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Record Details


AERCOARE-AERMOD Alternative Model Application in Support of Outer Continental Shelf PSD Air Permitting - CVOW-C
Record No: 22-III-01      Last Update: 11/23/2022


EPA Region: 3     Fiscal Year: 2022
States: VA
Record Type: Action
Pollutants: PM-2.5,NO2,SO2,CO,NOX,PM-10,PM     Sources: Unspecified Stationary Source,Drilling Rig,Ship
Models: OCD,AERMOD     Urban/Rural: Rural
Terrain: Essentially Flat     Regulations: PSD
Guideline: Guideline     Database: Both
Oral/Written: Written     Involvement: Review and Comment
Subjects: Technical Credibility of Nonguideline Techniques        
Comments:
Issue:

Dominion Energy Virginia (Dominion) has proposed the construction of an 
offshore wind energy farm off the coast of Virginia in the Commercial 
Lease of Submerged Lands for Renewable Energy Development on the OCS 
Offshore Virginia (Lease No. OCS-A-0483). The Coastal Virginia Offshore 
Wind-Commercial (CVOW-C) wind farm project will be considered a PSD major 
source during both construction and operation. As a result, air quality 
modeling will be conducted for CO, NO2, PM10, PM2.5, and SO2 to demonstrate 
compliance with the National Ambient Air Quality Standards (NAAQS) and 
appropriate PSD Increments.

Dominion has requested to use an alternative model, as provided in Section 
3.2 of the Guideline on Air Quality Models (40 CFR Part 51, Appendix W), 
to conduct its PSD air quality modeling analysis. Specifically, Dominion 
has requested to use the Coupled Ocean-Atmosphere Response Experiment 
(COARE) bulk flux algorithm, as implemented in the AERCOARE meteorological 
data preprocessor program, to prepare meteorological data for use in the 
American Meteorological Society/Environmental Protection Agency Regulatory 
Model (AERMOD) dispersion program in lieu of the preferred Offshore and 
Coastal Dispersion (OCD) model to assess ambient impacts in a marine 
environment.

EPA Region 3 has conducted a thorough review of Dominion’s request and has 
found the proposed application of the alternative model to be satisfactory 
and addresses the requirements of the Guideline, Section 3.2.2(b), 
Condition (3), including the subsequent five elements contained in 
Section 3.2.2(e). As such, pursuant to the Guideline, Sections 3.0(b) and 
3.2.2(a), Region 3 currently intends to approve the use of proposed coupled 
AERCOARE-AERMOD alternative model approach for the CVOW-C project air permit 
application.

C/H Response:

The Model Clearinghouse concurs with EPA Region 3’s proposed approval of 
a coupled AERCOARE-AERMOD alternative modeling approach for the air quality 
modeling analysis required in the Coastal Virginia Offshore Wind-Commercial 
wind farm project based the alternative model request package provided by 
Dominion Energy Virginia and the review documentation in the alternative 
model concurrence request memorandum provided by EPA Region 3. The Model 
Clearinghouse encourages EPA Region 3 to respond to Dominion and to the 
docket for federal permitting actions related to the CVOW-C project with a 
letter of alternative model approval, as appropriate. The information 
associated with the EPA Region 3 alternative model approval and the Model 
Clearinghouse concurrence should be available for comment during the 
appropriate public comment period(s).


Given the possible importance of platform downwash and shoreline 
fumigation, the Model Clearinghouse continues to recommend caution and 
careful review before additional alternative model considerations of the 
coupled AERCOARE-AERMOD model methodology in other projects. This case-
specific Model Clearinghouse concurrence does not constitute a generic 
approval of a coupled AERCOARE-AERMOD approach for other applications 
elsewhere. However, the scope of the technical assessment submitted here 
and with similar AERCOARE-AERMOD alternative model requests continue to 
provide a good basis for such considerations.
Memoranda:

Memo:  Model Clearinghouse review of an alternative model application of AERCOARE 
in conjunction with AERMOD in Support of Outer Continental Shelf PSD air 
permitting of the Coastal Virginia Offshore Wind-Commercial wind power 
project
        Dated: November 23, 2022
        From:  George Bridgers, Model Clearinghouse Director
                 Air Quality Modeling Group, Air Quality Assessment Division, 
                 Office of Air Quality Planning and Standards
        To:    Timothy A. Leon Guerrero, Meteorologist
                 Air Analysis Branch, Air and Radiation Division
                 EPA Region 3, Philadelphia, Pennsylvania
               Alice Chow, Branch Chief
                 Air Analysis Branch, Air and Radiation Division
                 EPA Region 3, Philadelphia, Pennsylvania
                 
Memo:  Concurrence Request for Approval of Alternative Model AERCOARE in 
Conjunction with AERMOD, in Support of Outer Continental Shelf PSD air permitting 
of the Coastal Virginia Offshore Wind-Commercial wind power project
        Dated: October 25, 2022
        From:  Timothy A. Leon Guerrero, Meteorologist
                 Air Analysis Branch, Air and Radiation Division
                 EPA Region 3, Philadelphia, Pennsylvania
        Thru:  Alice Chow, Branch Chief
                 Air Analysis Branch, Air and Radiation Division
                 EPA Region 3, Philadelphia, Pennsylvania
        To:    George Bridgers, Model Clearinghouse Director
                 Air Quality Modeling Group, Office of Air Quality Planning and Standards

Memo:  Virginia Electric and Power Company - Coastal Virginia Offshore Wind Commercial Project
Updated Request for Approval for Use of the Alternative Model AERMOD/AERCOARE for 
Offshore Modeling of the Coastal Virginia Offshore Wind Commercial Project
            Dated: September 29, 2022

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