic impact due to a reduction in replacement parts purchases for the vehicles being replaced would be partially offset by purchases of replacement parts for the new vehicles in the delivery fleet. Overall vehicle maintenance costs for the Postal Service would decrease, as the high-maintenance cost vehicles would be removed from the fleet, and maintenance time and money could be focused on more preventive maintenance of newer vehicles. The resale or scrapping of an estimated 8,000 minivans and another estimated 11,000 vehicles (LLVs), would provide revenue opportunities for used auto dealers, scrap dealers, recyclers, and waste management and disposal firms. This large purchase of the new and replacement vehicles from suppliers located within the country over a three-year period would either generate new jobs, or maintain the existing levels of employment in these firms. There is a good potential for job creation throughout the entire supply chain for the new vehicle production, and spending by the workforce would result in both direct and indirect positive benefits locally and regionally. The Proposed Action would lead to new employment opportunities for approximately 7,000 persons nationwide over a three-year period. This assumes one new hire for every new delivery route, and the Postal Service would begin hiring for these positions starting in FY The new opportunities would be for carriers and it is probable that most of the jobs would be filled by qualified persons located in the same geographic area. The annual salaries for this particular job type range between $55,000 and $56,500 (USPS 2016c), which is much higher than annual per-capita income of $28,930 reported by the U.S. Census Bureau (2017a). These new jobs, creating up to $396 million in new salaries, would result in spending for goods and services and result in both direct and indirect economic benefits to the urban and rural areas where the jobs would be created. The estimated 5,000 new city routes would be spread across the delivery network, such that the majority of cities would be receiving a minimal number of routes. Based on FY 24

37 2014 to FY 2016 trends, the estimated 5,000 new vehicles (and associated new carrier positions) would be added to 2,136 city ZIP codes in the total Postal Service city network of 11,675 ZIP codes. The large majority (99.9 percent) of the 11,675 city ZIP codes would add only three vehicles (and carrier positions) per year, based on past trends. Only 19 ZIP codes are projected to add more than three vehicles (and carrier positions) per year to address route growth. The largest number of new routes and new vehicles added to any one ZIP code in FY 2015 and FY 2016 was 13, which was for ZIP code in Bend (near Portland), Oregon; assuming the trend continues, about 19 new routes (and hence, 19 carrier positions) would be added to that ZIP code over the next three years. The socioeconomic impact of these additional carrier positions and vehicles, while positive, would be insignificant. In any one city, the largest number of new routes would be in Houston, Texas, a city spread over 667 square miles. Only 84 new routes are projected to be needed over the three-year FY 2017 to FY 2019 period (based on 28 routes added per year from FY 2015 to FY 2016); however, only 5 ZIP codes in Houston (out of 94 ZIP codes) are projected to have two to four new vehicles added per year. Therefore, in even the city with the largest need for new routes, the beneficial socioeconomic impact in a city of this size from the additional carrier positions and vehicles would be insignificant. The new vehicles would also benefit the carriers themselves, as they would be equipped with safety features such as stability control, traction control, emergency braking assistance and other standard features such as driver side airbags, ABS brakes, and height adjustment safety belts. All these features are expected to improve the overall safety environment for the carriers and some reduction in driver fatigue and vehicle accident rates is anticipated. Any reduction in accident rates and the associated improvement in the overall workplace safety environment would have positive social and economic benefits. The general population, including LMI persons, would also benefit from the Proposed Action by the Postal Service s use of new vehicles with enhanced safety features and lower air emissions Alternative Action The leasing of new vehicles would result in similar overall beneficial socioeconomic impacts to the nation as the Proposed Action of acquiring the vehicles, as leasing would involve the same number of vehicles. Leasing the vehicles would spread the beneficial impact to the economy across several years, and over a multi-year period assumed in the cash flow analyses, contribute about ten times more to the economy than purchasing the vehicles. 25

38 Fuel costs and benefit to the economy would be the same as under the Proposed Action. The beneficial socioeconomic impact from the additional carrier positions and vehicles would be the same as under the Proposed Action and therefore insignificant. The general population, including LMI persons, would benefit from the Alternative Action by the Postal Service s use of new vehicles with lower air emissions; and benefit from the vehicles enhanced safety features. 4-4 Transportation Transportation - Background and Regulatory Compliance State Departments of Transportation (DOTs) are generally responsible for the design, construction, and maintenance of their state highway systems, as well as the portion of the Federal highways and interstates within their boundaries. Arterials, connectors, rural roads, and local roads are typically constructed and maintained by county or city governments. Local governments regulate whether Transportation Impact Analyses are required. Furthermore, regional review processes may be enforced where an adverse transportation impact is perceived to cross jurisdictional lines. The level and content of analysis, methodology, data used, and the overall process can vary greatly from jurisdiction to jurisdiction and from study to study. Additionally, the threshold used to determine whether a transportation impact analysis is needed and the definition of the threshold can vary by jurisdiction. In a typical approach, a jurisdiction develops a threshold criteria for the number of new peak hour and/or daily trips allowed before a study is required as well as criteria for the size of the study area based on the number of new trips projected. The Postal Service is not subject to local requirements but often follows these transportation regulations and thresholds. Despite these variations in how and when detailed transportation impact analyses are conducted, general procedures for conducting such studies are borne out of traffic engineering methods and succinctly documented in the Institute of Transportation Engineers (ITE) publication Transportation Impact Analyses for Site Development (ITE 2010). This publication suggests that in lieu of a locally preferred or required determinant, an appropriate threshold is the addition of 100 or more new inbound or outbound vehicle trips during the surrounding area or adjacent roadway s peak hour of traffic. Peak hour is the hour of heaviest traffic usually at the beginning or end of the workday when large numbers of people are traveling to and from work. Local jurisdictions often define specific peak hours. 26

39 In the final step of a Transportation Impact Analysis, the proponent makes recommendations for feasible transportation improvements intended to offset adverse transportation impacts determined to be directly caused by an increase or change in traffic associated with a site. When the recommendation is a tangible infrastructure improvement, the proponent typically conducts another analysis to indicate whether the Level of Service (or similar performance measures) would improve to desirable levels as a result of the recommended improvement. However, in certain cases especially where infrastructure improvements are not feasible local jurisdictions may be open to other strategies including the creation of travel demand management programs (employee rideshare programs, staggered work and/or delivery schedules, etc.) or investments in general transportation funds Transportation Affected Environment Postal Service delivery routes are located in urban, suburban and rural areas. Urban areas are generally characterized by a complex and extensive system of roads, including major freeways, arterials, and surface streets. Urban roads typically support high levels of traffic, which often result in roadway segment and intersection congestion. More suburban environments can be characterized by fewer roads and a predominance of two-lane and four-lane roads. Generally, rural roads have lower traffic volumes with minimal congestion Overview of the Postal Service Transportation Network Collection, mail processing, transportation, and delivery are the major functions within the Postal Service. Several modes of transportation are used to move the mail between facilities, as determined by the quantity to be moved and the transit time allowable under the service standards. A simplified diagram of how mail flows through the postal system is presented in Figure 5. & Transportation Process Figure 5 - Postal Service Mail Processing Figure 5 - Postal Service Mail Processing & Transportation Process 27

40 The objective of mail distribution is to collect, transport, and deliver mail expeditiously within specified service standards for each class of mail. Postal Service transportation networks exist to support mail processing and delivery activities. Transportation is the link connecting the outgoing and incoming distribution elements that create the network. Generally, mail enters the Postal Service network via collection boxes, retail windows, detached mail units at mailer facilities, or business mail entry units at postal facilities. Facilities such as Post Offices, stations, branches, and contract postal units collect outgoing mail from customers. At the same time, mail arriving at these facilities is taken out for delivery. After the outgoing mail is collected, it is handed off to an origin processing facility. Mail proceeds through origin processing facilities, consolidation facilities, and destination processing facilities. Mail is transported from origin processing facilities to the final destination facilities, loaded into Postal Service delivery fleet vehicles (including those that are the subject of the Proposed Action), and then delivered to the destination address. The Postal Service surface transportation can be characterized generally in two categories, transport of large volumes of mail between processing facilities and to post offices and from post offices to and from delivery points. This PEA focuses on the transport of mail to and from post offices and delivery points (businesses and residences). This transport occurs on city streets, county roads and major highways. Cargo vans are used to transport large volumes of mail from processing plants and mailer plants to post offices and airport facilities. Spotters are used to move trailers to and from docks and to stage trailers for loading and unloading between postal facilities. Trailers are used to transport large volumes of mail from mailer's plants and processing plants to post offices and airport facilities. Delivery vehicles form the backbone of the Postal Service transportation system providing delivery of mail to and from post offices and destination points including businesses and residences. The delivery vehicles consist primarily of RHD LLV vehicles, RHD FFV vehicles, minivans and delivery vans. These are custom-built vehicles designed for efficient mail delivery to and from residences and businesses Traffic The current delivery fleet of 203,853 vehicles traveled approximately billion miles in FY 2016, as shown in Table

41 Table Annual Vehicle Miles by Existing Delivery Fleet Vehicles Type of Vehicle Miles Traveled (FY 2016) Two-ton trucks 37,684,265 Cargo Vans 40,675,781 FFVs 121,866,610 Delivery Vans 9,440,881 LLVs 918,255,089 Minivans 88,035,150 Total 1,215,957,776 Traffic associated with the 164,380 vehicles that are LLVs and minivans was spread over an estimated billion miles annually (FY 2016) and nationwide, as shown on Table Table Annual Vehicle Miles by Existing Delivery Fleet Vehicles Associated with the Proposed Action Type of Vehicle Number of Vehicles Mileage (FY 2016) Miles per Vehicle LLVs 141, ,255,089 6,528 Minivans 23,000 88,035,150 3,818 Total 164,380 1,006,290, The average annual mileage for the estimated 8,000 LHD minivans being replaced is 3,818 each, for a total of approximately 30,544,000 miles annually; the average annual mileage for the estimated 11,000 RHD LLVs being replaced is 6,528 miles each, for a total of approximately 71,808,000 miles annually, for a total of 102,352,000, or 8.4 percent of the combined billion annual delivery fleet mileage. The vehicles are traversing roads and highways in both city and rural environments with varying traffic densities and levels of congestion throughout the day. Carriers typically pick up mail and leave on delivery routes in the morning, typically after morning rush hour. These carriers complete their routes and typically return to the facility before evening rush hour. The Postal Service s complement of approximately 203,853 delivery fleet employees within the mail delivery network also generates trip traffic when they travel to and from the location where they pick up their Postal Service delivery vehicle. Assuming most employees ride alone and drive a privately owned vehicle (POV), for the purpose of the programmatic analysis, an estimated maximum number of 203,853 employees use POVs and accordingly 407,706 POV trips are generated daily. Using an assumed 24- mile daily average roundtrip commute mileage (based on 2009 FHWA data) and using a 29

42 conservative assumption that no public transportation is used, miles traveled by mail delivery employees is approximately 4.89 million daily (1.531 billion annually) Safety, Accessibility, and Parking Site circulation, parking, and accessibility for most Postal Service facilities comply with the Postal Service Handbook RE-4 (2005). The specific circulation patterns, vehicle routing, and parking associated with a Postal Service facility vary based on the type of facility. Parking areas for postal vehicles are typically gated or otherwise accesscontrolled for authorized users. Any parking or vehicle safety-related issues identified are handled per Postal Service safety requirements. The Postal Service emphasizes safety for all aspects of the transportation network. Postal Service policy document Handbook EL-804, Safe Driver Program (Postal Service June 2014a), provides not only driver safety guidance and policies but also addresses or references safety standards related to Postal Service vehicles. The Postal Service also follows local standards and provides additional traffic safety at the facility level. Vehicle incidents are tracked and used to address safety issues and improve Postal Service safety performance in the area of transportation. The existing delivery fleet vehicles have a variety of safety features, based on the make and model year of the vehicle. Older models do not have the latest vehicle safety equipment, including driver airbags, four-wheel ABS brakes, height adjustment safety belts, low- tire pressure signals, stability control, traction control, and emergency braking assistance Public Transportation The Postal Service is working to minimize petroleum use from Federal employee travel by matching Post Office staffing levels to future mail volumes, encouraging carpooling and public transportation, and expanding use of web-based technologies for meetings and training. Public transportation is not used for transport of mail. Some Postal Service employees use public transportation to travel to and from work each day or periodically. Based on U.S. Census five-year estimates for the United States (2017c) data, 5.1 percent of U.S. employees use public transportation (bus, metro/transit rail, commuter rail, or intercity rail). This typically occurs where public transportation is located in metropolitan areas near the Postal Service s facilities. Where available, the Postal Service encourages employees to participate in ride-share and trip-reduction programs, which are most often available where air quality nonattainment is an issue. The Postal Service participates in trip-reduction programs, where applicable. 30

