The aim of the Comet Nucleus Sounding Experiment by Radiowave Transmission (CONSERT) is the characterization of the inner structure and electrical properties of the Chuyurmov-Gerasimenko's nucleus. The instrument will sound the comet's nucleus between the lander Philae at the comet's surface and the Rosetta main spacecraft. A coarse three-dimensional model of the complex dielectric permittivity inside the nucleus will be reconstructed from the whole set of data obtained during the first science phase [3]. The work presented here show how a limited set of data acquired at grazing angles during a single low altitude fly-by can be used to characterize the shallow sub-surface of the nucleus. The study is based on simulated data obtained by two different electromagnetic models: the accurate pseudo spectral time-domain method and a much faster ray-based approximation taking into account material and path-loss.