SB QST @ ARL $ARLB038
ARLB038 ARRL Again Complains to FCC about Illegal Marketing of Electronic
Lighting Ballasts

ZCZC AG38
QST de W1AW
ARRL Bulletin 38  ARLB038
> From ARRL Headquarters
Newington CT  December 29, 2015
To all radio amateurs

SB QST ARL ARLB038
ARLB038 ARRL Again Complains to FCC about Illegal Marketing of Electronic
Lighting Ballasts

The ARRL has again complained to the FCC to allege illegal marketing of
electronic RF lighting ballasts, operating under Part 18 of the Commission's
rules, on the part of two major retailers. Letters went out this week to the
FCC Enforcement Bureau and its Office of Engineering and Technology claiming
Part 18 marketing regulations violations by Lowe's and by Walmart stores. At
issue is the sale of non-consumer RF lighting ballasts to consumers who, in
several instances, were told by store personnel that it was okay to install
these in a residential setting. In addition, non-consumer and residential-class
ballasts are intermixed in store displays with inadequate signage to direct
consumers to the correct choice. Both letters asked the FCC to investigate and
commence enforcement proceedings with respect to the two stores' marketing and
retail sale of RF lighting devices in the US.

"ARRL purports to show that the retailer is...marketing and selling to
consumers (by retail sale) non-consumer Part 18 RF lighting devices which are
not intended for residential deployment, to consumers who have specifically
noted their intention to deploy the devices in residential applications," ARRL
Chief Counsel Chris Imlay, W3KD, said in similar complaint letters to the
Commission on December 28 and December 29. Part 18 emissions limits for
consumer devices are far lower than those allowed for non-consumer devices.

"ARRL has received numerous complaints from Amateur Radio operators of
significant noise in the medium (MF) and high frequency (HF) bands between 1.8
MHz and 30 MHz from 'grow lights' and other Part 15 and part 18 RF lighting
devices," Imlay continued. "These devices are easily capable of emitting RF
noise sufficient to preclude Amateur Radio MF and HF communications (and, as
well, AM broadcast station reception) throughout entire communities."

Supporting both complaints are extensive and detailed reports by ARRL
Laboratory EMC Specialist Mike Gruber, W1MG. The reports recount incidents of
actual purchases of Part 18 RF lighting devices
intended for commercial use to consumers who made clear to store personnel that
they intended to use the devices at home. Gruber's report includes multiple
photographs that depict in-store displays of the products in question and
showing signage that does not adequately explain which devices may be sold to
whom.

The ARRL has asked that all non-consumer devices be removed from retail sale
and marketing at the stores and to track and recall non-consumer devices
already sold to consumers.

In his report, Gruber concluded that retailers should require purchasers of
non-consumer Part 18 RF lighting devices to provide a valid contractor's
number. He also advised that the stores improve
display signage to make it clear that non-consumer Part 18 devices may not be
used in residential settings.

Earlier this year, the ARRL sent similar complaint letters to the FCC regarding
the marketing of Part 18 RF lighting devices by The Home Depot. The League also
has complained about specific RF lighting "grow light" devices that it has
alleged exceed Part 18 emission limits.

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/EX

)\/(ark

"So let me ask you a question about this brave new world of yours. When you've
killed all the bad guys, and when it's all perfect, and just and fair, and when
you have finally got it exactly the way you want it, what are you going to do
with the people like you? The trouble makers. How are you going to protect your
glorious revolution from the next one?" - The twelfth Doctor

... As far as we know it just may be a recipe for biscuits.
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