43 In addition, the Postal Service maintains a Commuter Benefits Program that offers taxfree cost benefits that promote various commuting options, including public transit and vanpooling Transportation Environmental Consequences No Action Alternative Existing traffic levels associated with current Postal Service operations would not change as a result of the No Action Alternative. To meet the demand for new delivery points over the next three years, the existing delivery fleet would be used; existing routes would be expanded, with no new routes and no new or additional vehicles. Additional miles would be driven using existing vehicles. For purposes of this analysis it has been estimated that some 24,867,850 miles would be added to the existing routes, an increase of 2 percent of the total annual delivery fleet mileage (1.216 billion in FY 2016). This is based on the assumption that the expanded routes would address the additional delivery points by lengthening the routes and would not have to return to the starting point, thereby traveling approximately one half the mileage of the projected new routes. These additional miles would be insignificant in any one location and result in an insignificant increase in traffic. No new employees would be added, so no new mileage would be traveled by POVs. As a result of not acquiring an estimated 26,000 new vehicles under the No Action Alternative, the existing delivery vehicles could continue to age and experience more frequent breakdowns, potentially resulting in safety concerns and traffic delays on roadways. No changes to existing accessibility and parking conditions would occur; and no changes to public transportation would occur because delivery employee positions would not change, and the Postal Service would continue to encourage employees to use public transportation (and ride-sharing, etc.) where available. Since existing fleet delivery vehicles would continue to be used, the benefits of improved safety equipment available in newer-model vehicles would not be realized. Traffic Proposed Action Under the Proposed Action, an estimated 19,000 of the new vehicles would be replacement vehicles for aged and high-maintenance cost vehicles. Routes and mileage associated with these vehicles would not change, as shown in Table

44 The new replacement vehicles would be less susceptible to breakdowns, resulting in fewer traffic delays and safety concerns. Table Annual Vehicle Miles Associated with Proposed Action (and Alternative Action) Type of Vehicle Number of Vehicles Mileage (FY 2016) Miles per Vehicle New* Vehicles LLV (*Replacements) 141, ,255,089 6,528 11,000 Minivans (*Replacements) *New Additional Vehicles 23,000 88,035,150 3,818 8,000 Rural: 9,922 City: 5,978 Total 164,380 1,006,290,239 26,000 Notes: Number of Vehicles does not include 9,195 Mixed Delivery Vehicles The number of vehicles is estimated Anticipated Miles 71,808,000 (no change) 30,544,000 (no change) 7,000 49,735, ,352,000 (no change); 49,735,700 (additional) Up to an estimated 7,000 new vehicles would traverse new delivery routes, including an estimated 2,000 rural routes and an estimated 5,000 city routes, for an estimated total of 49,735,700 miles driven annually (Table 4-4.3). The estimated 2,000 rural routes would be in areas with minor traffic volumes due to the rural locations, such that the additional vehicles would have an insignificant effect on traffic. The estimated 5,000 city routes would be spread across the Delivery network, such that the majority of cities would be receiving a minimal number of new routes. The need for new routes has been based on projected trends in added routes experienced across the country between FY 2014 and FY The trends are expected to continue for at least the next three years, the period when the new vehicles are needed. Based on the FY 2014 to FY 2016 trend, an estimated 5,000 new vehicles would be added to 2,136 city ZIP codes in the total Postal Service city network of 11,675 ZIP codes, with an average of an estimated 1,667 new vehicles being added to the network each year. The large majority (99.9 percent) of the estimated 11,675 city ZIP codes would add only three vehicles per year, based on past trends. The impact on traffic from adding nine new vehicles to one ZIP code over a three-year period would be insignificant. Only 19 ZIP codes are projected to receive more than three vehicles per year. The largest number of new routes and new vehicles added to any one ZIP code in FY 2015 and FY 2016 was 13 for ZIP code in Bend (near Portland), Oregon; assuming the trend continues, about 19 new routes would be added to that ZIP code over the next three years. As previously discussed in Section , the largest number of new routes and new vehicles in a city would be in Houston, Texas, with 84 new routes projected over the 32

45 three-year FY 2017 to FY 2019 period (based on 28 vehicles added per year from FY 2015 to FY 2016); however, only 5 ZIP codes in Houston (out of 94 ZIP codes) are projected to have two to four new vehicles added per year. Therefore, in even the city with the largest need for new routes, the impact on traffic would be insignificant, as Houston encompasses 667 square miles and 84 new routes would be insignificant in a city this large. New employees needed for the approximately 7,000 new vehicles would commute an assumed 24 miles round trip per day, assuming conservatively that all of the new employees use their own POV. The new employee POV mileage nationwide would therefore be an estimated 52,584,000 annually, an increase of approximately 3 percent. Also as previously discussed in Section , Houston, Texas would gain the most new employees in any one city, with a total of 84 over the three-year vehicle acquisition period. With Houston s total population of approximately 2,300,000 in 2015 (U.S. Census Bureau 2017b), the addition of approximately 84 new workers would have an insignificant impact on traffic, especially considering that some of these new employees might use public transportation to travel to and from work. In summary, the Postal Service anticipates the impact on surface traffic from an additional estimated 7,000 delivery vehicles and associated POV vehicles would be negligible and therefore insignificant. Safety, Accessibility, and Parking Replacement of the aged and high maintenance-cost vehicles with new vehicles would result in fewer breakdowns, and fewer safety concerns in connection with the breakdowns. Vehicles would be safer to drive due to newer-model year vehicle safety equipment, including driver airbags, four-wheel ABS brakes, height adjustment safety belts, low- tire pressure signals, stability control, traction control, and emergency braking assistance. Initial Postal Service-provided training for carriers on driving, maneuvering, and parking the new vehicles would further enhance safety from use of the new vehicles. Traffic would increase slightly from the new employees and vehicles added; however, with the maximum number of new employees at most locations being nine or less over the three-year period, the traffic impact would be insignificant. Likewise accessibility and parking is more than adequate at these facilities, and could accommodate the additional vehicles and personnel with insignificant impact. 33

46 Public Transportation Postal Service employee ridership on public transportation, where available proximate to postal facilities, would likely increase with the new employees being added consistent with nationwide averages. The Postal Service expects that any increase in postal employee ridership would not significantly affect public transportation on a national basis. Impacts on public transportation and Postal Service operations and employees from any workforce complement increases would be negligible and perhaps even beneficial because of increased ridership and the associated revenues to public transportation providers. Conclusion - Transportation Adverse impacts to certain aspects of transportation would be negligible on a national level due to the Proposed Action. Potential air quality and socioeconomic impacts resulting from transportation are addressed in the respective sections of this PEA Alternative Action The effects of an estimated 26,000 new vehicles on transportation would be the same as the Proposed Action since the new vehicles are the same in number. 4-5 Noise Noise - Background Information and Regulatory Setting Noise is defined as unwanted sound that interferes with normal human activities or wildlife behavior, or can otherwise diminish environmental quality. Human response to noise can vary depending on the source, listener sensitivity and expectations, the time of day, and the distance from the source. The effects of noise changes must be considered in terms of the environment external to facilities as well as internal. The external effects are a concern to nearby businesses, community facilities considered sensitive receptors and residential neighborhoods. Sensitive receptors include populations within facilities in which occasional or persistent sensitivity to noise above ambient levels exists, such as at or near hospitals, amphitheaters, nursing homes, and certain locally designated districts. Noise, or sound, is most commonly measured in decibels (db) on the A-weighted scale (db(a)), which is the scale most similar to the range of sounds that the human ear can hear. The Day-Night Average Sound Level (DNL) is an average measure of sound accepted by Federal agencies as a standard for estimating sound impacts and establishing guidelines for compatible land uses. 34

47 The Occupational Safety and Health Administration (OSHA) regulates noise as it affects workers and could affect Postal Service workers in its facilities. The Postal Service has developed a Management Instruction EL , Hearing Conservation Programs (Postal Service 2000), as required by the OSHA standard, 29 CFR , Occupational Noise Exposure, that provides the policy for implementing and maintaining a facility-level hearing conservation program. Hearing conservation programs strive to prevent initial occupational hearing loss, preserve and protect remaining hearing, and equip workers with the knowledge and hearing protection devices necessary to safeguard themselves. Additional relevant background noise information is presented in Appendix D Noise - Affected Environment Postal Service facilities are located primarily in more urban or suburban locations. Noise levels in these environments vary continuously over a period of time depending on the contributing sound sources within the noise environment. Background noise level changes throughout a typical day, but does so gradually, corresponding to addition and subtraction of distant noise sources such as traffic and atmospheric conditions. Generally, noise levels are reduced during evening hours. Traffic from Postal Service delivery and POV vehicles contributes to external noise around postal facilities and on delivery routes primarily during daytime hours according to delivery truck arrivals/departures and POV vehicle arrival/departures. Employee POV arrival/departures are concentrated around the start/end of tours, which vary by facility. The Postal Service follows an internal anti-idling policy that is supportive of local noise ordinances. Postal Service vehicles and POVs can also create noise inside structures such as residences and businesses and repair work on vehicles can create noise in VMFs. Postal Service policy limits sound-level exposure to 85 db(a), and performs equipment maintenance to minimize noise levels, and applies engineering controls to structures in equipment areas if documented sound levels are above this limit (Postal Service 2000). Postal Service vehicle maintenance personnel are required to wear hearing protection if noise levels cannot be controlled to below OSHA limits. 35

48 4-5.3 Noise - Environmental Consequences No Action Alternative Under the No Action Alternative, the number and types of POVs and delivery vehicles, and associated noise would not change. Time frames for arrivals of POVs would not change, although departures for POVs and arrivals/departures for delivery vehicle traffic could change as a result of extended routes, increased delivery points and increased time for loading of vehicles and deliveries using the existing delivery fleet. The No Action Alternative would result in insignificant adverse effects on the exterior or interior noise environments because even though routes and hours would be extended, the additions would be spread throughout the delivery network nationwide such that no one area would experience significant increased noise Proposed Action The Proposed Action could slightly impact local exterior and internal noise environments through transportation activities. The estimated 19,000 new replacement vehicles would generate no more noise than the vehicles being replaced and possibly less noise due to advances in noise control on newer vehicles. The estimated 7,000 new additional vehicles would generate noise over and above the current levels. However, with worse-case scenario being the addition of vehicles in Houston, Texas, and only approximately 84 new vehicles over the three-year period in a city with over 2,300,000 inhabitants and extending over 667 square miles, the added noise generated by these vehicles would be insignificant. In general, considering the new replacement vehicles with more advanced noise controls and the new added vehicles, the estimated 26,000 vehicles would contribute negligible adverse impacts to the noise environment Alternative Action Noise effects for the Alternative Action would be the same as the Proposed Action since the number and types of new vehicles would be the same. 4-6 Air Quality Air Quality Background and Regulatory Setting Clean Air Act The primary regulatory requirements for addressing and maintaining the nation s air resource are detailed in the Clean Air Act (CAA), which was passed in 1970 and amended in 1990 to reduce air pollution across the United States. This PEA examines 36

