The phase transition for turbulent diffusion, reported by Avellaneda and Majda [Avellaneda, M. & Majda, A. J. (1994) Philos. Trans. R. Soc. London A 346, 205-233, and several earlier papers], is traced to a modeling assumption in which the energy spectrum of the turbulent fluid is singularly dependent on the viscosity in the inertial range. Phenomenological models of turbulence and intermittency, by contrast, require that the energy spectrum be independent of the viscosity in the inertial range. When the energy spectrum is assumed to be consistent with the phenomenological models, there is no phase transition for turbulent diffusion.
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