While HPBA Pacific has met with and discussed the upcoming recommendation for rule 421 with the Sacramento Air Quality district staff, our association is compelled to suggest even stronger language as it pertains to using visible smoke as a trigger during curtailments. And we feel certain that the basin's air will clear more rapidly if the air district would more strongly urge the changeout or upgrade to modern technology.

We understand that the Air District is compelled to affect the air quality standards to meet the 35 mcg/m3 federal standard. We have supported and continue to support the change out program that the air district has had and believe that these financial incentives greatly help the consumers in purchasing clean burning products. We have acknowledged that of the three options available that the air district presented recently, the recommended proposal is most palatable for us.

However, there are several changes to this approach that the board should consider. First, make it mandatory to change out or remove any old devices at the time of home sale. This has been successfully adopted in Placer County and can be successful in Sacramento. Secondly, make the program a two stage burn and not 3. Get rid of the voluntary phase and lower the phase 1. It will reduce confusion, make the program easier to administer and likely increase compliance. Also, create a category of clean, solid fuel appliances that can burn at anytime. All staff calculations are based on solid fuel devices emitting 7.5 g/hr. Choose a number like 3 g/hr or 2 g/hr and let these devices burn anytime. With this change, people who want to burn wood and pellets in their EPA Certified stoves will be able to heat their homes. Lastly, mandate that solid fuel devices burn clean everyday. Nobody should emit visible smoke, and if they are, they are burning dirty.

Using energy efficient clean products will help clean Sacramento’s air.