unstable conditions and lightwinds and increased differences for neutral and stable conditionsand stronger winds. The higher cut-off rate of 8% reduces thedifferences also in this case.The application of this constant factor neglects the effect of atmosphericturbulence which is going to reduce local concentrationdifferences in a plume by turbulent mixing downwind an emissionsource. This is assumed most effective in unstable conditions, itsimportance decreasing with increasing atmospheric stability. Thepeak-to-mean concept presented in Section 2.2 takes thisassumption into account. Even if one could argue that the stabilitydependent
peak-to-mean approach presented in Section 2.2 lacksprecise experimental evidence, the resulting separation distancesare in an expected range. This is certainly not the case for the largeseparation distances in Fig. 9. In Germany, separation distances arecalculated solely with the overall factor 4; therefore, these separationdistances in Fig. 9b have to be compared with the AODMresults in Fig. 5a or Fig. 7a. This comparison reveals the enormousdifferences in separation distances especially for NW wind inKittsee when the two models are applied according to their standardprocedures.How is the definition of separation distances as given in Section