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 re   
   idential-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.   
      
   NNNN   
   /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.   
   ---   
    * Origin:  (1:3634/12.73)