Enclosure

EPA Response to Letter in Support of Wise County’s Petition for Reconsideration 

from State Representative Wayne Smith, District 128 

By letter dated July, 12 2012, Wayne Smith, State Representative for District 128, submitted a letter in 

Support of Wise County’s Petition for Reconsideration for the EPA to reconsider the final area 

designation for Wise County in the Dallas-Forth Worth (DFW) area. For the reasons discussed below 

and in the Response to Wise County’s Petition for Reconsideration, the EPA is denying the Wise 

County Petition. For the sake of clarity, we have organized this response according to the structure of 

your July 12, 2012 letter. 

I. Concern About Treatment of the Oil and Gas Industry 

Issue: Your letter expresses concern that the EPA’s decision was announced shortly after the discovery 

of 2010 comments made by former EPA Region 6 Administrator Al Armendariz, stating that the EPA’s 

enforcement goal was to “crucify” the oil and gas industry. 

Response: The EPA’s final designation decision for the DFW area was based on the EPA’s evaluation of 

the data and technical information, extensive and thoughtful consideration of input from TCEQ and 

other interested parties. The EPA’s Office of Air and Radiation works closely with technical staff in the 

EPA’s regional offices to ensure that decisions are based on the factual record and are consistent across 

the country. As demonstrated in the Technical Support Document (TSD) accompanying the EPA’s 

intended designations issued in December, 2011 and the TSD accompanying the final designation on 

April 30, 2012, the EPA performed a thorough assessment of information relevant to five designationsrelated factors in determining which areas should be included as part of the DFW nonattainment area. 

The final decision was made by Administrator Lisa Jackson based on the record before the EPA. We 

further note that there are other Texas counties where oil and gas production and activity occur that were 

initially considered for inclusion into a nonattainment area, but were ultimately not included. For 

example Hood County, Texas and Matagorda County, Texas were considered and proposed for 

inclusion in their respective areas. However, following a review of comments from Texas and from 

public commenters and upon further evaluation of all available data relevant to their contribution to 

ozone violations, we determined those counties should not be included as part of a nonattainment area. 

Our record details those decisions. 

II. Support for Wise County Petition: 

Issue: Your Letter urges the EPA to carefully consider the Wise County Petition for Reconsideration. 

Response: We carefully considered the petition filed by Wise County and have included a copy of our 

Response to the Wise County Petition for Reconsideration. 

 
III. Emissions Data and Modeling: 

Issue: Your Letter claims that the EPA must demonstrate that emission sources in the County make a 

meaningful contribution to the DFW nonattainment area ozone exceedances. Your Letter also claims 

that the EPA’s reliance on HYSPLIT modeling only estimates hourly positions of wind parcels and is 

not capable of directly measuring the transport of ozone from one area to another. Further, your letter 

claims that back trajectory analysis is of limited use in tracking ozone contribution and transport, per the 

EPA TSD for 2004 ozone designations; “... trajectory analysis ... does not take into consideration 

atmospheric chemical processes, the injection of emissions, or the deposition of material along the 

trajectory path.” 

Response: This issue was raised during the comment period; thus it is not an appropriate basis for 

reconsideration. We addressed these comments in our record, as detailed below. See our final DFW TSD 

titled “Dallas-Fort Worth, Texas Final Area Designations for the 2008 Ozone National Ambient Air 

Quality Standards” and “Responses to Comments Document (RTC) on the State and Tribal Designation 

Recommendations for the 2008 Ozone National Ambient Air Quality Standards (NAAQS)” in the 

docket for this action. As stated in our preliminary and final TSDs and in our RTC document, the 

HYSPLIT model is a sophisticated tool but it only accounts for wind direction and potential transport of 

airborne pollutants; it is not a photochemical dispersion model and therefore cannot be used to estimate 

or project ozone formation from precursor pollutants. See RTC pages 14, 60 and TSD pages 14 -15. 

However, the HYSPLIT results provide other useful information. The HYSPLIT approach provides 

transport/back trajectories during high ozone events to determine if Wise County emissions of ozone 

precursors are located within the area of potential contribution. As stated in the TSD, the emissions in 

Wise County are large enough that they could contribute to ozone exceedance levels at a downwind 

monitor. The EPA’s review of the Texas Commission on Environmental Quality’s (TCEQ’s) 

photochemical source apportionment modeling (SAM) indicated that Wise County emissions contribute 

to ozone exceedance levels at a number of monitors in the DFW area on certain days included in 

TCEQ’s modeling. In our Final decision, the EPA considered the SAM submitted by TCEQ during the 

comment period to help evaluate the ozone generation potential of emissions from Wise County, in 

addition to our consideration of HYSPLIT results and Wise County emissions.1 Together, this 

information indicated that emissions from Wise County are carried to the violating monitors on days 

with high ozone levels. 

