Iowa's Beneficiary Mitigation Plan


This plan summarizes how the state plans to use the mitigation funds allocated to it under the environmental mitigation trust.

In the spring of 2017, an input-gathering survey was available for the public to submit ideas on how Iowa could best use its environmental mitigation trust funds. Participation was invaluable to the process. The state agency working group used the information from the survey to prepare a draft plan for review by the Governor and the public.

Our draft Beneficiary Mitigation Plan was available for public comment through May 25, 2018. Over 120 comments were received during the formal comment period. A summary of the comments is shown below. The Beneficiary Mitigation Plan was submitted to the VW Settlement trustee on August 8, 2018.

Mitigation Plan Requirements


  1. The plan must be submitted no later than 30 days prior to submitting its first funding request.
  2. The plan is intended to provide the public with insight into the high-level vision for use of the funds.
  3. The plan shall explain the process by which the beneficiary shall seek and consider public input on its plan.
  4. The plan must list the eligible mitigation actions selected to achieve the goals and the percentage of funds to be used for each action.
  5. The plan must include a description of how the beneficiary will consider the potential beneficial impact of the selected actions on air quality in areas that bear a disproportionate share of air pollution burden.
  6. The plan also needs to contain a general description of the expected ranges of emissions benefits realized by the implementation of the selected actions identified in the plan.
  7. The plan needs to contain only the level of detail "reasonably ascertainable" at the time of submission.
  8. The plan is not intended to be binding and can be adjusted by the beneficiary.

Eligible Nitrogen Oxides Reduction Projects

Click on the boxes below to view more information about each project.

Class 8 local freight or port drayage trucks (large trucks)
  • Includes 1992-2009 model years (may include 2010-2012 models if state already requires upgrades).
  • Eligible trucks must be scrapped.
  • Government-owned: All options up to 100 percent funded.
  • Nongovernment-owned: Variable fund percentages based on mitigation.
    • New diesel or alternative fuel engine (e.g., natural gas, propane, hybrid) vehicle.
      • Repower: IU to 40 percent funded.
      • Purchase new: Up to 25 percent funded (up to 50 percent for drayage trucks).
    • All-electric engine: Includes charging infrastructure.
      • Repower: Up to 75 percent funded.
      • Purchase new: Up to 75 percent funded.
Class 4-7 local freight (medium trucks)
  • Includes 1992-2009 model years (may include 2010-2012 models if state already requires).
  • Eligible medium trucks must be scrapped.
  • Government-owned: All options up to 100 percent funded.
  • Nongovernment owned: Variable fund percentages based on mitigation
    • New diesel or alternative fuel engine (e.g., natural gas, propane, hybrid) vehicle.
      • Repower: Up to 40 percent funded.
      • Purchase new = up to 25 percent funded
    • All-electric engine: Includes infrastructure.
      • Repower: Up to 75 percent funded.
      • Purchase new: Up to 75 percent funded.
Class 4-8 school, shuttle, or transit buses
  • Includes 1992-2009 model years (may include 2010-2012 models if state already requires).
  • Eligible trucks must be scrapped
  • Government-owned: All options up to 100 percent funded.
  • Nongovernment-owned: Variable fund percentages based on mitigation.
    • New diesel or alternative fuel engine (e.g., natural gas, propane, hybrid) vehicle.
      • Repower: Up to 40 percent funded.
      • Purchase new: Up to 25 percent funded.
    • All-electric engine: Includes charging infrastructure.
      • Repower: -Up to 75 percent funded.
      • Purchase new: Up to 75 percent funded.
Freight switchers (pre-Tier 4 switcher locomotives that operate 1,000 or more hours per year)
  • Eligible freight switchers must be scrapped.
  • Government-owned: All options up to 100 percent funded.
  • Nongovernment-owned: Variable fund percentages based on mitigation.
    • New diesel or alternative fuel engine (e.g., natural gas, propane, hybrid) vehicle.
      • Repower: Up to 40 percent funded.
      • Purchase new: Up to 25 percent funded.
    • All-electric engine: Includes infrastructure.
      • Repower: Up to 75 percent funded.
      • Purchase new: Up to 75 percent funded.
Ferries/Tugs (unregulated, Tier 1 or Tier 2 marine engines)
  • Eligible equipment that is replaced must be scrapped.
  • Government-owned: All options up to 100 percent funded.
  • Nongovernment-owned: Variable fund percentages based on mitigation.
    • New Tier 3 or Tier 4 diesel or alternative fuel engine (e.g., natural gas, propane, hybrid) vehicle.
      • Repower; Up to 40 percent funded.
    • All-electric engine: Includes infrastructure.
      • Repower: Up to 75 percent funded.
Ocean going vessel (OGV) shore power
  • Systems that enable a compatible vessel’s engine to remain off while it is at berth.
    • Shore power includes cables, cable management systems, shore power coupler systems, distribution control systems, and power distribution components.
  • OGVs may be upgraded with an Environmental Protection Agency certified remanufacture system or an EPA verified engine upgrade.
  • Government-owned: Up to 100 percent funded.
  • Nongovernment-owned: Up to 25 percent funded.
Airport ground support equipment
  • Tier 0, Tier 1, or Tier 2 diesel powered.
  • Uncertified or certified to 3grams per brake horsepower-hour or higher emissions, spark ignition engine-powered.
  • Eligible airport ground support equipment must be scrapped.
  • May be repowered or replaced with an all-electric engine.
  • Government-owned: Up to 100 percent funded.
  • Nongovernment-owned: Up to 75 percent funded.
Forklifts and port cargo handling equipment (greater than 8,000 lbs lift capacity)
  • Eligible equipment must be scrapped.
  • May be repowered or replaced with an all-electric engine.
  • Government-owned: Up to 100 percent funded.
  • Nongovernment-owned: Up to 75 percent funded.
Light-duty zero-emission vehicle supply equipment
  • Can use up to 15 percent of allocation.
    • Acquire, install, operate, and maintain equipment.
      • Level 1, Level 2, or DC fast chargers located in a public place, workplace, or multi-unit dwelling.
      • Hydrogen fuel cell supply equipment, including hydrogen dispensing equipment that is located in a public place.
      • Percentages based on type and location.
Diesel Emission Reduction Act (DERA) option
  • May be used for nonfederal voluntary match or overmatch.
  • May be used for actions eligible under DERA, but not specified in the settlement.
  • Trust funds shall not be used to meet the nonfederal mandatory cost share requirements of any DERA grant.