49 the potential impacts from the No Action Alternative, the Proposed Action and the Alternative Action in comparison to the requirements of the CAA. The CAA focuses on specific air pollutants ( criteria pollutants ) associated with harming human health and the environment. The USEPA has assigned acceptable airborne concentration levels to each of the criteria pollutants, which are now the National Ambient Air Quality Standards (NAAQS). Furthermore, the USEPA is responsible for revising these standards when necessary as new air quality data and related impacts on human health and the environment become available. Local air pollution agencies are responsible for enforcing the NAAQS. The Clean Air Act Amendments (CAAA) of 1990 also set emission limits for certain air pollutants from specific sources, set new source performance standards based on best demonstrated technologies, and established national emission standards for hazardous air pollutants. The Act also mandates the USEPA approve State Implementation Plans (SIPs) to ensure that local agencies comply with the Act. Each state must have a SIP that identifies how the state will attain and/or maintain air quality standards. Some states have adopted their own air quality standards that are either as stringent as, or more stringent than, the NAAQS. Criteria Pollutants Federal air quality standards are currently established for the six criteria pollutants: carbon monoxide (CO), nitrogen dioxide (NO 2 ), ozone (O 3 ), sulfur dioxide (SO 2 ), lead (Pb), and particulate matters [measured as less than 10 microns in diameter (PM 10 ) and less than 2.5 microns in diameter (PM 2.5 )]. The CAAA specifies two sets of NAAQS primary and secondary for each of the criteria pollutants, as shown in Table E-1 in Appendix E. Primary standards define levels of air quality necessary to protect public health, including the health of sensitive populations such as people with asthma, children, and the elderly; secondary standards define levels of air quality necessary to protect against decreased visibility and damage to animals, crops, vegetation, and buildings. Standards have been established using average exposure times, based on the health and welfare effects of each pollutant. Air Quality Control Regions and Attainment Status in the United States The USEPA established Air Quality Control Regions (AQCRs) for the country according to whether the region meets Federal primary and secondary air quality standards. An AQCR or portion of an AQCR can be classified as attainment, nonattainment, maintenance, or unclassifiable with regard to whether the air quality standards for each of the criteria pollutants are being met or exceeded within the area. Attainment describes a condition in which one or more of the six pollutants meet the standards in 37

50 an area and is applicable only for those criteria pollutants meeting the NAAQS. Nonattainment describes a condition in which one or more of the six pollutants do not meet the standards in an area. Unclassifiable indicates that air quality in the area cannot be classified and the area is treated as attainment for regulatory purposes. An area can have all three classifications depending on the specific criteria pollutant. Areas designated as maintenance were formerly nonattainment areas but are currently attaining the NAAQS. The CAA requires Federal actions to conform to any applicable SIP, and the USEPA has promulgated regulations implementing this requirement. States develop SIPs to achieve the NAAQS in nonattainment areas or to maintain attainment of the NAAQS in maintenance areas. Figures illustrating current nonattainment and maintenance areas for O 3, SO 2, PM 10, PM 2.5, and Pb are presented in Appendix E. Currently, no nonattainment areas are designated for nitrogen oxides (NO x ). These designations do not exist for CO General Conformity On November 30, 1993, the USEPA promulgated a set of regulations known as the General Conformity regulations (40 CFR 51 Subpart W) that include procedures and criteria for determining whether a proposed Federal action would conform to the applicable SIPs. The General Conformity Rule ensures that the actions taken by Federal agencies in nonattainment and maintenance areas do not interfere with a state s plans to attain and maintain national standards for air quality. Under the General Conformity Rule, Federal agencies must work with State, Tribal and local governments in a nonattainment or maintenance area to ensure that Federal actions conform to the air quality plans established in the applicable State or Tribal implementation plan. Only actions that cause emissions in designated nonattainment and maintenance areas are subject to the regulations. The purpose of the General Conformity Rule is to ensure that Federal activities do not cause or contribute to a new violation of NAAQS; ensure that actions do not cause additional or worsen existing violations of the NAAQS; and ensure that attainment of the NAAQS is not delayed. Therefore, Federal entities are required to find that the total direct or indirect emissions from the Federal action will conform to the purpose of the SIP or not otherwise interfere with the State s ability to attain and maintain the NAAQS. Before an USEPA Regional Administrator approves a Federal action, an applicability analysis must be conducted to see whether a conformity determination is required. According to the applicability analysis, the General Conformity regulations apply to all Federal actions except those that are: 38

51 Covered by transportation conformity Have emissions clearly at or below de minimis levels Classified as an exempt action in the rule Covered by a Presumed-to-Conform approved list The USEPA created de minimis emission levels for each criteria pollutant to limit the need to conduct conformity determinations for Federal projects with minimal emission increases. The attainment status of the project area determines the de minimis levels that are applicable for a project. When the total direct and indirect emissions from a proposed project are below the de minimis levels, the project would not be subject to a conformity determination. The CO, PM 10, PM 2.5, SO 2, and O 3 precursor (NO x and Volatile Organic Compounds [VOC]) emissions are subject to General Conformity requirements. The de minimis thresholds set for both nonattainment areas and maintenance areas in accordance with the requirements of 40 CFR (b)(1) and 40 CFR (b)(2), respectively, are presented in Table E-2 in Appendix E. The Conformity Regulations apply only to pollutants or their precursors that are emitted in designated nonattainment or maintenance areas. Federal actions that cause emissions only in areas not designated as nonattainment or maintenance, such as attainment or unclassified areas, are not required to evaluate conformity for the action even though the emissions may impact a nonattainment or maintenance area. The boundaries of the nonattainment and maintenance areas are generally defined in the designations. In most cases the boundaries are political boundaries such as county lines or area physical features. This PEA examines the potential effects of the air emissions for the No Action Alternative, the Proposed Action and the Alternative Action in relation to these de minimis thresholds and the attainment, maintenance or nonattainment areas Greenhouse Gas (GHG) In addition to NAAQS criteria pollutants, the impact of greenhouse gases (GHGs) is also considered during air quality evaluation. Global climate change is a transformation in the average weather of the Earth, which can be measured by changes in temperature, wind patterns, and precipitation. Scientific consensus has identified human-related emissions of GHGs above natural levels as a significant contributor to global climate change. GHGs effectively trap heat in the atmosphere and influence Earth s temperature. GHGs include water vapor, carbon dioxide (CO 2 ), methane (CH 4 ), nitrous oxide (N 2 O), ground-level O 3, and fluorinated gases such as chlorofluorocarbons 39

52 (CFCs) and hydrochlorofluorocarbons (HCFCs) (United States Global Change Research Program [USGCRP] 2009). As there is no specific significance threshold for GHG, this PEA examines the potential effects of the GHG emissions for the No Action Alternative, the Proposed Action, and the Alternative Action relative to USEPA s 2009 rule outlining mandatory reporting of GHGs from certain sources emitting 25,000 metric tons or more of CO 2 equivalents (CO 2 e) per year Air Quality - Affected Environment Mobile Sources Air Emissions This section describes the Affected Environment in terms of existing air emissions from the current Postal Service delivery fleet vehicles planned for replacement. This will establish a basis for evaluating the relative impacts on air quality and regulatory requirements of the three alternatives being considered. The air emission rates vary based on the type of vehicle as described in the following sections. The emissions evaluations have been performed using the USEPA MOtor Vehicle Emission Simulator (MOVES) model, a state-of-the-science emission modelling system that estimates emissions for mobile sources for criteria pollutants, GHGs, and air toxics. Aged Minivans Proposed for Replacement The aged minivans being replaced are model-years 2006 and Based on the USEPA s MOVES model (USEPA 2014), minivans are categorized as light commercial truck. The Postal Service has estimated the average miles traveled for each minivan to be 3,818 miles per year; therefore, the number of miles associated with the estimated 8,000 aged minivans on a nationwide basis is approximately 30,544,000 miles per year. The nationwide air emission rates associated with the model-year minivans are estimated as 3.04 tons per year (TPY) for VOC, 7.90 TPY for NO x, TPY for CO, 0.51 TPY for PM 2.5, 2.63 TPY for PM 10, and 0.13 TPY for SO The nationwide emissions of aged minivans (model-years 2006 and 2007) were calculated based on the total mileage per year and the emission factor from USEPA MOVES for light commercial truck fueled by gasoline. The emission factors were estimated based on an urban unrestricted road type in Westchester County, New York, and 25 mph of vehicle speed. To be conservative, Westchester County was selected as a representative county for vehicle emission factors since the greatest number of highest maintenance-cost LLVs are located in Westchester County, NY based on USPS data; in addition, the 40

53 Accident-Damaged & High-Maintenance Cost LLVs Proposed for Replacement Based on USEPA s MOVES model, the estimated 11,000 accident-damaged and highmaintenance cost LLVs are also categorized as light commercial truck, and the model years are The Postal Service has estimated the average miles traveled per each LLV vehicle to be 6,528 miles per year; therefore, the number of miles associated with the total number of the estimated 11,000 LLVs on a nationwide basis is estimated to be approximately 71,808,000 miles per year. The nationwide air emission rates associated with these 11,000 LLVs are estimated as TPY for VOC, TPY for NO x, TPY for CO, 4.68 TPY for PM 2.5, TPY for PM 10, and 0.26 TPY for SO 2. 4 Stationary Sources Typical stationary air pollution sources at Postal Service VMFs include boilers and appliances that burn natural gas or fuel oil for heating, emergency power generators, fire pump engines, vehicle or painting operations (paint spray booths), parts washers (cold solvent degreasing), fuel storage tanks, and gasoline dispensing. Current Postal Service vehicle maintenance operations minimally impact air quality; operations follow applicable regulatory requirements; and the Postal Service applies for and complies with applicable environmental permits where required. Therefore the air quality impacts from vehicle maintenance operations have not been evaluated in this PEA General Conformity Air quality conditions vary widely across the geographic area in which the Postal Service operates the vehicles planned for replacement. Figures 1 through Figure 5 in Appendix E present nationwide nonattainment designation maps for ozone (VOC and NO x ), SO 2, PM 10, PM 2.5, and Pb, respectively GHG The Postal Service generates GHG emissions from facility energy use, transportation fuel use, waste generation, employee commuting, contracted transportation services, New York area (where Westchester County is located) is a moderate ozone nonattainment area. The average emission factors from 2006 and 2007 were used. 4 The nationwide emissions of accident-damaged and high-maintenance cost LLV (model-years ) were calculated based on the total mileage per year and the emission factor from USEPA MOVES for a light commercial truck fueled by gasoline. The emission factors were estimated based on an urban unrestricted road type in Westchester County, NY, and 25 mph of vehicle speed. To be conservative, Westchester County was selected as a representative county for vehicle emission factors since the greatest number of high-maintenance cost LLVs are located in Westchester County, NY based on USPS data; in addition, the New York area (where Westchester County is located) is a moderate ozone nonattainment area. The emission factor for 1994 of model year was conservatively used to calculate the least negative emission rates. 41

54 and other sources. The Postal Service s target is to reduce GHG emissions by 30 percent by FY 2025 (USPS 2017b). Delivery fleet vehicles emit a variety of gases during their operations; some of which are GHGs, including CO 2, CH 4 (methane), and N 2 O (nitrous oxide). The nationwide total GHG emissions, or carbon dioxide equivalent (CO 2 e), currently generated by the Postal Service and calculated using FY 2012 data are estimated to be 12,060,000 metric tons (MT) CO 2 e, which is million MT Air Quality Environmental Consequences No Action Alternative Under the No Action Alternative, average mileage per delivery route would increase to meet the increased delivery demand that would occur regardless of the Proposed Action. This PEA conservatively assumes that this would be accomplished by extending existing routes in a manner that does not require a return trip by the carrier and that therefore the mileage increase would be one-half that of new routes under the Proposed Action, or approximately 24,867,850 miles. The increased nationwide emission rates for vehicles covering the extended routes are therefore estimated to be TPY for VOC, TPY for NO x, TPY for CO, 3.89 TPY for PM 2.5, 6.06 TPY for PM 10, and 0.10 TPY for SO 2. While the No Action Alternative would not be subject to the General Conformity Rule, a conservative applicability analysis (using the existing vehicles emissions data but the same General Conformity methodology as for the Proposed Action [see Table in Section ]) would show emissions of: 0.81 TPY for VOC, 1.58 TPY for NO x, 9.91 TPY for CO, TPY for PM 2.5, 0.14 TPY for PM 10, and TPY for SO 2, which is well below the most stringent de minimis threshold level. Nationwide GHG emissions under the No Action Alternative would increase by 14,270 metric TPY, which is well below the 25,000 metric tons reporting threshold. Therefore, the No Action Alternative would not have a significant effect on the environment with respect to GHG emissions Proposed Action This section describes the broad air quality issues associated with the Proposed Action as a whole. 42