The statement from the 2004 TSD does not contradict anything we have said in the designation process 

for the 2008 Ozone NAAQS. We note that HYSPLIT back trajectories were utilized in the 2004 

designations in many areas and consideration of emissions in the back trajectory areas and their potential 

to contribute to ozone levels were also part of the technical analyses in many areas. We further note that 

the State of Texas helped fund a report finalized in April 2004 that was also used in the DFW ozone 

designations decision in 2004 that included HYSPLIT and emissions analysis and source apportionment 

photochemical modeling.2

Issue: Your Letter claims that TCEQ demonstrated that Wise County emissions rarely, if ever, 

contribute to ozone violations in other counties. TCEQ presented evidence that portions of the DFW 

area contribute to ozone levels in Wise County, not the other way around. 

 

1

 HYSPLIT was the only model we used during our evaluation of the meteorological portion of our five-factor analysis to 

inform our preliminary designations. See our preliminary TSD for Texas, posted to the docket in December, 2011. 2

 Final Report Dallas-Ft. Worth Transport Project Prepared for Houston Advance Research Center, April 6, 2004. 
Response: This issue was raised during the comment period; thus it is not an appropriate basis for 

reconsideration. We addressed these comments in our record, as detailed below. As demonstrated in our 

TSDs and RTC, although Wise County is often downwind from the DFW area, on occasions the 

meteorological regime of the area is characterized by light and variable winds in which emissions from 

sources in Wise County are transported to nearby ozone monitors. See TSD pages 14 – 15 and RTC 

document page 60 (“[w]ith regard to meteorology for these counties, we note that we not only looked at 

wind patterns but also the more sophisticated wind trajectory models based on days on which elevated 

ozone concentrations were measured in the area; such days are more representative of meteorological 

and atmospheric conditions that are conducive to the generation of ground-level ozone and exceedances 

of the ozone NAAQS in the DFW area.”). It is on such days that the DFW area experiences some of its 

highest ozone concentrations, and the monitors nearest the sources in Wise County are among the 

monitors recording the highest ozone readings. As detailed in the record, these meteorological analyses, 

together with the other four factors we evaluated, informed our decision to designate Wise County as 

nonattainment. 

Issue: Your letter states that the EPA has not provided sufficient justification to utilize a wind analysis in 

this case, when it has disregarded that same wind analysis in other instances. 

Response: This issue was raised during the comment period; thus it is not an appropriate basis for 

reconsideration. We addressed these comments in our record, as detailed below. First, your letter does 

not describe what is meant by “wind analysis,” so we will assume you are referring to the HYSPLIT 

analysis. We further assume that by “disregarded that same wind analysis,” you mean “did not use 

HYSPLIT analysis in other instances.” As we stated in our RTC on pages 13 and 59, “[t]he adequacy of 

a particular meteorological analysis cannot be determined generically, but must be determined as one 

part of the multi-factor process used for each individual region under consideration.” In addition, as we 

stated in our RTC on page 59, for purposes of identifying potential local and regional source/receptor 

patterns, the HYSPLIT wind trajectory model is an excellent tool for determining the frequencies for 

which areas potentially contribute to high ozone levels and is preferred over more basic assessments of 

wind speed and direction at a given point location (e.g., wind roses, or pollution roses). These basic 

assessments, such as wind roses, are potentially misleading in cases where wind speeds are light and the 

wind direction is variable. The light and variable meteorological regime is one of the classic 

meteorological types that results in high ozone in the DFW area. In this designation process and other 

designation processes, the EPA has indicated that HYSPLIT does not directly model ozone, but does 

yield potential transport of emissions from one area to another. As we said on page 14 of the TSD, “By 

knowing where an air mass has traveled before reaching a monitor where an exceedance has occurred, 

one can consider what potential areas of emission sources could have contributed to the exceedance.” 

