Palo Verde and Environmental Justice
A Report by Environmental Hope & Justice
Table of Contents
Executive Sumary................................................................................... 1
Arizona Renewable Energy Standards Initiative..................................... 3
Arizona Corporation Commission............................................................ 3
Arizona Department of Environmental Quality........................................ 4
Maricopa Association of Governments................................................... 4
State Implementation Plan (SIP)............................................................ 5
Constitutional Crisis................................................................................ 7
Environmental Justice Executive Order.................................................. 8
Title VI.................................................................................................... 9
Table 1 High Ozone Days....................................................................... 11
Table 2 Most Polluted Cities................................................................... 12
Table 3 Arizona Largest Cities................................................................ 12
Attachment 1........................................................................................... 15
Attachment 2........................................................................................... 18
Attachment 3........................................................................................... 20
The closure of Palo Verde would represent an environmental injustice because it will be replaced with mostly fossil fuel-generated electricity, which will increase smog that will increase negative health effects in minority and low-income communities.
Environmental Hope and Justice (EHJ) believes the passage of a state initiative to support traditional renewable energy sources would not only lead to the closure of the Palo Verde nuclear power plant, but would also cause a state constitutional crisis. Such a state initiative would directly conflict with the State Implementation Plan (SIP).
The Arizona Renewable Energy Standards Initiative (ARESI) could appear on the ballot in Arizona as an initiated constitutional amendment on November 6, 2018 if proponents can get 225,963 valid signatures by July 5, 2018. The measure would require electric utilities that sell electricity in Arizona to acquire 50 percent of electricity from renewable resources in 2030 and each year thereafter.
Within the Maricopa nonattainment area, the National Ambient Air Quality Standard has not yet been attained for the 2008 eight-hour ozone standard of 0.075 parts per million (ppm). The 2015 eight-hour ozone standard is 0.070 ppm. The area is classified as a Moderate Area under the Clean Air Act.
If the Arizona Renewable Energy Standards Initiative passes, it will trigger a constitutional crisis. It will pit the Arizona Department of Environmental Quality (ADEQ), the Arizona Corporation Commission (ACC), and the Maricopa Association of Governments (MAG) against each other. A state initiative that closes what is a significant ozone control measure (operation of emission-free Palo Verde) would usurp the power of the state agencies in charge of regulating the Clean Air Act at the state level with a measure that runs directly counter to its mission.
MAG has not included the environmental justice consequences of closing Palo Verde due to the passage of the ARESI. Considering the constitutional crisis the passage of ARESI would cause and considering the fact that environmental justice related to Palo Verde closure has not been included in the SIP, the state attorney general should remove the initiative from the ballot until these matters have been resolved.
The closure of Palo Verde would represent an environmental injustice because it will be replaced with mostly fossil fuel-generated electricity, which will increase smog that will increase negative health effects in minority and low-income communities. Electricity bills will also increase, which will be a significant burden on vulnerable communities.
The federal Clean Air Act is implemented at the state level by the Arizona Department of Environmental Quality. The State Implementation Plan is prepared by the Maricopa Association of Governments (MAG) and is submitted to the U.S. Environmental Protection Agency (EPA) by the Arizona Department of Environmental Quality (ADEQ). Arizona has never been in attainment for ozone under the Clean Air Act. The MAG SIPs have not worked in bringing the state into compliance with the Clean Air Act. The penalties for being in nonattainment for ozone under the Clean Air Act have not worked in bringing the state into compliance. This is with Palo Verde operating and there is no way the state can gain Clean Air Act compliance if the plant closes. Thus, the state SIP should include Palo Verde as an existing ozone control measure in the Maricopa Eight-Hour Ozone Nonattainment Area.
Environmental Hope and Justice (EHJ) believes the passage of a state initiative to support traditional renewable energy sources would not only lead to the closure of the Palo Verde nuclear power plant, but would also cause a state constitutional crisis. Such a state initiative would directly conflict with the State Implementation Plan (SIP). Such a state initiative would directly conflict with the mission of the Arizona Department of Environmental Quality, which implements the federal Clean Air Act at the state level. The closure of Palo Verde by the state initiative runs counter to the intent of the federal Clean Air Act. MAG’s SIP authority would also be compromised because it could not write a plan that would meet the requirements of the Clean Air Act to gain compliance under the ozone standard.
