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# Appendix E

BenMAP Health Benefit Analysis

2012 PM2.5 Plan

SJVUAPCDSan Joaquin Valley Unified Air Pollution Control District Dec ember 20, 2012

Appendix E

: BenMAP Health Benefit Analysis

2012 PM2.5 Plan This page intentionally blank

.San Joaquin Valley Unified Air Pollution Control District Dec ember 20, 2012

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- 1 Appendix E : BenMAP Health Benefit Analysis

2012 PM2.5 Plan 

### 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 im proved 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

BenM AP analysis seeks to answer two question s: First, g iven the reductions in population exposure to PM2.5 by 2019 that will result from this combined body of

control and incenti ve 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 c ases of disease , aggravated symptoms, lost work,

and premature mortality?

E.1 Background

Ov e r course of the past decade, ongoing progress in the fields of epidemiology and geographic information systems (GIS) have resulted in the development of comput er 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

hea lth 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 popul ation 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 un der contract

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

Bakersfield and Fresno/C lovis 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 Analys is 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 H ealth 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.orgSan Joaquin Valley Unified Air Pollution Control District Dec ember 20, 2012

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- 2 Appendix E : BenMAP Health Benefit Analysis

2012 PM2.5 Plan dom estic 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 endpo ints such as asthma

a ttacks and chronic bronchitis. A comparable health benefit e stimation 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 ai r basins. 4

E.2 How BenMAP Works

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

reductions in the incidence rates 5 of 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 an alyses of the health endpoints in question.

For example, i n order to accurately estimate reductions in dai ly 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 respon se 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 i n 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 incrementa l incre ase 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 peer

reviewed epidemiological studi es 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 BenM AP 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 f rom external modeling sou rces 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 Bas ins

. California State University

-- Fullerton, Institute for Economic a nd 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.San Joaquin Valley Unified Air Pollution Control District Dec ember 20, 2012

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- 3 Appendix E : BenMAP Health Benefit Analysis

2012 PM2.5 Plan rely on a single monitor to determine average county exposure, BenMAP also has the ability to estimat e overall county P M2.5 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 expo sure surfaces for each county. First, a baseline grid is created that contains the pre

- exis t ing pollutant exposure level and baseline incidence rates for health endpoints as well as a control grid containing red uctions in average pollutant exposure as specified by the analyst.

Next, the BenMAP analyst must select appropriate CRFs for targe t endpoints prior to estimating the reduction in negative health effects that results from reduced county

- level
exposure to o zone or PM 2.5 . T his requires the analyst to select CRFs from one or more prior health studies for each heal th endpoint . W ith technical assistance from EPA staff, the District has been able to import into BenMAP the CRFs for five endpoints that

are deriv ed 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, as thma 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

de fined by incidence reductions for each health e ndpoint

, for the target county population s 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 Effe ct s = 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 ast hma 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 Es timate: The health effect estimate is an estimate of the
percentage reduction in adverse health effect s due to unit reductions in a mbient air pollution. CRFs from prior e pidemiological 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 htt p://www.fresnostate.edu/chhs/cvhpi/publications/index.htmlSan Joaquin Valley Unified Air Pollution Control District Dec ember 20, 2012

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2012 PM2.5 Plan 4. Exposed Po pulation: The exposed population is the number of people affecte d by the improvement in air quality

.

Finally, BenMAP calculates the economic value of avoided health eff ects 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 o f 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 hea lthcare 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 l arge bronchi (medium

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

bacteria and m ay 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 surve ys 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; Valley

Based CRF

): Reflecting the large body of experimental, clinical, and epidemio logical 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 es timate 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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- 5 Appendix E : BenMAP Health Benefit Analysis

2012 PM2.5 Plan blocked coronary artery. In this c ase, 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 Respir atory Symptoms (Adults 18

- 64) : Individuals with pulmonary vulnerability such as asthmatics often experience respiratory impairmen t that

does not result in medical treatment or lost work but are nonetheless results in a restriction of activity or other imp airment . 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 def ined 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, Val ley

- 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 bas ed 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 Res piratory Symptoms (Children 9

- 11 ): This endpoint is defined by the existence of two or more symptoms including throat congesti on, 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

s hort

- term illness, most typically due to respiratory impairment. Valuation is based on the county median daily wage.

12. Prem ature Mortality (Adults 30

- 99) : Premature death is defined in epidemiolog ical studies as a death from a n air pollutant

- related cause prior toSan Joaquin Valley Unified Air Pollution Control District Dec ember 20, 2012

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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

elev ated PM2.5 exposure in relatively large sample s of the U

. S

. urban population. Because t he most robust statistical relationships with premature mortality have been found with ischemic heart disease 10 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 presen ted 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 resul ts 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 difference s 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 proportio nally 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 th at 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 dis ease 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 hypert ension (high blood pressure), and is more common in men and those who

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

11 Stand ard 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.pdfSan Joaquin Valley Unified Air Pollution Control District Dec ember 20, 2012

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- 7 Appendix E : BenMAP Health Benefit Analysis

2012 PM2.5 Plan E.5 Valuation Results

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

end points, 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

no n

- 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

es timated 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 impair ed health, as well as the cons tricted 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 ov er 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 Dec ember 20, 2012

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2012 PM2.5 Plan 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

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2012 PM2.5 Plan Table E

- 1 BenMAP Estimates of Mean Annual Reduction s in Health Effects Under the Plan by 2019

Health Endpoint Totals Fresno Kern San Joaquin Stanislaus Tulare Merced K ings 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 funct ions (CRF) derived from the 2011 Valley Epidemiological Study conducted by CSU Fresno and UCSF

- Fresno.San Joaquin Valley Unified Air Pollution Control District Dec ember 20, 2012

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2012 PM2.5 Plan Figure E

- 2 Avoided Disease Inc idence by 2019 d ue to Lower PM2.5 Exposure

Fig ure 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 DaysSan Joaquin Valley Unified Air Pollution Control District Dec ember 20, 2012

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2012 PM2.5 Plan Figure E

- 4 County Annual Avoided Deaths due to Prem ature Mortality by 2019

207

172

86

72 61

26 23 24



### 0 50 100 150 200 

### 250

Kern Fresno Tulare San Joaquin Stanislaus Merced Kings MaderaSan Joaquin Valley Unified Air Pollution Control District Dec ember 20, 2012

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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 $102,151,964San Joaquin Valley Unified Air Pollution Control District Dec ember 20, 2012

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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 FresnoSan Joaquin Valley Unified Air Pollution Control District Dec ember 20, 2012

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