While it is true that the EPA was unable to use HYSPLIT modeling to inform our decisions for all 

areas,3

 we believe that it is a valuable tool and should not be disregarded where the information is 

available, even if the information is not available in all areas. We considered HYSPLIT results in all 

 

 

3

 HYSPLIT modeling was used in the analysis for 16 areas. See the TSDs for Allentown-Bethlehem-Easton, PA; Baltimore, 

MD; Lancaster, PA; Pittsburgh-Beaver Valley, PA; Reading, PA; Philadelphia-Wilmington-Atlantic City, PA-NJ-MD-DE 

(for DE, MD, PA); Washington, DC-MD-VA; Charlotte-Rock Hill, NC-SC; Knoxville, TN; Memphis, TN-MS-AR (TN, MS 

portions); Chicago-Naperville, IL-IN-WI; Baton Rouge, LA; Dallas-Fort Worth, TX; Memphis, TN-MS-AR (AR portion); 

Houston-Galveston-Brazoria, TX; Denver-Boulder-Greeley-Ft Collins-Loveland, CO; and San Luis Obispo (Eastern San 

Luis Obispo), CA.
cases where we had such information and the analysis was deemed appropriate for use.4

 As indicated in 

the HYSPLIT and ambient monitoring data presented in our preliminary and final TSDs, the Eagle 

Mountain Lake and Keller monitor sites experience elevated concentrations of ozone on days in which 

wind back trajectories from these monitor sites traverse Wise County. 

 

4

 We note that there was a situation where a limited HYSPLIT evaluation in an area in Pennsylvania was determined to not 

be appropriate for use in a specific case due to unique issues. 

Enclosure 

EPA Response to Petition for Reconsideration from Wise County, Office of the County Judge 

By letter dated June 15, 2012, the Office of the County Judge of Wise County, Texas petitioned the EPA 

to reconsider the final area designation for Wise County in the DFW area. For the reasons discussed 

below, the EPA is denying the Petition. For the sake of clarity, we have organized this response 

according to the below general headings. 

I. Emissions and Emissions-Related Data 

Issue: Petitioner asserts that Wise County and the Texas Commission on Environmental Quality (TCEQ) 

presented the EPA with additional information (before and after the public comment period) 

demonstrating that the EPA’s assessment of its multi-factor analysis, including emissions and emissionsrelated data was in error. Further, Petitioner claims that the EPA’s analysis did not include certain 

scientific and monitored TCEQ report revisions related to the oil and gas sector pneumatic emissions for 

the periodic emissions inventory. Furthermore, the source apportionment modeling (SAM) submitted by 

TCEQ and relied upon by the EPA did not use the updated oil and gas sector pneumatic emissions and 

therefore most likely overestimated these emissions in the modeling. 

Response: Petitioner raised the consideration of such additional emissions related data in two comment 

letters submitted during the public comment period; thus these issues are not an appropriate basis for 

reconsideration. We addressed these comments in our record, as detailed below. In October 2011 TCEQ 

submitted a revised 2008 emissions inventory for oil and gas sector pneumatic VOC emissions, and we 

did consider the revised VOC emissions data as part of our final designation decision (see Technical 

Support Document, herein referred to as the TSD, pages 6-7). See also page 55 of the Response to 

Comment (RTC) document on the State and Tribal Designation Recommendations for the 2008 Ozone 

National Ambient Air Quality Standards (NAAQS) in the docket for this action where we explain that 

we “reviewed the updated emissions data reported by the TCEQ....” In the RTC, we further state that 

“even with the reduced 2009 VOC emissions data, the emissions from Wise County still contribute to 

measured violations of the 2008 ozone National Ambient Air Quality Standards (NAAQS) at monitors 

in neighboring counties.” [RTC page 56]. The TCEQ submitted additional SAM modeling data on 

February 29, 2012 to the EPA that did not include the October 2011 revised oil and gas sector pneumatic 

VOC emissions data. However, we did review the October 2011 revised data, before making our final 

designation decision, and concluded that it did not have a significant effect on Wise County’s 

contribution. 

In support of those conclusions, it is indicated in the record that DFW is a nitrogen oxide (NOx)-limited 

area and VOC reductions have not shown as much benefit as corresponding NOx reductions in past 

modeling conducted by TCEQ. Furthermore, we recognized that the VOCs that are potentially 

overestimated are from oil and gas operations and that these VOC emissions “are relatively 

nonreactive,” i.e., they are less likely to result in ozone formation than VOCs that are more reactive. 

