Linked below is Part 2b of Tom Morrissey's review of the NESCAUM "Assessment". Part 2b focuses on density, data, and invalid test runs.
NESCAUM was unable to achieve the required density in a majority of its tests reviewed, rendering these tests invalid and raising red flags about their methods. Appended to Part 2b are 10 pages of emails written during the week of 7/5/2021 between Tom and the EPA, in which they try to derive whether NESCAUM meets the requirements of its own proposed standard in runs documented to EPA. The data sets for ALT-140 are very small, but even now there are obvious problems with load density, large coal beds, and representative low burns meeting the criteria spelled out in ALT-140.