0

Appendix E

BenMAP Health 

Benefit Analysis

2012 PM2.5 Plan

SJVUAPCD
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

Appendix E: BenMAP Health Benefit Analysis

2012 PM2.5 Plan

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E-1 Appendix E: BenMAP Health Benefit Analysis

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Appendix E: BenMAP Analysis

This section of the report presents the empirical results of the District’s estimation of the 

health benefits from the 2012 PM2.5 Plan via application of the BenMAP model 

developed by US EPA. BenMAP is a sophisticated computer software model that is 

well-suited for estimating the regional health benefits from improved air quality resulting

from controls and incentives put in place by the 2012 PM2.5 Plan as well as concurrent 

controls on PM2.5 originating from other plans.

1 2

 The timeframe for the analysis 

extends from the base year of 2007 until the attainment date of 2019. In short, the 

BenMAP analysis seeks to answer two questions: First, given the reductions in 

population exposure to PM2.5 by 2019 that will result from this combined body of 

control and incentive measures, how much reduction in specific measures of disease 

and premature mortality (such as daily hospital admissions for asthma) will occur by 

2019 when compared to what was observed in 2007? And second, what is the 

economic value of those avoided cases of disease, aggravated symptoms, lost work, 

and premature mortality?

E.1 Background 

Over course of the past decade, ongoing progress in the fields of epidemiology and 

geographic information systems (GIS) have resulted in the development of computer 

models that are capable of estimating the health benefits of improved air quality with 

reasonable accuracy when properly applied. These models estimate the number of 

avoided cases of certain diseases and other health impairment categories, known as 

health endpoints, which result from a specified reduction in exposure to criteria air 

pollutants, e.g. ozone and fine particulates (PM2.5). This reduction could be the result 

of an individual emission control rule with a substantial reduction in annual population 

exposure or, in this case, a set of controls comprising a regional component of a SIP. 

For example, a BenMAP application to an individual rule has been conducted by the 

Central Valley Health Policy Institute, California State University, Fresno under contract 

to the District.3 The study isolated the reduction in annual PM 2.5 exposure in the 

Bakersfield and Fresno/Clovis metro areas that results from daily restrictions in 

 

1

See Abt Associates Inc. (2012) BenMAP Environmental Benefits Mapping and Analysis Program: User’s Manual. 

Prepared for the Office of Air Quality Planning and Standards, U.S. EPA, Research Triangle Park, NC (October). 

Available at: http://www.epa.gov/air/benmap/models/BenMAPManualOct2012.pdf. See 

http://www.epa.gov/air/benmap/ for more information on BenMAP, downloading the program, and for technical 

documents. BenMAP version 4.0 was used in this analysis.

2

SJVAPCD Health Science Advisor, David Lighthall, Ph.D., received BenMAP training from the Community Modeling 

and Analysis System in Chapel Hill, NC under contract to the U.S. EPA. Additional technical assistance for this 

analysis was provided to the District by Charles Fulcher and Neal Fann, EPA Office of Air Quality Planning and 

Standards.

3

Lighthall, D., D. Nunes, and T. Tyner. (2008) Environmental Health Evaluation of Rule 4901: Domestic Wood 

Burning in the San Joaquin Valley. Central Valley Health Policy Institute, California State University, Fresno.

Conducted for and funded by the San Joaquin Valley Air Pollution Control District. See http//www.cvhpi.org
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

E-2 Appendix E: BenMAP Health Benefit Analysis

2012 PM2.5 Plan

domestic wood burning imposed by Rule 4901 and the resultant health benefits. Rule 

4901’s restrictions in wood burning were estimated to provide a large (13% or more) 

reduction in annual exposure to PM 2.5 in the study areas, resulting in substantial 

estimated reductions in premature mortality and other health endpoints such as asthma 

attacks and chronic bronchitis. A comparable health benefit estimation model was 

employed by Hall et al. (2008) to estimate the health and economic benefits of 

achieving federal ozone and PM2.5 standards in the San Joaquin Valley and South 

Coast air basins.4

E.2 How BenMAP Works 

There are two central objectives in BenMAP analyses. First, the program estimates 

reductions in the incidence rates5of what are known as health endpoints (i.e. avoided 

cases of disease, premature death, impaired health, and aggravation of symptoms) 

based on a specified improvement in ambient air quality for a target area and its 

population. The degree of improvement is based on statistical relationships between 

exposure to a given criteria pollutant and health that are derived from previously 

published epidemiological studies (see further discussion below). The second objective 

involves assigning an economic value to those avoided cases of health problems, again 

based on previously published economic analyses of the health endpoints in question. 