The initiative measure might state a goal of relying on renewables for a large percentage of electricity production, but the reality is that natural gas will be used to produce the baseload electrical power needed by the state.
Arizona Renewable Energy Standards Initiative
The Arizona Renewable Energy Standards Initiative (ARESI) could appear on the ballot in Arizona as an initiated constitutional amendment on November 6, 2018 if proponents can get 225,963 valid signatures by July 5, 2018. The ballot initiative was filed with the secretary of state on February 20, 2018 and if approved, Arizona Public Service (APS) says it will create negative market conditions that will force them to close the Palo Verde nuclear plant.
The measure would require electric utilities that sell electricity in Arizona to acquire electricity from a certain percentage of renewable resources each year. The amount would increase each year from 12 percent in 2020 to 50 percent in 2030 and each year thereafter. The measure would define renewable energy to include solar, wind, biomass, certain hydropower, geothermal, and landfill gas energies.
Arizona Corporation Commission
The Arizona Corporation Commission’s (ACC) mission is to power Arizona’s future by ensuring safe, reliable, and affordable utility services; growing Arizona’s economy as we help local entrepreneurs achieve their dream of starting a business; modernizing an efficient, effective, and responsive government agency; and protecting Arizona citizens by enforcing an ethical securities marketplace.
Article 15 of the Arizona Constitution establishes the Arizona Corporation Commission. Only 7 states have constitutionally formed Commissions. Arizona is one of only 13 states with elected Commissioners. In the 37 other states, Commissioners are appointed by either the governor or the legislature.
In most states, the Commission is known as the Public Service Commission or the Public Utility Commission. Our Commission, however, has responsibilities that go beyond traditional public utilities regulation. These additional roles include facilitating the incorporation of businesses and organizations, securities regulation and railroad/pipeline safety.
By virtue of the Arizona Constitution, the Commissioners function in an Executive capacity, they adopt rules and regulations thereby functioning in a Legislative capacity, and they also act in a judicial capacity sitting as a tribunal and making decisions in contested matters.
The Commission is required by the Arizona Constitution to maintain its chief office in Phoenix and it is required by law to conduct monthly meetings.
In 2006, the Commission approved the Renewable Energy Standard and Tariff (REST). These rules require that regulated electric utilities must generate 15 percent of their electricity from renewable sources and are required to file annual implementation plans describing how they will comply with the REST rules. The proposals include incentives for customers who install solar energy technologies for their own homes and businesses. The Commission’s Renewable Energy Standards encourage utilities to use solar, wind, biomass, biogas, geothermal and other similar technologies to generate “clean” energy to power Arizona’s future.
Arizona Department of Environmental Quality (ADEQ)
Under the Environmental Quality Act of 1986, the Arizona State Legislature created ADEQ in 1987 as the state’s cabinet-level environmental agency. ADEQ is composed of three environmental programs: Air Quality, Water Quality and Waste, with functional units responsible for technical, operational and policy support. ADEQ carries out several core functions: planning, permitting, compliance management, monitoring, assessment, cleanups and outreach.
For ADEQ, the SIP Section compiles SIP revisions for all counties of Arizona, particularly those outside major cities like Phoenix and Tucson. In addition, local agencies like the Maricopa Association of Governments and the Pima Association of Governments complete SIP revisions for their respective counties and ADEQ submits them to EPA.
Maricopa Association of Governments
Maricopa Association of Governments (MAG) is a Council of Governments that serves as the regional agency for the greater Maricopa region in Arizona. MAG provides regional planning and policy decisions in areas of transportation, air quality, water quality, and human services for Maricopa County and the metropolitan Phoenix area. MAG was formed in 1967.
MAG was designated by the Governor of Arizona in 1978 and recertified by the Arizona Legislature in 1992 to serve as the regional air quality planning agency for the Maricopa County nonattainment area. In this role, MAG develops regional air quality plans to address air pollution problems. In June 2016, the Governor certified MAG as the lead planning organization for the Pinal County PM-10 and PM-2.5 nonattainment areas.
State Implementation Plan (SIP)
Within the Maricopa nonattainment area, the National Ambient Air Quality Standard has not yet been attained for the 2008 eight-hour ozone standard of 0.075 parts per million (ppm). The 2015 eight-hour ozone standard is 0.070 ppm. The area is classified as a Moderate Area under the Clean Air Act. The Maricopa Association of Governments (MAG) was designated by the Governor of Arizona in 1978 and recertified by the Arizona Legislature in 1992 to serve as the Regional Air Quality Planning Agency to develop plans to address air pollution problems (A.R.S. Section 49-406 A.).
