The undersigned serves as General Counsel for ARRL, the national association for Amateur Radio. In that capacity I filed yesterday with the Commission's Enforcement Bureau and with the Laboratory of the Office of Engineering and Technology the attached complaint on behalf of ARRL with respect to a radiofrequency lighting device. The device is commonly known as a "grow light" and it is used for agricultural and horticultural applications. It is being sold now at retail through such large outlets as Sears and Amazon.com. This model, the Lumatek LK-1000 electronic ballast, sold to consumers, is typical in terms of its performance, and many other types of "grow lights" are being imported, marketed, sold and deployed now. 

As can be seen from the Conducted Emissions Test Report submitted with the Complaint, the device under test grossly exceeds the Commission's Part 18 limits for conducted emissions, throughout the entire medium-frequency and high-frequency range. 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. The same is true with MF or HF Amateur Radio operation throughout entire frequency allocations. ARRL's laboratory has noted preclusive interference from these devices at distances up to 1/2 mile from the single emitter.  

ARRL is sending copies of this to you because of your well-known concern with the revitalization of the AM Broadcast Service. As the comments in Docket 13-249 will reflect, noise in the AM Broadcast Band is a major impediment to any revitalization effort. It is also a major problem for users of the HF spectrum, and especially radio Amateurs, who conduct their public service avocation, in major part, from their residences. 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. 

We hope that the Commission's Enforcement Bureau will take immediate action to remove this product from retail sale and to take appropriate action against the importer of the device. In a larger sense, however, an investigation should be initiated into other, similar RF lighting ballasts, as many, perhaps most have been observed by ARRL to exhibit the same grossly excessive conducted emission levels as does this device.

Thank you for your review of this complaint. 

Kind regards,

Chris Imlay

General Counsel, ARRL