Re: [digitalradio] FCC Technology Jail: ROS Dead on HF for USA Hams
I am not going to wade back into part 97 for this, but I believe 5 khz audio is beyond the scope of being communications quality. I know a number people who have a lot of rebuilt broadcast audio gear and are also audiophiles, many in the pro audio business and they are really in to this. Regardless, more than 3 khz if not blatantly illegal is certainly not what the FCC intended. From: "John B. Stephensen" Reply-To: Date: Mon, 22 Feb 2010 20:27:41 - To: Subject: Re: [digitalradio] FCC Technology Jail: ROS Dead on HF for USA Hams The 300 baud limit applies only to the HF RTTY/data segments. In the phone/image segments below 29 MHz there s no baud rate limit but the bandwidth is limited by the following parts of 97.307(f). (1) No angle-modulated emission may have a modulation index greater than 1 at the highest modulation frequency. (2) No non-phone emission shall exceed the bandwidth of a communications quality phone emission of the same modulation type. The total bandwidth of an independent sideband emission (having B as the first symbol), or a multiplexed image and phone emission, shall not exceed that of a communications quality A3E emission. Given the width of some amateur AM signals on 80 meters, this limit seems to be 10 kHz below 29 MHz. 73, John KD6OZH > > - Original Message - > > From: Trevor . <mailto:m5...@yahoo.co.uk> > > To: digitalradio@yahoogroups.com > > Sent: Monday, February 22, 2010 09:18 UTC > > Subject: Re: [digitalradio] FCC Technology Jail: ROS Dead on HF for USA Hams > > > > > > > > > However, there may be scope in interpretation of the regs. Up until a few > years ago many US amateurs were under the impression that you could only send > a maximum of 300 bits per second on HF. What the rules actually specified was > a maximum symbol rate of 300 Baud and, probably because no had thought to do > so, there was no limit specified on the number of carriers you could > transmit. That's how these days US hams can run digital voice/sstv. >
Re: [digitalradio] FCC Technology Jail: ROS Dead on HF for USA Hams
The 300 baud limit applies only to the HF RTTY/data segments. In the phone/image segments below 29 MHz there s no baud rate limit but the bandwidth is limited by the following parts of 97.307(f). (1) No angle-modulated emission may have a modulation index greater than 1 at the highest modulation frequency. (2) No non-phone emission shall exceed the bandwidth of a communications quality phone emission of the same modulation type. The total bandwidth of an independent sideband emission (having B as the first symbol), or a multiplexed image and phone emission, shall not exceed that of a communications quality A3E emission. Given the width of some amateur AM signals on 80 meters, this limit seems to be 10 kHz below 29 MHz. 73, John KD6OZH - Original Message - From: Trevor . To: digitalradio@yahoogroups.com Sent: Monday, February 22, 2010 09:18 UTC Subject: Re: [digitalradio] FCC Technology Jail: ROS Dead on HF for USA Hams However, there may be scope in interpretation of the regs. Up until a few years ago many US amateurs were under the impression that you could only send a maximum of 300 bits per second on HF. What the rules actually specified was a maximum symbol rate of 300 Baud and, probably because no had thought to do so, there was no limit specified on the number of carriers you could transmit. That's how these days US hams can run digital voice/sstv.
