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Maximizing a windfall

The Illinois Environmental Protection Agency was awarded $108 million to mitigate pollution caused by Volkswagen. The agency's plan wisely maximizes its bang for the buck, but we must ensure that mitigation happens in the places that need it most

Richard Hurd, Flickr

In September 2015, it came to light that Volkswagen had intentionally installed a “defeat device” on millions of diesel engines over the course of 6 years, allowing cars to pass emissions testing despite emitting up to 40 times the legal nitrogen oxide (NOx) limit. NOx is a greenhouse gas and the principle precursor to ozone, a major pollutant in urban environments. Nearly 600,000 of the affected vehicles were sold in the US. As a result VW faced criminal charges for violating the Clean Air Act and was fined $15 billion in a multipart settlement. The largest portion of the settlement, $10 billion, is being used to buy back or repair the offending vehicles. Another $2 billion has been set aside for investment in zero emission vehicle infrastructure, such as electric vehicle charging stations. The final part of the settlement establishes a $2.86 billion environmental mitigation trust fund that states can use to fund projects reducing NOx emissions. The Illinois Environmental Protection Agency (IEPA) has received $108 million as part of the trust, and developed a draft Beneficiary Mitigation Plan (BMP) to explain how they intend to use the money. Over the past several months, MPC was involved in the agency’s outreach efforts, and was invited, along with the public, to provide feedback.

The settlement offers a rare opportunity to improve public health, promote sustainable transportation and enhance environmental stewardship. As a regional planning and advocacy organization that encapsulates these goals, MPC decided to weigh in. We provided IEPA with written comments on the draft BMP that we hope will help them clarify their intent and maximize the impact this award can have on communities most impacted by ozone pollution. The VW Trust established eight mitigation actions that are eligible for funding. Essentially, these are classes of diesel engine vehicles that can be replaced or retrofitted to reduce NOx emissions. IEPA’s plan broadly classifies them as on-road (such as trucks and buses) and off-road (such as locomotives, ferries and tugboats). The plan largely prioritizes off-road vehicles because they’re the largest per-vehicle NOx emitters in the state. For instance, modernizing a single diesel locomotive is equivalent to removing hundreds of light-weight trucks from the road. For tugboats, that number climbs into the thousands.

Unfortunately, the IEPA plan does not clearly indicate what type of vehicles are actually creating the problem in areas experiencing disproportionate ozone exposure. Focusing on off-road projects will undoubtedly yield the greatest short-term NOx reduction in the aggregate, but will that mitigation occur where it’s needed most? Tugs and trains emit a lot of NOx, but they’re constrained to a relatively small area. Trucks and buses, on the other hand, drive directly and repeatedly though our communities. There are a lot more of them, too.  MPC has asked IEPA to release a more robust methodology to show that focusing on off-road projects yields the greatest public health benefit for the greatest number of people. If that turns out not to be the case, then MPC believes the plan should be updated accordingly. You can read our full feedback here.

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