--- In digitalradio@yahoogroups.com, Dave Ackrill <dave.g0...@...> wrote:
>
> Does anyone have a definition of real spread spectrum?  As I hate to 
> think  what will happen when/if people with even less knowledge than I 
> have of what 'real' spread spectrum is get the idea that RIO is 
> something that it is actually not and start their inevitable campaign of 
> 'It's illegal, it's immoral and it makes you fat', to use the words of 
> the song...
> 
> Dave (G0DJA)
>

Well, as a G0 its perfectly acceptable that you don't know.  The K's N's W's 
and A's have no such excuse.

Lets check out 47CFR2.201 and see what type of signal ROS is.

The first letter is modulation.  Clearly its F Frequency modulated.  I read the 
ROS PDF and its basically a 16FSK that has its carrier frequency 
modulated/wiggled in a peculiar pattern.

The number is "nature of signal(s) modulating the main carrier".  Clearly its 
2, "A single channel containing quantized or digital information with the use 
of a modulating sub-carrier, excluding time-division multiplex".  That 
sub-carrier is the 16FSK, which thankfully (?) isn't TDM data.

The second letter is "type of information to be transmitted".  Well, obviously 
that is D for data.  We're not sending "E" voice or "A" telegraph or whatever 
here.

So, the overall "FCC Emission designator" would pretty obviously be "F2D".

Where can we run F2D?  First, hit FCC 97.305(c) "authorized emission types" 
table.  The FCC says SS only on 222 and up.  I have no idea what inspires 
people to publically claim you can only run SS on 432 and up, as 97.305(c) 
explicitly permits it on 222 and up.  For another example, on 30M we can do 
RTTY or DATA.  

How does "DATA" or "RTTY" or "SS" or "PULSE" relate to emissions designators?  
The FCC helpfully defines that in 97.3(c)

To qualify as SS all it needs per 97.3(c)(8) is "Spread-spectrum emissions 
using bandwidth-expansion modulation emissions having designators with A, C, D, 
F, G, H, J or R as the first symbol; X as the second symbol; X as the third 
symbol."

F2D doesn't seem to match the def of "SS".

To qualify as DATA all it needs per 97.3(c)(2) is "Telemetry, telecommand and 
computer communications emissions having (i) designators with A, C, D, F, G, H, 
J or R as the first symbol, 1 as the second symbol, and D as the third symbol; 
(ii) emission J2D; and (iii) emissions A1C, F1C, F2C, J2C, and J3C having an 
occupied bandwidth of 500 Hz or less when transmitted on an amateur service 
frequency below 30 MHz. Only a digital code of a type specifically authorized 
in this part may be transmitted."

F2D doesn't seem to match the def of "DATA".

Looks like USA folks can't transmit ROS at all, on any band.  Ooops.

Will people fooling around with ROS get dragged to court?  Probably not.  See 
97.305(b) "A station may transmit a test emission on any frequency authorized 
to the control operator for brief periods for experimental purposes, except 
that ... (essentially no SS or pulse where not otherwise permitted)".  So, 
fooling around for testing and experimentation of a new mode is well within the 
law by this exception.  Running a contest, a regular schedule, a formal net, 
DXing, QSL card collecting, county hunting, or extensive ragchewing would be 
strictly verboten under 97.305(b).  The key is doing it in a documented manner 
as an experiment, like as a research experiment or an article for QEX.  Realize 
that big brother can deprive you of your life and liberty at any time for any 
reason, its not as if a rule prevents that, it just claims Big Bro won't do it, 
and politicians never lie...

In summary, the problem seems to be FM modulating the carrier of the 16FSK.

73 de Vince N9NFB

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