Re: [digitalradio] FCC Technology Jail: ROS Dead on HF for USA Hams
--- On Mon, 22/2/10, expeditionradio wrote: > Several years ago, there was a proposal to FCC to provide > regulation by bandwidth rather than content. However, it > failed to be adopted, and ARRL's petition to limit bandwidth > was withdrawn And the irony is that in 1977 (33 years ago!) the FCC itself proposed band planning by bandwidth with segments for 350 Hz, 3.5 kHz and 7.5 kHz. At the time the ARRL bitterly opposed it and the FCC withdrew the proposal. However, there may be scope in interpretation of the regs. Up until a few years ago many US amateurs were under the impression that you could only send a maximum of 300 bits per second on HF. What the rules actually specified was a maximum symbol rate of 300 Baud and, probably because no had thought to do so, there was no limit specified on the number of carriers you could transmit. That's how these days US hams can run digital voice/sstv. So it's down to interpretation and it'll hinge on the FCC's formal definition of Spread Spectrum with luck ROS will fall outside of it. Does anybody plan to contact the FCC this morning to get their view ? 73 Trevor M5AKA
Re: [digitalradio] FCC Technology Jail: ROS Dead on HF for USA Hams
Feel free to disagree, but please show respect for opinions that differ from yours. "BS" is not the most respectful term when disagreeing. Andy K3UK On Sun, Feb 21, 2010 at 9:36 PM, W2XJ wrote: > > > > Bonnie you have a Ham unfriendly addenda. Say what you like but at the end of > the day it is BS. > >
Re: [digitalradio] FCC Technology Jail: ROS Dead on HF for USA Hams
RF is RF and the FCC does not care how the frequency expansion is done, whether by VFO shift or supressed carrier tone shift. I am shocked that Bonnie does not understand that simple principle. For example, true FSK is done by VFO shift, but FSK is also done on SSB by tone shift. The result is identical, the only difference being that the transceiver does not have to be linear with FSK shift, but it does with tone frequency shift to prevent splatter. The problem with ROS is that the frequency shift is by a method too similar to that used in VFO-shifting spread spectrum (frequency hopping) transceivers, so to the observer, there is no difference. It is the frequency hopping that makes ROS spread spectrum, and unfortunately, that is against the FCC regulations. If it were not, there could possibly be spread spectrum transceivers using tone shifts much wider than an IF bandwidth, even using soundcards, just like SDR's spectrum displays use. In that case, more than one voice channel would be taken up for the benefit of the SS user, to the detriment of adjacent stations, or even those farther away, if there were no other limitations on bandwidth utilized. 73 - Skip KH6TY W2XJ wrote: Bonnie you have a Ham unfriendly addenda. Say what you like but at the end of the day it is BS. *From: *expeditionradio > *Reply-To: *> *Date: *Mon, 22 Feb 2010 01:09:14 - *To: *> *Subject: *[digitalradio] FCC Technology Jail: ROS Dead on HF for USA Hams Given the fact that ROS Modem has been advertised as Frequency Hopping Spread Spectrum (FHSS), it may be quite difficult for USA amateur radio operators to obtain a positive interpretation of rules by FCC to allow use of ROS on HF without some type of experimental license or waiver. Otherwise, hams will need an amendment of FCC rules to use it in USA. Sadly, this may lead to the early death of ROS among USA hams. If ROS Modem had simply provided the technical specifications of the emission, and not called it "Spread Spectrum", there would have been a chance for it to be easily adopted by Ham Radio operators in USA. But, the ROS modem designer is rightfully proud of the design, and he lives in a country that is not bound by FCC rules, and probably had little or no knowledge of how his advertising might prevent thousands of hams from using it in USA. But, as they say, "You cannot un-ring a bell, once it has been rung". ROS signal can be viewed as a type of FSK, similar to various other types of n-ary-FSK presently in widespread use by USA hams. The specific algorithms for signal process and format could simply have been documented without calling it Frequency Hopping Spread Spectrum (FHSS). Since it is a narrowband signal (using the FCC and ITU definitions of narrowband emission = less than 3kHz) within the width of an SSB passband, it does not fit the traditional FHSS description as a