What basis does BNSF have for the specific coal dust standards that BNSF has adopted?
BNSF has been conducting scientific studies of coal dust for several years. Among other things, the studies have involved collecting and analyzing data on coal dust emissions from thousands of trains. BNSF has retained and worked closely with engineering consultants to design monitoring devices for coal dust emissions, to implement protocols for measuring coal dust emissions from particular trains, and to analyze the results of field tests. With its outside consultants, BNSF has determined that limiting coal dust emissions to the IDV.2 levels specified in Items 100 and 101 would reduce coal dust emission levels by about 85%.