The MAG 2017 Eight-Hour Ozone Moderate Area Plan has been prepared to meet the requirements in Section 182(b) of the Clean Air Act and improve air quality in the Maricopa eight-hour ozone nonattainment area. The attainment date for Moderate Areas is July 20, 2018. A Moderate Area Plan was due by January 1, 2017. The Moderate Area Plan is required to include reasonable further progress; reasonably available control technology; reasonably available control measures; new source review; emissions inventories; modeling attainment demonstration for 2017 (ozone season prior to the attainment date); contingency measures; and motor vehicle emissions budgets for transportation conformity. Moderate Areas are also required to make the submissions for Marginal Areas.
The concentration of ozone in the air in Phoenix is occasionally above the 2008 ozone standard and frequently above the 2015 ozone standard. Maricopa Association of Governments (MAG) submitted a State Implementation Plan (SIP) to EPA in January 2017 for the 2008 ozone standard. Key controls in the plan include:
· Summer fuel reformulation
· Emissions testing
· Federal Tier 2 and Tier 3 vehicle fuel standards
· Coordinated traffic signal systems
The SIP should include ‘continued operation of Palo Verde’ as a key control. Although such specific recommendations are not included in SIPs, the unique nature of Palo Verde as the nation’s largest nuclear plant should give it a special consideration. MAG is working on a SIP for the 2015 standard. This SIP will likely be submitted to the EPA in 2020.
The MAG SIP clearly overstates the projected NOx reductions in its regression analysis. This is unexpected by the MAG because it did not include the possibility of the closure of Palo Verde. The MAG SIP for ozone states:
Uncertainty of Projected 2017 Emissions for Electric Generating Units (EGU): The ten-year maximum EGU emissions over 2005-2014 in Maricopa County were used as the 2017 projected EGU emissions for the attainment demonstration. Using the ten-year maximum for the 2017 EGU emissions is very conservative because the EPA’s national inventory of NOx emissions for power plants show substantial decreases over 1990-2015. An alternative no-growth assumption for the EGU emissions between 2011 and 2017 was tested for the modeled attainment of the 2008 ozone standard. The alternative no-growth approach lowered the future design values by up to 0.6 ppb. The no-growth assumption for the 2017 EGU emissions projection provides a significant safety margin for the modeled attainment demonstration.
The alternative no-growth assumption will clearly lose its 0.6 ppb if Palo Verde is closed. There will be EGU emissions growth if Palo Verde closes.
If a state agency’s SIP is ruled to be unacceptable by EPA, the EPA can take over drafting the plan. If MAG knowingly writes a SIP that does not acknowledge the significant contribution that Palo Verde brings to the state, then the agency assigned to write the plan is placing control over that plan at risk.
If the Arizona Renewable Energy Standards Initiative passes, it will pit the Arizona Department of Environmental Quality, the Arizona Corporation Commission, and the Maricopa Association of Governments against each other. Although MAG completes SIP revisions for their respective counties and ADEQ submits them to EPA, the state constitutional crisis is activated when the ACC usurps their authority by implementing the Arizona Renewable Energy Standards Initiative. It is common knowledge that APS will close Palo Verde if ARESI passes. MAG will be forced to complete a SIP that cannot meet the EPA requirements under the Clean Air Act for ozone attainment. The ADEQ will be forced to submit a SIP that cannot meet the EPA requirements. EPA might have to take over the program, as is allowed under the law. EPA does not have any authority to force Palo Verde to stay open. Nuclear power plants are regulated by the Nuclear Regulatory Commission (NRC). Thus, this constitutional alteration will throw the state clean air program into chaos.
A state initiative that closes what is a significant ozone control measure (operation of emission-free Palo Verde) would usurp the power of the state agencies in charge of regulating the Clean Air Act at the state level with a measure that runs directly counter to its mission. The façade of putting the measure to the voters is disingenuous because informed proponents know they are bypassing the established channels for regulating the Clean Air Act at the state level. The Arizona Corporation Commission is in no way authorized or capable of managing or regulating CAA goals. Yet the passage of the ARESI will put ACC in charge of meeting the requirements of the CAA.