conventional wideband technique. It probably would not have been viewed as FHSS under the spirit and intention of the FCC rules. It doesn't hop the VFO frequency. It simply FSKs according to a programmable algorithm, and it meets the infamous 1kHz shift 300 baud rule. http://www.arrl.org/FandES/field/regulations/news/part97/d-305.html#307f3 <http://www.arrl.org/FandES/field/regulations/news/part97/d-305.html#307f3> This is a typical example of how outdated the present FCC rules are, keeping USA hams in "TECHNOLOGY JAIL" while the rest of the world's hams move forward with digital technology. It should come as no surprise that most of the new ham radio digital modes are not being developed in USA! But, for a moment, let's put aside the issue of current FCC "prohibition" against Spread Spectrum and/or Frequency Hopping Spread Spectrum, and how it relates to ROS mode. Let's look at "bandwidth". There is the other issue of "bandwidth" that some misguided USA hams have brought up here and in other forums related to ROS. Some superstitious hams seem to erroneously think that there is an over-reaching "bandwidth limit" in the FCC rules for data/text modes on HF that might indicate what part of the ham band to operate it or not operate it. FACT: "There is currently no finite bandwidth limit on HF data/text emission in USA ham bands, except for the sub-band and band edges." FACT: "FCC data/text HF rules are still mainly based on "content" of the emission, not bandwidth." New SDR radios have the potential to transmit and receive wider bandwidths than the traditional 3kHz SSB passband. We will see a lot more development in this area of technology in the future, and a lot more gray areas of 20th century FCC rules that inhibit innovation and progress for ham radio HF digital technology in the 21st
Re: [digitalradio] FCC Technology Jail: ROS Dead on HF for USA Hams
Bonnie's note describes the US/FCC regulations issues regarding ROS and SS really well. It's the best description of the US problem I've seen on this reflector. After reading what seems like hundreds of notes, I now agree that if ROS uses FHSS techniques, as its author says it does (and none of us has seen the code), then even though it 1) uses less 3 kHz bandwidth, 2) does not appear to do any more harm than a SSB signal and 3) is similar to other FSK modes, it is not legal in FCC jurisdictions. As Bonnie points out, ROS "doesn't hop the VFO frequency," but within the 2.5 bandwidth, it technically is SS. This would be true if ROS used 300 Hz bandwidth instead of 2.5 kHz, but hopped about using FHSS within the 300 Hz bandwidth. So I have to agree the FCC regs are not well written in this case. Regarding the corollary issue of US/FCC regulations focused on content instead of bandwidth, I'm not competent to comment. Jim - K6JM - Original Message - From: expeditionradio To: digitalradio@yahoogroups.com Sent: Sunday, February 21, 2010 5:09 PM Subject: [digitalradio] FCC Technology Jail: ROS Dead on HF for USA Hams Given the fact that ROS Modem has been advertised as Frequency Hopping Spread Spectrum (FHSS), it may be quite difficult for USA amateur radio operators to obtain a positive interpretation of rules by FCC to allow use of ROS on HF without some type of experimental license or waiver. Otherwise, hams will need an amendment of FCC rules to use it in USA. Sadly, this may lead to the early death of ROS among USA hams. If ROS Modem had simply provided the technical specifications of the emission, and not called it "Spread Spectrum", there would have been a chance for it to be easily adopted by Ham Radio operators in USA. But, the ROS modem designer is rightfully proud of the design, and he lives in a country that is not bound by FCC rules, and probably had little or no knowledge of how his advertising might prevent thousands of hams from using it in USA. But, as they say, "You cannot un-ring a bell, once it has been rung". ROS signal can be viewed as a type of FSK, similar to various other types of n-ary-FSK presently in widespread use by USA hams. The specific algorithms for signal process and format could simply have been documented without calling it Frequency Hopping Spread Spectrum (FHSS). Since it is a narrowband signal (using the FCC and ITU definitions of narrowband emission = less than 3kHz) within the width of an SSB passband, it does not fit the traditional FHSS description as a conventional wideband technique. It probably would not have been viewed as FHSS under