John B. Stephensen wrote: > > A lawyer with an engineering degree would be the best person > to interpret FCC regulations. The ARRL has engineers and lawyers and > deals with the FCC so they are the best source of free advice in the U.S.
No disrespect intended to the ARRL tech leads, but I'm personally aware of three cases where the initial read from ARRL tech contacts were overturned later when examined properly. And same for the ad-hoc ULS query to the FCC that followed on two of them. One was never opposed by the FCC. One of those decisions specifically involved code injection to randomize the resultant carriers & sidebands. It was not SS or encryption, but some construed it to be. Another involved Frequency multiplexing. Back to ROS, My observation is that the FCC said "the author states it's SS, and he is best positioned to know"... Not that different than I'd expect for a query sent without any context. No idea what qualifications agent 3820 has, they may be great, or may just be licensing. We have other engineer resources that can be worked with when engaged properly. I don't have a horse in this race, just hate seeing things play out this way. Anytime we go to the FCC with an amateurish "is this legal" we lose, both directly with the (no surprise) cursory read that is very conservative and long term with lost credibility. I've seen the right way play out more than once, and this was not it! ROS has many aspects of SS, and might technically be a form of SS. But it also is missing some of the key attributes that makes SS disallowed below 222 Mhz, and as such should be evaluated in more than a cursory fashion. By forcing the issue (poorly, in my mind), we lost that opportunity. Or certainly muddied the waters enough that it will now be 10x harder to get a clean read. This has nothing to do with the merits of the mode, it's the process and the "putting the amateur back in amateur radio" behavior associated with it. Kind of pathetic, if you think about it. Have fun, and better luck with the next mode! Alan km4ba