Accordingly, we did consider the potential impact of the new reported VOC emission levels on our 

 
interpretation of the SAM results for Wise, Hood, and Matagorda Counties and concluded that the 

impacts would be negligible.1

Issue: Petitioner claims that because of Wise County’s small population and vehicle miles traveled 

(VMT), it is unexpected that these types of emissions would have any significant contribution to ozone 

formation. 

Response: Petitioner raised the issue of the use of population and VMT data as indicators for 

determining “contribution” during the public comment period, thus it is not an appropriate basis for 

reconsideration. We addressed those comments in the record, as detailed below. While we 

acknowledged that Wise’s population and VMT are smaller in comparison to that of other parts of the 

DFW nonattainment area,2 we explain in our record that other factors, such as the total emissions from 

the area, meteorology, and proximity to violating monitors supported our determination that Wise 

County contributes to violations of the NAAQS in the DFW area. As stated in our TSD, the 2008 

Emissions Inventory for Wise County shows that Wise County’s nitrogen oxide emissions of 11,911 

tons per year (tpy) are the 6th highest of the 19 county DFW Combined Statistical Area (CSA) and the 

County’s volatile organic compound emissions of 17,609 tpy are the fourth highest of the 19 counties. 

See TSD pages 6-7, table 3.3 The TSD demonstrates that there are six ozone monitors violating the 

standard in the two counties adjacent to Wise County (TSD Figure 1, page 3) and notes that Wise 

County is less than 1⁄2 mile from a violating monitor with a design value of 0.085 parts per million (TSD 

2008 to 2010 data, pages 5 and 23). We also evaluated meteorological transport patterns during 

exceedances using NOAA’s HYSPLIT model. These patterns indicate that emissions from Wise County 

are transported to the DFW ozone monitors violating the standard based on 2008-2010 data, and we 

conclude that the Wise County emissions are large enough that they can contribute to ozone 

exceedances on certain days. See TSD pages 14-17, 19, 20, and 23. Wise County’s population and VMT 

data indicated that Wise County’s relatively high total emissions derive more from point and area 

sources associated with oil and gas production activities in the county. 

II. Meteorological Analysis 

Issue: Petitioner claims that Wise County is unlikely to contribute to high ozone days in the DFW area 

because the conditions conducive to ozone formation in the DFW area occur on days that are sunny, 

warm, and where winds are predominantly from the east or southeast or winds speeds are slow. 

Furthermore, “the DFW area produces enough emissions” to result in violations on high ozone days 

without considering contributions from Wise County. 

 

1

 Final TSD, pages 6-8; Houston Final TSD, pages 5-7; RTC pages 52-56, including “...the VOC emissions resulting from 

oil & gas production activities are relatively nonreactive in the photochemical generation of ground-level ozone and that 

additionally the DFW area is NOx-limited such that VOC emissions in general do not contribute as much as NOx emissions 

to the generation of ground-level ozone.” And “EPA has since reviewed the updated emissions data reported by the TCEQ 

and notes that the revised numbers do not affect the ranking of the counties for VOC emissions. EPA’s analysis indicates that 

even with the reduced 2009 VOC emissions data, the emissions from Wise County still contribute to measured violations of 

the 2008 ozone NAAQS at monitors in neighboring counties. In making our final decision, we considered the reduced

emissions and the reduction in drilling activity since 2009.” The Governor’s comment letter dated February 29, 2012, pages 

17-21, also referred to other TCEQ documents that further support that DFW area is a NOx limited regime and changes to 

VOC levels do not result in much impact in ozone levels: TCEQ 2011 DFW 1997 8-hour Ozone Attainment Demonstration 

SIP – “APPENDIX E: Protocol for the Eight-Hour Ozone Modeling of the Dallas-Fort Worth Area,” and “APPENDIX D: 

Conceptual Model For The DFW Attainment Demonstration SIP Revision For The 1997 Eight-Hour Ozone Standard.”

2 See the final DFW TSD includes an evaluation of population data and traffic data for the 19 counties in the DFW CSA 

(TSD, pages 9-14). The TSD included data for Wise County and the DFW CSA (TSD, tables 6, 8 and 10).
Response: Petitioner raised the use of meteorological data during the public comment period and thus it 

is not an appropriate basis for reconsideration. We addressed this comment in the record, as detailed 

below. While we agree that Wise County is downwind of the violating monitors on some high ozone 

days in the DFW area, our analysis shows that it is upwind on other high ozone days. Therefore we 

believe that Wise County does contribute to violations of the ozone standard at nearby monitors. 