the spirit and intention of the FCC rules. It doesn't hop the VFO frequency. It simply FSKs according to a programmable algorithm, and it meets the infamous 1kHz shift 300 baud rule. http://www.arrl.org/FandES/field/regulations/news/part97/d-305.html#307f3 This is a typical example of how outdated the present FCC rules are, keeping USA hams in "TECHNOLOGY JAIL" while the rest of the world's hams move forward with digital technology. It should come as no surprise that most of the new ham radio digital modes are not being developed in USA! But, for a moment, let's put aside the issue of current FCC "prohibition" against Spread Spectrum and/or Frequency Hopping Spread Spectrum, and how it relates to ROS mode. Let's look at "bandwidth". There is the other issue of "bandwidth" that some misguided USA hams have brought up here and in other forums related to ROS. Some superstitious hams seem to erroneously think that there is an over-reaching "bandwidth limit" in the FCC rules for data/text modes on HF that might indicate what part of the ham band to operate it or not operate it. FACT: "There is currently no finite bandwidth limit on HF data/text emission in USA ham bands, except for the sub-band and band edges." FACT: "FCC data/text HF rules are still mainly based on "content" of the emission, not bandwidth." New SDR radios have the potential to transmit and receive wider bandwidths than the traditional 3kHz SSB passband. We will see a lot more development in this area of technology in the future, and a lot more gray areas of 20th century FCC rules that inhibit innovation and progress for ham radio HF digital technology in the 21st century. Several years ago, there was a proposal to FCC to provide regulation by bandwidth rather than content. However, it failed to be adopted, and ARRL's petition to limit bandwidth was withdrawn http://www.arrl.org/news/stories/2007/04/27/101/?nc=1 Thus, USA hams will continue to be in Technology Jail without access to many new modes in the foreseeable future :( Best Wishes, Bonnie Crystal KQ6XA
Re: [digitalradio] FCC Technology Jail: ROS Dead on HF for USA Hams
Bonnie you have a Ham unfriendly addenda. Say what you like but at the end of the day it is BS. From: expeditionradio Reply-To: Date: Mon, 22 Feb 2010 01:09:14 - To: Subject: [digitalradio] FCC Technology Jail: ROS Dead on HF for USA Hams Given the fact that ROS Modem has been advertised as Frequency Hopping Spread Spectrum (FHSS), it may be quite difficult for USA amateur radio operators to obtain a positive interpretation of rules by FCC to allow use of ROS on HF without some type of experimental license or waiver. Otherwise, hams will need an amendment of FCC rules to use it in USA. Sadly, this may lead to the early death of ROS among USA hams. If ROS Modem had simply provided the technical specifications of the emission, and not called it "Spread Spectrum", there would have been a chance for it to be easily adopted by Ham Radio operators in USA. But, the ROS modem designer is rightfully proud of the design, and he lives in a country that is not bound by FCC rules, and probably had little or no knowledge of how his advertising might prevent thousands of hams from using it in USA. But, as they say, "You cannot un-ring a bell, once it has been rung". ROS signal can be viewed as a type of FSK, similar to various other types of n-ary-FSK presently in widespread use by USA hams. The specific algorithms for signal process and format could simply have been documented without calling it Frequency Hopping Spread Spectrum (FHSS). Since it is a narrowband signal (using the FCC and ITU definitions of narrowband emission = less than 3kHz) within the width of an SSB passband, it does not fit the traditional FHSS description as a conventional wideband technique. It probably would not have been viewed as FHSS under the spirit and intention of the FCC rules. It doesn't hop the VFO frequency. It simply FSKs according to a programmable algorithm, and it meets the infamous 1kHz shift 300 baud rule. http://www.arrl.org/FandES/field/regulations/news/part97/d-305.html#307f3 This is a typical example of how outdated the present FCC rules are, keeping USA hams in "TECHNOLOGY JAIL" while the rest of the world's hams move forward with digital technology. It should come as no surprise that most of the new ham radio digital modes are not being developed in USA! But, for a moment, let's put aside the issue of current FCC "prohibition" against Spread Spectrum