MAG would also be placed in the position of writing a SIP that it knows would not work. No state agency should engage in any activity that promotes the addition of one pound of an EPA Criteria Pollutant. This is because state agencies should be promoting measures that reduce air pollutants, particularly pollutants in which they are in noncompliance. The measure would be usurping the regulatory powers of DEQ and MAG and would automatically force them to work against their own missions.
Environmental Justice Executive Order
The federal Executive Order on Environmental Justice encourages consideration of environmental justice concerns, especially the impact of programs and activities on low-income and minority populations. MAG is responsible for incorporating environmental justice concerns in its planning and programming processes, and the enforcement of statewide compliance, including the MAG region. Historically, the MAG Human Services Planning Program has considered the needs of populations vulnerable to discrimination or exclusion. These populations may be described by minority race or ethnicity, low income, functional limitations or disabilities, or advanced age. On May 28, 2014, the MAG Regional Council approved the MAG Title VI and Environmental Justice Programs.
Although American Indians have much lower populations than Hispanic and Blacks, they have the highest asthma rates in Arizona. Hispanics make up about 40% of the populations of the largest cities in Arizona. These items are examined more extensively in the Demographics section of this report.
MAG has clearly not included the environmental justice consequences of closing Palo Verde due to the passage of the ARESI. Considering the constitutional crisis the passage of ARESI would cause and considering the fact that environmental justice related to Palo Verde closure has not been included in the SIP, the state attorney general should remove the initiative from the ballot until these matters have been resolved.
Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color and national origin by recipients and sub-recipients of federal funds and prohibits exclusion from participation in, denial of benefits, or being subjected to discrimination under any program or activity receiving federal financial assistance. MAG is responsible for incorporating Title VI requirements and environmental justice concerns in its planning and programming processes, and the enforcement of statewide compliance. The MAG Title VI Program is implemented through the Title VI Coordinator. The Coordinator is responsible for reviewing and updating the program in collaboration with the division liaisons.
MAG has clearly not included the Title VI considerations of closing Palo Verde due to the passage of the ARESI. The closure of Palo Verde represents an environmental injustice by discriminating against vulnerable populations. Considering the constitutional crisis the passage of ARESI would cause and considering the fact that Title VI related to Palo Verde closure has not been included in the SIP, the state attorney general should remove the initiative from the ballot until these matters have been resolved.
The combination of not including environmental justice and Title VI considerations in the SIP regarding the closure of Palo Verde due to the ARESI, should render the proposed constitution measure null and void. In addition, the constitutional crisis caused by the passage of ARESI should render consideration of the measure null and void. The State Attorney General needs to step in to avoid this travesty of justice.
According to the 2010 Census, the ethnic and racial composition of Phoenix was:
· White: 65.9% (45.6% non-Hispanic)
· Black or African American: 6.5% (6% non-Hispanic)
· Native American: 2.2%
· Asian: 3.2%
· Native Hawaiian and Pacific Islander: 0.2%
· Other race: 0.1%
· Two or more races: 3.6%
· Hispanic or Latino of any race: 40.8%
Phoenix is about half White and half Hispanic or Latino. Tucson is also about half White and half Hispanic or Latino. The high percentage of Hispanics congregated together is illustrated in Attachment 3.
According to the Statistical Atlas, the ethnic and racial composition of Tucson is:
· White: 65.9% (46.6% non-Hispanic)
· Black or African American: 5.1% (6% non-Hispanic)
· Native American: 2.2%
· Asian: 2.7%
· Native Hawaiian and Pacific Islander: 0.2%
· Other race: 2.0%
· Two or more races: 3.6%
· Hispanic or Latino of any race: 41.4%
According to the American Lung Association (ALA) “State of the Air 2018” report, Maricopa County had 92 Orange Ozone Days (See Table 1). Such designated days are unhealthy for sensitive populations. Maricopa County is also listed as being in nonattainment for ozone.
High Ozone Days
Notes: 1. INC indicates incomplete monitoring data for all three years. Therefore, those counties are excluded from the grade analysis. 2. DNC indicates that there is no monitor collecting data in the county.
Maricopa County gets an F grade from the American Lung Association (ALA) (See Table 1). Phoenix is also the eighth most polluted city in the USA according to the ALA. (See Table 2). Phoenix, which is in Maricopa County, received an F grade for air quality by the ALA.