As our record states, “EPA evaluated available meteorological data to help determine how 

meteorological conditions, such as weather, transport patterns and stagnation conditions, would affect 

the fate and transport of precursor emissions contributing to ozone formation.” We note that based on 

past research by TCEQ and the EPA, light winds with weak frontal passages and conversion zones are a 

common meteorological condition that often leads to high ozone in the DFW area. (Final TSD, page 14). 

Our evaluation of the HYSPLIT figures (Final TSD pages 28-31) and the individual HYSPLIT modeling 

files indicates that light and variable winds occurred during some of the highest monitored ozone days 

and that some of these days included the transport of emissions from Wise County to the sites of the 

monitored exceedances. We also note that a review of the individual trajectory files, available in the 

docket, shows that several of the days during which trajectories passed through Wise County were also 

days that made up the first to fourth highest monitored values (which are the values used in establishing 

the Design Value) at the Eagle Mountain Lake and Keller monitors during the periods evaluated; these 

individual trajectory files were included in the supporting materials for the EPA’s preliminary and final 

designations. The Source Apportionment Modeling (Final TSD pages 15-20) also indicates that for a 

limited number of days during the period of the modeling analysis there were several occasions in 

which emissions from Wise County were transported to the nearby Eagle Mountain Lake and Keller 

monitoring sites (and other DFW area monitors) and contributed to the ozone exceedance levels. We 

note that the modeling analysis incorporates all NOx and VOC emissions from Wise County. 

While it is unclear precisely what portion of the Combined Statistical Area (CSA) the Petitioner is 

referring to when it suggests that “DFW area” produces enough emissions to result in a violation of the 

standard on high ozone days, we assume the Petitioner is referring to the portion of the DFW CSA 

designated nonattainment for the 1997 ozone NAAQS. While this may be true, it is not the sole factor 

we must evaluate as it does not address whether emissions from another county (such as Wise County) 

may also contribute to that violation. See Catawba County v. EPA, 571 F.3d 20 (D.C. Cir. 2009). 

III. Opportunity to Comment 

Issue: Petitioner claims that Wise County was not provided a sufficient review of the information that 

Wise County and TCEQ submitted. Further, the EPA did not offer a lawful opportunity for Wise County 

and others to be involved in the decision-making process or air quality analysis. Finally, the EPA has not 

directly shared its data and justification for designating Wise County as nonattainment, and there was no 

rebuttal process. 

Response: This issue relates to an opportunity to comment on information submitted to EPA during the 

comment period and the EPA’s evaluation of that information in the final rulemaking, including the final 

TSD. As a general matter, agencies are not required to provide an additional opportunity for public 

comment on material supporting a final rule, such as responses to comments or on information 

supporting a response to a comment. Such an approach would result in an unworkable endless 

rulemaking process. See Catawba, 571 F.3d at 50-51 (In rejecting a claim by New York that it should 

have been allowed additional input into the EPA’s decision to rely on a different monitor for evaluating 

contribution for the final designation than it did for the intended designation the court noted that such an 
ongoing exchange with the States is inconsistent with the CAA and that “Congress imposed deadlines 

on EPA and thus clearly envisioned an end to the designation process.”) See also International 

Fabricare Institute v. EPA, 972 F.2d 384, 399 (D.C. Cir. 1992) (notice and comment is not intended to 

result in “interminable back-and-forth”) and Community Nutrition Institute v. Block, 749 F.2d 50, 58 

(D.C. Cir. 1984) (agency is not required to provide additional opportunity to comment on its response to 

comments). This is particularly true when the material does not substantively change the proposed 

action of the agency or does not significantly change the basis for the Agency’s decision. With regard to 

the designation process, there is additional reason that an additional opportunity for public comment is 

not warranted. For designations, section 107(d) of the Clean Air Act (CAA) sets forth a detailed and 

specific process between the EPA and the states. This provision provides: (i) that Governors of states 

make the initial recommendations to the EPA for designations and boundaries; and (ii) that the EPA 

provide the states with 120 days notice of any intended modifications to the state recommendation prior 

to finalizing the designation. The 120-day notification process is for the purpose of providing “such 

State with an opportunity to demonstrate why any proposed modification is inappropriate.” The CAA 

does not expressly provide a role for any other entity (including local governments) and, moreover, 

expressly waives the notice and public comment process of the Administrative Procedure Act for initial 

designations for new or revised NAAQS. 

