Greetings. Yesterday, I filed the attached complaint with the FCC's Enforcement Bureau and the OET laboratory. Accompanying the complaint was the attached Conducted Emissions Test Report prepared by Ed Hare, Mike Gruber and our consultant Jerry Ramie, KI6LGY. This is a well-done test report and the lab staff should be congratulated for it. Below is the text of an e-mail that I sent this morning to FCC Commissioner Pai about this. The reason we targeted Pai is that he has taken on as his own crusade the revitalization of AM Broadcasting. There is an open docket now on AM revitalization and one of the recurring themes (because I raised it, among several others) in comments in that docket is the high and increasing level of RF noise in the AM broadcast band. RF Lighting devices, and especially these "grow lights" that we are complaining about have interference potential of epic proportions. Marijuana growers are using them in large numbers, as are legitimate horticulturalists. So it is a big threat. Thanks on this also to Kermit Carlson, who has shepherded this along from its inception. 73, Chris W3KD Christopher D. Imlay Booth, Freret & Imlay, LLC 14356 Cape May Road Silver Spring, Maryland 20904-6011 (301) 384-5525 telephone (301) 384-6384 facsimile W3KD@ARRL.ORG -----Original Message----- From: Chris Imlay <w3kd@aol.com> To: ajit.pai <ajit.pai@fcc.gov>; brendan.carr <brendan.carr@fcc.gov> Cc: kcraigie <kcraigie@arrl.org>; dsumner <dsumner@arrl.org>; kermit <kermit@fnal.gov> Sent: Thu, Mar 13, 2014 12:37 pm Subject: Complaint of Part 18 Rule Violations, RF Lighting Device; AM Broadcast Interference Greetings, Commissioner Pai: 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 Christopher D. Imlay Booth, Freret & Imlay, LLC 14356 Cape May Road Silver Spring, Maryland 20904-6011 (301) 384-5525 telephone (301) 384-6384 facsimile W3KD@ARRL.ORG