For example, in order to accurately estimate reductions in daily asthma ER admissions

attributable to improved air quality, it is necessary to determine the incremental 

decrease in the incidence rate for asthma ER admissions that occurs in response to an 

incremental decrease in exposure to PM2.5. This metric, known as a concentration 

response function or CRF, is derived from studies that compare daily or annual rates of

disease with variations in exposure to PM2.5. Examples of CRFs derived from various 

epidemiological studies are depicted in Figure E-1 below. Note that, for the most part, 

the relationship between PM2.5 concentrations and incidence levels are linear, meaning 

that each incremental increase in PM2.5 results in the same incremental increase in the 

disease incidence rate irrespective of the PM2.5 concentration. EPA has incorporated 

into BenMAP CRFs for a range of health endpoints selected from among the top peerreviewed epidemiological studies in the U.S. As a result, BenMAP users are able to 

estimate with reasonable accuracy the reductions in daily or annual incidence of a given 

health endpoint that would be expected from a given reduction in exposure to PM2.5. 

 

Key elements of the BenMAP analytical process include the following: First, BenMAP 

users must specify the percentage improvement in ambient air quality for the area in 

question, typically counties. PM2.5 or ozone concentration data is either imported from 

external modeling sources or generated from a national set of air pollution monitoring 

data that is pre-loaded into BenMAP. The latter was used in this analysis. Rather than 

 

4 Hall, J., V. Brajer, and F. Lurmann. (2008) The Benefits of Meeting Federal Clean Air Standards in the South Coast 

and San Joaquin Valley Air Basins. California State University--Fullerton, Institute for Economic and Environmental 

Studies. See http://business.fullerton.edu/centers/iees/

5

The incidence rate is defined by the percentage of a given population, e.g. 10,000 or 100,000 people, who 

experience the health endpoint on a given day, year, or other time period.
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E-3 Appendix E: BenMAP Health Benefit Analysis

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rely on a single monitor to determine average county exposure, BenMAP also has the 

ability to estimate overall county PM2.5 exposure by averaging observed concentrations 

from all monitors in the county. At the same time, this averaging takes into 

consideration any differences in population density surrounding each monitor in the 

county. The net result are two air quality grids or population exposure surfaces for each 

county. First, a baseline grid is created that contains the pre-existing pollutant exposure 

level and baseline incidence rates for health endpoints as well as a control grid

containing reductions in average pollutant exposure as specified by the analyst.

Next, the BenMAP analyst must select appropriate CRFs for target endpoints prior to 

estimating the reduction in negative health effects that results from reduced county-level 

exposure to ozone or PM 2.5. This requires the analyst to select CRFs from one or 

more prior health studies for each health endpoint. With technical assistance from EPA 

staff, the District has been able to import into BenMAP the CRFs for five endpoints that 

are derived from the 2010 San Joaquin Valley epidemiological study (based on the 

combined populations of Bakersfield, Fresno, and Modesto).6 The endpoints, depicted 

in shaded boxes in Table E-1, include myocardial infarction, asthma ER admissions for 

ages 0-19, asthma ER admissions for ages 20+, asthma hospital admissions for ages 0-

19, and asthma hospital admissions for ages 20+. 

In the next step, BenMAP estimates the county-level reduction in health effects, as 

defined by incidence reductions for each health endpoint, for the target county 

populations and timeframe that results from the specified decline in PM2.5 exposure. 

Custom demographic information can be employed or default population data contained 

within BenMAP can be used for past, current, and future years based on population 

growth functions in the program. A simplified example of estimating the health effect 

can be summarized as follows:

Health Effects = Health Baseline Incidence × Air Quality Change × Health 

Effect Estimate × Exposed Population 

1. Health Baseline Incidence: The health incidence rate is an estimate of the 

average number of people that die or become ill over a given period of time and 

for a standard population unit that exists prior to any change in air quality, e.g. 

220 cases of asthma per 1,000 individuals per year.

