Excellent idea to ask FCC for an opinion.  

Dave K3DCW referred to Part 97, but the section he quoted really only describes 
emission mode designation codes for SS, and does not technically describe how 
FCC defines SS.  It's almost as if Part 97 assumes the definition is so well 
known that it's not necessary to define it.

Problem is, for many years, SS really did operate over a very large bandwidth, 
much wider than 2.5 kHz.  It was thought use of that form of SS had the 
potential of interfering with many narrowband users. That was not necessarly 
true, of course.  But now we are seeing modes that are much narrower band.  

I would be good if FCC responds to your letter with their technical description 
of SS.  It's possible they will say that if you modulate tones within 500 hz 
using frequency hopping SS techniques, then that is SS.  It's also possible 
they would agree that a transmission less than 2.5 kHz wide does not qualify as 
SS, even though the modulation technique use SS methods.

But right now, I think that since Part 97 does not appear to define what SS is, 
it is not possible to definitively say whether ROS is legal or not legal in FCC 
jurisdictions.  Asking FCC for an opinion is a great idea.

     Jim - K6JM

This is from Dave K3DCW's comment:
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.

  ----- Original Message ----- 
  From: Andy obrien 
  To: digitalradio@yahoogroups.com 
  Sent: Sunday, February 21, 2010 7:41 AM
  Subject: [digitalradio] ROS, legal in USA? Letter to FCC


    
  I have compiled a letter to Laura Smith Esq, at the FCC,  with details of 
this mode.  I will let you all know when I receive a reply.

  Andy K3UK


  

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