55 Air Emissions Net Potential Impacts Resulting from Nationwide Action Vehicle emission rates vary based on the type of vehicle, as indicated previously; therefore, the potential impacts are presented by type of vehicle being replaced and new additional vehicles for new routes. Aged Minivans Proposed for Replacement (see Table E-3.a in Appendix E) Based on the USEPA s MOVES model (USEPA 2014), both the aged minivans and light-duty trucks or Class 2 trucks (that would replace the aged minivans) are categorized as the same vehicle type (i.e., light commercial truck ); therefore, the emission factors would stay the same if all other factors (i.e., model year, mileage, speed, temperature, altitude, fuel properties, etc.) are the same. It was assumed in this analysis that the only difference between minivans being replaced and the new vehicles would be the model (make and year), while all other factors were assumed to be the same. While the aged minivans are model-years , the new vehicles modelyears would be The miles associated with the estimated 8,000 new replacement vehicles on a nationwide basis would be the same as the replaced minivans, and total approximately 30,544,000 miles per year. Therefore, the new nationwide air emission rates associated with the new ( model year) vehicles are estimated as: 0.38 TPY for VOC, 1.08 TPY for NO x, TPY for CO, 0.39 TPY for PM 2.5, 2.49 TPY for PM 10, and 0.08 TPY for SO 2. 5 In contrast, the nationwide air emission rates associated with continuing to operate the aged minivans (i.e., the No Action Alternative) are estimated as: 3.04 TPY for VOC, 7.90 TPY for NO x, TPY for CO, 0.51 TPY for PM 2.5, 2.63 TPY for PM 10, and 0.13 TPY for SO 2 by replacing the aged minivans. Therefore, the net emissions would represent decreases of 2.66 TPY for VOC, 6.82 TPY for NO x, TPY for CO, 0.12 TPY for PM 2.5, 0.14 TPY for PM 10, and 0.04 TPY for SO 2, and the aged minivans replacement portion of the Proposed Action would have a beneficial effect on the current air quality. 5 The nationwide emissions of new replacement vehicles (model-years ) were calculated based on the total mileage per year and the emission factor from USEPA MOVES for a light commercial truck fueled by gasoline. The emission factors were estimated based on an urban unrestricted road type in Westchester County, New York, and 25 mph of vehicle speed. For the purpose of this analysis, based on current projections, it is expected that 7,250 vehicles would be replaced in FY 2018, and 750 vehicles would be replaced in FY The emissions were estimated based on the number of vehicles and the corresponding mileage for each model year. 43

56 Accident-Damaged & High-Maintenance Cost LLVs (see Table E-3.b in Appendix E) An estimated 11,000 accident-damaged and high-maintenance cost LLVs would be replaced by new light-duty trucks and Class 2 trucks over the next three years. Based on USEPA s MOVES model, both types of vehicles are categorized as the same vehicle type (i.e., light commercial truck); therefore, the emission factors would stay the same if the model year, mileage, speed, temperature, altitude, fuel properties, etc. are the same. It was assumed that the only difference between new vehicles and replaced vehicles would be the model (make and year), while all other factors are assumed to be the same. The new vehicles would be model-years , and replace the accident-damaged and high-maintenance cost LLVs, which are model-years The miles associated with the estimated 11,000 new replacement vehicles on a nationwide basis would be the same as the 11,000 replaced vehicles, and total approximately 71,808,000 miles per year. The nationwide air emission rates associated with the new model-year vehicles are estimated as 0.95 TPY for VOC, 3.03 TPY for NO x, TPY for CO, 0.91 TPY for PM 2.5, 5.85 TPY for PM 10, and 0.20 TPY for SO 2. 6 In contrast, the nationwide air emission rates associated with continuing to operate the accident-damaged and high-maintenance LLVs (i.e., the No Action Alternative) are estimated as: TPY for VOC, TPY for NO x, TPY for CO, 4.68 TPY for PM 2.5, TPY for PM 10, and 0.26 TPY for SO 2 by replacing the LLVs. Therefore, the net air emissions represent decreases of TPY for VOC, TPY for NO x, TPY for CO, 3.76 TPY for PM 2.5, 4.25 TPY for PM 10, and 0.07 TPY for SO 2 and the LLV replacements portion of the Proposed Action would have a beneficial effect on the current air quality. Route Growth Additional Vehicles (see Table E-3.c in Appendix E) Considering the Postal Service s combined delivery fleet of 203,853 total vehicles, the estimated number of new vehicles to be acquired due to route growth (approximately 7,000) is only 3.4 percent of the total on a nationwide basis. 6 The nationwide emissions of new COTS (model-year ) vehicles were calculated based on the total mileage per year and the emission factor from the USEPA MOVES model for a light commercial truck fueled by gasoline. The emission factors were estimated based on an urban unrestricted road type in Westchester County, NY, and 25 mph of vehicle speed. For the purpose of this assessment, it is projected that 3,667 vehicles would be replaced in each of the three years (FY 2017, 2018, and 2019). The emissions were estimated based on the number of vehicles and the corresponding mileage for each model year. 44

57 The average mileage for Postal Service city routes and rural routes from historical data 7 was used to estimate the future mileage for the additional estimated 7,000 Postal Service carrier vehicles associated with route growth. The Postal Service has estimated the additional transportation miles on a nationwide basis for FY to be approximately 49,735,700 miles per year for route growth (29,891,500 miles per year associated with 5,000 vehicles for city route growth, and 19,844,200 miles per year associated with 2,000 vehicles for rural route growth). The estimated nationwide air emission increases associated with the route growth vehicles would be 0.65 TPY for VOC, 2.02 TPY for NO x, TPY for CO, 0.63 TPY for PM 2.5, 4.05 TPY for PM 10, and 0.14 TPY for SO 2. 8 A corresponding number of additional mail carriers would be associated with the additional estimated 7,000 vehicles acquired for route growth. The additional workers would generate trip traffic going to and from work using POVs. Therefore, for the purpose of this programmatic analysis, an estimated maximum number of 7,000 employees would use POVs and accordingly 7,000 round-trips would be generated daily. Although the Postal Service encourages employee carpooling, and an estimated 5.1 percent of U.S.-employed persons use public transportation (U.S. Census Bureau 2017c), the analysis for this PEA has been based on all new employees using POVs, in order to be conservative. Assuming an average roundtrip commute of 24 miles each day, the estimated POV miles on a nationwide basis for FY would be approximately 52,584,000 miles per year. 9 7 Average mileage for a city route is 19.1 miles per day per vehicle and the average mileage for a rural route is 31.7 miles per day per vehicle. Based on 313 working days per year, the annual mileages were estimated. 8 The nationwide emissions of additional vehicles associated with route growth were calculated based on the total mileage per year and the emission factor from the MOVES model for light commercial vehicles. The emission factors were estimated based on an urban unrestricted road type in Westchester County, NY, and a rural unrestricted road type in Albany County, NY, and a 25 mph vehicle speed for both city and rural routes. To be conservative, Westchester District was selected as a representative county for vehicle emission factors since the District has a large number of routes (over 1,250) and the New York area (where Westchester County is located) is a moderate ozone nonattainment area. Albany County was selected for the rural analysis because of proximity to Westchester County for regional consistency. For a city route, it is expected that up to an estimated 1,667 vehicles would be added in each of the three years (FYs ). For a rural route, it is expected that an estimated 340 vehicles, 1,025 vehicles, and 635 vehicles would be added in FY 2017, 2018, and 2019, respectively. The emissions were estimated based on the number of vehicles and the corresponding mileage for each model year. 9 Based on 24 miles per day, 7,000 vehicles, and 313 working delivery days per year (Sundays not included), the annual mileages were estimated separately for city and rural routes. 45

58 The estimated nationwide air emission increases associated with the new POV miles would be 3.02 TPY for VOC, 8.44 TPY for NO x, TPY for CO, 1.05 TPY for PM 2.5, 2.73 TPY for PM 10, and 0.12 TPY for SO Considering both the additional route-growth Postal Service vehicles and the associated POVs, the additional emissions associated with the route-growth portion of the Proposed Action if all 7,000 vehicles are purchased would be 3.67 TPY for VOC, TPY for NO x, TPY for CO, 1.68 TPY for PM 2.5, 6.78 TPY for PM 10, and 0.26 TPY for SO 2, which would cause a negligible adverse effect on current air quality nationwide. Net Changes in Air Emissions As summarized below in Table 4-6.1, the total air emission changes from the Proposed Action if all 26,000 new vehicles are purchased are a decrease of TPY for VOC, TPY for NO x, TPY for CO, and 2.21 TPY for PM 2.5, and an increase of 2.38 TPY for PM 10, and 0.14 TPY for SO 2. For VOC, NO x, CO, and PM 2.5, the Proposed Action would decrease emissions and have a net beneficial impact nationwide. For PM 10 and SO 2, small emission increases were estimated on a nationwide basis and would have a negligible impact on air quality nationwide. 10 The nationwide emissions of POVs associated with the new employees were calculated based on the total mileage per year and the emission factor from the MOVES model for passenger cars. The emission factors were estimated based on an urban restricted road type in Westchester County, NY and a rural restricted road type in Albany County, NY, and 40 mph of vehicle speed for both city and rural routes. Westchester County was selected as a representative county for vehicle emission factors since the District has a large number of routes (over 1,250) and the state of New York is a moderate ozone nonattainment area. Albany County was selected for the rural analysis because of the proximity to Westchester County for regional consistency. 46

59 Table Net Air Emission Changes from Nationwide Action (Tons per Year) Air Emissions (TPY) Replacing Aged Minivans Replacing accidentdamaged & highmaintenance cost LLVs Route Growth: New Vehicles Route Growth: POV Transportation Net (Total) VOC NO x CO PM 2.5 PM 10 SO 2 CO 2 e , , , , ,137tons See Table E-5.a, Table E-5.b, Table E-5.c, and Table E-5.d in Appendix E TPY = Tons per Year MT = Metric Tons = 20,083 MT Considering the Postal Service s combined delivery fleet of 203,853 total vehicles, the number of additional estimated vehicles that would be acquired due to route growth (7,000) is only 3.4 percent of the total delivery fleet on a nationwide basis. The air emission reductions associated with the replacement of vehicles offset the air emission increases associated with the route growth (Postal Service vehicles and POVs). Therefore, the Postal Service anticipates that the Proposed Action would have a beneficial effect on current air quality. General Conformity The Proposed Action would cause emissions in more than one nonattainment or maintenance area throughout the United States. These actions are national in scope and would affect all of the areas. Currently, no specific information associated with the future route growth (and POVs) is available regarding how many vehicles would be added to each nonattainment or maintenance area over the next three years (FY ). However, based on the trend of city route growth over the last three years (FY ), 11 the assumption is 11 Based on USPS s city route changes (FY ) data for each Postal Service District, the total increased number of vehicles for city routes for last three years (FY ) is 6,838, which is similar to the proposed number of additional estimated vehicles (7,000) due to route growth for next three years 47

