CITY OF BRIDGEPORT 

Ms. Lisa Jackson 

Administrator of USEPA 

USEPA Headquarters 

12000 Pennsylvania Avenue, N.W. 

Mail Code: IIO1A 

Washington, DC 20460 

RE: ATTENTION DOCKET ID NO. EPA-HQ_OAR-2008-0476. 

RESOLUTION OPPOSITION WITH REQUEST FOR RECONSIDERATION AND 

CALL FOR CONGRESSIONAL INTERVENTION IN THE MATTER OF WISE 

COUNTY, TEXAS BEING DESIGNATED AS MEMBER OF DALLAS-FORT 

WORTH (DFW) AREA NAAQS 2012 EIGHT HOUR OZONE NONATTAINMENT 

AREA. 

Director Jackson: 

On behalf of the City of Bridgeport, Texas, located in Wise County, please accept this 

letter with attached Resolution No. 2012-16 as official notice of the City's request for rereview and reconsideration of your Conclusion Decision to add Wise County to the DFW 

Area nonattainment designation. 

This resolution was adopted by the Bridgeport City Council during the regular meeting 

held on Tuesday, July 17, 2012. It is in support of Wise County Commissioners Court 

Resolution No. FYI 2-07 adopted on May 29, 2012 and mailed to you on June 15, 2012. 

If you have any questions regarding this resolution, please contact me at 940-683-3402 

or via e-mail at Imceachern(cit yofbridqeport.net. The City of Bridgeport appreciates 

your consideration of this matter. 

cc: (see next page) 

900 THOMPSON ST. BRIDGEPORT, TX 76426 '940.683.3400 . 940.683.3401 


www. cityofbridgeport. net
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tschirmergov.state.tx. us 

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biII.mceIhaney(co.wise.tx.us
RESOLUTION NO. 	C

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF 

BRIDGEPORT, TEXAS, IN OPPOSITION OF THE CONCLUSION BY 

THE ENVIRONMENTAL PROTECTION AGENCY (EPA) TO 

DESIGNATE WISE COUNTY, TEXAS AS AN ADDITION TO THE 

DALLAS-FORT WORTH AREA NAAQS 2012 EIGHT-HOUR OZONE 

NONATTAINMENT AREA. 

In the matter of the United States Environmental Protection Agency (EPA) Responses 

to State and Tribal 2008 Ozone Designation Recommendations and its conjunctive 

conclusive decisions made from the EPA final "2012 Spring Review" of said 2008 

Ozone Designation Recommendations in regards to ATTENTION DOCKET ID NO. 

EPA-HQ-OAR-2008-0476, the City of Bridgeport, Wise County, Texas, respectfully 

submits this vigorous Resolution of Protest to the EPA and associated Administrative 

Officials, along with a Call for warranted United States Congressional Intervention of the 

EPA 2012 designation of inclusion of Wise County, Texas into the Dallas-Fort Worth 

Area (DFW) Nonattainment Regional Area. 

With this Resolution of Protest, the City of Bridgeport, Texas requests a full re-review by 

the EPA of the Technical Analysis Support Documentation and other associated 

Scientific Facts as were duly and timely submitted during the called EPA Comment 

Periods, by both Wise County, Texas and the Texas Commission on Environmental 

Quality (TCEQ). 

Thus, the basis of this Resolution with call for review is formulated on justification of the 

previous actions and is so cited as being as follows: 

WHEREAS, On or about May 1, 2012, the Environmental Protection Agency 

(EPA) announced that Wise County, Texas, is to be designated as an addition to the 

present nine (9) county Dallas-Fort Worth (DFW) Area list of designated nonattainment 

of the 2008 eight-hour ozone standard; and 

WHEREAS, On October 31, 2011, the Texas Commission on Environmental 

Quality (TCEQ) recommended to the appropriate EPA departments, with supporting 

technical documentation, as to why Wise County should be designated as part of 

the DFW non-attainment area; and 

WHEREAS, From October 2011 through February 2012 and during the EPA's 

designated public comment period, Wise County and the TCEQ presented the EPA with 

additional support documentation which clearly demonstrates that the EPA's 

assessment of it own emission and meteorological factors (EPA'S Factor 2: Emissions 

and Emissions-Related Data) were either ignored, incorrect, and/or did not include 

revised TCEQ scientific and monitoring data, including TCEQ report revisions related to 

the oil and gas sector pneumatic emissions for the Periodic Emissions Inventory; and
WHEREAS, According to EPA data, Wise County's minute 2010 population was 

59,127, (or only approximately 0.95% of the current nine county DFW non-attainment 

population of approximately 6.2 million) and Wise County's 2008 vehicles miles traveled 

(VMT) of 969 million miles compared to the DFW area's 61,900 million (61.9 Billion) 

