Thanks again Jose, I have all your documentation (current only) and I think this is where some of the confusion was created. part of your documentation clearly defines the transmissions as "spread spectrum". In the true sense, this is not really correct as you have noted. In true spread spectrum, the instantaneous transmitted frequency is not necessarily "random" at all. Rather, the transmitter and receiver MUST be synchronized to a common pattern via an algorithm/code of some sort. Since your transmitter output frequency is determined only by the input tones, which are determined by the input data + FEC coding, it does NOT become SS, as you have correctly noted. It should not be necessary to jump through numerous legal hoops solely because someone else sent an unfinished document to the FCC and asked for a "ruling". So far, there has been no "ruling, only and opinion based on the data presented in the request.
My suggestion would be simply remove any references to spread spectrum and change those references to FSK instead in ROS documentation v1.01. This should easily provide any US amateur plenty of backup to be able to show good faith that he is operating within the US FCC rules. Thanks again, John KE5HAM --- In digitalradio@yahoogroups.com, jose alberto nieto ros <nietoro...@...> wrote: > > You can download ROS User Guide 1.0 > > The introduction explain what is ROS and It speak about a 144 tone FSK. > > In a few days a will write a introduction to FSK esquemes. > > Thanks. > > > > > ________________________________ > De: John <ke5h...@...> > Para: digitalradio@yahoogroups.com > Enviado: mié,24 febrero, 2010 00:06 > Asunto: [digitalradio] Re: Consensus? Is ROS Legal in US?` > >  > Thank you Andy ...... > > This has been the point of many [posters here all along. It is only > considered spread spectrum because the author claimed it so, not because it > is technically so. Jose, are you hearing us? because of the way your program > operates an SSB transmitter, it "should" be defined as a form of FSK, "NOT > SPREAD SPECTRUM" .... > > Many of us here in the US would like to use your program and experiment with > it, but we are regulated by the FCC (we US hams did not write the rules we > have to abide by). They determined it to be spread spectrum solely because > you have declared it as such, and apparently for no other reason. > > Can you offer us some help here Jose? (like maybe recheck if it really is > spread spectrum vs FSK) and re-write your description? > > Thanks, > > John > KE5HAM > > --- In digitalradio@ yahoogroups. com, Andy obrien <k3ukandy@ .> wrote: > > > > The FCC has stated , today, that IF the author describes it as spread > > spectrum, the USA ham is responsible for determining the accuracy of this > > claim. They also affirmed that SS is not legal below 220 Mhz. The ARRL > > technical folks said today that , based on the description available, they > > believe it is SS and not legal in the USA below 220 Mhz. > > > > So the ARRL seems pretty clear. The FCC leaves some wiggle room for the ham > > that feels confident enough to withstand a potential future challenge from > > the FCC. Logic would dictate that if the FCC comes knocking, it world be > > hard to say it is NOT SS...if the author AND the FCC decide that it is. > > > > e,g. If I came out with a "new" mode that was just CW, but claimed it was > > SS, the average ham would be able to easily prove my claim wrong IF the FCC > > ever tried to take action against someone for using it. However, if a new > > mode appeared technically close to SS, it would be hard to prove the FCC > > wrong. If Jose re-wrote his description and dropped any reference to spread > > spectrum and frequency hopping, those USA hams using it would be safe unless > > the FCC decided for some odd reason to investigate the mode formally and > > make a ruling. If Jose maintains his description, the mode is not likely to > > get any use in the USA. > > > > > > Andy K3UK > > >
