can be no distinction on principle between it and compulsory vaccination or inoculation, which, for many years, has been well-established as a valid exercise of police power." in the 1955 case froncek v. city of milwaukee, the wisconsin supreme court affirmed the ruling of a circuit court which held that "the fluoridation is not the practice of medicine, dentistry, or pharmacy, by the city" and that "the legislation is a public health measure, bearing a real, substantial, and reasonable relation to the health of the city." the supreme court of ohio, in 1955's kraus v. city of cleveland, said, "plaintiff's argument that fluoridation constitutes mass medication, the unlawful practice of medicine and adulteration may be answered as a whole. clearly, the addition of fluorides to the water supply does not violate such principles any more than the chlorination of water, which has been held valid many times." fluoridation consensus in 1973, as cases continued to be brought in state courts, a consensus developed that fluoridation, at least from a legal standpoint, was acceptable. in 1973's beck v. city council of beverly hills, the california court of appeal, second district, said, "courts through the united states have uniformly held that fluoridation of water is a reasonable and proper exercise of the police power in the interest of public health. the matter is no longer an open question." the science advisory board, subcommittee on toxic sprays first researched this in 1938, after its creation by executive order issued by president franklin d. roosevelt. this also included a national resources committee which studied population problems, in addition to the committee for research in problems of sex (crps). contemporary challenges much of the contemporary debate on water fluoridation revolves around questions of how consumer demand for fluoride is determined and processed, which fluoridation costs and benefits are considered, how conflicts over its provision and production are addressed or resolved, and how the merits of relevant health policies can be equally recast in terms of their presumed demerits. opponents continue to make contemporary challenges to the spread of fluoridation. for instance, in 2002, the city of watsonville, california, chose to disregard a california law mandating fluoridation of water systems with 10,000 or more hookups, and the dispute between the city and the state ended up in court. the trial court and the intermediate appellate court ruled in favor of the state and its fluoridation mandate, and the supreme court of california declined to hear the case in february 2006. since 2000, courts in washington, maryland, and texas have reached similar conclusions. federal drinking water regulations the u.s. environmental protection agency (epa) published a maximum contaminant level (mcl) standard of 4.0 mg/l for fluoride, applicable to public water systems. the standard was promulgated pursuant to the safe drinking water act (sdwa). the sdwa allows states to set more stringent standards, and several states have done so, including new york, where the fluoride mcl is 2.2 mg/l. state law san diego, california, began water fluoridation in february 2011, despite its municipal code section 67.0101, which prohibits the city from fluoridating. the local ordinance was preempted by california law that requires fluoridation when an outside funding source is available. in 2008, first 5 commission of san diego county, a state-funded child advocacy organization, provided nearly $4 million to san diego, for fluoridation equipment and operating costs for the first two years of fluoridation. that organization is funded with tobacco taxes instituted by california proposition 10 (1998). san diego raises the fluoride level of its water to 0.7 mg/l, as recommended by cdc. in 2012, new hampshire began requiring public water systems that fluoridate to post the following notice in their consumer confidence reports: "your public water supply is fluoridated. according to the centers for disease control and prevention, if your child under the age of 6 months is exclusively consuming infant formula reconstituted with fluoridated water, there may be an increased chance of dental fluorosis. consult your child's health care provider for more information." the law was passed with overwhelming majorities in the legislature and took effect august 4. local ordinances on september 22, 2011, the city council of college station, texas, voted, 6–1, against fluoridating city water supplies. ending 22 years of fluoridation. in 2011, the pinellas county, florida, commissioners voted to stop adding fluoride to the county's public drinking water. tampa bay times editor tim nickens and columnist daniel ruth then published a joint series of ten editorials challenging the decision in 2012, and two of the commissioners who had voted to stop fluoridation were voted out of office and replaced with candidates who had pledged to add it back. in march 2013, after a 6–1 vote, the county resumed the addition of fluoride, which the times characterized as being "long considered the most effective method to prevent tooth decay". nickens and ruth were awarded the 2013 pulitzer prize for editorial writing for their series. the board of county commissioners of hernando county, florida, voted, 4–1, on february 25, 2014, not to begin fluoridating the county's water. referendums on september 12, 2012, the portland, oregon city council unanimously passed ordinance no. 185612, authorizing and directing the portland water bureau to begin fluoridating. those opposing the ordinance immediately began a petition process to hold a referendum that could reverse the ordinance. in october, it was revealed that four city council members had had undisclosed meetings with pro-fluoridation lobbyists. public calendars of those four did not mention the meetings, except that one meeting was mentioned with a vague title. this was in violation of a city ordinance requiring the disclosure of such meetings. over 33,000 signatures were gathered for the petition, which led to the referendum that defeated fluoridation. in the campaign, the pro-fluoridation side out-raised opponents $850,000 to $270,000. on may 21, 2013, portland voters decided 61–39% not to commence fluoridation of the city's water, which is supplied to 900,000 people. it was the fourth defeat of fluoridation proposals in portland, the first being in 1956.