2. Air Quality Change (Delta): The air quality change is the difference between the 

starting air pollution level (i.e. the baseline), and the air pollution level due to 

reduced exposure (i.e. the control).

3. Health Effect Estimate: The health effect estimate is an estimate of the 

percentage reduction in adverse health effects due to unit reductions in ambient 

air pollution. CRFs from prior epidemiological studies provide the source for 

effect estimates in BenMAP.

 

6 Capitman, J.A., & Tyner, T.R. (2011). The Impacts of Short-Term Changes in Air Quality on Emergency Room and 

Hospital Use in California's San Joaquin Valley. Fresno, CA: Central Valley Health Policy Institute for the San Joaquin 

Valley Air Pollution Control District. Retrieved from http://www.fresnostate.edu/chhs/cvhpi/publications/index.html
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

E-4 Appendix E: BenMAP Health Benefit Analysis

2012 PM2.5 Plan

4. Exposed Population: The exposed population is the number of people affected 

by the improvement in air quality. 

Finally, BenMAP calculates the economic value of avoided health effects due to 

reduced ozone or PM2.5. To summarize:

Economic Value = Health Effect × Value of Health Effect

There are several ways to calculate the economic value of health effect changes

depending on the nature of the health endpoint. For example, the value of an avoided 

premature death is generally calculated using the Value of a Statistical Life (VSL). The 

VSL is an economic estimate of the social value of premature death that is used to 

guide policy makers in making public investments in public health or safety. VSL 

estimates range from $3.8 to $8.9 million per case.7 VSL estimates are based on either 

contingent valuation surveys or wage risk studies.8 In the case of non-fatal health 

endpoints, the economic benefits are based on (1) cost of illness (COI) estimates from 

national healthcare datasets, (2) lost wages based on San Joaquin Valley wage rates, 

or (3) estimates from survey research regarding what individuals are willing to pay to 

avoid an illness such as acute bronchitis, known as willingness to pay (WTP). These 

economic valuation functions for key health endpoints are contained within BenMAP 

and can also be imported for custom analyses.

E.3 Summaries of Health Endpoints Used in the Analyses

1. Acute Bronchitis (Children 8-14): Acute bronchitis is an inflammation of the large 

bronchi (medium-size airways) in the lungs that is usually caused by viruses or 

bacteria and may last several days or weeks.9 PM 2.5 exposure has the effect of 

increasing vulnerability to infection. Health savings in BenMAP are based on 

health surveys of patients’ willingness to pay (WTP) estimates for their child 

avoiding a six day illness.

2. Acute Myocardial Infarction (AMI or non-fatal heart attack; Adults over 19; ValleyBased CRF): Reflecting the large body of experimental, clinical, and 

epidemiological evidence of cardiovascular (CV) impacts from elevated PM2.5, 

AMI is a key health endpoint in assessing the health benefits from reduced 

PM2.5. AMI results from reduced blood supply to the heart, typically from a 

 

7

For a further discussion of the VSL, see BenMAP Technical Appendices. Office of Air Quality Planning and 

Standards, U.S. EPA. Prepared by Abt Associates, Inc. September 2008. Available at: 

http://www.epa.gov/air/benmap/docs.html 

8 Contingent valuation studies are based on surveys that ask how much individuals would be willing to pay to avoid a 

given health problem. Wage risk studies estimate the value of a single life by looking at the premium paid to workers 

in occupations that face an increased risk of occupational mortality. For example, a high rise steel worker accepts a 

1 in 1,000 (0.001 probability) greater chance of occupational mortality in return for an annual wage premium of 

$5,000. The VSL in this situation is then based on multiplying that incremental risk to equal a probability of 1, i.e. 

1,000 X $5,000 = $5,000,000.

9 Wenzel RP, Fowler AA (2006). "Clinical practice. Acute bronchitis". N. Engl. J. Med. 355 (20): 2125–30. 

doi:10.1056/NEJMcp061493. 
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E-5 Appendix E: BenMAP Health Benefit Analysis

2012 PM2.5 Plan

blocked coronary artery. In this case, the CRF was based on the 2011 Valley 

Epidemiological Study referenced above, which relied on observed hospital 

admissions in Bakersfield, Fresno, and Modesto. Valuation estimates for AMI 

are based on lost wages and cost of illness (COI).

