Re: [digitalradio] FCC on ROS post on ARRL website!
Dave AA6YQ wrote: However the source of this proof would have to come from someone other than the ROS developer, who now has no credibility with the FCC whatsoever. Is that what the FCC said, or is that just your opinion, Dave? Dave (G0DJA)
RE: [digitalradio] FCC on ROS post on ARRL website!
AA6YQ comments below. From: digitalradio@yahoogroups.com [mailto:digitalra...@yahoogroups.com] On Behalf Of Dave Ackrill Sent: Friday, March 05, 2010 3:14 AM To: digitalradio@yahoogroups.com Subject: Re: [digitalradio] FCC on ROS post on ARRL website! Dave AA6YQ wrote: However the source of this proof would have to come from someone other than the ROS developer, who now has no credibility with the FCC whatsoever. Is that what the FCC said, or is that just your opinion, Dave? My opinion, Dave. My posts have been explicit when attributing comments or positions to FCC personnel. Dave
[digitalradio] FCC on ROS post on ARRL website!
http://www.arrl.org/news/stories/2010/03/04/11377/?nc=1 So we can forget about here in the US...too bad it looked really nice...73, Alan
Re: [digitalradio] FCC on ROS post on ARRL website!
On 03/04/2010 02:02 PM, Alan wrote: http://www.arrl.org/news/stories/2010/03/04/11377/?nc=1 So we can forget about here in the US...too bad it looked really nice...73, Alan I don't read it like that. The FCC just says that: 1) spread spectrum is not allowed on HF, and 2) The Commission does not determine if a particular mode 'truly' represents spread spectrum, and 3) The licensee of the station transmitting the emission is responsible for determining that the operation of the station complies with the rules. Once Jose publishes a full specification for ROS (one that is complete enough to create an interoperable alternative implementation), US hams will be able to make the technical determination that the FCC requires us to make. Until then, there is no way to be sure whether or not ROS is legal to use in the US. We simply do not have enough info to make the determination. I expect that cautious US hams will avoid ROS until there is certainty that ROS is in fact legal. -- All rights reversed.
Re: [digitalradio] FCC on ROS post on ARRL website!
If anyone doubts that ROS is actually spread spectrum, download, unzip and compare screen captures of both ROS and FMSK64, idling, and when data (a string of periods) is sent. It is easy to see that the frequencies of the ROS carriers are not determined by the data, but that the data is modulating each carrier where it has been place by an independent code. http://home.comcast.net/~hteller/compare.zip. According to Jose, one of the characteristics of FHSS is, 2. Spreading is accomplished by means of a spreading signal, often called a code signal, which is independent of the data. Independent of the data is the operative term here, and the spectrum analysis pictures clearly indicate that is so. After seeing this, as the FCC engineers at the Wireless Telecommunications Bureau (without relying on the agent) obviously could see with their own spectrum analysis also saw, there is no doubt the ROS is NOT 144FSK, but some form of spread spectrum, which is currently illegal for US amateurs to use below 222 Mhz. However, the story does not have to end here - a petition to the FCC to allow spread spectrum, if the spreading will not exceed the width of a phone signal, together with any other necessary limitations, can be submitted and the FCC decision possibly amended. That is how it MUST be done here, and the ONLY WAY it is done. The FCC receives many such petitions all the time, so anyone interested in being able to use ROS on HF in this country only has to put together such a petition. I believe the FCC website has instructions for submitting petitions, and Googling around will show many examples to follow. 73 - Skip KH6TY Rik van Riel wrote: On 03/04/2010 02:02 PM, Alan wrote: http://www.arrl.org/news/stories/2010/03/04/11377/?nc=1 http://www.arrl.org/news/stories/2010/03/04/11377/?nc=1 So we can forget about here in the US...too bad it looked really nice...73, Alan I don't read it like that. The FCC just says that: 1) spread spectrum is not allowed on HF, and 2) The Commission does not determine if a particular mode 'truly' represents spread spectrum, and 3) The licensee of the station transmitting the emission is responsible for determining that the operation of the station complies with the rules. Once Jose publishes a full specification for ROS (one that is complete enough to create an interoperable alternative implementation), US hams will be able to make the technical determination that the FCC requires us to make. Until then, there is no way to be sure whether or not ROS is legal to use in the US. We simply do not have enough info to make the determination. I expect that cautious US hams will avoid ROS until there is certainty that ROS is in fact legal. -- All rights reversed.
