Message Information

2G12Jtj[ 19	?11O: 17 

ATTENTION DOCKET ID NO. EPA-HO OAR-2008-0476 

RECEi\/F 

July 17, 2012 

Ms. Lisa Jackson 

Administ:rator of USEPA 

USEPA Headquarters 

12000 Pennsylvania Avenue, N.W. 

Mail Code: 1IO1A 

Washington, DC 20460 

RE: ATTENTION DOCKET ID NO. EPA-HQOAR-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 Look Local Wise County Task Force, Wise County, Texas, please accept this letter 

with attached Look Local Wise County Task Force Resolution No. I as official notice of request for 

re-review and reconsideration of your Conclusion Decision to add Wise County to the DFW Area
nonattainment designation. 

We do not believe that Wise County's inclusion was based upon valid scientific evidence and would 

invite the EPA to use hard data, rather than unreliable modeling, to reach its conclusions. 

Phil Major 

President 

Look Local Wise County Task Force 

P0 Box 2253 

Decatur, Wise County, Texas 76234 

Cc List: attached: 

I ackson.hsa@Epa.gov

McCarthv.gina@Epa.gov

Colemansam@Epa.gov Edlund.carl@Epa.gov

Dona1dsongiiv@Epa.gcy 

Kay.granger@mail.housgoy 

Chance.McNeelv@mail.house.gov

Tateieid@mailhouse.gqy 

tschirmer@gov.state.tx.us

Greg.abbott@txattorneygeneral.gov

Craigestessciate.stateJus 

Diannehelms@senate.state.tx.us

Caleb.troxclair@house.state.tx.us

Phi1.king@house.state.ty.us

Brvanshaw@tceg.texas gov 

Zak.covar@tceg.texas.gov

Steve.hagle@tccg.texas.gov

Donna.huff@tceg.texas.gov

Davjd.b1met@tcq.texgQI 

meastland@nctcog.org

bill.mcelhaney@co.wise.tx.us

krnccomis@citvofirndgeport.net

bemmons@citvofbridgeport.net

wmyers@bndgeportedc.com

jadams@decatur-edccom 

martin.woodruff(embargmail.com

bshannon@decaturtx.org

EPA resolution.doc 

OEX Processing Information
LOCAL WISE COUNTY TASK FORCE


WISE COUNTY, TEXAS 

RESOLUTION 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 Look Local Wise County Task Force, 

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, Look Local Wise County Task Force 

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 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 (DEW) Area list of designated nonattainment 

of the 2008 eight-hour ozone standard; and
WHEREAS, On October 31, 2011, the Texas Commission on EnvirDnmental 

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

technical documentation, as to why Wise County should not be designated as part of 

the DEW 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 DEW non-attainment 

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

(VMT) of 969 million miles compared to the DEW 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 DFW ozone-formation.; and 

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

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

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

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

located within Wise County) and given the DFW 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 updated 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 Look Local Wise County Task Force 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 I 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 Look Local Wise County Task Force 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 respecifully requesting reconsideration of the EPA 2012 designation of inclusion of Wise County, Texas into the 

Dallas-Fort Worth Area (DFW) Nonattainment Regional Area; and 

WHEREAS, a nonattainment designation would impose unwarranted significant 

economic ramifications on members of the Look Local Wise County Task Force, and 

citizens of 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 HEREBY RESOLVED BY THE LOOK LOCAL WISE 

COUNTY TASK FORCEOF, WISE COUNTY, TEXAS: 

Section 1. The Look Local Wise County Task Force strongly and respecifully 

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. 

Section 2. The Look Local Wise County Task Force 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. 

Section 3. The Look Local Wise County Task Force 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. 

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.
Section 5. This resolution was voted upon and unanimously approved by the 

Board of Directors of the Look Local Wise County Task Force to be 

in effect immediately upon its adoption; said Directors being: Phil 

Major, Cyd Bailey, Carey Williams, William Myers, Jocly Adams, 

Tiffany Evans, Lisa Caraway, Frieda Haley, Amber Fogelman, Joe 

Neil Henderson, Amanda Williams, Debroah Mann, Susan Miller, 

Caleb Lahue. 

I, the undersigned, do hereby certify that this ORDER was resolved and adopted by the 

attending Look Local Wise County Task Force Directors, so named hereinabove, and, 

thus PASSED AND APPROVED in a regular Look Local Wise County Task Force 

Directors' Meeting this 17th day of July, 2012. 

Phil Major, President 

Look Local Wise County Task Force 

Wise County, Texas