3. Acute Respiratory Symptoms (Adults 18-64): Individuals with pulmonary 

vulnerability such as asthmatics often experience respiratory impairment that 

does not result in medical treatment or lost work but are nonetheless results in a 

restriction of activity or other impairment. Studies have shown that the frequency 

of these symptoms, including wheezing, coughing, and shortness of breath, is 

relatively high. Valuation is based on WTP to avoid symptoms for a day.

4. Asthma Exacerbation (Children 6-18): This endpoint is defined by incidence of 

shortness of breath and/or experiencing an asthma attack. The valuation 

estimate is based on parents’ WTP for their child avoiding one or more 

symptoms on a given day.

5. Emergency Room Visits, Asthma (Ages 0-19 and 20-99, Valley-Based CRF): 

The incidence reduction estimate is divided into two age groups. However, these 

age groups are combined in the valuation (health savings) estimate. Health 

savings are derived from COI surveys. 

6. Hospital Admissions, Asthma (Ages 0-19 and 20-99, Valley-Based CRF): The 

incidence reduction estimate is divided into two age groups. However, these age 

groups are combined in the valuation (health savings) estimate. Health savings 

are derived from COI surveys.

7. Hospital Admissions, Cardiovascular (Adults 18-99): This endpoint is based on 

increases in admission rates for all CV cases except acute myocardial infarction 

for ages 18-99. Valuation results are based on COI and wage loss estimates.

8. Hospital admissions, Respiratory (Adults 18-64): This endpoint is based on 

admissions due to chronic lung disease. Health costs are based on average 

COI. 

9. Lower Respiratory Symptoms (Children 7-14): This endpoint is defined by the 

existence of two or more symptoms including chest tightness, coughing up 

phlegm, and wheeze. The valuation estimate is based on parents’ WTP for their 

child avoiding two or more symptoms on a given day.

10.Upper Respiratory Symptoms (Children 9-11): This endpoint is defined by the 

existence of two or more symptoms including throat congestion, coughing, 

shortness of breath, wheezing, and several others. The valuation estimate is 

based on parents’ WTP for their child avoiding two or more symptoms on a given 

day. 

11.Work Loss Days (Adults 18-64): This is an estimate of work days lost due to 

short-term illness, most typically due to respiratory impairment. Valuation is 

based on the county median daily wage.

12.Premature Mortality (Adults 30-99): Premature death is defined in 

epidemiological studies as a death from an air pollutant-related cause prior to 
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E-6 Appendix E: BenMAP Health Benefit Analysis

2012 PM2.5 Plan

their expected age of death, the latter based on actuarial research. Typically this 

period falls between 10 and 15 years before normal life expectancy. There are a 

number of epidemiological studies that have analyzed the mortality impact of 

elevated PM2.5 exposure in relatively large samples of the U.S. urban 

population. Because the most robust statistical relationships with premature 

mortality have been found with ischemic heart disease10 and lung cancer, CRFs 

for these endpoints were selected. Conversely, there is less compelling 

statistical evidence regarding elevated PM2.5 and all-cause mortality and this 

CRF option was not selected. BenMAP valuation of the social cost of avoided 

mortality was based on the average of 26 VSL studies.

E.4 Incidence Results 

Mean 2019 annual incidence reductions by county for the full set of endpoints used in 

the analysis are presented in Table E-1.

11

 The results for the non-fatal endpoints are 

displayed in Figure E-2 and E-3 and the avoided fatality results are shown in Figure E-4. 

These reductions are based on county by county estimates of reduced annual daily 

exposure to PM2.5 that are derived from ARB’s modeling estimates of cumulative 

emission reductions and lower design values resulting from control measures in the 

2012 PM2.5 Plan and related controls from previously adopted plans. As noted, the 

base year for estimating reduced annual daily exposure is 2007. Differences across 

county estimates reflect the combined effect of (1) population differences ranging from a 

high in Fresno County to a low in Madera County and (2) different percentage 

reductions in annual daily PM2.5 for each county depending on the ARB modeling 

results. In general, counties with the highest design values experienced proportionally 

higher percentage reductions in annual daily PM2.5 by 2019. 