Most Polluted Cities
#1 Los Angeles-Long Beach, CA
#2 Bakersfield, CA
#3 Visalia-Porterville-Hanford, CA
#4 Fresno-Madera, CA
#5 Sacramento-Roseville, CA
#6 San Diego-Carlsbad, CA
#7 Modesto-Merced, CA
#8 Phoenix-Mesa-Scottsdale, AZ
Table 3 shows that Phoenix and Tucson are the two largest cities in Arizona.
Arizona - Largest Cities
According to the American Lung Association “Asthma Burden Report,”
Asthma is a common chronic respiratory condition that affects millions of Americans across the age span on a daily basis. In Arizona, it is estimated that more than 615,000 residents have asthma. Asthma can be a life-threatening condition – almost 100 Arizona residents die every year due to asthma. In Arizona, more than 27,000 emergency department and hospital discharges were attributable to asthma in 2014. The estimated cost of this care was $115 million.
Clearly, asthma is a major problem in Arizona. It is important that no actions should be taken by the state that would serve to exacerbate air quality in Arizona. According to the Arizona Department of Health Services, Chronic Lower Respiratory Disease (CLRD) (i.e., asthma, emphysema and chronic bronchitis) is a leading health priority in Arizona. CLRD is the third leading cause of death in Arizona, responsible for almost 3,300 deaths a year.
Compared to all U.S. residents, Arizonans are disproportionately impacted by asthma. In 2014, 9.6% of adult Arizonans reported having asthma, compared to a national rate of 8.9%. This equates to more than 484,000 Arizona adults with asthma. In addition, 10.9% of Arizona youth (17 years and younger) reported having asthma, compared to a national rate of 9.2%. This equates to more than 174,000 Arizona youth with asthma. So, in total, more than 615,000 Arizonans reported having asthma, or 1 in every 11 residents.
In Arizona, American Indians had the highest rates of adult asthma prevalence for the period 2011 to 2014. Current Asthma among Arizona Adults by Race / Ethnicity include: White 10.2%, Black/ African American 10.1%, Hispanic 6.7%, Asian/ Pacific 2.6%, and American Indian 11.2%. Clearly, the American Indians in Arizona have a vested interest in that state meeting its Clean Air Act attainment goals. Although the African American population is small in Arizona, the asthma rate is comparable to the White asthma rate.
In 2013, 93 Arizonans died due to asthma. In addition, asthma negatively impacts the quality of life for hundreds of thousands of Arizonans. In 2014, there were a total of 5,720 Arizona hospital discharges in which asthma was the first-listed diagnosis. This is 0.8% of the total 637,060 discharges in 2014. That same year, there were 27,481 emergency department (ED) visits in Arizona hospitals in which asthma was the first-listed diagnosis (1.3% of all emergency department visits). According to the Arizona Department of Health Services hospital charges for asthma-related hospitalizations and emergency department visits exceeded $115 million in 2014.
The vast majority of emergency room visits and hospital inpatient discharges were in Maricopa County and Pima County (See Attachment1). In 2014, Maricopa County had 18,296 asthma emergency room visits and 3,404 asthma hospital inpatient discharges. Pima County had 3,113 asthma emergency room visits and 1,076 asthma hospital inpatient discharges.
A number of counties in Arizona are in nonattainment of one or more Criteria Pollutants. Phoenix-Mesa, AZ in Maricopa County are listed as Moderate for 8-hour ozone. Phoenix-Mesa, AZ in Pinal County are listed as Moderate for 8-hour ozone. (See Attachment 1)
The closure of the Pablo Verdes nuclear power plant because of the passage of the Arizona Renewable Energy Standards Initiative will represent an environmental injustice. It represents an environmental injustice because it will violate the state clean air rules and regulations related to clean air and violates the spirit of environmental justice. Vulnerable communities and people will suffer more due to the premature closure of Palo Verdes.
Passage of the Arizona Renewable Energy Standards Initiative will create a constitutional crisis. It will unnecessarily pit state agencies against each other. It will trigger such a constitutional crisis by creating an obstacle to the state’s achieving attainment of the Clean Air Act rules. The initiative should be voided by vote or fiat.
