Approved by the CLCA Board of Directors on March 25, 1999
The California Landscape Contractors Association acknowledges and understands that public opposition to the use of gasoline-powered leaf blowers is based upon concerns about sound, dust, and air emissions. However, an outright ban of this valuable equipment would be the severest of all possible remedies and one that would eliminate its many benefits. A ban should be a last resort and enacted only after exhausting all other alternatives.
It is CLCA's position that many such alternatives currently exist. They would alleviate the public's concerns about gasoline-powered leaf blowers without depriving the landscape maintenance contractor of this extremely efficient and safe tool. We wish to help find a solution to this issue that is fair and equitable to both the public and the leaf blower user. Therefore, we respectfully offer the following information for consideration. CLCA opposes across-the-board bans on gasoline-powered leaf blowers, such as the Los Angles ordinance that prohibits their use within 500 feet of a residence. CLCA believes these bans are unnecessary, bad public policy, and extremely harmful to the landscape industry.
Leaf blowers are essential for landscape maintenance professionals. This is because these machines are very efficient tools for cleaning up leaves and other small debris from landscape sites. Since their development in the 1970s, leaf blowers to a large extent have supplanted brooms, hoses, and rakes. Leaf blowers even perform functions that no other tool can handle effectively, such as cleaning areas covered by rock, gravel, bark, or mulch -- with minimal disturbance.
Leaf blowers save enormous amounts of time. Most landscape industry estimates suggest that it takes at least five times as long to clean a typical landscape site with a broom and rake than it does with a power leaf blower. A similar estimate was provided in 1994 by the City of San Luis Obispo for its parks and public buildings; the city's maintenance supervisors estimated that their crews would take 50 hours to do work that took 10 hours with leaf blowers, and that much of the work would require the use of water. Some estimates substantially exceed the five times one rule-of-thumb: in a 1992 labor efficiency comparison report, the City of Whittier concluded that a job that took 2.25 labor hours with a backpack leaf blower took 76 labor hours with a hose and 282 with a broom! The bottom line is that without leaf blowers, public agencies and private owners would have to spend more time on outdoor work or accept a lower level of upkeep.
Time is money. CLCA members servicing landscape maintenance accounts estimate that their costs would increase an average of 20.7 percent if they had to perform the same functions without the leaf blower. This estimate comes from a survey that CLCA sent its members in late 1998.
CLCA believes many clients can't afford or are not willing to pay for the additional costs of performing landscape maintenance without the leaf blower. In fact, CLCA members servicing landscape maintenance accounts believe they could pass along less than a third (31.6 percent) of their increased costs through increased landscape maintenance fees. This information also comes from CLCA's 1998 membership survey.
Most clients would do one of the following in the case of a ban: (1) expect their landscape maintenance firm to provide the same standard of care as before without paying more money for the service, (2) allow their landscapes to deteriorate, (3) do the work themselves, or (4) flaunt the law by using leaf blowers or hiring gardeners willing to do so. The last option is a possibility because leaf blower bans have been difficult to enforce in municipalities that have passed an ordinance to date. That option would adversely affect our members because we play by the rules by the very nature of the way our businesses are organized. CLCA members are all state-licensed contractors. We have a license bond on file with the Contractors State License Board, and we pay workers' compensation as well as liability insurance. We deduct federal and state income taxes from payrolls. Many of our members offer health insurance for employees and their families. Unfortunately, we compete against a vast underground economy of unlicensed operators that does not play by the rules. We believe these unlicensed operators would flaunt a leaf blower ban if given the chance, and consequently they would be able to underbid our members for landscape maintenance contracts. Legitimate landscape contractors could go out of business and their employees would lose good paying jobs.
Most landscape maintenance clients are not rich. They are more likely to be middle income homeowners. Also, many are elderly and some are disabled. To ask these homeowners to pay more or do the work themselves is unrealistic and unfair.
The leaf blower is an alternative to hosing down walks and driveways with water. Using water in this manner is unreasonable in drought-prone California. The reality is that people will always take the next easiest course of action when one course of action is closed to them. Hosing down walkways and driveways is much easier, quicker, and more efficient than broom cleaning those surfaces.
Leaf blowers are no louder than many other types of power equipment. Some of the newer model leaf blowers are actually more quiet than many other types of lawn and garden power equipment.
High decibel sound exposure can be severely damaging to hearing. The U.S. Department of Labor Occupational Safety & Health Administration (OSHA) requires a hearing protection program for employees when sound exposures equal or exceed an eight-hour, time-weighted average sound level of 85 decibels. CLCA members typically require their employees to use hearing protection whenever power equipment is used. Although OSHA's regulation should not be taken to imply that lower decibels are always safe, compare it with the sound from the more advanced leaf blowers. Most of the newer machines are rated at, or less than, 70 decibels at 50 feet at full throttle. And, unlike landscape maintenance personnel, who need hearing protection because of their long hours of exposure to sound coming from a machine a few feet away from their ears, residents and homeowners are exposed to leaf blower sound for only a few minutes a week at much greater distances.
CLCA acknowledges that leaf blowers can be a nuisance. However, we believe the culprits are old technology and improper use. Both problems can be remedied by means other than indiscriminate bans.
