Self-regulating means that we police ourselves and obey the rules on the honor system. It also might mean the Official Observers assist in regulations. "Regulating" means following rules, not interpreting them for our own benefit, but as accurately as possible.

If you were the FCC and had received a seven page document describing ROS as FHSS, and then later received a two page "technical description" that was COMPLETELY DIFFERENT, but that ROS had not changed, would you believe the first document or the second, knowing that the mode may really be FHSS butis now called something else in order to achieve legal status?

Under these circumstances, I DO think they will put enough effort into this to find the TRUTH. It is clear that they can no longer just believe the author, since his story has done a 180 degree shift, so I would think they feel they are now obligated to make tests to determine if the mode really is FHSS or FSK144, or something else, since they no longer can trust what the author says. The change is so enormous that it is not just a matter of having left something out the first time.

My guess is the FCC will, but from the spectral analysis Steiner has made, there is probably no problem. It is just that the author, who claims he is the dependable source, simply cannot be trusted 100% to tell the truth, and has already reversed himself once.

Tough situation. :-(

73 - Skip KH6TY



W2XJ wrote:
Skip

Do you really think the FCC will put that much effort into this? They really want amateur radio to be self regulating. I think that people who bother the comish with such trivia degrades the hobby. When the administration of our activities become too burdensome, the FCC will be less inclined to support it. I can not see them using valuable engineering time on this.

What the FCC stated was that based on the documentation, the developer claimed it was SS but it was up to the individual amateur to make the determination. They made no ruling or determination, just a carefully worded opinion of a staff member. Part of holding a license is being able to determine which operation is legal. The same thing came up over digital repeaters a few years ago. An FCC staff member told an interested group at Dayton that if they were qualified to hold their license, they should have the ability to read and interpret the rules and figure it out for themselves.

------------------------------------------------------------------------
*From: *KH6TY <kh...@comcast.net <kh...@comcast.net>>
*Reply-To: *<digitalradio@yahoogroups.com <digitalradio@yahoogroups.com>>
*Date: *Sat, 27 Feb 2010 09:58:58 -0500
*To: *<digitalradio@yahoogroups.com <digitalradio@yahoogroups.com>>
*Subject: *Re: [digitalradio] Re: There is a pattern in the ROS signal when idling

Thanks for the clarification, Rein.

That agrees with what Steinar sees, and with the Wikipedia discussion, which says in part, "Most pseudorandom generator algorithms produce sequences which are uniformly distributed </wiki/Uniform_distribution_%28discrete%29> by any of several tests. It is an open question, and one central to the theory and practice of cryptography </wiki/Cryptography> , whether there is any way to distinguish the output of a high-quality PRNG from a truly random sequence without knowing the algorithm(s) used and the state with which it was initialized."

The differentiating factor in FHSS is apparently whether or not the data is superimposed on the carriers, or if the carrier frequencies are determined by the data. I cannot see that happing in ROS, and I can in all the FSK modes, but maybe I just do not know how to find it for sure. I guess the FCC engineers will probably figure out if ROS is actually spread spectrum as originally claimed, or FSK with FEC as now claimed.

It is just hard to imagine that someone as intelligent and capable as Jose could make such a huge mistake after writing seven pages of text and diagrams describing the mode the first time! No wonder the FCC believed him! Will they now believe him, or will they believe that the so-called "technical description" now on the ROS website is just an attempt to get ROS considered legal on HF? Probably they will believe only their own tests now, so we will have to wait for those.

The FCC does not care about the "mode", or what it is called, but only what is transmitted on the air.
73 - Skip KH6TY



pa0r wrote:

    SS uses pseudorandom codes to wag the carrier(s).
    EVERY pseudorandom code is repetitive, the length may vary.
73, Rein PA0R --- In digitalradio@yahoogroups.com <digitalradio@yahoogroups.com>
    <mailto:digitalradio%40yahoogroups.com
    <mailto:digitalradio%40yahoogroups.com>> , KH6TY <kh...@...>
    <mailto:kh...@... <mailto:kh...@...>>  wrote:
    >
    > That's a good analysis, Steinar. Is it possible to see if the
    pattern
    > changes when sending data? That is all the FCC is concerned
    about. The
    > pattern has to change when sending data and not just remain the
    same to
    > exclude it from being FHSS.
    >
    > 73 - Skip KH6TY
    >
    >
    >
    >
    > Steinar Aanesland wrote:
    > >
    > > [Attachment(s) <#TopText> from Steinar Aanesland included below]
    > >
    > > Hi Skip
    > >
    > > I have been monitoring a ROS idling over time using DL4YHF's
    Spectrum
    > > Lab. Here is the results.You can clearly see a pattern
    > >
    > > 73 de LA5VNA Steinar
    > >
    > > On 26.02.2010 12:29, KH6TY wrote:
    > > > Alan,
    > > >
    > > > Of course, the FCC rules on SS are outdated and ROS should be
    allowed
    > > > due to its narrow spreading range, but the road to success is
    not to
    > > > just rename a spread spectrum modem to something else and try
    to fool
    > > > the FCC. This is a sure way to lose the battle. The genie is
    already
    > > > out of the bottle!
    > > >
    > > > Instead, just petition the FCC for a waiver, or amendment, to the
    > > > regulations that are a problem, to allow FHSS as long as the
    spreading
    > > > does not exceed 3000 Hz and the signal is capable of being
    monitored
    > > > by third parties. Do this, and there is not a problem
    anymore. But, do
    > > > not try to disguise the fact that FHSS is being used by
    calling it
    > > > something else, as that undermines the credibilty of the
    author of the
    > > > mode and will make the FCC even more determined not to it on
    HF/VHF.
    > > >
    > > > It looks to me that the tone frequencies are clearly being
    generated
    > > > independently from the data and then the data applied to the
    randomly
    > > > generated frequency. There is NO pattern to ROS like there is
    to FSK
    > > > modes, even to 32 tone FSK (Olivia 32-1000) or to 64 tone FSK
    > > > (MT63-2000). This is a signature of FHSS.
    > > >
    > > > “/If/ it walks /like a duck/, quacks /like a duck/, /looks
    like a
    > > > duck/, it must be a /duck/‡.
    > > >
    > > > It looks like ROS really is FHSS when you look at it on a
    spectrum
    > > > analyzer, and the spectrum analyzer does not lie.
    > > >
    > > > 73 - Skip KH6TY
    > > >
    > > >
    > > >
    > >
    > >
    >



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