Current Nonattainment Counties for All Criteria Pollutants
Paul Spur/Douglas (Cochise County), AZ - (Moderate)
Hayden, AZ - (Moderate)
Miami, AZ - (Moderate)
Sulfur Dioxide (2010)
Sulfur Dioxide (2010)
Phoenix, AZ - (Serious)
8-Hr Ozone (2008)
Phoenix-Mesa, AZ - (Moderate)
Ajo (Pima County), AZ - (Moderate)
Rillito, AZ - (Moderate)
Hayden, AZ - (Moderate)
Miami, AZ - (Moderate)
Phoenix, AZ - (Serious)
West Pinal, AZ - (Moderate)
West Central Pinal, AZ - (Moderate)
Sulfur Dioxide (1971)
Hayden (Pinal County), AZ
Sulfur Dioxide (2010)
8-Hr Ozone (2008)
Phoenix-Mesa, AZ - (Moderate)
Santa Cruz County
Nogales, AZ - (Moderate)
Nogales, AZ - (Moderate)
Yuma, AZ - (Moderate)
ED visits and discharges of inpatients with asthma
(1st listed diagnosis) by county of residence, Arizona, 2014
County of residence
Hospital Inpatient Discharges
Percentage of Hispanics by Zip Code in Phoenix, AZ
1-40 out of 40 total
[ 1 ]
Percentage of Blacks by Zip Code in Phoenix, AZ
 Arizona Corporation Commission, Our Mission and Background. http://www.azcc.gov/Divisions/Administration/about.asp
 Id., http://www.azcc.gov/divisions/utilities/electric/environmental.asp
 Arizona Department of Environmental Quality, About Us. http://www.azdeq.gov/AboutUs
 ADEQ, SIP. http://www.azdeq.gov/SIP
 Maricopa Association of Governments. About Us. http://azmag.gov/About-Us/About-MAG
 MAG, Regional Air Quality Planning. http://azmag.gov/Programs/Environmental/Regional-Air-Quality-Planning
 Id., Ozone: Unlike other pollutants, ozone is not directly emitted into the atmosphere. Ozone is formed through a chemical reaction that occurs between volatile organic compounds (VOC) and nitrogen oxides (NOx) in the presence of sunlight. Peak ozone concentrations typically occur from May through September. Ozone (2008 standard: 75 ppb). Ozone (2015 standard: 70 ppb). EPA.
 Arizona Department of Environmental Quality. http://www.azdeq.gov/node/4185
 Id., p 6-13.
 Criteria Pollutant: The Clean Air Act requires EPA to set National Ambient Air Quality Standards (NAAQS) NAAQS are currently set for carbon monoxide, lead, ground-level ozone, nitrogen dioxide, particulate matter, and sulfur dioxide (six common air pollutants also known as criteria air pollutants).
 Maricopa 2017 Eight-Hour Ozone Moderate Area Plan For the Maricopa Nonattainment Area, December 2016. P. 7-7. http://azmag.gov/portals/0/Documents/EP_2016-12-09_MAG-2017-EightHour-Ozone-Moderate-Area-Plan-for-the-Maricopa-Nonattainment-Area.pdf
 Id. P. 7-7.
 U.S. Census Bureau. https://www.census.gov/quickfacts/fact/table/phoenixcityarizona/PST045216
 Statistical Atlas, https://statisticalatlas.com/place/Arizona/Tucson/Race-and-Ethnicity
 American Lung Association, State of the Air 2018. http://www.lung.org/our-initiatives/healthy-air/sota/city-rankings/states/arizona/
 Air Quality Index. Unhealthy for sensitive groups. http://www.lung.org/our-initiatives/healthy-air/outdoor/air-pollution/air-quality-index.html
 American Lung Association, State of the Air 2018. http://www.lung.org/our-initiatives/healthy-air/sota/city-rankings/most-polluted-cities.html
 Geonames, Biggest Cities in Arizona. www.geonames.org/US/AZ/largest-cities-in-arizona.html
 American Lung Association (in Arizona), Arizona Department of Health Services, “The 2016 Arizona Asthma Burden Report,” Executive Summary, p. 3. https://www.azdhs.gov/documents/prevention/tobacco-chronic-disease/az-asthma-burden-report.pdf
 Id., p. 9.
 Id., p. 10.
 Id., p. 12.
 Id., p. 18-19.
 EPA Green Book. https://www3.epa.gov/airquality/greenbook/ancl.html
 Id., p. 20.
 Zip Atlas, Percentage of Hispanics by Zip Code in Phoenix, AZ. http://zipatlas.com/us/az/phoenix/zip-code-comparison/percentage-hispanic-population.htm
 Zip Atlas. Percentage of Blacks by Zip Code in Phoenix, AZ. http://zipatlas.com/us/az/phoenix/zip-code-comparison/percentage-black-population.htm