In F R Cattle Co. v. State, 866 S.W.2d 200 (Tex. 1993), the State sued under the Texas Clean Air Act to enjoin the emission of odors from a large commercial calf-raising operation. The defendant filed a plea to the jurisdiction, arguing that the Act did not afford jurisdiction for the State's suit because the odors complained of were produced by natural processes and the Act expressly did not apply to such odors. The trial court sustained the plea after hearing evidence and making findings. The court of appeals reversed, holding that as a matter of law the odors from the calf-raising operation were not produced by natural processes. The Court concluded that the issue could not be determined as a matter of law. The Court reversed and remanded the case to the court of appeals to determine whether the evidence was factually sufficient to support the trial court's ruling. (866 S.W.2d at 205.)