Although no public comment period is required, the EPA opted to provide such a comment period for 

the 2012 ozone designations. On December 20, 2011 (76 FR 78872), the EPA published a notice in the 

Federal Register inviting public comment from interested parties other than states and tribes on the 

letters sent to states with the intended designations. The notice provided that any comments should be 

received on or before January 19, 2012, but, in response to requests from several parties, including Wise 

County, the EPA extended the public comment period to February 3, 2012. (See 77 FR 2678, 

January 19, 2012). In addition, if an interested party requested to meet with the EPA, we provided 

such an opportunity. 

We further disagree that the EPA has not shared its justification for including Wise County as part of the 

designated nonattainment area. By its initial recommendation letter of March 10, 2009, the State of 

Texas recommended that the EPA designate the following counties as nonattainment for the DFW Area: 

Collin, Dallas, Denton, Ellis, Hood, Johnson, Kaufman, Parker, Rockwall and Tarrant. In a second letter 

of October 31, 2011, Texas revised is initial recommendation for the DFW area to exclude Hood County 

based on an assessment of 2008-2010 air quality data. On December 9, 2011, the EPA notified Texas of 

its preliminary response to recommendations from Texas indicating that it intended to modify the state's 

recommended area designations and boundaries for the DFW to include Hood and Wise Counties as 

nonattainment. The initial TSD provided an analysis to support the EPA’s intended designations. (See 

“Texas Area Designations for the 2008 Ozone National Ambient Air Quality Standards,” December 11, 

2011). We asked the state to submit any additional information by February 29, 2012, for the EPA to 

consider before it made final decisions on designations. 

Based on comments received from several parties, including the State of Texas, and additional 

information received during the public comment process for the designations, the EPA ultimately 

excluded Hood County and included Wise County in the DFW nonattainment area, as detailed in the 

TSD accompanying the final designations rule that was published in the Federal Register on April 30, 

2012, and (“Dallas-Fort Worth, Texas Final Area Designations for the 2008 Ozone National Ambient 

Air Quality Standards”).4

 

4

 Regarding the data used to inform our decision and the justification for the decision, we refer the petitioner to our TSD (for

air quality, emissions, and meteorological data) and RTC in the docket for this rulemaking, which provide our reasoning for 

the inclusion of Wise County. Our decisions concerning nonattainment designations for the DFW area are based on technical 
IV. Economic Harm 

Issue: Petitioner claims that a nonattainment designation would impose significant economic 

ramifications on citizens and businesses in Wise County. 

Response: This issue could have been raised during the comment period and in fact was raised by other 

parties, such as the State of Texas. Thus it is not an appropriate basis for reconsideration. As stated in 

the RTC, “under section 107(d) of the CAA, the EPA is required to designate as nonattainment an area 

that is violating a new or revised national ambient air quality standard or that contributes to a nearby 

violation. . . . In determining whether an area should be designated nonattainment, the EPA does not 

consider economic impacts because that is not relevant for determining whether an included area is 

violating the NAAQS or is a nearby area that is contributing to a violation as provided under CAA 

section 107(d).” See RTC pages 14-15. As such, the criteria for designations in Section 107 of the CAA 

do not provide for the EPA to consider economic effects. See RTC, pages 52-53. As we stated in our 

RTC document, we intend for the implementation rulemaking for the 2008 ozone NAAQS to address the 

minimum planning and emissions control obligations for areas designated nonattainment. As the EPA 

considers the required elements of implementation for the 2008 ozone NAAQS, it is our goal to propose 

approaches that provide flexibility and opportunity for efficiency to the extent such approaches are 

consistent with the CAA and will not jeopardize expeditious attainment of the public health and welfare 

goals of the CAA. To the extent the CAA does not mandate specific control measures, states may 

consider economic concerns in development of their state implementation plans to address air quality. 

(See RTC pages 14-15, 52-53, and 61). Finally, we note that DFW counties designated nonattainment, 

such as Dallas, Denton, Collin, Parker, Tarrant, etc., have continued to grow despite their previous 

nonattainment designations (see TSD page 10, Table 6). 

 facts pertaining to these specific counties, information supplied by the TCEQ, and the EPA’s independent evaluation as 

explained in the TSD. [RTC page 52, see, TSD pages 1-31]