Of note is the BenMAP estimate of 671avoided cases of pre-mature mortality. This 

estimate is roughly consistent with comparable estimates of mortality reductions from 

PM2.5 reductions that were conducted by ARB (2010) and Hall et al. (2008; cited 

above).12 It should be noted that for several of the health symptom endpoints, incidence 

reductions are based on the relatively narrow age ranges—reflecting the studies upon 

which the CRF was based. As a result, these endpoint results reflect a proportional 

underestimation of health benefits for the entire Valley population, both in terms of the 

actual incidence reductions and the corresponding economic benefits.

 

10 Ischemic heart disease is characterized by reduced blood supply to the heart muscle usually due to coronary artery 

disease (atherosclerosis of the coronary arteries). Its risk increases with age, smoking, hypercholesterolaemia (high 

cholesterol levels), diabetes, and hypertension (high blood pressure), and is more common in men and those who

have close relatives with ischemic heart disease. See: http://en.wikipedia.org/wiki/Ischaemic_heart_disease

11 Standard deviations for incidence estimates are not included here but are available upon request.

12 CARB (2010) Estimate of Premature Deaths Associated with Fine Particle Pollution (PM2.5) in California Using a 

U.S. Environmental Protection Agency Methodology. Sacramento, CA: California Air Resources Board. Available at: 

http://www.arb.ca.gov/research/health/pm-mort/pm-report_2010.pdf
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E-7 Appendix E: BenMAP Health Benefit Analysis

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E.5 Valuation Results 

Subsequent to estimating the annual reductions in incidence of the selected health 

endpoints, BenMAP assigns a dollar value to each endpoint for each county based on 

the cost factors applicable to the endpoint in question. The valuation results for the 

non-fatal endpoints are displayed in Table E-2 and the county fatality valuation is shown 

in Figure E-5. By 2019, county by county reductions in PM2.5 attributable to total 

emission reductions from the 2012 PM2.5 Plan and related PM2.5 control measures are 

estimated to result in over $102.15 million in annual avoided health costs associated 

with non-fatal health endpoints. Because BenMAP cannot capture the full range of 

health impacts and costs, such as foregone career or recreational benefits due to 

impaired health, as well as the constricted age range for some symptom-related 

endpoints as discussed above, this figure most certainly underestimates the full benefits 

of attaining the 2006 PM2.5 standard in 2019 by a substantial margin. 

In the case of premature mortality, a VSL of $7.99 million per case in 2010 dollars was 

used. The estimated social benefit from the 671 cases of avoided deaths is 

approximately $5.36 billion. Irrespective of the logic of assigning a dollar value to each 

case of avoided death in BenMAP, the intrinsic value of saving over 600 lives annually 

by 2019 is arguably the single most compelling justification for the 2012 PM2.5 Plan. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

E-8 Appendix E: BenMAP Health Benefit Analysis

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Figure E-1 Selected Concentration Response Functions

Reprinted from Pope, C.A., and D. Dockery (2006, p. 720) Health Effects of Fine 

Particulate Air Pollution: Lines that Connect. Journal of Air and Waste Management 

Association 56: 709-742.
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E-9 Appendix E: BenMAP Health Benefit Analysis

2012 PM2.5 Plan

Table E-1 BenMAP Estimates of Mean Annual Reductions in Health Effects Under the Plan by 2019

Health Endpoint Totals Fresno Kern San 

Joaquin Stanislaus Tulare Merced Kings Madera

Acute Myocardial 

Infarction 93 29 25 9 7 11 3 4 4

HA, Asthma 0-19 131 56 28 9 11 13 4 4 6

HA, 

Cardiovascular 175 47 51 16 14 26 6 10 5

HA, Asthma 20-99 246 64 77 30 16 35 11 7 6

ER Visits, Asthma 

20-99 407 123 94 48 28 53 22 23 16

ER Visits, Asthma 

0-19 699 252 160 47 44 90 36 35 37

Acute Bronchitis 1,498 404 406 149 127 222 72 64 54

Upper Respiratory 

Symptoms 15,523 4,206 4,294 1,482 1,260 2,334 728 667 552

Lower Respiratory 

Symptoms 19,011 5,093 5,207 1,887 1,595 2,829 912 807 681

Asthma 

Exacerbation 114,376 31,144 31,124 11,269 9,469 17,037 5,445 4,867 4,021

Work Loss Days 125,138 34,816 35,300 11,752 10,077 16,882 5,367 6,303 4,641

Mortality 671 172 207 72 61 86 26 23 24

Note: Shaded health endpoints are based on concentration response functions (CRF) derived from the 2011 Valley 