Re: [digitalradio] FCC on ROS post on ARRL website!
Typo - should have read MFSK64 not FMSK64. 73 - Skip KH6TY KH6TY wrote: If anyone doubts that ROS is actually spread spectrum, download, unzip and compare screen captures of both ROS and FMSK64, both at idling, and when data (in this case, only a string of periods) is sent. It is easy to see that the frequencies of the ROS carriers are not determined by the data, but that the data is modulating each carrier where it has been randomly placed by an independent code. http://home.comcast.net/~hteller/compare.zip. According to Jose, one of the characteristics of FHSS is, 2. Spreading is accomplished by means of a spreading signal, often called a code signal, which is independent of the data. Independent of the data is the operative term here, and the spectrum analysis pictures clearly indicate that is so. After seeing this, as the FCC engineers at the Wireless Telecommunications Bureau (without relying on the agent) obviously could see with their own spectrum analysis), there is no doubt in my mind that ROS is NOT 144FSK, but some form of spread spectrum, which is currently illegal for US amateurs to use below 222 Mhz. However, the story does not have to end here - a petition to the FCC to allow spread spectrum, if the spreading will not exceed the width of a phone signal, together with any other necessary limitations to make it acceptable, can be submitted and the FCC decision possibly amended. That is how it MUST be done here, and the ONLY WAY it is done. The FCC receives many such petitions all the time, so any individual or group interested in being able to use ROS on HF in this country only has to put together such a petition. A lawyer is not required. I believe the FCC website has instructions for submitting petitions, and Googling around will disclose many examples to follow. 73 - Skip KH6TY Rik van Riel wrote: On 03/04/2010 02:02 PM, Alan wrote: http://www.arrl.org/news/stories/2010/03/04/11377/?nc=1 http://www.arrl.org/news/stories/2010/03/04/11377/?nc=1 So we can forget about here in the US...too bad it looked really nice...73, Alan I don't read it like that. The FCC just says that: 1) spread spectrum is not allowed on HF, and 2) The Commission does not determine if a particular mode 'truly' represents spread spectrum, and 3) The licensee of the station transmitting the emission is responsible for determining that the operation of the station complies with the rules. Once Jose publishes a full specification for ROS (one that is complete enough to create an interoperable alternative implementation), US hams will be able to make the technical determination that the FCC requires us to make. Until then, there is no way to be sure whether or not ROS is legal to use in the US. We simply do not have enough info to make the determination. I expect that cautious US hams will avoid ROS until there is certainty that ROS is in fact legal. -- All rights reversed.
RE: [digitalradio] FCC on ROS post on ARRL website!
The FCC said 'ROS' is viewed as 'spread spectrum,' and the creator of the system describes it as that. We assume that he knows what he created. This is unequivocal. However, the FCC also says The Commission does not determine if a particular mode 'truly' represents spread spectrum as it is defined in the rules. The licensee of the station transmitting the emission is responsible for determining that the operation of the station complies with the rules. Thus if someone were to convince the FCC that ROS is in fact not spread spectrum, then ROS could be used on HF by US operators. However the source of this proof would have to come from someone other than the ROS developer, who now has no credibility with the FCC whatsoever. 73, Dave, AA6YQ -Original Message- From: digitalradio@yahoogroups.com [mailto:digitalra...@yahoogroups.com]on Behalf Of Rik van Riel Sent: Thursday, March 04, 2010 5:54 PM To: digitalradio@yahoogroups.com Subject: Re: [digitalradio] FCC on ROS post on ARRL website! On 03/04/2010 02:02 PM, Alan wrote: http://www.arrl.org/news/stories/2010/03/04/11377/?nc=1 So we can forget about here in the US...too bad it looked really nice...73, Alan I don't read it like that. The FCC just says that: 1) spread spectrum is not allowed on HF, and 2) The Commission does not determine if a particular mode 'truly' represents spread spectrum, and 3) The licensee of the station transmitting the emission is responsible for determining that the operation of the station complies with the rules. Once Jose publishes a full specification for ROS (one that is complete enough to create an interoperable alternative implementation), US hams will be able to make the technical determination that the FCC requires us to make. Until then, there is no way to be sure whether or not ROS is legal to use in the US. We simply do not have enough info to make the determination. I expect that cautious US hams will avoid ROS until there is certainty that ROS is in fact legal. -- All rights reversed.
