[SFDXA] ARRL to FCC: "Grow Light" Ballast Causes HF Interference, Violates Rules

[Bill]

 From Chuck W4ROA:


    ARRL to FCC: “Grow Light” Ballast Causes HF Interference, Violates Rules

    The ARRL has formally*complained*
    <http://www.arrl.org/files/media/News/Complaint%20Letter%20re%20Lumatek%20RF%20Lighting%20Device.pdf>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-100 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/*
    <http://www.arrl.org/files/media/News/Lumatek%20Cond%20Emissions%20Test%20Report%20Pt18b%20Rev%20D.pdf>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. The ARRL also called
    on the FCC to consider enforcement proceedings against the importer,
    Hydrofarm Horticultural Products of Petaluma, California.

    “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.