In Jopson v. Feather River Air Quality Management Dist. (2003) 108 Cal.App.4th 492, an air quality management district (district) issued marketable emission reduction credits (ERCs) to a ranch owner as a result of the owner's reduced burning of agricultural waste. While sale of the ERCs was pending, the district discovered that it had miscalculated their value. The district recalculated the ERCs; the owner completed the sale for a substantially reduced purchase price, and then brought suit for negligence. Jopson argued the district negligently performed the operational tasks of "identifying, calculating, and banking" the ERCs. (Id. at p. 499.) The court of appeal rejected this contention, explaining that, by using an incorrect fuel loading factor, the district obtained false information and then communicated the misinformation to Jopson. Jopson then relied to its detriment on the miscalculated ERCs, a misrepresentation of a true and existing fact. Although the mathematical calculation of ERCs, like the inflated appraisal in United States v. Neustadt (1961) 366 U.S. 696, misrepresented the true value of the plaintiff's interests, "there is something fundamentally and qualitatively different about calculating or appraising value that does not change the actual value of the real estate, ERCs, etc. and actively participating in conduct that does." (Id. at pp. 499-501, and cases cited therein.)