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ARRL General Bulletin ARLB038 (2015)

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

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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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