60 that the same trend of growth would continue for both quantity and location over the next three years (FY ). Based on historical route growth data per Postal Service District ( area ), 12 the largest growth of new routes (192) occurred in the Suncoast District of Florida (generally centered around Tampa), which is an attainment area for all criteria pollutants except SO 2. The second largest growth of new routes (185) occurred in the Houston District in Texas (generally centered around Houston, but includes many other nearby cities including Baytown, Beaumont, Deer Park, Huntsville, La Porte, Lake Jackson, League City, Orange, Pasadena, and Pearland), which is a moderate ozone nonattainment area. The third-largest growth of new routes (179) occurred in the Bay Valley District in California (generally centered around San Jose, but includes many other nearby cities including Berkeley, Oakland, Concord, San Leandro, Fremont, Martinez, Richmond, Livermore, San Ramon, Danville, and Hayward), which is a marginal ozone nonattainment area. The fourth largest growth of new routes (148) occurred in the Capital District (in Washington D.C. and Maryland), which is a marginal ozone nonattainment area. The fifth largest growth of new routes (140) occurred in the Rio Grande District in Texas (generally centered around San Antonio, but includes many other nearby cities including El Paso, Austin, Corpus Christi, Laredo, Midland, San Marcos, Harlingen, and Midland), which is an attainment area. Reductions in the number of routes occurred in several areas. Since the District area defined in the city route growth data is greater in area than the designated nonattainment area in most cases, using the District area should represent a more conservative vehicle growth number than the nonattainment area boundary. General conformity analysis was performed based on the worst-case assumption using the maximum number of vehicle growth from any Postal Service District (area)-level and the worst-case nonattainment area de minimis threshold. If the worst-case emission increase for the worst-case area were below the general conformity s most stringent de minimis threshold for all applicable criteria pollutants, all other areas located in any other nonattainment or maintenance area should comply with the de minimis level and should not trigger a general conformity analysis. This worst-case general conformity analysis at a District-level is presented below. It was assumed that the maximum number of gained/increased routes in any District (e.g., 192 additional delivery vehicles and 192 POVs associated with route growth in the Suncoast District) would be placed in the worst-case nonattainment area (i.e., extreme (FY ). Therefore, it was assumed that the trend of growth for both quantity and location over the next three years would be similar to the last three years. 12 City route changes (FY ) data indicate the number of increased vehicles for the last three years for each Postal Service District. It was assumed that a Postal Service District is comparable to an area for general conformity applicability analysis. 48

61 ozone nonattainment area). Therefore, the analysis was conservatively performed by comparing the emissions estimated based on the maximum number of gaining vehicles with the most stringent de minimis threshold (10 TPY of VOC and NO x, 100 TPY of CO and SO 2, 100 TPY of PM 2.5 and 70 TPY of PM 10 ). 13 The analysis conservatively did not take into account the emission reductions from the vehicle replacements (i.e., aged minivans, and accident-damaged and high-maintenance cost LLVs), but considered emission increases only from additional vehicles. Based on the maximum number of gained routes (maximum 192 additional vehicles and 192 additional POVs per facility 14 ) in an area, the estimated air emission rates are 0.1 TPY of VOC, 0.3 TPY of NO x, 4.25 TPY of CO, TPY of PM 2.5, 0.17 TPY of PM 10, and TPY of SO 2, per area. These emissions are significantly below the most stringent de minimis threshold levels for all pollutants in the worst-case nonattainment area (i.e., extreme ozone nonattainment area). Therefore, by rule (40 CFR (b)), the project is considered de minimis and would have no negative effects on the applicable SIP. Thus, the General Conformity rule does not apply to the Proposed Action. The emissions associated with the project estimated as part of the General Conformity Review, and the relevant worst-case de minimis levels, are summarized in Table Table Applicability Analysis for General Conformity for Worst-Case Area Source Additional Delivery Vehicle associated with Route Growth Additional POV associated with new employees Emissions (Tons) VOC NO x CO PM 2.5 PM 10 SO 2 CO 2e Total Worst-Case De Minimis level n/a Will Emissions Exceed De Minimis Threshold? No No No No No No n/a Greenhouse Gas (GHG) Potential nationwide GHG emission changes, and area-wide GHG emission increases were calculated as shown in the Tables and 4-6.2, respectively. The estimated nationwide GHG increase from the Proposed Action assuming all 26,000 new vehicles 13 The worst-case threshold was selected based on extreme nonattainment area for Ozone (VOC and NO x ), all nonattainment area for CO and SO 2, serious nonattainment area for PM 10, and direct emissions for nonattainment area for PM This PEA conservatively assumes that POVs would constitute indirect emissions under the General Conformity Rule s regulations. 49

62 are purchased is 20,083 metric tons CO 2 e annually, approximately 0.17 percent 15 of the total GHG generated by the Postal Service in FY 2012 (USPS 2013), which is well below the 25,000 metric tons reporting threshold and therefore indicates that the Proposed Action would not have a significant effect on the environment with respect to GHG emissions Alternative Action The Alternative Action studied by the Postal Service is to lease the vehicles instead of outright purchase, which would be of the same quantity and type and use the same routes. The Alternative Action is therefore identical to the Proposed Action in terms of potential air quality impacts and would have no significant impact on air quality. 4-7 Community Services Community Services - Background Information and Affected Environment Local municipalities or county governments provide emergency fire and police services to Postal Service facilities. The Postal Service also has its own police force and Postal Inspection Service for crime deterrence, protection, and investigation of crimes. Firstaid kits are present in all processing facilities to treat minor cuts and bruises; employees are instructed to call local emergency and medical service providers for fire and healthrelated emergencies. Community service providers are equipped to handle current Postal operations, and these operations do not result in adverse effects to community services or emergency preparedness of local municipalities, county governments, or the nation. The Postal Service in turn provides a community service by delivering and collecting mail to and from residential and business addresses. The Postal Service follows certain service standards related to mail delivery. Currently, these include the following delivery times by type of mail: Priority Mail: 1-3 days First-Class Mail: 1-3 days Periodicals: 1-9 days Package Services: 2-8 days Standard Mail: 3-10 days 15 The total CO 2 e based on FY 2012 was estimated to be 12,060,000 MT CO 2 e (USPS 2013). 50

63 The Postal Service maintains its fleet of delivery vehicles in order to meet these delivery standards Community Services - Environmental Consequences No Action Alternative Under the No Action Alternative, the Postal Service would not acquire or lease an estimated 26,000 new vehicles. Use of the existing delivery fleet could lead to additional vehicle breakdowns, thereby requiring additional emergency services. The adverse impacts to these services would be insignificant on a local or national level. Continuing to deliver and collect mail with the existing fleet of vehicles, would result in extended routes and overtime and longer hours for the existing delivery staff in order to maintain service standards. The aged and high-maintenance cost vehicles would tend to require additional maintenance with time; these additional requirements would increase stress on the delivery staff and equipment and on staff maintaining the fleet and make meeting the service standards more difficult Proposed Action The estimated 19,000 new replacement vehicles would traverse the same routes as the replaced vehicles; however, the new replacement vehicles are expected to have fewer breakdowns, resulting in fewer emergency response needs and therefore beneficial impacts on community services. The estimated 7,000 new vehicles would be placed on new routes spread across the delivery network nationwide so that no area would experience significant additions or impacts. The greatest addition of 84 vehicles and routes added over the three-year period in Houston, Texas, with its population of over 2,300,000 inhabitants spread over some 667 square miles, would not significantly impact medical or emergency community services. Local municipalities or county governments nationwide would continue to provide emergency police and fire services for the delivery fleet included in the Proposed Action, with insignificant adverse impacts Alternative Action The Alternative Action of leasing the estimated 26,000 new vehicles would have the same insignificant impacts as the Proposed Action. Demands on community services by the new additional vehicles would be the same as with the Proposed Action and effects on the delivery staff would be identical. 51

64 4-8 Utilities and Infrastructure Utilities and Infrastructure - Background Information and Affected Environment Postal Service Delivery Operations are supported by established utility and infrastructure systems that provide power, communications, water, wastewater, stormwater, and transportation services sufficient for the facilities needs. Private companies normally provide power and communication services, while municipalities usually own and maintain water, wastewater and transportation systems; privately owned well systems could provide a limited number of facilities with water. Postal Service facilities are generally located within large utility networks and use a relatively small portion of the systems total capacity. The Postal Service has actively pursued conservation opportunities for many years and has been able to reduce consumption of resources and the effect of postal operations on utility and infrastructure systems. These accomplishments provide opportunities and capacity for future incremental changes without significantly impacting existing systems Utilities and Infrastructure - Environmental Consequences No Action Alternative Existing impacts to utilities and infrastructure resulting from Postal Service delivery operations are insignificant. As a result of not acquiring the estimated 19,000 new replacement vehicles and 7,000 new additional vehicles under the No Action Alternative, the aged and high-maintenance cost delivery vehicles could experience more frequent breakdowns and increased repairs. This would place strains on VMFs and employees, and increase the use of utilities, including water and wastewater. Based on the negligible number of Postal Service delivery vehicles compared to the total of vehicles nationwide, the additional impacts would be negligible and therefore insignificant. Existing VMFs and commercial repair shops would be used, but with no new facility construction or expansion required, infrastructure is in place for the existing facilities and utilities would not be significantly impacted. No impacts to public transportation would occur Proposed Action The Proposed Action of acquiring the estimated 19,000 new replacement vehicles and 7,000 new additional vehicles would not result in additional or expansion or disposal of facilities that service the delivery fleet. Therefore, existing impacts to utilities and infrastructure resulting from delivery operations would continue to be insignificant, and no additional adverse or beneficial impacts to utilities or infrastructure would occur. 52

65 Water and wastewater use would increase insignificantly for the VMFs servicing the new additional vehicles. However, the number of additional vehicles in any one ZIP code would be negligible and the required additional water and wastewater use insignificant. The largest influx of new vehicles in Houston, Texas (84 vehicles over the three-year period) would be insignificant in a city of over 2,300,000 inhabitants and covering 667 square miles in area. Impacts to public transportation could be beneficial at facilities that increase employee complement to the extent that more employees use the system and there is a corresponding increase in revenue Alternative Action The Alternative Action of leasing the estimated 19,000 new replacement vehicles and 7,000 new additional vehicles would have the same insignificant impacts on utilities and infrastructure as the Proposed Action. The replacement vehicles would require less maintenance, requiring less water and wastewater; and the new additional vehicles would be added over a large area and therefore result in insignificant impacts on the national and even on a local level. 4-9 Energy Requirements and Conservation Energy Requirements and Conservation - Background Information and Affected Environment Federal agencies are required to meet a number of energy management and conservation goals through several Executive Orders and legislative measures. Postal Service facility operations incorporate energy conservation measures that comply with the Energy Independence and Security Act (EISA) of 2007, the National Energy Conservation Policy Act, the Energy Policy Act (EPAct) of Furthermore, the Postal Service seeks to fulfill the spirit of the non-mandatory Executive Order 13693, Planning for Federal Sustainability in the Next Decade. Operation of the Postal Service delivery fleet requires fuel for powering the fleet of 203,853 vehicles that move the mail throughout the year, as summarized on Table

66 Table Annual Bulk and Commercial Fuel for Delivery Fleet Vehicles (FY 2016) Type of Vehicle Bulk Fuel Commercial Fuel Total Two-ton trucks 1,178,528 4,244,372 5,422,900 Cargo Vans 3,525,063 2,962,387 6,487,450 FFVs 477,683 16,428,045 16,905,728 Delivery Vans 112,970 1,291,394 1,404,364 LLVs 1,609, ,721, ,330,404 Minivans 523,876 9,574,399 10,098,275 Total 7,427, ,221, ,649,120 Postal Service Sustainability Goals for fuels include reducing Postal-vehicle petroleum fuel use 20 percent by FY 2015; increasing Postal-vehicle alternative fuel use 10 percent annually by FY 2015; and reducing contract vehicle petroleum fuel use 30 percent by FY 2025 (Postal Service 2017b). The Postal Service has analyzed fuel consumption for each type of delivery vehicle in its current fleet, including vehicles in the light-duty truck and Class 2 truck category (e.g., LLVs, minivans and delivery vans). Based on FY 2016 Postal Service vehicle fuel consumption data, the estimated mileage rate by the current LLVs and minivans is 8.7 mpg. Postal Service acquired approximately million gallons of fuel for its 141,380 LLVs and estimated 23,000 minivans in FY Based on the same FY 2016 vehicle fuel consumption data, the estimated fuel usage rate by the current delivery vans in the delivery fleet is 6.7 mpg, and the Postal Service acquired approximately 1.4 million gallons of fuel for those vehicles. Assuming an average of 8.7 mpg for each of the 8,000 minivans and 11,000 LLVs being replaced, the Postal Service acquired 11,764,598 gallons for these vehicles in FY For the purpose of this analysis, the Postal Service fuel consumption rate of 6.7 mpg for the current delivery vans is used to conservatively estimate fuel consumption for the new vehicles purchased under the Proposed Action, rather than the LLV and minivan fuel consumption rate of 8.7 mpg. It should be noted that this 6.7 mpg rate was observed after the vehicles were used over a short period of time when the vehicles were new and could be expected to increase after some initial break-in period Energy Requirements and Conservation - Environmental Consequences No Action Alternative The 19,000 aged and high-maintenance cost vehicles would remain in the Postal Service s delivery fleet under the No Action Alternative. With no new vehicle replacements, the aged and high maintenance vehicles would likely experience some 54