CLCA strongly encourages leaf blower manufacturers to place a high priority on sound reduction improvements. However, credit should go where credit is due. Today's leaf blowers are significantly more quiet than their predecessors of 10 years ago. Manufacturers have steadily reduced sound levels in response to customer need. As of January 1999 at least two manufacturers had introduced revolutionary leaf blowers that generate a mere 62 dBa at full throttle at fifty feet from the source -- without sacrificing performance. Manufacturers can be expected to make future sound reduction improvements, if given the chance.
CLCA believes that landscape maintenance professionals and homeowners should be informed about the sound levels of leaf blower equipment before purchase. We believe that most buyers, if properly informed, would opt for the most quiet equipment, all other factors being equal. Unfortunately, some manufacturers do not disclose this information. CLCA, therefore, would support a state mandate that required all manufacturers to test the sound levels of their gas-powered leaf blower models according to the provisions of the American National Standards Institute (ANSI) B 175.2 Standard for Hand-Held and Backpack Gasoline-Engine-Powered Blowers. We also would support a state law that required all equipment and packaging to be clearly and durably marked with the decibel rating.
Although CLCA prefers other methods of dealing with leaf blower sound, our association does not oppose efforts to prohibit outmoded equipment -- as long as the standards are not unreasonable in light of the existing technology on the market. We suggest that efforts to prohibit outmoded equipment be accompanied by buy-back programs that permanently remove the equipment from service. At a minimum, bans on outmoded equipment should go into effect at least one year after a decision is made. This would give users crucial lead time to phase out their equipment.
CLCA believes the vast majority of commercial operators use their leaf blowers responsibly. Nevertheless, we acknowledge that improper use is a problem. It is caused chiefly by lack of knowledge, but, regrettably, it is sometimes a result of lack of courtesy for others.
Cities, municipalities, and the CLCA should partner together to educate the public as well as the landscape industry about proper use of leaf blower equipment. Educational programs should include the following information:
CLCA believes that informed citizens and landscape maintenance workers are likely to be more considerate. For the few bad apples who may lack common courtesy even with increased knowledge, city ordinances to require proper use under penalty of a steep fine may be necessary. CLCA does not oppose ordinances that mandate common sense rules of leaf blower courtesy.
Nor would CLCA oppose an ordinance requiring a governor attachment to leaf blowers that limited their throttle speed in order to meet local dba requirements. Such an ordinance would address the sound problem from outmoded equipment without going so far as to remove that equipment from the market. On the negative side, however, this solution would prevent users from switching to a higher throttle speed on the few occasions when it may be appropriate to do so, such as when they are doing their work at a substantial distance away from other people.
Electric-powered leaf blowers are not an acceptable substitute for gas-powered machines. Most landscape maintenance professionals estimate that electric leaf blowers reduce efficiency by 50 percent. They tend to be less powerful than gas leaf blowers, and they are limited by the need for an extension cord that must be continually plugged in and unplugged. In addition, they can be hazardous to operators. Swimming pools, spas, garden ponds, and moisture from landscape irrigation make for a potential electric shock problem. Finally, the heavier duty electric leaf blowers, which are comparable in power to gas leaf blowers, do not reduce sound that significantly. Plus, the electric leaf blower's sound is compounded by the noise produced by a generator if electrical outlets aren't available. According to the results of a survey sent to CLCA members in late 1998, more landscape contractors would resort to brooms and rakes than electric leaf blowers if they were prevented from using gas-powered equipment.
As manufacturers have steadily lowered the decibel levels of leaf blowers in recent years, criticism of the machines has to some extent shifted away from sound and towards dust and air emissions concerns. As far as dust is concerned, it should be pointed out that brooms create dust too. So does the wind for that matter. Properly used leaf blowers do not raise inordinate amounts of dust. Rule 403 of the South Coast Air Quality Management District states that " a person shall not cause or allow the emissions of fugitive dust from any active operation, open storage pile, or disturbed surface area such that the presence of such dust remains visible in the atmosphere beyond the property line of the emission source." Blower users can and should follow this rule.
The air emissions issue is a spurious issue when applied to local leaf blower regulations. In 1995 the California Air Resources Board (CARB) put in place Tier I Standards that by 1998 had reduced air emissions from two-stroke engines by 30 to 70 percent. CARB Tier II Standards, which go into place on January 1, 2000, will cut emissions from handheld equipment by 74 percent by 2010. The Tier II Standards are stringent -- so stringent that many manufactures initially asserted they would be unable to meet them. Air pollution issues are being addressed, and should be addressed, by CARB, the federal Environmental Protection Agency (EPA), and the regional air quality districts -- not individual cities and counties. Moreover, the frequently used criticism that leaf blowers produce emissions greater than automobiles should be placed in proper perspective. Actual emissions from leaf blowers are few because of the equipment's intermittent use. For example, one year of volatile organic compound (VOC) emissions from automobiles compares to 21 years of emissions from portable lawn and garden products. Portable lawn and garden equipment contributes only 0.8 percent of all U.S. VOC emissions, 0.6 percent of carbon monoxide emissions, and no nitrogen oxide emissions. (This comparison comes from an analysis of EPA emissions inventory data prepared for the Portable Power Equipment Manufacturers Association by Heiden & Associates of Washington, DC.)
CLCA members are always willing to work constructively with city, county, and state public officials to develop win-win solutions to this increasingly prominent issue.