[RFI] ARRL Again Complains to FCC about Illegal Marketing of Electronic Lighting Ballasts

[Roger (K8RI)]

As a data point and FYI as this is only one installation:

I have 6 of the 2 tube, 4 footers in the basement, O have 11 0f the 
commercial 2 tube, 8 footers in my shop.  We have 22 60 and 75W LEDs on 
the ground floor in the house and 4 ~ 200W equivalent CFLs in the 
garage, soon to be replaced with LEDs.
4 floods and 2 0n each corner of the shop for a total of 12 floods . All 
I can remember is the floods are not LED, CFl, or standard 
incandescent.  They will eventually be replaced with LED type when they 
will handle the temperature extremes

NOTE: All wiring in the shop is in 1/2 and 3/4" EMT.

I operate 160 through 440 with the exception of 220.  "So far", I've 
never had a case of interference from CFL, LED, or fluorescent lights, 
or ballasts, yet I know the potential is there for all of the types I 
use as well as the ballasts.  I've only lost a few CFLs, 1 LED in 2 
years and no floods that I remember.I qualified this by stating  "so 
far", because the next batch of lights or ballasts from the big box 
stores could change all this,could

When the LED failed, it would occasionally change brightness over a 
period of several months. Briefly it was off and on a few times before 
failing. I noticed no interference during that period.

73

Roger  (K8RI)


On 1/3/2016 Sunday 1:46 AM, Ed-K0iL wrote:
> After reading the ARRL's actions with Lowe's and Wal-Mart, thought I'd share
> some experience and info on electronic ballast at Home Depot.
>
> While replacing a dead ballast recently, I discovered that The Home Depot
> personnel have no idea which ballasts are meant for residential and which
> are for commercial/office.  Nothing in the display area indicates if they're
> for residential or commercial use, and the three Home Depots employees I
> asked could not tell me either.
>
> I found the T8 replacement GE PRO-LINE ballasts they sell states it meets
> Part 18 but it's only on the body of the ballasts in the smallest print they
> could use.  I believe based on their wording, after I found a magnifier
> lense and my glasses, the more expensive units are NOT for consumer use
> (Part 18 Class A) and states "Commercial Grade" on the red lettering box of
> 4 (model GE232MV-N-DIY or GE432MV-N-DIY).  Nearly everything I found on Home
> Depot's web pages are this type.
>
> The less expensive GE ballasts (GE232HO-N-DIY & GE296HO-N-DIY, the "HO" may
> be for HOME?) mentions Part 18 and states for consumer use (has Gold
> PRO-Line lettering not red).
>
> Price & print color is perhaps the only way the average person can tell the
> difference.  So hope all your DIY neighbors are cheap and only buy the lower
> costs ballasts.  Commercial electricians however may think they're doing
> your neighbor a favor installing the "better" and more expensive ballast
> since he probably gets a commercial rate discount for quantity purchases.
>
> I also found the complete 4 ft 2-light fixtures made by Lithonia with the
> ballast made by Accupro (Model No. AP-RC-232IP-102-1) states it complies
> with 47 CFR Part 18 "consumer limits".
> On their spec sheets I found online
> [ http://www.lithonia.com/specsheets.aspx?cid=67054 ]
> [
> http://www.acuitybrandslighting.com/library//ll/documents/specsheets/accupro
> %20ballast.pdf ]
> it states: "Ballast shall comply with the limits of FCC Part 18C Class B
> (residential) and Class A".  I've had these installed for years with no
> noticeable RFI even with my roof mount antenna only about 15-20 ft away from
> it.
>
> 73, de ed -K0iL
>
> -----Original Message-----
> From: ARRL Web site [mailto:memberlist at www.arrl.org]
> Sent: Tuesday, December 29, 2015 5:27 PM
>
> 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.
> NNNN
> /EX
>
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