A recent ARRL proposal for rule making submitted to the FCC (RM 10413) yet again proposes activity that would harm or even destroy current 222 MHz. activity, activity that is now in the best scientific traditions of Amateur Radio. This proposal would promote spread spectrum modulation on the 135 centimeter Ham band. Past admonishments from VHF and weak signal groups have explained to the ARRL why this is untenable.

The nature of spread spectrum causes a rise in noise floor level that is proportional to the number of users within a given range of frequencies. SCRRBA, the Southern California Repeater and Remote Base Station Association, which is the FCC recognized frequency coordination group in southern California has denounced spread spectrum use on the bands for which it provides coordination. SCRBBA's Robin Critchell has elaborated to spread spectrum promoters, 'tell us how greatly the noise floor will be heightened for your proposed activity, and we will tell you if this is acceptable for proper coordination'. The spread spectrum promoters can't do this though. The reason they can't is that they don't know!

As more and more stations engage in spread spectrum communication, the noise floor increases. This would occur as a geometric progression. The more users, the higher and higher the noise floor becomes. For Frequency Modulation users this would probably not be too much of a problem. Even for FM'ers though, it would depend on how good the noise limiting was in their particular receivers. Even many "land mobile" commercial receivers popularly used to fabricate repeaters may not be immune. Most of the commonly used Japanese radios would most likely be susceptible. The most egregious and deleterious problem would be to Single Sideband (SSB) and Continuous Wave (CW really iCW) operations. There is no provision that would limit or relieve the noise floor condition as it would be 'seen' by such product detector receivers.

Now, the ARRL does point out that any such spread spectrum operation would have to comply to present FCC rules. This means that, the spread spectrum operation should not interfere with other recognized modes of operation, and that it should tolerate interference from existing modes. How would this work? The answer is it wouldn't!

Spread spectrum users would have no idea what communication on SSB or iCW they were interfering with. They wouldn't know it was going on, and does anyone think that they would ask? The spread spectrum radios would not be compatible with SSB or iCW. Spread spectrum users would not invest in SSB/iCW capable equipment just so they could see if it might be OK to fire up their spread spectrum transmitter! So, how would they know what communications they were interfering with? Even if none were happening at the moment they started transmitting, what if the wavelength was then to become available to support weak signal DX communication? The answer is that any spread spectrum transmission would destroy this possibility! The modes are just simply not compatible. One must yield to the other. So who must yield?

The 135 centimeter band is a truly magic band! Since it is only available in the United States, its both magic and rare! It is only in the last several years that SSB and iCW weak signal stations on this band have discovered and promoted the nature of long distance (DX) signal propagation available on this band. Since the band is available to only U.S. Hams, it is the last Ham band that should be considered for spread spectrum. We need to use and promote this band, not pollute and destroy it! The ARRL has been told this before. They are evidently not remembering this! I wonder what their own technical advisors think of this. Since I used to be one, I can tell you that I told them about this years ago!

Please investigate this matter yourself. Inquire with "Weak Signal" VHF Ham clubs. Inquire with SCRRBA. Read the ARRL proposal on the Internet at : http://www.arrl.org/announce/regulatory/refarm/ The 222 MHz. portion of this proposal is found in section 21. Please read it and respond to the FCC before the cutoff date of May 16. Each of us as licensed Hams are the trustees of better than 23 thousand MegaHertz of Amateur Radio spectrum. If we don't protect our radio frequency spectrum, noone else will!