67 decline in mpg with time such that additional fuel would be required to maintain the same fleet of vehicles. Although no new vehicles or routes would be added, the existing routes would have to be expanded and the existing fleet would have to cover the expanded routes. As discussed in Section , for purposes of this analysis it has been estimated that some 24,867,850 miles would be added to the existing routes, based on the assumption that the expanded routes would be lengthened to address the additional points and would not have to return to the starting point, thereby adding approximately one half the mileage of the projected new routes. Using the assumed mileage rate for LLVs and minivans of 8.7 mpg, approximately 2,858,374 additional gallons of fuel would be purchased to fuel the vehicles over the expanded routes; this fuel would be purchased from either bulk suppliers and stored in existing regulated tanks at postal facilities, or from commercial retailers. In 2016, about billion gallons (or about 3.41 billion barrels) of finished motor gasoline were consumed in the United States (United States Energy Information Administration 2017). The United States has ample available fuel, and the additional 2 percent increase in fuel purchased for Postal Service delivery fleet vehicles would not significantly impact the fuel supplies and energy resources, as it represents less than percent of the total gasoline used for motor vehicles in Proposed Action The Postal Service s recent experience with its delivery van model (Class 2 truck) weighing 8,900 pounds (approximately three to four thousand pounds heavier than the existing minivans and LLVs) has indicated a fuel economy of 6.7 mpg. By replacing the existing minivans and LLVs with a Class 2 truck similar to the current delivery vans, fuel economy could decrease 23 percent from the 8.7 mpg currently consumed for the existing vehicles, which would make the goal of achieving a 30 percent overall fleet reduction by year 2025 more difficult. The mileage is affected by the heavier weight of the newer vehicles and by the use of technologies lacking in the existing fleet, such as air conditioning. The Postal Service anticipates that the average mpg for the light-duty trucks might improve with time. For example, one manufacturer website lists a 2017 delivery van model with USEPA mileage estimated at 15 mpg city and 22 mpg highway, so it is possible the new vehicles would achieve a higher mpg than the current, aging fleet. However, for this PEA, the Postal Service conservatively assumes that the mileage rate for the new replacement vehicles would be less than that of the replaced vehicles. The new replacement vehicles would therefore require an estimated 14.7 million gallons of fuel, an increase of 3.39 million gallons, or 30 percent. The estimated 7,000 new vehicles that would be added to the delivery fleet would utilize additional fuel over and above the current fleet usage. Assuming the additional vehicles travel 49,735,700 miles over the three-year period and assuming the vehicles achieve 55

68 worse-case 6.7 mpg, the fleet would need to acquire approximately 7.42 million gallons of additional fuel for the new routes. The additional estimated million gallons of fuel required annually for the new replacement vehicles and new additional vehicles would represent an approximate 7 percent increase compared to the Postal Service s total FY 2016 delivery fleet fuel purchase of million gallons. A 7 percent increase would have a moderately adverse impact on the Postal Service s fuel consumption rates, after taking into account the 3 percent projected increase in delivery routes and the deteriorating condition of the existing vehicles. The effect of the additional energy resources on the environment would be insignificant, as it represents percent of the total gasoline used for motor vehicles in 2016 (United States Energy Information Administration 2017). Manufacturer websites also advertise less frequent oil changes, which would be an improvement for the new vehicles, and would achieve some reduction in new oil quantities required for the replaced vehicles. No new facilities or expansions are required to maintain the new vehicles; therefore, no adverse impacts on existing Postal Service facility energy reduction efforts are expected Alternative Action Impacts on energy usage and conservation would be similar to that expected under the Proposed Action because the leased vehicles would be of the same quantity and type and travel the same routes Solid and Hazardous Materials and Wastes Solid and Hazardous Materials and Wastes - Background Information and Regulatory Setting Solid wastes relevant to Postal Service delivery vehicle maintenance and delivery operations include discarded materials that are abandoned (disposed of, burned or incinerated), recycled, or considered inherently waste-like. The Postal Service generates limited quantities of hazardous wastes, which are solid wastes that are specifically listed as hazardous or exhibit the characteristics of hazardous waste as defined by the Resource Conservation and Recovery Act (RCRA) Solid and Hazardous Materials and Waste - Affected Environment The Postal Service has long-standing commitments and established programs to minimize the amount and type of materials needed to support its service obligation and operations. Included are established programs to encourage the purchase of 56

69 environmentally preferable products and services, to reduce the amount of solid waste generated, and to divert as much material as possible through recycling and waste to energy initiatives. The Postal Service has national contracts with vendors for collection, and refinement, or recycling of materials such as used tires, used oil, oil filters and antifreeze from Postal Service VMFs. Metal is recycled with local scrap metal operators when feasible. The Postal Service has a corporate sustainability goal to divert at least 50 percent of landfill waste to recycling. The Postal Service follows environmentally responsible practices that help recycle materials that would otherwise be disposed as regulated or hazardous waste. For example, in FY 2016 through a program with a national hazardous waste disposal supplier, the Postal Service sent over 380,000 gallons of used motor oil for recycling/re-refining; over 464,000 gallons of oily waste for oil recovery/recycling; over 42,000 gallons of antifreeze (glycol) for recycling; over 8,000 gallons of parts washer solvent for recycling/reuse; over 256,000 pounds of used oil filters for reclamation; over 18,000 pounds of used batteries for reclamation; and over 114,000 pounds of universal waste mercury bulbs for reclamation. In addition, in FY 2016 over 566,000 short tons of solid waste were generated, of which over 255,000 short tons were recycled, over 280,000 short tons were sent to landfills, and over 30,000 short tons were incinerated in waste to energy facilities (USPS 2017b). The Postal Service has established policies and procedures for controlling the purchase and use of hazardous materials; and management and disposal or recycling of hazardous wastes in accordance with regulatory requirements. The Postal Service encourages minimization of the purchase and storage of such materials and encourages non-hazardous or green product use Solid and Hazardous Materials and Waste - Environmental Consequences No Action Alternative The types and volumes of wastes currently generated by the existing delivery fleet would tend to increase slightly as the same vehicles would have expanded routes requiring more ongoing maintenance, such as oil changes and tires, and more overhaul maintenance due to vehicle failure. Based on an assumed mileage of 24,867,850 estimated for the expanded routes, the waste volumes would increase less than 2 percent. The No Action Alternative would therefore not result in significant impacts associated with solid and hazardous materials and waste. 57

70 Proposed Action Under the Proposed Action the Postal Service would initially generate an increased amount of solid and hazardous waste, as some of the vehicles would be scrapped. Parts, materials, and liquids would be reused and recycled to the extent possible. As the estimated 19,000 new replacement vehicles are deployed, they would create approximately the same waste quantities and types as the vehicles that are being replaced, although vehicle manufacturer websites advertise less frequent oil changes as an improvement for the new light-duty and Class 2 trucks, which would achieve some reduction in new oil quantities required for the replaced vehicles. Additional waste would be generated from the estimated 7,000 new vehicles being operated and maintained over a three-year period. Based on the total delivery fleet of 203,853 currently in the system an addition of an estimated 7,000 new vehicles would be only a 3.4 percent increase in vehicles, which would result in a corresponding 3.4 percent increase in wastes, which is insignificant. The waste types would not differ substantially from the wastes generated currently Alternative Action The wastes generated under the Alternative Action of leasing the same number of vehicles would be the same as under the Proposed Action Summary of Potential Environmental Impacts Table presents a summary of potential environmental impacts that could result from implementation of the No Action Alternative, Proposed Action, and Alternative Action. 58

71 Table Potential Environmental Impacts Summary Matrix Environmental Resource Area Key: Impact symbols: B = beneficial effect; N = no effect or negligible effect; M = moderately adverse effect; and S = significant effect Duration symbols: P = permanent effect; T = temporary effect; and N/A = not applicable Mitigation symbols: Y = can be mitigated; N = cannot be mitigated; NR = not required; and N/A = not applicable No Action Alternative Proposed Action Alternative Action Impacts Duration Mitigation Impacts Duration Mitigation Impacts Duration Mitigation Physical Environment A. Topography N N/A N/A N N/A N/A N N/A N/A B. Geology and soils 1. Characteristics N N/A N/A N N/A N/A N N/A N/A 2. Toxic and hazardous potential N N/A N/A N N/A N/A N N/A N/A C. Hydrology and Water Quality 1. Local groundwater N N/A N/A N N/A N/A N N/A N/A 2. Lakes and streams N N/A N/A N N/A N/A N N/A N/A 3. Floodplains N N/A N/A N N/A N/A N N/A N/A 4. Wetlands N N/A N/A N N/A N/A N N/A N/A 5. Wild and scenic rivers N N/A N/A N N/A N/A N N/A N/A 6. Site surface drainage N N/A N/A N N/A N/A N N/A N/A D. Prime farmland N N/A N/A N N/A N/A N N/A N/A E. Fish and wildlife 1. Alteration of vegetation N N/A N/A N N/A N/A N N/A N/A 2. Rare or endangered species N N/A N/A N N/A N/A N N/A N/A F. Botanical 1. Alteration of vegetation N N/A N/A N N/A N/A N N/A N/A 2. Rare or endangered species N N/A N/A N N/A N/A N N/A N/A Cultural Environment G. Historical and archaeological resources 1. Archaeological resources N N/A N/A N N/A N/A N N/A N/A 2. Historic resources N N/A N/A N N/A N/A N N/A N/A 59

72 Table Potential Environmental Impacts Summary Matrix Environmental Resource Area H. Socioeconomics Key: Impact symbols: B = beneficial effect; N = no effect or negligible effect; M = moderately adverse effect; and S = significant effect Duration symbols: P = permanent effect; T = temporary effect; and N/A = not applicable Mitigation symbols: Y = can be mitigated; N = cannot be mitigated; NR = not required; and N/A = not applicable No Action Alternative Proposed Action Alternative Action Impacts Duration Mitigation Impacts Duration Mitigation Impacts Duration Mitigation 1. Employment N N/A NR B P NR B P N/A 2. Economic considerations to Postal Service M P NR B P NR M NR N/A 3. Local and nationwide economic considerations N N/A N/R N P NR N N/R NR 4. Environmental justice N N/A N/A N N/A N/A N N/A N/A I. Land use and planning 1. Compatibility N N/A N/A N N/A N/A N N/A N/A 2. Aesthetic considerations N N/A N/A N N/A N/A N N/A N/A 3. Residential development N N/A N/A N N/A N/A N N/A N/A 4. Industrial potential N N/A N/A N N/A N/A N N/A N/A 5. Environmental conditions of existing buildings at site N N/A N/A N N/A N/A N N/A N/A J. Transportation 1. Traffic and circulation N P NR N P NR N P NR 2. Safety N to M P NR B P NR B P NR 3. Accessibility and parking N N/A N/A N N/A N/A N N/A N/A 4. Public transportation N P NR N P NR N P NR K. Noise 1. Traffic N P NR N P NR N P NR 2. Exterior postal operations N P NR N P NR N P NR 3. Interior postal operations N P NR N P NR N P NR 60

73 Table Potential Environmental Impacts Summary Matrix Environmental Resource Area Key: Impact symbols: B = beneficial effect; N = no effect or negligible effect; M = moderately adverse effect; and S = significant effect Duration symbols: P = permanent effect; T = temporary effect; and N/A = not applicable Mitigation symbols: Y = can be mitigated; N = cannot be mitigated; NR = not required; and N/A = not applicable No Action Alternative Proposed Action Alternative Action Impacts Duration Mitigation Impacts Duration Mitigation Impacts Duration Mitigation L. Air quality 1. Indoor air quality N N/A NR N P NR N P NR 2. Air quality / emissions N N/A NR B P NR B P NR M. Community Services 1. Medical N P N/A N N/A N/A N N/A N/A 2. Fire and Police Protection N P N/A N N/A N/A N N/A N/A N. Utilities and Infrastructure 1. Availability N P N/A N N/A N/A N N/A N/A 2. Location N P N/A N N/A N/A N N/A N/A 3. Capabilities N N/A NR N N/A NR N N/A NR O. Energy requirements and conservation N P NR M P NR M P NR P. Solid and hazardous materials and waste generation N P NR N P NR N P NR 1. Solid and hazardous materials N P NR N P NR N P NR 2. Waste generation N P NR N P NR N P NR 3. Recycling N P NR N P NR N P NR 61

