Model Clearinghouse Information Storage and Retrieval System
Record Details

Issue:

New Fortress Energy Louisiana FLNG LLC is proposing to construct, own, 
and operate the New Fortress Energy (NFE) Louisiana FLNG Project, a 
deepwater port export terminal, approximately 16 nautical miles off the 
southeast coast of Grand Isle, Louisiana (West Delta Lease Block 38). The 
project will be considered a PSD major source, with significant emissions 
of NOX, CO, VOC, PM, PM10, PM2.5, SO2, H2SO4, and GHGs. As a result, air 
quality modeling will be conducted for NO2, CO, PM10, PM2.5, and SO2 to 
demonstrate compliance with the National Ambient Air Quality Standards 
(NAAQS) and appropriate PSD Increments.

New Fortress Energy Louisiana FLNG LLC 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, New Fortress Energy Louisiana FLNG LLC 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 6 has conducted a thorough review of New Fortress Energy Louisiana 
FLNG LLC’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 NFE 
Louisiana FLNG Project air permit application.

C/H Response:

The Model Clearinghouse concurs with EPA Region 6’s proposed approval of 
a coupled AERCOARE-AERMOD alternative modeling approach for the air quality 
modeling analysis required in the NFE Louisiana FLNG Project based on the 
alternative model request package provided by New Fortress Energy Louisiana 
FLNG LLC and the review documentation in the alternative model concurrence 
request memorandum and technical support document provided by EPA Region 6. 
The Model Clearinghouse encourages EPA Region 6 to respond to New Fortress 
Energy Louisiana FLNG LLC and to the docket for federal permitting actions 
related to the NFE Louisiana FLNG Project with a letter of alternative model 
approval, as appropriate. The information associated with the EPA Region 6 
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.

Memo:  Model Clearinghouse review of an alternative model application of AERCOARE 
in conjunction with AERMOD in support of PSD air permitting of the New Fortress 
Energy Louisiana FLNG Project
        Dated: March 29, 2023
        From:  George Bridgers, Model Clearinghouse Director
                 Air Quality Modeling Group, Air Quality Assessment Division, 
                 Office of Air Quality Planning and Standards
        To:    Ashley Mohr, Regional Air Permit Modeler
                 Air Permits Section, Air and Radiation Division
                 EPA Region 6, Dallas, Texas
               Jeffrey Robinson, Manager
                 Air Monitoring and Grants Branch, Air and Radiation Division
                 EPA Region 6, Dallas, Texas
                 
Memo:  Concurrence Request for Approval of Alternative Model AERCOARE in Conjunction 
with AERMOD, in Support of Clean Air Act Permitting Effort
        Dated: March 1, 2023
        From:  Ashley Mohr, Regional Air Permit Modeler
                 Air Permits Section, Air and Radiation Division
                 EPA Region 6, Dallas, Texas
        Thru:  Jeffrey Robinson, Manager
                 Air Monitoring and Grants Branch, Air and Radiation Division
                 EPA Region 6, Dallas, Texas
        To:    George Bridgers, Director of Model Clearinghouse
                 Air Quality Modeling Group, Air Quality Assessment Division, 
                 Office of Air Quality Planning and Standards

Memo:  Technical Review of the New Fortress Energy (NFE) Louisiana FLNG LLC request to use
the AERCOARE meteorological data preprocessor program in conjunction with
AERMOD in support of their Prevention of Significant Deterioration (PSD) Permit
Application
            Dated: February 21, 2023