I am worried this will be deleted as a duplicate question, so I will try to be extra clear what I am asking:
In some reference frames, static friction can do positive work. If you have a crate in the back of an accelerating truck, static friction does work on the crate, when everything is observed from someone in an inertial reference frame on the side of the street.
Can we say something similar, in an even remotely useful sense, for the friction between a wheel and the road (for an accelerating car with no slipping)? Is there a reference frame in which the static friction from rolling does positive work?