The closest you get to a true definition in Part 97 is in section 97.3 
Definitions, Para C, line 8:
(8) SS. 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.

ROS uses SSB so the first designator is J (this meets the definition) and it 
uses bandwidth-expansion. (this meets that definition as well)  Thus, taking 
this definition literally, it is indeed Spread Spectrum and is thus illegal 
below 222MHz....at least that the conservative interpretation that I'll stick 
with until we get a ruling otherwise.


====================
Dave
K3DCW
Real radio bounces off the sky





On 21 Feb, at 2:45 AM, J. Moen wrote:

> 
> 
> What is the FCC definition of spread spectrum, and where can it be located on 
> the internet?
>  
>    Jim - K6JM
>  
> ----- Original Message -----
> From: John B. Stephensen
> To: digitalradio@yahoogroups.com
> Sent: Saturday, February 20, 2010 7:58 PM
> Subject: [digitalradio] ROS - make it legal in USA
> 
> 
> ROS is MFSK16 with frequency hopping so it is SS per the FCC definition as 
> the bandwidth is expanded. However, the FCC never fined anyone during the 
> period when Hellscreiber was used illegally so I doubt that they would do so 
> with ROS.
>  
> What ROS users should do is email their ARRL representative and have them 
> petition the FCC to change the rules. One solution is to eliminate the 
> emission designators and change the RTTY/data segment of each HF band to 
> 0-500 Hz wide emissions and the phone/image of each HF band to 0-8 kHz wide 
> emissions with 0-20 kHz above 29 MHz. 
>  
> 73,
>  
> John
> KD6OZH
> 
> 

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