Bonnie's note describes the US/FCC regulations issues regarding ROS and SS
really well. It's the best description of the US problem I've seen on this
reflector.
After reading what seems like hundreds of notes, I now agree that if ROS uses
FHSS techniques, as its author says it does (and none of us has seen the code),
then even though it 1) uses less 3 kHz bandwidth, 2) does not appear to do
any more harm than a SSB signal and 3) is similar to other FSK modes, it is not
legal in FCC jurisdictions.
As Bonnie points out, ROS "doesn't hop the VFO frequency," but within the 2.5
bandwidth, it technically is SS. This would be true if ROS used 300 Hz
bandwidth instead of 2.5 kHz, but hopped about using FHSS within the 300 Hz
bandwidth. So I have to agree the FCC regs are not well written in this case.
Regarding the corollary issue of US/FCC regulations focused on content instead
of bandwidth, I'm not competent to comment.
Jim - K6JM
----- Original Message -----
From: expeditionradio
To: digitalradio@yahoogroups.com
Sent: Sunday, February 21, 2010 5:09 PM
Subject: [digitalradio] FCC Technology Jail: ROS Dead on HF for USA Hams
Given the fact that ROS Modem has been advertised as Frequency Hopping Spread
Spectrum (FHSS), it may be quite difficult for USA amateur radio operators to
obtain a positive interpretation of rules by FCC to allow use of ROS on HF
without some type of experimental license or waiver. Otherwise, hams will need
an amendment of FCC rules to use it in USA.
Sadly, this may lead to the early death of ROS among USA hams.
If ROS Modem had simply provided the technical specifications of the
emission, and not called it "Spread Spectrum", there would have been a chance
for it to be easily adopted by Ham Radio operators in USA.
But, the ROS modem designer is rightfully proud of the design, and he lives
in a country that is not bound by FCC rules, and probably had little or no
knowledge of how his advertising might prevent thousands of hams from using it
in USA.
But, as they say, "You cannot un-ring a bell, once it has been rung".
ROS signal can be viewed as a type of FSK, similar to various other types of
n-ary-FSK presently in widespread use by USA hams. The specific algorithms for
signal process and format could simply have been documented without calling it
Frequency Hopping Spread Spectrum (FHSS). Since it is a narrowband signal
(using the FCC and ITU definitions of narrowband emission = less than 3kHz)
within the width of an SSB passband, it does not fit the traditional FHSS
description as a conventional wideband technique.
It probably would not have been viewed as FHSS under the spirit and intention
of the FCC rules. It doesn't hop the VFO frequency. It simply FSKs according to
a programmable algorithm, and it meets the infamous 1kHz shift 300 baud rule.
http://www.arrl.org/FandES/field/regulations/news/part97/d-305.html#307f3
This is a typical example of how outdated the present FCC rules are, keeping
USA hams in "TECHNOLOGY JAIL" while the rest of the world's hams move forward
with digital technology. It should come as no surprise that most of the new ham
radio digital modes are not being developed in USA!
But, for a moment, let's put aside the issue of current FCC "prohibition"
against Spread Spectrum and/or Frequency Hopping Spread Spectrum, and how it
relates to ROS mode. Let's look at "bandwidth".
There is the other issue of "bandwidth" that some misguided USA hams have
brought up here and in other forums related to ROS. Some superstitious hams
seem to erroneously think that there is an over-reaching "bandwidth limit" in
the FCC rules for data/text modes on HF that might indicate what part of the
ham band to operate it or not operate it.
FACT:
"There is currently no finite bandwidth limit on HF data/text emission in USA
ham bands, except for the sub-band and band edges."
FACT:
"FCC data/text HF rules are still mainly based on "content" of the emission,
not bandwidth."
New SDR radios have the potential to transmit and receive wider bandwidths
than the traditional 3kHz SSB passband. We will see a lot more development in
this area of technology in the future, and a lot more gray areas of 20th
century FCC rules that inhibit innovation and progress for ham radio HF digital
technology in the 21st century.
Several years ago, there was a proposal to FCC to provide regulation by
bandwidth rather than content. However, it failed to be adopted, and ARRL's
petition to limit bandwidth was withdrawn
http://www.arrl.org/news/stories/2007/04/27/101/?nc=1
Thus, USA hams will continue to be in Technology Jail without access to many
new modes in the foreseeable future :(
Best Wishes,
Bonnie Crystal KQ6XA
