03/14/2014 The ARRL has formally complained to the FCC, contending that a “grow light” ballast being widely marketed and sold is responsible for severe interference to the MF and HF bands. The League urged Commission action to halt sales of the Lumatek LK-1000 electronic ballast and to recall devices already on store shelves or in the hands of consumers. In a March 12 letter to the Commission’s Enforcement Bureau and its Office of Engineering and Technology, ARRL General Counsel Chris Imlay, W3KD, said the ARRL’s own laboratory testing revealed that the Lumatek device exhibited excessive conducted emissions, in violation of the FCC’s rules. “ARRL has received numerous complaints from Amateur Radio operators of significant noise in the medium and high frequency bands between 1.8 MHz and 30 MHz from ‘grow lights’ and other RF lighting devices generally,” Imlay told the Commission. “The level of conducted emissions from this device is so high that, as a practical matter, one RF ballast operated in a residential environment would create preclusive interference to Amateur Radio HF communications throughout entire neighborhoods.” An extensive Conducted Emissions Test Report detailing the ARRL Lab’s test results was attached to the League’s correspondence. “[T]he Report concludes from the conducted emissions tests that the six highest emissions from the device in the HF band vastly exceed the quasi-peak limit specified in Section 18.307(c) of the Rules,” Imlay related. The ARRL further pointed out that, while a FCC sticker has been affixed to the device, it lacked FCC compliance information. FCC Part 18 rules require RF lighting devices to provide an advisory statement with the device, notifying users that it could interfere with radio equipment operating between 0.45 MHz and 30 MHz. The League noted that the device is imported into the US and marketed and sold by Sears, where ARRL purchased its test sample, as well as by Amazon.com and other retail outlets. “ARRL respectfully requests that your office take the appropriate action with respect to this device without delay,” Imlay’s letter concluded. Copies of the correspondence were sent to the importer. In separate correspondence to FCC Commissioner Ajit Pai, seeking his review of the complaint, Imlay said the Lumatek unit was “typical in terms of its performance, and many other types of ‘grow lights’ are being imported, marketed, sold and deployed now.” One of Pai’s main interests is the revitalization of the AM Broadcast Band, where noise can be an impediment to reception. “It is not at all an exaggeration that even one of these electronic ballasts operated in a residential neighborhood makes any AM Broadcast reception impossible,” Imlay asserted. The League included a copy of its test report with the letter to Commissioner Pai. “Marked increases in the noise floor at MF and HF, year-over-year, are well-known to active Amateur Radio licensees, and it is devices such as the Lumatek LK-1000 and its progeny that are major contributors to this noise pollution,” Imlay added.