74 United S Environmental Compliance a This page intentionally left blank. 62

75 5-1 Introduction 5 CUMULATIVE IMPACTS Cumulative impacts are the impacts on the environment that result from the incremental impact of an action when added to other past, present, and reasonably foreseeable future actions. Cumulative Impacts result when the effects of an action are added to or interact with other effects in a particular place and within a particular time frame. The cumulative impacts of an action can be viewed as the total effects (magnitude, extent, or duration) on a resource, ecosystem, or human community of that action and all other activities affecting that resource, no matter what entity (Federal, non-federal, or private) is taking the actions. A discussion of cumulative impacts resulting from projects that are proposed, recently completed, or anticipated to be implemented in the near future is presented below. The analysis of cumulative impacts requires specific knowledge of other actions occurring or proposed to occur within or near the geographic study area. Given the nationwide scope of the Proposed Action, identifying the actions of others would be very difficult. Therefore, this cumulative impact analysis focuses on the impacts of the Proposed Action when combined with other completed or planned broad, nationwide Postal Service actions involving acquisition of new vehicles to replace aged and high maintenance vehicles. 5-2 Geographic Extent and Time Frame The acquisition of an estimated 26,000 vehicles is nationwide in its scope, with vehicles to be added to various ZIP codes in accordance with the age and/or high-maintenance cost of delivery vehicles assigned to that code and to serve anticipated future new routes. Therefore, the geographic extent of this cumulative impact analysis is also national in scope. The PEA also discusses potential impacts of the Proposed Action on some resources on a more local basis based on local conditions such as air quality attainment areas. The cumulative impact analyses take these into consideration recognizing, however, that there may not be any geographic overlap for the individual actions. The temporal scope of this analysis includes past actions taken or ongoing and planned future actions related to upgrading the delivery fleet vehicles, but not part of the Proposed Action s estimated 26,000 vehicles. These actions started in 2015 and will continue through 2019, as described in Section

76 This analysis does not include any future procurement decision regarding the replacement of the wider Postal Service delivery fleet, as that action will receive its own NEPA analysis. 5-3 Past, Present, and Reasonably Foreseeable Projects and Actions Considered The Postal Service s multi-year vehicle plan includes other, routine vehicle acquisitions that are either planned or underway to replace high maintenance vehicles, provide continuity of service, and meet changes in mail volume and makeup. The purchase of delivery vans in 2015 and 2016 replaced 12,472 minivans that were over their planned 10-year life expectancy. Additionally, the procurement of 7,198 Mixed Delivery and Collection One-Ton vehicles began in 2015 and is scheduled to run through 2017 to replace all existing One- and Two-Ton vehicles. Future plans to replace aged and high-maintenance cost vehicles include the acquisition of 2,141 Cargo vans to replace currently Postal Service-owned Cargo vans. These vans will be acquired in 2017 and Additionally, some 376 Postal Serviceowned Spotters will be replaced in 2018 and These Cargo vans and Spotters serve a unique purpose in the delivery fleet such that it is essential that these vehicles be in good working condition to minimize time spent in maintenance. The Cargo vans are used to transport large volumes of mail from mailers plants and Postal Service processing facilities to post offices and airports around the country. Spotters are used to move trailers to and from docks and to stage trailers for loading and unloading between Postal Service facilities. Spotters remain within the P&DC complex and do not travel on highways while the Cargo vans primary route of travel is on highways throughout the United States. Replacement decisions for the Cargo vans and Spotters are primarily based on the following five factors: 1) Age and Mileage 2) High Cost of Maintenance and Costs of Operation 3) Obsolescence 4) Changes in Operational Requirements 5) Environmental Requirements Of the 2,517 Cargo vans and Spotters identified for replacement, each has met or exceeded one or more of the established criteria for replacement. The maintenance 64

77 cost for the vans is averaging $16,016 annually and the cost of maintaining the Spotters is averaging $14,069 annually. The multi-year vehicle plan also projects the need for replacing 12,000 Postal-owned trailers over a 3-year period beginning 2017 through The trailers are used to transport large volumes of mail and equipment to and from P&DCs. The 3,600 proposed trailer acquisitions are to replace Postal-owned trailers that are between 19 and 48 years of age, far exceeding the expected life span of 12 years. Many are nonroad worthy and are being used for storage at the P&DCs. The remaining acquisitions are to replace leased trailers. 5-4 Discussion of Potential Cumulative Impacts Resources Not Studied in Detail Implementation of the Proposed Action would not have a cumulative impact on the environmental resources not studied in detail by this PEA, listed in Section 4-2 (topography, geology, soils, prime farmland; hydrology, water resources, floodplains, and wetlands; vegetation and wildlife; and coastal zone); therefore, there is no potential for cumulative impacts with respect to these resources Socioeconomics The Postal Service assessed the potential for cumulative socioeconomic impacts related to employment and economic considerations. Since the Proposed Action does not have the potential for a disproportionate adverse impact on environmental justice as discussed previously in this PEA, it would not result in cumulative impacts. The following discussion mirrors the discussion in Section 4-3 (Socioeconomics) of this PEA Employment The replacement of an estimated 19,000 vehicles under the Proposed Action would have neither a beneficial nor adverse impact on employment, as the existing workforce would continue to operate those vehicles. However, the addition of approximately 7,000 new positions to the carrier staff under the Proposed Action would be a beneficial benefit and the net impact to employment would be positive. The acquisition of replacement vehicles in 2015 and 2016 and planned in 2017 through 2019 should not affect employment as the existing workforce would continue to operate the replacement vehicles. 65

78 Economic Considerations The replacement of 12,472 minivans in 2015 and 2016 was a positive benefit to the economy overall and the communities where the vehicles were manufactured and sold. The replacement of 2,141 Cargo vans and 376 Spotters likewise will have a positive effect on the communities where the vehicles are manufactured and sold as will the 12,000 replacement trailers to be acquired between 2017 and The Proposed Action of acquiring an estimated 19,000 replacement vehicles and an estimated 7,000 new route vehicles would have a beneficial impact on the economy overall and the communities where the vehicles are manufactured and sold. The new jobs for the new routes would result in spending for goods and services and result in both direct and indirect economic benefits to the urban areas where the jobs would be created. The areas most affected are described in Section , Socioeconomics Transportation The acquisition of replacement vehicles in 2015 and 2016 and planned in 2017 through 2019 should not affect transportation, as the vehicles will be traversing the same or similar routes as the vehicles being replaced. The acquisition of Spotters would replace vehicles that are currently operating within the P&DC properties and are not travelling on highways, roads or streets. Therefore these vehicles would not impact traffic in any way. The acquisition of replacement vehicles under the Proposed Action would also have no effect on transportation as the vehicles would assume the same or similar routes as the vehicles being replaced. The Proposed Action would add approximately 7,000 new vehicles to new routes in City (5,000) and Rural (2,000) areas. The majority of the ZIP codes with newly added routes would have fewer than 3 new routes (1 vehicle and driver per route) added annually, which is an insignificant amount in comparison to the total population and vehicles for that area. For example, the city of Houston is projected to have the most new routes, but the total population of Houston and city size can accommodate the new routes and traffic without significant impacts Air Quality The replacement of an estimated 8,000 minivans with new light-duty trucks and Class 2 trucks and the replacement of an estimated 11,000 accident-damaged and highmaintenance cost vehicles with new light-duty trucks and Class 2 trucks under the Proposed Action have both been shown to have net negative air emissions. Therefore, these replacements have no adverse effect on air quality. Likewise, it can be assumed that the emissions associated with the replacement of the 2,141 Cargo vans in 2017 and 2018 with newer vehicles with lower emission rates would have net negative 66

79 emissions. The replacement of the trailers should have no emissions effects and the replacement of 376 Spotters with new vehicles should have equal or negative air emissions. In summary, the replacement vehicles from the Proposed Action and other replacement actions should have net negative emissions and therefore a beneficial impact on air quality. The addition of an estimated 7,000 new vehicles for new routes would result in increased emissions which have been calculated as 0.65 TPY for VOC, 2.02 TPY for NO x, TPY for CO, 0.63 TPY for PM 2.5, 4.05 TPY for PM 10, and 0.14 TPY for SO 2. Considering the entire Postal Service delivery fleet of 203,853 vehicles, the additional vehicles represent an increase of only 3.4 percent and the emission increase would be less than 3.4 percent of the total emissions from the delivery fleet. The combined effects of the decreased emissions from the replacement vehicles and the added emissions from the new route vehicles would have a negligible effect on air quality Noise Environment The noise generated from the replacement vehicles acquired in 2015 and 2016 and the replacement vehicles being acquired in 2017 through 2019, which are separate actions from the Proposed Action, should be equal to or possibly be less than the vehicles being replaced. The net effect would have an insignificant impact on the noise environment. Likewise, the noise effects from the replacement of an estimated 19,000 aged and highmaintenance cost vehicles with new light-duty trucks and Class 2 trucks under the Proposed Action should be equal or possibly less than the vehicles being replaced. This would have an insignificant impact on the noise environment. The estimated 7,000 new added vehicles under the Proposed Action would generate noise over and above the current levels. However, with worse-case scenario being the addition of 84 new vehicles in Houston over the three-year period in a city of 667 square miles with over 2,300,000 inhabitants, the added noise from these vehicles would be insignificant. In general, considering the new replacement vehicles with more advanced noise controls and the new added vehicles, the estimated 26,000 vehicles would contribute negligible adverse impacts to the noise environment. The noise effects from the Proposed Action and the other acquisition actions should also have negligible adverse impact on the noise environment Community Services The Proposed Action would include an estimated 19,000 new replacement vehicles and the actions involving vehicle acquisitions in 2015 and 2016 as well as those in

80 through 2019 not included in this Proposed Action are also replacement vehicles. The impact on community services as a result of these replacement actions would not change from the present impacts. The addition of an estimated 7,000 new vehicles for new routes would result in additional demands on community services; however, considering the city with the largest number of new routes and new vehicles would be Houston with a total population of 2,300,000 inhabitants, the addition of 84 new routes and employees would have a negligible impact on community services, then the impact over the nationwide delivery network would be similarly negligible Utilities and Infrastructure The Proposed Action would include an estimated 19,000 new replacement vehicles and the actions involving vehicle acquisitions in 2015 and 2016 as well as those in 2017 through 2019 not included in this Proposed Action are also replacement vehicles. The impact on utilities and infrastructure as a result of these replacement actions would not change from the present impacts. The addition of an estimated 7,000 new vehicles for new routes would result in additional demands on utilities and infrastructure; however, considering the city with the largest number of new routes and new vehicles would be Houston with a total population of 2,300,000 inhabitants, the addition of 84 new routes and employees would have a negligible impact on utilities and infrastructure in that area. Accordingly, the impact on utilities and infrastructure nationwide should be similarly negligible Energy Requirements and Conservation The Proposed Action would include an estimated 19,000 new replacement vehicles; the actions involving vehicle acquisitions in 2015 and 2016 as well as those in 2017 through 2019 not included in this Proposed Action are also replacement vehicles. The impact on energy requirements and conservation as a result of these replacement actions would have a moderately adverse impact on the Postal Service s fuel consumption rates. The addition of an estimated 7,000 new vehicles for new routes would result in additional demands for energy; however, considering the city with the largest number of new routes and new vehicles would be Houston with a total population of 2,300,000 inhabitants, the addition of 84 new routes and employees would have a negligible impact on energy requirements. The effect of the additional energy resources on the environment would be insignificant. The Postal Service experience with its delivery vans in the recent past has indicated an average mileage of 6.7 mpg, a decrease of 25 percent from the current 8.7 mpg that would make the goal of achieving a 20 percent reduction by 2020 more difficult. The Postal Service anticipates that the average mpg of the new vehicles might be higher 68