The complete list of eligible nitrogen oxides reduction projects can be found in Appendix D-2 of first partial consent decree.

For a description of vehicle classifications please refer to the Truck Classification Chart below.

Truck Classes Categorized by the Gross Vehicle Weight Rating (GVWR)


Survey responses

A survey was placed on the website from February to April 2017 to seek input on how the VW Settlement Trust funds should be spent. Approximately 500 survey responses were received, with the most popular supporting the use of funds for school bus replacements, specifically for buses utilizing alternative fuel sources such as propane. The public was also overwhelmingly in favor of funding zero-emission vehicle infrastructure for light-duty electric vehicles and supplementing the Diesel Emission Reduction Act grant program.

Survey Responses


Draft plan comments

Approximately 120 formal responses were received on the draft plan and were generally positive. A majority of the comments were in support of using funds to replace school buses, specifically focused on propane or electric buses.

Draft Plan Comments


Working Group Members

A state agency working group, coordinated by the Iowa Department of Transportation, has been tasked with reviewing the Volkswagen settlement requirements and evaluating potential uses of these dollars.

  • Jared Smith - Iowa Department of Transportation
  • Deb Arp - Iowa Department of Transportation
  • Stuart Anderson - Iowa Department of Transportation
  • Stephanie Weisenbach - Iowa Economic Development Authority
  • MK Anderson- Iowa Economic Development Authority
  • Karl Wendt - Iowa Department of Administrative Services
  • Max Christensen - Iowa Department of Education
  • Max Miller - Iowa Department of Justice, Office of the Attorney General of Iowa
  • Ben Bellus - Iowa Department of Justice, Office of the Attorney General of Iowa
  • Marnie Stein - Iowa Department of Natural Resources
  • Stu Schmitz - Iowa Department of Public Health

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