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
>> >> >
>> >> >
>> >> >
>> >> >
>> >> >
>> >>
>> >>
>> >
>>
>>
>

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