and/or Frequency Hopping Spread Spectrum, and how it relates to ROS mode. Let's look at "bandwidth". There is the other issue of "bandwidth" that some misguided USA hams have brought up here and in other forums related to ROS. Some superstitious hams seem to erroneously think that there is an over-reaching "bandwidth limit" in the FCC rules for data/text modes on HF that might indicate what part of the ham band to operate it or not operate it. FACT: "There is currently no finite bandwidth limit on HF data/text emission in USA ham bands, except for the sub-band and band edges." FACT: "FCC data/text HF rules are still mainly based on "content" of the emission, not bandwidth." New SDR radios have the potential to transmit and receive wider bandwidths than the traditional 3kHz SSB passband. We will see a lot more development in this area of technology in the future, and a lot more gray areas of 20th century FCC rules that inhibit innovation and progress for ham radio HF digital technology in the 21st century. Several years ago, there was a proposal to FCC to provide regulation by bandwidth rather than content. However, it failed to be adopted, and ARRL's petition to limit bandwidth was withdrawn http://www.arrl.org/news/stories/2007/04/27/101/?nc=1 Thus, USA hams will continue to be in Technology Jail without access to many new modes in the foreseeable future :( Best Wishes, Bonnie Crystal KQ6XA
Re: [digitalradio] FCC Technology Jail: ROS Dead on HF for USA Hams
You can't unscramble eggs. On Sun, Feb 21, 2010 at 7:09 PM, expeditionradio wrote: > Given the fact that ROS Modem has been advertised as Frequency Hopping > Spread Spectrum (FHSS), it may be quite difficult for USA amateur radio > operators to obtain a positive interpretation of rules by FCC to allow use > of ROS on HF without some type of experimental license or waiver. Otherwise, > hams will need an amendment of FCC rules to use it in USA. > > Sadly, this may lead to the early death of ROS among USA hams. > > If ROS Modem had simply provided the technical specifications of the > emission, and not called it "Spread Spectrum", there would have been a > chance for it to be easily adopted by Ham Radio operators in USA. > > But, the ROS modem designer is rightfully proud of the design, and he lives > in a country that is not bound by FCC rules, and probably had little or no > knowledge of how his advertising might prevent thousands of hams from using > it in USA. > > But, as they say, "You cannot un-ring a bell, once it has been rung". > > ROS signal can be viewed as a type of FSK, similar to various other types > of n-ary-FSK presently in widespread use by USA hams. The specific > algorithms for signal process and format could simply have been documented > without calling it Frequency Hopping Spread Spectrum (FHSS). Since it is a > narrowband signal (using the FCC and ITU definitions of narrowband emission > = less than 3kHz) within the width of an SSB passband, it does not fit the > traditional FHSS description as a conventional wideband technique. > > It probably would not have been viewed as FHSS under the spirit and > intention of the FCC rules. It doesn't hop the VFO frequency. It simply FSKs > according to a programmable algorithm, and it meets the infamous 1kHz shift > 300 baud rule. > http://www.arrl.org/FandES/field/regulations/news/part97/d-305.html#307f3 > > This is a typical example of how outdated the present FCC rules are, > keeping USA hams in "TECHNOLOGY JAIL" while the rest of the world's hams > move forward with digital technology. It should come as no surprise that > most of the new ham radio digital modes are not being developed in USA! > > But, for a moment, let's put aside the issue of current FCC "prohibition" > against Spread Spectrum and/or Frequency Hopping Spread Spectrum, and how it > relates to ROS mode. Let's look at "bandwidth". > > There is the other issue of "bandwidth" that some misguided USA hams have > brought up here and in other forums related to ROS. Some superstitious hams > seem to erroneously think that there is an over-reaching "bandwidth limit" > in the FCC rules for data/text modes on HF that might indicate what part of > the ham band to operate it or not operate it. > > FACT: > "There is currently no finite bandwidth limit on HF data/text emission in > USA ham bands, except for the sub-band and band edges." > > FACT: > "FCC data/text HF rules are still mainly based on "content" of the > emission, not bandwidth." > > New SDR