Richard A. Hyde, P.E., in His Official Capacity as Executive Director of the Texas Commission on Environmental Quality; And the Texas Commission on Environmental Quality v. Harrison County, Texas

Opinion

ACCEPTED 15-24-00014-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 3/6/2025 10:46 AM Ron Beal CHRISTOPHER A. PRINE Professor Emeritus & Attorney at Law CLERK 2530 Wooddale Circle RECEIVED IN 15th COURT OF APPEALS Waco, TX 76710 AUSTIN, TEXAS (254)-366-4198 3/6/2025 10:46:23 AM ron_beal@baylor.edu CHRISTOPHER A. PRINE Clerk

15th Court of Appeals March 6, 2025 P.O. Box 12852 Austin, TX 78711

Re: TCEQ v. Harrison Cty. Case No: 15-24-00014-CV Amicus Brief

Dear Honorable Justices of the 15th Court of Appeals:

I have received no compensation for the preparation, writing and filing of this amicus brief. The entire contested case process which was intended by the Legislature to secure fair and reasonable hearings is truly predicated on the last step that the agency must complete; to set forth in writing the exact law applicable and what it means, then set forth the exact underlying, basic facts the agency determined to be proven by a preponderance of the evidence, and to finally apply the law to those facts to determine the result. Without these detailed findings, the hearing is a farce, and any appeal is a farce for a party has no meaningful basis to establish that harm has occurred. This Court must declare any order that does not comply with 2001.141 to be void or the complete Legislative intent will be eviscerated. Sincerely, /s/ Ron Beal Ron Beal Professor Emeritus of Law Bar No. 24005041 2530 Wooddale Circle Waco, TX 76710 (254) 366-4198 ron_beal@baylor.edu

CERTIFICATE OF COMPLIANCE I certify that this document was produced on a computer using Microsoft Word and contains 251 words, as determined by the computer’s software’s word count function, excluding the sections of the document listed in Texas Rules of Appellate Procedure 9.4(i)(1). CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document has been served on March 6, 2025, by e-file and/or electronic mail in accordance with the Texas Rules of Civil Procedure to the following:

Appellant TCEQ Jake Marx J. Amber Ahmed Office of the Attorney General P.O. Box 12548, (MC-066) Austin, TX 78711-2548

Cross Appellant/Appellee: Volvo Cars

James P. Allison 1301 Nueces Street, Suite 201 Austin, TX 78701 /s/ Ron Beal

Ron Beal Bar No. 24005041 Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.

Ronald Beal on behalf of Ronald Beal Bar No. 24005041 ron_beal@baylor.edu Envelope ID: 98138001 Filing Code Description: Letter Filing Description: Letter Status as of 3/6/2025 10:51 AM CST

Associated Case Party: Harrison County

Name BarNumber Email TimestampSubmitted Status

James P. Allison j.allison@allison-bass.com 3/6/2025 10:46:23 AM SENT

Legal Secretary allison.bass@allison-bass.com 3/6/2025 10:46:23 AM SENT

Julia McVey j.mcvey@allison-bass.com 3/6/2025 10:46:23 AM SENT

Susana Naranjo-Padron s.naranjo-padron@allison-bass.com 3/6/2025 10:46:23 AM SENT

Case Contacts

Name BarNumber Email TimestampSubmitted Status

irene tong irene.tong@oag.texas.gov 3/6/2025 10:46:23 AM SENT

Jake Marx jake.marx@oag.texas.gov 3/6/2025 10:46:23 AM SENT

Shelby Thompson shelby.thompson@oag.texas.gov 3/6/2025 10:46:23 AM SENT

James ScottMcCarley scott.mccarley@oag.texas.gov 3/6/2025 10:46:23 AM SENT