This may be picking nits, but there is no such requirement--the settlement agreements are completely silent about how the car makes its way to the turn-in location. The requirement is that it be able to move under its own power, but does not specify how it gets to the dealer.
I'll go further and say that it doesn't even need to be operable. Yes, it says so on the website but not in the court docs. Exempt: "Owners whose Eligible Vehicle (i) could not be driven under the power of its own 2.0-liter TDI engine on June 28, 2016,"
2.33. “Eligible Vehicle” means Model Year 2009 through 2015 Volkswagen and Audi light-duty vehicles equipped with 2.0-liter TDI engines that (3)for an Eligible Owner, are currently Operable or cease to be Operable only after the Opt-Out Deadline; and "
Opt out has passed. Drag it in on rims if you must.