I disagree. We are required to determine whether a mode is legal before using it. The author initially described ROS as being spread spectrum. Part 97 precludes the use of spread spectrum on HF, but gives no clear definition of spread spectrum. The FCC bears responsibility for this lack of clarity, and so cannot blame amateurs who seek their help in determining whether ROS is legal on HF. They do work for us, after all.
In my conversation with Dawn (FCC agent 3820), there was not a whiff of "why are you guys annoying us with this nonsense?". She wasn't happy about having her words publicly twisted into "ROS is legal on HF", though. 73, Dave, AA6YQ -----Original Message----- From: digitalradio@yahoogroups.com [mailto:digitalra...@yahoogroups.com]on Behalf Of J. Moen Sent: Wednesday, March 03, 2010 1:04 PM To: digitalradio@yahoogroups.com Subject: Re: [digitalradio] Re: Statement on Withdrawal of Support for ROS (K3UK Sked Pages) "And think real hard next time before calling the FCC. Ham radio was the net loser in this episode. We are already viewed as squabbling children at the FCC, and this type of episode just reinforces that view of amateur radio." AMEN. Jim - K6JM ----- Original Message ----- From: Alan Barrow To: digitalradio@yahoogroups.com Sent: Wednesday, March 03, 2010 8:06 AM Subject: Re: [digitalradio] Re: Statement on Withdrawal of Support for ROS (K3UK Sked Pages) pd4u_dares wrote: > ... considering legal action ... has an apparent plan ... may have understandably frustrated Jose > I really have mixed feelings about how this all played out as well. While I don't agree with ban lists, I can see where the software author could get very frustrated at what could be perceived as an attempt to get a new mode banned. My observation is that when an "arms length" ham goes to the ARRL/FCC with an "is this legal" it nearly always results in a "at first glance we do not think so". Historically, this is nearly always done by people opposed to the new mode, and looking to see it banned. Having seen this happen more than once, and having detailed information on two of those cases, it's the wrong way to handle such a query, even if done in good faith. And like most times this occurs, with more detail, and maybe a bit more objective presentation (like making it clear it's ssb bandwidth with an audio sample), the FCC Input is reversed. (it was never a decision, just an opinion based on the facts at hand) In this particular case it's made much worse by the sparse, poor wording in the fcc regs. The issue was not that ROS technically used SS type techniques. Or even could clearly be called SS using the ITU definition. Instead, the core issue was: "did ROS behave like traditional SS in a way that would cause interference and thus was banned under 220 mhz. " And the answer to that is clearly no. It behaves like many other AFSK'ish modes that use an SSB bandwidth. Other legal modes use randomization in a way that by very strict interpretation could be called SS. Had it hopped across 100khz, using vco rf stages, it'd clearly be illegal. Personally, I think it's unfair to compare to the other authors, as they have never had such a (real or perceived) attack on their software, the product of many hours of work. And we had cross language/culture issues at play here as well. This was not an "I don't like it", or "it does not work well", all authors have to deal with that. It was a "we don't think it should be used" debate. And much more personal and at risk. So my view is that we should all learn from this, put the swords back in the scabbards, and not alienate someone who took the time to create something innovative, and made it available for use. For free. And think real net loser hard next time before calling the FCC. Ham radio was the in this episode. We are already viewed as squabbling children at the FCC, and this type of episode just reinforces that view of amateur radio. Sincerely, Alan km4ba