Epidemiological Study conducted by CSU Fresno and UCSF-Fresno.
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E-10 Appendix E: BenMAP Health Benefit Analysis

2012 PM2.5 Plan

Figure E-2 Avoided Disease Incidence by 2019 due to Lower PM2.5 Exposure

Figure E-3 Reduced Disease Symptoms and Lost Work by 2019

93

131 175

246

407

699

1,498

0

200

400

600

800

1,000

1,200

1,400

1,600 (Cross-hatched endpoint reductions are based on CRFs from the 

2011 Valley Epididemiological Study)

15,523 19,011

114,376

125,138

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

Upper Respiratory

Symptoms

Lower Respiratory

Symptoms

Asthma

Exacerbation

Work Loss Days

 
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E-11 Appendix E: BenMAP Health Benefit Analysis

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Figure E-4 County Annual Avoided Deaths due to Premature Mortality by 2019

207

172

86

72

61

26 23 24

0

50

100

150

200

250

Kern Fresno Tulare San JoaquinStanislaus Merced Kings Madera
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E-12 Appendix E: BenMAP Health Benefit Analysis

2012 PM2.5 Plan

Table E-2 Annual Estimated Reductions in Non-Fatal Health Costs by 2019 for Each Health Endpoint

Madera Merced Kings Stanislaus San Joaquin Tulare Kern Fresno Endpoint

Totals

Hospital 

Admissions, 

Respiratory

$11,977 $8,624 $10,620 $30,716 $34,483 $53,035 $168,286 $69,212 $386,955

Emergency Room 

Visits, Asthma $20,191 $22,534 $22,412 $27,826 $37,031 $55,680 $98,426 $145,396 $429,496

Acute Bronchitis $25,948 $34,690 $30,587 $60,626 $71,573 $106,243 $194,735 $193,358 $717,759

Acute Myocardial 

Infarction $135,234 $116,189 $137,330 $236,316 $292,119 $357,647 $842,946 $963,904 $3,081,686

Upper Respiratory 

Symptoms $130,833 $172,385 $157,888 $298,416 $351,078 $552,944 $1,017,185 $996,355 $3,677,083

Lower Respiratory 

Symptoms $161,316 $215,913 $191,203 $377,829 $446,874 $670,151 $1,233,296 $1,206,413 $4,502,994

Hospital 

Admissions, 

Asthma

$199,604 $255,334 $192,114 $446,696 $655,726 $787,629 $1,749,358 $1,992,572 $6,279,033

Hospital 

Admissions, 

Cardiovascular

$204,764 $247,980 $374,376 $548,160 $607,102 $987,523 $1,969,346 $1,828,704 $6,767,955

Asthma 

Exacerbation $374,797 $507,524 $453,618 $882,581 $1,050,305 $1,587,928 $2,900,901 $2,902,789 $10,660,442

Work Loss Days $695,183 $767,170 $909,471 $1,641,778 $2,010,104 $2,391,386 $5,810,543 $5,313,370 $19,539,004

Acute Respiratory 

Symptoms $1,704,678 $1,981,334 $2,324,078 $3,728,577 $4,360,359 $6,209,217 $12,950,455 $12,850,859 $46,109,557

County Totals $3,664,525 $4,329,677 $4,803,697 $8,279,521 $9,916,754 $13,759,382 $28,935,476 $28,462,931 $102,151,964
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E-13 Appendix E: BenMAP Health Benefit Analysis

2012 PM2.5 Plan

Figure E-5 County Annual Avoided Non-Fatal Health Costs by 2019

$3.66 m

$4.33 m $4.80 m

$8.28 m

$9.92 m

$13.76 m

$28.94 m

$28.46 m

$0

$5,000,000

$10,000,000

$15,000,000

$20,000,000

$25,000,000

$30,000,000

$35,000,000

Madera Merced Kings Stanislaus San

Joaquin

Tulare Kern Fresno
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

E-14 Appendix E: BenMAP Health Benefit Analysis

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