VMT reasons that it would be highly unexpected that VMT emissions for Wise County 

would have any significant contribution to DEW ozone-formation.; and 

WHEREAS, Data from the EPA's Factor 3: Meteorology (weather/transport 

patterns for the DFW Area), clearly shows that prevailing winds are from the east and 

southeast, meaning that Wise County is usually downwind of the DFW urban plume and 

unlikely to contribute to high ozone values (There are currently no ozone monitors 

located within Wise County) and given the DEW area's large population, automobile 

fleet, and variety of industry, the DEW area produces enough emissions on its own to 

result in a high ozone day - without the contributions of any of Wise County's factor 

numbers of population, VMT, and oil and gas activities.; and 

WHEREAS, under the TCEQ's Supplemental Analysis on Factors 2; Emissions 

and Emissions Related Data and Factor 3: Meteorology (weather/transport patterns) for 

the DEW area, the TCEQ utilized an additional modeling tool, Comprehensive Air 

Quality Model with extensions (CAMx) Anthropogenic Precursor Culpability Assessment 

(APCA) as additional complementary information to the meteorology and emissions 

factors. The EPA did not use the u pdated oil and gas sector pneumatic emissions being 

submitted by the TCEQ in October 2011 to the EPA for Periodic Emissions Inventory 

from scientific and technical modeling and source apportionment analysis as provided, 

and therefore the VOC emissions as calculated by the stated resources/analysis 

methods are most likely overestimated in the modeling; and 

WHEREAS, the City of Bridgeport, Texas has concluded from all the noted 

information and attached reports reviewed in other Analysis and Reports, along with the 

stated comments and conclusions as contained herein, that the EPA has not provided 

the citizens of Wise County a sufficient and accurate review of the evidence and data as 

submitted by Wise County and the TCEQ to support its conclusive decision to add Wise 

County to the designated nonattainment area of DEW Region, and therefore has 

denied, with prejudice, a lawful offer or opportunity to interact and work together with 

Wise County's local government officials, the State of Texas TCEQ, industry leaders, 

Economic Development Boards, Chambers of Commerce, and other stakeholders of 

Wise County in regards to EPA's air quality monitoring / decision making process, nor 

has EPA directly shared its specific data and justification leading to said Conclusion to 

place Wise County in the nonattainment region with no rebuttal process; and, 

WHEREAS, the City of Bridgeport, Texas fully agrees with and supports Wise 

County Judge Bill McElhaney's previous comments to the EPA, including scientific and 

technical data, other pertinent information, and the June 15, 2012, Resolution of the 

Wise County Commissioners Court respectfully requesting re-consideration of the EPA 

2012 designation of inclusion of Wise County, Texas into the Dallas-Eort Worth Area 

(DEW) Nonattainment Regional Area; and 

Resolution Opposing Inclusion in the DFW Nonattainment Area 	 2
WHEREAS, a nonattainment designation would impose unwarranted significant 

economic ramifications on members of the City of Bridgeport, Texas, citizens of the City 

of Bridgeport Area, and Wise County in general, and that it is clear that EPA lacks 

sufficient scientific data to justify this Conclusion decision in regards to Wise County's 

inclusion designation. 

NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY 

OF BRIDGEPORT, TEXAS: 

That the City of Bridgeport strongly and respectfully requests that the EPA 

Director and other Congressional Officials remove Wise County from its Conclusion list 

of designated nonattainment Counties within the DFW Area immediately, being for 

those reasons and associated justification so stated within this Resolution. 

That the City recognizes the benefits of Wise County governments and 

leadership working with the Texas Commission on Environmental Quality (TCEQ) and 

to develop and implement plans, policies, programs and projects to improve the air 

quality in the Dallas-Fort Worth Metropolitan Area and comply with EPA regulations. 

That the City affirms its full support for Wise County governments to work with 

the TCEQ and EPA in apprising and determining true present and future statuses of air 

quality in Wise County, Texas. 

That this resolution will also be transmitted to the TCEQ Commissioners, the 

Governor of the State of Texas, the North Central Texas Council of Governments, other 

Entities and concerned stakeholders of Wise County; and all of Wise County's 

Honorable Federal and State Legislative Representatives. 

That this resolution was voted upon and unanimously approved by the City 

Council of the City of Bridgeport to be in effect immediately upon its adoption; said City 

Council members being: Scott Cheves, Kathy Kennedy, Ilene Enochs, Bobby Brazier 

and Billy Fred Walker. 

Resolution Opposing Inclusion in the DFW Nonattainment Area	 3
eith McComis, Mayor 

Jesica Mc'Eachern, City Secretary 

DULY PASSED AND APPROVED BY THE CITY COUNCIL OF THE CITY OF 

BRIDGEPORT, TEXAS, BY A VOTE OF 3 TO 0 , ON THIS THE (1' DAY OF ___________,2012.

APPROVED: 

Resolution Opposing Inclusion in the DEW Nonattainment Area 4