The ARRL has filed a formal complaint with the FCC, alleging that The Home Depot home improvement chain has been illegally marketing certain RF-ballast lighting devices in violation of FCC Part 18 rules. Accompanying the League’s July 14 letter to FCC Enforcement Bureau Spectrum Enforcement Division Chief Bruce Jacobs and Office of Engineering and Technology Laboratory Division Chief Rashmi Doshi was a 20-page report prepared by the ARRL Laboratory’s Mike Gruber, W1MG. His report outlines four instances in which The Home Depot sold non-consumer-rated RF lighting devices having far greater emission limits and intended for commercial use to consumers who specifically voiced an intention to use the devices in residential settings. In some cases, information included with devices sold to consumers indicated that they were for commercial use only, but not all products sold included such a notice.
“Clearly Home Depot’s marketing and sale of non-consumer ballasts is not adequate to ensure compliance with FCC Part 18 requirements,” Gruber’s report concluded. The ARRL asked the FCC to “investigate and commence and enforcement proceeding” regarding The Home Depot’s retail marketing and sale of RF lighting devices in the US.
In its letter, the League noted that it has received numerous complaints from the Amateur Radio community of “significant noise” in the bands between 1.8 and 30 MHz from so-called “grow light” ballasts and other RF lighting devices regulated under FCC Part 15 and Part 18 rules.
“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 and at distances of up to ½ mile from the device,” the ARRL said. According to the League, its investigations in several states revealed an alarming number of instances of retail sale of electronic lighting ballasts, in which non-consumer-rated ballasts were mixed in with consumer ballasts and other consumer products. Gruber’s report noted that the conducted emission limit for consumer-rated devices are 22 dB lower than their commercial counterparts for all amateur bands below 30 MHz.
“In most of the stores surveyed, unsuspecting consumers have no way of knowing the significance of consumer vs. non-consumer ballasts,” the League said. “In some cases, ‘commercial’ grade ballasts, with their associated non-consumer emission limits, appeared to be a heavier duty or superior product. The display signage typically used implies, therefore, that commercial ballasts are also a product upgrade for home use.” The ARRL said that store display signage typically did not mention or adequately address applicable FCC Part 18 requirements, as they pertain to interference in a residential environment.
The League said that in the four instances where actual purchases of RF lighting devices were made at The Home Depot retail outlets, purchasers “specifically asked about residential deployment of non-consumer RF lighting ballasts.” The ARRL said it’s apparent that The Home Depot — and, by inference, other similar retail stores — is “actively and knowingly engaged” in selling commercial RF lighting products to customers for use in residential environments.
“If this activity is left unchecked the Commission will continue to note a deterioration in ambient noise levels and preclusive interfering signals for both AM broadcasters and Amateur Radio licensees in the entirety of the high-frequency bands,” the League’s complaint said.
The ARRL asked the Commission to “take appropriate action” with respect to The Home Depot and other retail outlets marketing such RF lighting devices “without delay.”
A copy of the letter was sent to The Home Depot’s Atlanta, Georgia, Store Support Center.