In most legal documents, specific references override general ones.
In this discussion, only the FCC attorneys can decide what is allowed
and what is not. Until then, the specific regulations regarding SS are
assumed to be the law in this country, no matter how badly it is desired
to use the new mode, and what rationalizations are made for being able
to use it.
This road has been traveled before!
73 - Skip KH6TY
w2xj wrote:
I have spent the last hour looking through part 97. I find nothing that
would prohibit ROS in the HF bands subject to adhering to those segments
where the bandwidth is allowed. In fact the rules would appear to
support such operation:
(b) Where authorized by §§ 97.305(c)
and 97.307(f) of this part, a station may
transmit a RTTY or data emission
using an unspecified digital code, except
to a station in a country with
which the United States does not have
an agreement permitting the code to be
used. RTTY and data emissions using
unspecified digital codes must not be
transmitted for the purpose of obscuring
the meaning of any communication.
When deemed necessary by a District
Director to assure compliance
with the FCC Rules, a station must:
(1) Cease the transmission using the
unspecified digital code;
(2) Restrict transmissions of any digital
code to the extent instructed;
(3) Maintain a record, convertible to
the original information, of all digital
communications transmitted
I also do not see anything in the part 97 subsection on spread spectrum
( if in fact ROS was really determined to be an SS mode) that would make
ROS non compliant.
Part 97 technical standards mostly harmonize US rules with ITU
international treaties They are written to be quite broad in order to
permit experimentation. So long as the coding technique is public and
can be received by anyone, the real restriction is based on allowable
bandwidth and power allocated for a given frequency.
John B. Stephensen wrote:
> The attachments are a good illustration why the rules should be
changed. Olivia and ROS use a similar amount of spectrum so the FCC
shouldn't be calling one legal and the other illegal based on how they
were generated.
>
> 73,
>
> John
> KD6OZH
>
> ----- Original Message -----
> From: Tony
> To: digitalradio@yahoogroups.com
<mailto:digitalradio%40yahoogroups.com>
> Sent: Sunday, February 21, 2010 08:20 UTC
> Subject: [digitalradio] A closer look at ROS [2 Attachments]
>
>
>
> [Attachment(s) from Tony included below]
>
>
>
> All,
>
> It would appear that ROS-16 is not much different than say Olivia
128 / 2K. The number of tones may differ, but they both use MFSK
modulation with sequential tones running at 16 baud. The question is
how can ROS be considered a SS frequency hoping mode while Olivia and
it's derivatives are not?
>
> A closer look shows that they are quite similar (see attached).
>
> Tony -K2MO
>
>
>
>
>
