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AERMOD COMMENTS

AERMOD COMMENTS. Air & Waste Management Assoc. AB-3 Committee. General Comments. General impressions of AERMOD are favorable Model evaluation record is impressive There are some implementation, documentation and guidance issues that need to be dealt with quite soon

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AERMOD COMMENTS

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  1. AERMOD COMMENTS Air & Waste Management Assoc. AB-3 Committee

  2. General Comments • General impressions of AERMOD are favorable • Model evaluation record is impressive • There are some implementation, documentation and guidance issues that need to be dealt with quite soon • The existence of these issues should not be used as a basis to delay promulgation

  3. General Comments (2) • There is a need for AERMAP to accommodate 10m DEM files

  4. Implementation Issues • Provide the intended schedule for promulgation of AERMOD • Clarify the grandfathering of ISCST3 • How long will EPA support ISCST3? • Are there any situations where ISCST3 can continue to be used after AERMOD becomes the EPA model of choice without a demonstration?

  5. Implementation Issues (2) • Provide adequate funding for a “point of contact” where questions can be answered reasonably quickly and accurately • Provide adequate funding for timely maintenance and corresponding documentation of the AERMOD code

  6. Guidance Issues • Provide sufficient guidance to assure reasonable consistency in the applications of AERMOD • Provide guidance on the use of Bulk-Richardson Scheme (RDT) for use of on-site data in remote areas without cloud cover data • Standardize and provide guidance on the use of PVMRM method

  7. Guidance Issues (2) Improve guidance on using land use parameters: • Guidance on defining “seasons” (see MPRM Manual Table 3-4) • Should multiple land use sectors be used, and, if so, when?

  8. Guidance Issues (3) • Complete and release AERSCREEN, the screening tool for AERMOD • Will AERSCREEN be designated as a “screening model” in Appendix W? • Provide adequate guidance on how and when to use AERSCREEN

  9. Documentation Issues • It is unclear from the AERMET documentation whether the land use sectors are for the upwind direction or downwind direction • AERMET documentation fails to indicate which onsite met. variables are active and which are simply “placeholders” • Addition of an appendix to the User’s Guide could accomplish this

  10. Summary • We encourage the prompt release of AERMOD • Work and funding is needed in the areas of: • Implementation • Guidance • Documentation

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