radios have the potential to transmit and receive wider bandwidths > than the traditional 3kHz SSB passband. We will see a lot more development > in this area of technology in the future, and a lot more gray areas of 20th > century FCC rules that inhibit innovation and progress for ham radio HF > digital technology in the 21st century. > > Several years ago, there was a proposal to FCC to provide regulation by > bandwidth rather than content. However, it failed to be adopted, and ARRL's > petition to limit bandwidth was withdrawn > http://www.arrl.org/news/stories/2007/04/27/101/?nc=1 > > Thus, USA hams will continue to be in Technology Jail without access to > many new modes in the foreseeable future :( > > Best Wishes, > Bonnie Crystal KQ6XA > > > > > > Try Hamspots, PSKreporter, and K3UK Sked Page > http://www.obriensweb.com/skedpskr4.html > Yahoo! Groups Links > > > >
[digitalradio] FCC Technology Jail: ROS Dead on HF for USA Hams
Given the fact that ROS Modem has been advertised as Frequency Hopping Spread Spectrum (FHSS), it may be quite difficult for USA amateur radio operators to obtain a positive interpretation of rules by FCC to allow use of ROS on HF without some type of experimental license or waiver. Otherwise, hams will need an amendment of FCC rules to use it in USA. Sadly, this may lead to the early death of ROS among USA hams. If ROS Modem had simply provided the technical specifications of the emission, and not called it "Spread Spectrum", there would have been a chance for it to be easily adopted by Ham Radio operators in USA. But, the ROS modem designer is rightfully proud of the design, and he lives in a country that is not bound by FCC rules, and probably had little or no knowledge of how his advertising might prevent thousands of hams from using it in USA. But, as they say, "You cannot un-ring a bell, once it has been rung". ROS signal can be viewed as a type of FSK, similar to various other types of n-ary-FSK presently in widespread use by USA hams. The specific algorithms for signal process and format could simply have been documented without calling it Frequency Hopping Spread Spectrum (FHSS). Since it is a narrowband signal (using the FCC and ITU definitions of narrowband emission = less than 3kHz) within the width of an SSB passband, it does not fit the traditional FHSS description as a conventional wideband technique. It probably would not have been viewed as FHSS under the spirit and intention of the FCC rules. It doesn't hop the VFO frequency. It simply FSKs according to a programmable algorithm, and it meets the infamous 1kHz shift 300 baud rule. http://www.arrl.org/FandES/field/regulations/news/part97/d-305.html#307f3 This is a typical example of how outdated the present FCC rules are, keeping USA hams in "TECHNOLOGY JAIL" while the rest of the world's hams move forward with digital technology. It should come as no surprise that most of the new ham radio digital modes are not being developed in USA! But, for a moment, let's put aside the issue of current FCC "prohibition" against Spread Spectrum and/or Frequency Hopping Spread Spectrum, and how it relates to ROS mode. Let's look at "bandwidth". There is the other issue of "bandwidth" that some misguided USA hams have brought up here and in other forums related to ROS. Some superstitious hams seem to erroneously think that there is an over-reaching "bandwidth limit" in the FCC rules for data/text modes on HF that might indicate what part of the ham band to operate it or not operate it. FACT: "There is currently no finite bandwidth limit on HF data/text emission in USA ham bands, except for the sub-band and band edges." FACT: "FCC data/text HF rules are still mainly based on "content" of the emission, not bandwidth." New SDR radios have the potential to transmit and receive wider bandwidths than the traditional 3kHz SSB passband. We will see a lot more development in this area of technology in the future, and a lot more gray areas of 20th century FCC rules that inhibit innovation and progress for ham radio HF digital technology in the 21st century. Several years ago, there was a proposal to FCC to provide regulation by bandwidth rather than content. However, it failed to be adopted, and ARRL's petition to limit bandwidth was withdrawn http://www.arrl.org/news/stories/2007/04/27/101/?nc=1 Thus, USA hams will continue to be in Technology Jail without access to many new modes in the foreseeable future :( Best Wishes, Bonnie Crystal KQ6XA
