  The recent study by Klingenberg, Oberlack & Pluemacher (2020) proposes a new
strategy for modeling turbulence in general. A proof-of-concept is presented
therein for the particular flow configuration of a spatially evolving turbulent
planar jet flow, coming to the conclusion that their model can generate scaling
laws which go beyond the classical ones. Our comment, however, shows that their
proof-of-concept is flawed and that their newly proposed scaling laws do not go
beyond any classical solutions. Hence, their argument of having established a
new and more advanced turbulence model cannot be confirmed. The problem is
already rooted in the modeling strategy itself, in that a nonphysical
statistical scaling symmetry gets implemented. Breaking this symmetry will
restore the internal consistency and will turn all self-similar solutions back
to the classical ones. To note is that their model also includes a second
nonphysical symmetry. One of the authors already acknowledged this fact for
turbulent jet flow in a formerly published Corrigendum (Sadeghi, Oberlack &
Gauding, 2020). However, the Corrigendum is not cited and so the reader is not
made aware that their method has fundamental problems that lead to
inconsistencies and conflicting results. Instead, the very same nonphysical
symmetry gets published again. Yet, this unscientific behaviour is not
corrected, but repeated and continued in the subsequent and further misleading
publication Klingenberg & Oberlack (2022), which is examined in this update in
the appendix.
