That is part of the story but SS in that context is specifically defined in 97.3.
KH6TY wrote: > > §97.305 Authorized emission types is the regulation that > authorizes SS for 222 Mhz and above only. > > 73 - Skip KH6TY > > > > > w2xj wrote: >> >> >> Please provide a citation from part 97 that prohibits ROS even if it >> were deemed to truly be spread spectrum. >> >> KH6TY wrote: >> > In most legal documents, specific references override general ones. >> > >> > In this discussion, only the FCC attorneys can decide what is allowed >> > and what is not. Until then, the specific regulations regarding SS are >> > assumed to be the law in this country, no matter how badly it is >> > desired to use the new mode, and what rationalizations are made for >> > being able to use it. >> > >> > This road has been traveled before! >> > >> > 73 - Skip KH6TY >> > >> > >> > >> > >> > w2xj wrote: >> >> >> >> >> >> I have spent the last hour looking through part 97. I find nothing >> that >> >> >> >> would prohibit ROS in the HF bands subject to adhering to those >> segments >> >> where the bandwidth is allowed. In fact the rules would appear to >> >> support such operation: >> >> >> >> (b) Where authorized by §§ 97.305(c) >> >> and 97.307(f) of this part, a station may >> >> transmit a RTTY or data emission >> >> using an unspecified digital code, except >> >> to a station in a country with >> >> which the United States does not have >> >> an agreement permitting the code to be >> >> used. RTTY and data emissions using >> >> unspecified digital codes must not be >> >> transmitted for the purpose of obscuring >> >> the meaning of any communication. >> >> When deemed necessary by a District >> >> Director to assure compliance >> >> with the FCC Rules, a station must: >> >> (1) Cease the transmission using the >> >> unspecified digital code; >> >> (2) Restrict transmissions of any digital >> >> code to the extent instructed; >> >> (3) Maintain a record, convertible to >> >> the original information, of all digital >> >> communications transmitted >> >> >> >> I also do not see anything in the part 97 subsection on spread >> spectrum >> >> ( if in fact ROS was really determined to be an SS mode) that >> would make >> >> ROS non compliant. >> >> >> >> Part 97 technical standards mostly harmonize US rules with ITU >> >> international treaties They are written to be quite broad in order to >> >> permit experimentation. So long as the coding technique is public and >> >> can be received by anyone, the real restriction is based on allowable >> >> bandwidth and power allocated for a given frequency. >> >> >> >> John B. Stephensen wrote: >> >> > The attachments are a good illustration why the rules should be >> >> changed. Olivia and ROS use a similar amount of spectrum so the FCC >> >> shouldn't be calling one legal and the other illegal based on how >> >> they were generated. >> >> > >> >> > 73, >> >> > >> >> > John >> >> > KD6OZH >> >> > >> >> > ----- Original Message ----- >> >> > From: Tony >> >> > To: digitalradio@yahoogroups.com >> <mailto:digitalradio%40yahoogroups.com> >> >> <mailto:digitalradio%40yahoogroups.com> >> >> > Sent: Sunday, February 21, 2010 08:20 UTC >> >> > Subject: [digitalradio] A closer look at ROS [2 Attachments] >> >> > >> >> > >> >> > >> >> > [Attachment(s) from Tony included below] >> >> > >> >> > >> >> > >> >> > All, >> >> > >> >> > It would appear that ROS-16 is not much different than say Olivia >> >> 128 / 2K. The number of tones may differ, but they both use MFSK >> >> modulation with sequential tones running at 16 baud. The question is >> >> how can ROS be considered a SS frequency hoping mode while Olivia and >> >> it's derivatives are not? >> >> > >> >> > A closer look shows that they are quite similar (see attached). >> >> > >> >> > Tony -K2MO >> >> > >> >> > >> >> > >> >> > >> >> > >> >> >> >> >> > >> >> >