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transport tips continued shippers for nearly seven years. Instead, BNSF unilaterally issued a revised tariff (Dust 2), which went into effect October 1, 2011. PRB coal shippers are now facing the imposition of very expensive and ineffective dust control requirements that threaten the efficiency of PRB coal transportation. They have fought mightily to prevent the senseless expenditure of ratepayer monies, but like Don Quixote have often emerged bruised and bloody from their fights with the windmills (railroads). The STB has also told shippers what to do if they are threatened with any such penalty or sanction without having been given 60-days' notice, or what to do if they have been given 60-days' notice. This seems to leave BNSF helpless to enforce its dust amendment if shippers refuse to spray, but it clearly puts the onus on shippers to inform the STB if BNSF uses strong-arm tactics to compensate for the lack of enforceability in the dust control amendment. Does this mean shippers should go running to the STB every time one of the railroads subtly applies a pinky-twisting tactic such as threatening to raise rates, or going viral on miscellaneous charges? Does Spraying Really Do Any Good? There are known and unknown limitations on the performance of the toppers (surfactants). BNSF cannot explain how the fragile, low-water toppers it advocates would change anything. Many plants are over a thousand miles from the PRB. It is known that rainfall adversely affects the waterbased toppers. What will happen when the railroads' own operations and maintenance practices cause coal (not just dust but chunks as well) to come out of the cars or cause the crust that is formed with the topping agents to be disturbed? Will toppers lead to the "plywood" effect after a few hundred miles and actually wind up with more coal leaving the cars than before? It would be a shame to spend $100 million/year to decrease fugitive coal deposition, only to find the coal dust had been moved to a point down the line outside of the PRB. The BNSF Super Trials notably avoided any testing during the harsh Wyoming winter, so BNSF has no way to determine what will happen to this water-based system in cold weather. Author Dave Gambrel is a transportation consultant to the coal business. He was formerly the senior transportation executive for Peabody Energy Co. He may be reached at bunkgambrel@earthlink.net. January 2013 www.coalage.com 21