81 than this limited experience. For example, one manufacturer website lists a 2017 delivery van model with USEPA city mileage estimated at 15 mpg city and 22 mpg highway, so it is possible the new vehicles would be able to achieve a higher mpg than the current fleet. For the conservative evaluations included in this PEA, it is assumed that the mileage rate of the new vehicles would be less than that of the replaced vehicles (6.7 mpg versus 8.7 mpg). Manufacturer websites also advertise less frequent oil changes as an improvement for the new vehicles, which would achieve some reduction in new oil quantities required for the replaced vehicles. Considering that the new replacement and new vehicles make up a small percentage of the total delivery fleet and considering the mpg decrease for these vehicles is only 2 mpg, the combined impact of the acquisitions is still negligible Waste Generation and Disposal The estimated 19,000 new replacement vehicles under the Proposed Action, the replacement 12,000 trailers and 376 Spotters under a separate action from 2017 through 2019, and the 2,141 cargo vans replaced in 2015 and 2016 would generate approximately the same wastes and quantities of wastes as the vehicles being replaced under the Proposed Action, except for the initial generation and disposal of scrapped vehicle wastes. The Postal Service recycles materials to the extent possible, and waste is disposed of at licensed facilities that have capacity to handle the wastes. No adverse or beneficial impacts would occur from these actions. The estimated 7,000 new vehicles would generate additional wastes; however, this would be insignificant considering the total Postal Service s delivery fleet of 203,387 vehicles and waste generation across the nationwide delivery network. 5-5 Conclusion Potential impacts of the Proposed Action plus potential impacts of any of the other described actions do not have the potential to adversely impact a resource to the degree that their combined impacts could be significant. Therefore, the Proposed Action when considered in combination with the other projects would not produce a significant adverse cumulative impact on any environmental resource. Thus, implementation of the Proposed Action would not have a significant cumulative effect. 69

82 This page intentionally left blank. 70

83 6 MITIGATION MEASURES The intention of mitigation is to minimize (or eliminate) the effects of the Proposed Action on the environment. Specific laws, regulations, Executive Orders, agency policies, or guidance can require mitigation measures. Mitigation can also be required to minimize adverse impacts to less than significant and therefore support a FONSI. When this occurs, the mitigation must be implemented as part of the final action. Five types of mitigation are: Avoidance mitigation that avoids the impact entirely by not taking certain actions or parts of actions; Limitation of action mitigation that limits the degree or magnitude of an action; Restoration of the environment mitigation that restores the environment to its previous condition or better; Preservation and maintenance mitigation that changes the design of the action to include engineered systems that reduce emission of pollutants; and Replacement mitigation that replaces resources destroyed by the action, usually in an alternate location (Postal Service 2014b). The analyses conducted for this PEA identified numerous beneficial and negligible adverse impacts that might occur as a result of implementing the No Action Alternative, Proposed Action, and Alternative Action. The PEA did not find any significant impacts. Therefore no mitigation measures are necessary to conclude that the Proposed Action results in a FONSI. 71

84 This page intentionally left blank. 72

85 7 LIST OF PREPARERS Casey Cole Huron, Environmental Programs Analyst, Environmental Compliance and Risk Management, Office of Sustainability, U.S. Postal Service Davon M. Collins, Environmental Counsel, Procurement and Property Law, U.S. Postal Service Charles Allen, PE (Project Manager), AECOM Technical Services, Inc. Patti Slade (NEPA Technical Advisor/QA/QC; various PEA sections), AECOM Technical Services, Inc. Sunghye Chang Yun, Ph.D., P.E. (Air Quality), AECOM Technical Services, Inc. Larry Neal (Internal Technical Reviewer), AECOM Technical Services, Inc. Jagadish Prakash (Socioeconomics, Land Use and Planning, Community Services), AECOM Technical Services, Inc. 73

86 This page intentionally left blank. 74

87 8 REFERENCES 29 Code of Federal Regulations (CFR) , Occupational Noise Exposure. 39 CFR Part 775. National Environmental Policy Act Procedures. 40 CFR Part Postal Service s Regulations for Implementing NEPA. 39 United States Code (U.S.C.) 101. Postal Service, Universal Service Obligation Postal Service, General Authority, General Duties Postal Service, General Authority, Specific Powers. Council on Environmental Quality (CEQ) Final Guidance for Federal Departments and Agencies on Consideration of Greenhouse Gas Emissions and the Effects of Climate Change in National Environmental Policy Act Reviews. August 5. Executive Order 12898, Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations. February 11, Executive Order 13693, Planning for Federal Sustainability in the Next Decade. March 19, Federal Highway Administration (FHWA) FHWA Federal Highway Program Manual August 9, Federal Highway Administration report, Summary of Travel Trends: 2009 National Household Travel Survey, Report Number FHWA-PL June ITE (Institute for Transportation Engineers) Transportation Impact Analyses for Site Development: An ITE Recommended Practice. September. United States Census Bureau. 2017a. QuickFacts, United States. Accessed April 2017 < b. QuickFacts, Houston City, Texas. Accessed April 27. < c. American FactFinder. Accessed April 27. < d=acs_15_5yr_dp03&src=pt. 75

88 United States Department of Labor Bureau of Labor Statistics, Occupational Employment and Wages. May Postal Service Mail Carriers. Available at Accessed April 17, United States Energy Information Administration. Frequently Asked Questions, 2017, March 29, United States Environmental Protection Agency (USEPA) MOtor Vehicle Emission Simulator ( Online at: United States Global Change Research Program (USGCRP) Climate Literacy, The Essential Principles of Climate Science. March 30, (USPS) Management Instruction EL , Hearing Conservation Programs. January 25, Postal Service Handbook RE-4, Standards for Facility Accessibility Sustainability Report a. Handbook EL-804, Safe Driver Program b. Postal Service Handbook RE-6, Facilities Environmental Guide. August a. Future Ready, Fiscal Years 2017 to 2021, U.S. Postal Service Five-Year Strategic Plan b. Handbook EL-902, Agreement Between the and the National Rural Letter Carriers Association c. USPS, National Average Labor Rates, March 31, a. A Decade of Facts and Figures. USPS Website accessed April 14, 2017: b USPS Annual Sustainability Report c. Postal Terms. Visited April 13,

89 Appendix A GLOSSARY OF POSTAL SERVICE TERMS Asset Management - Asset Management has the functional leadership and responsibility for the fulfillment and distribution of retail and most accountable products; the demand, supply, and direct store replenishment planning; and inventory control for all postal inventories and assets. Carrier (1) An employee or contractor who delivers and collects mail on foot or by vehicle. (2) An individual contractor or private company (airline, trucking company, railroad, etc.) that transports the mail from one postal facility to another. (3) A competitor that legally provides delivery or freight forwarding service of letters, flats, and parcels individually and in bulk outside the U.S. mail City Carrier An employee who cases, delivers, and collects all mail classes along a city route by walking or driving to residences and businesses within an area authorized for city delivery service. City Delivery Delivery by city carriers of mail addressed to residences and business places within the city delivery limits of the Post Office. City Delivery Service Delivery by city carriers of mail addressed to residences and businesses within an area that has a population of at least 2,500 residents or more than 750 possible deliveries. The area must have paved or improved streets; street signs and house numbers displayed; and 50 percent of the building lots developed with residences and other structures. City Route A delivery route served by a city carrier. Delivery The act of taking mail from the Post Office to the customer. The mail itself taken to the customer s business or residential delivery address or picked up at a Post Office whether Post Office Box, window, or dock. Delivery Point (1) A single mailbox or other place to which mail is delivered. A street address does not necessarily represent a single delivery point because a street address such as one for an apartment building may have several delivery points. (2) A specific set of digits between 00 and 99 assigned to every address that is combined with the ZIP+4 code to provide a unique identifier for every delivery address. The DP is encoded within the POSTNET or Intelligent Mail barcode. District An administrative field unit that oversees most operational and support functions for Post Offices in a defined geographic area. Districts reports to an area office. Facilities Service Office An office reporting to Headquarters that manages, for a specific geographic area, facility activities such as leasing and real estate; asset management; and building repairs, alterations, and planning. A-1

90 Facility Any physical building used by USPS primarily for accepting mail, processing and distributing mail, and/or delivering mail (e.g., Post Office, processing and distribution center, and station or branch). Fiscal Year The 12-month period that is used to keep accounts and other records for applications such as budgeting, planning, and operations. The fiscal year begins on October 1 and ends on September 30 and is divided into 12 accounting periods (one for each month), grouped into four postal quarters Long-Life Vehicle A right-hand drive city delivery van with an aluminum body that can carry 1,000 pounds of cargo. It is designed to last 24 years. The first LLVs entered service in 1987, replacing the Jeep DJ-5. Network Distribution Center (NDC) A highly mechanized and automated mail processing facility formerly designated as a bulk mail center. NDCs are classified as Tier 1, Tier 2, or Tier 3 sites. Tier 1 sites handle the distribution of local (turnaround) and destination Standard Mail, Periodicals, and Package Services pieces. Tier 2 sites have Tier 1 responsibilities and handle the distribution of Standard Mail, Periodicals, and Package Services pieces locally and to the network. They also handle surface transfer center containerization and dispatch operations of outgoing and incoming Priority Mail, First-Class Mail, Periodicals, and Standard Mail pieces. Tier 3 sites have Tier 1 and Tier 2 responsibilities and serve as consolidation points for less than truckload volumes from Tier 2 sites. Post Office The basic organizational unit. Generally, each Post Office has primary responsibility for collection, delivery, and retail operations in a specific geographic area. Each year, Post Offices are categorized by revenue and mail volume. Processing and Distribution Center (P&DC) A central mail facility that distributes and dispatches part or all of both incoming mail and outgoing mail for a designated service area. It also provides instructions on the preparation of collection mail, dispatch schedules, and sorting plan requirements to mailers. The facility is usually a sectional center facility or a general mail facility, but it can also be a dedicated mail processing facility without a station or branch. Rural Carrier An employee assigned to case, deliver, and collect mail using a vehicle along a rural route and to provide most services available at a small Post Office. The rural carrier generally furnishes the vehicle and equipment for handling the mail, receiving Equipment Maintenance Allowance. Rural Delivery Service The nationwide network of rural routes operated primarily to deliver and collect mail from roadside mailboxes owned and maintained by residents of communities without convenient postal facilities. Vehicle Maintenance Facility A USPS repair shop and garage that maintains postal vehicles and provides support documents for vehicle cost and accounting reports. ZIP Code (1) Acronym for Zone Improvement Plan Code. A system of 5-digit codes that geographically identifies individual Post Offices or metropolitan area delivery stations associated with every mailing address. (2) The numeric representation of ZIP Code as opposed to a barcode representation. A-2

91 Appendix B NOTICE OF INTENT Federal Register Publication: NOI to Prepare PEA B-1

92 NOI Letters Sent to Stakeholders B-2

93 B-3

94 B-4

95 B-5

96 B-6

97 B-7

98 B-8

99 NOI Stakeholder Letter Mailing List Agency/Entity Contact Name or Position Mailing Address 1 U.S. Environmental Protection Agency 2 National Association of Postal Supervisors 3 United Postmasters and Managers of America 4 American Postal Workers Union, AFL-CIO 5 National Rural Letter Carriers' Association 6 National Association of Letter Carriers, AFL-CIO Kelly Knight Director, NEPA Compliance Division Brian J. Wagner President Gregory S. Acord, Anthony D. Leonardi Co-National Presidents Mark Dimondstein President Jeanette P. Dwyer President Fredric V. Rolando President U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, N.W. / Ariel Rios Bldg. Mail Code 2251A Washington DC National Association of Postal Supervisors 1727 King Street, Suite 400 Alexandria, VA United Postmasters and Managers of America 8 Herbert Street Alexandria, VA American Postal Workers Union, AFL-CIO 1300 L Street, NW Washington, DC National Rural Letter Carriers' Association 1630 Duke Street Alexandria, Virginia National Association of Letter Carriers, AFL-CIO 100 Indiana Avenue, NW Washington, DC B-9

100 This page intentionally left blank B-10

101 Appendix C NOTICE OF AVAILABILITY Federal Register Publication: NOA of Draft PEA C-1

102 C-2