[digitalradio] Re: The FCC's definition of Spread Spectrum
And, the response from the FCC doesn't provide any FCC position or interpretation of ROS, and further says The Commission does not determine if a particular mode truly represents spread spectrum as it is defined in the rules. Forget the petitions for waivers. File a federal lawsuit stating that the FCC's determination that ROS is SS and therefore unlawful on HF bands in the USA is arbitrary and capricious, based on the above statement that they have abdicated their statutory responsibility to make a technical examination of the proposed mode to see whether or not it fits their regulations. Yeah, I know, filing suit is an inherently unfriendly act. The FCC has been unfriendly to anything that is not a major corporate money maker for quite some time now. Time to start pushing the Commission back on track. 73 de Dave, NF2G
Re: [digitalradio] Re: The FCC's definition of Spread Spectrum
--- On Fri, 26/2/10, DaveNF2G d...@nf2g.com wrote: File a federal lawsuit stating that the FCC's determination that ROS is SS and therefore unlawful on HF bands in the USA is arbitrary and capricious, based on the My interpretation from over on this side of the Atlantic is that the FCC DID NOT say ROS was unlawful on HF. In fact in the response at http://groups.yahoo.com/group/digitalradio/message/34812 they specifically do not state the Commissions View on ROS saying: The Commission does not determine if a particular mode truly represents spread spectrum as it is defined in the rules. The sentence: ROS is viewed as spread spectrum, and the creator of the system describes it as that. Is NOT giving the Commissions determination of the mode. They are simply noting what is said in the original Request for clarification, which was basically some that Radio Amateurs view it as SS, hence the debate, and the author of the mode did indeed describe it as such. The FCC simply say it is up to the Operator to make a decision as to whether a mode is in breach of regulations. It is worth remembering that US Amateurs have been using CHIP64 on HF for 5 years, a long time. It is a Direct Sequence Spread Spectrum mode and described as such on the ARRL website. I am not aware of the FCC having had a problem with Amateur usage of that mode on HF. Out of curiosity what is the initial response of the FCC if an Amateur where to breach one of the regs ? Is it to sent them a letter informing them of the breach and asking them to desist ? Long term the solution looks like reform of the license regs but that may be easier said than done. It's over 32 years since the FCC itself first proposed band planning by bandwidth (their plan was for 350 Hz, 3.5 kHz, 7.5 kHz etc bandwidth segments) and 5 years since the ARRL submitted a similar proposal. Perhaps a 3rd attempt at changing introducing bandwidth planning will be successful ? I hope so. 73 Trevor M5AKA
[digitalradio] Re: The FCC's definition of Spread Spectrum
I have to agree with Trevor. Not only did the FCC not declare or rule ROS in any way, but the author NEVER asked for any clarification whatsoever. Also of note, once the author understood the difference in the way spread spectrum was being interpreted, he immediately changed the reference to it in ALL of his documentation. AGAIN, the author NEVER approached anyone to seek ANY opinion about it. That was the result of someone else doing so of their own volition. The FCC did say they viewed it as spread spectrum, not because of any technical inspection by them, but solely upon the documentation presented to them, and they qualified THAT by saying they assumed the author knew what he had written. There should be no further argument, and Andy asked that it stop, but it seems certain folks still have an axe to grind over it. Seems some want Jose to publish his code. That is just plain wrong on so many levels. For someone to even ask that is beyond ludicrous in the first place. It is in effect penalizing the preacher and his sermon because the janitor asked a policeman if the grass was cut correctly. The two just do not belong in the same discussion. Jose has clearly stated, and shown in the technical specifications this is NOT spread spectrum, no matter how some want to try to declare it so. Sorry Skip, but a spectral display does not necessarily show if a signal is spread spectrum or not. Jose shows that there are FEC bytes in the signal that are generated even if there is no signal present. He is still the author of the program and should know by now what the differences in spread spectrum and FSK are. I, for one believe that if this gentleman is intelligent enough to write this code, he is also savvy enough to recognize if it is spread spectrum or not. He has nothing to gain by falsifying it since the program and his efforts are free, just like many other programs out there for us hams to use and experiment with. I am having a great deal of difficulty understanding why this The FCC has ruled continues on. The FCC has NOT RULED on anything at all. PERIOD. An AGENT at the FCC answered a request for opinion' from an individual with no standing in the case as yet, and was presented with unfinished documents. That is like asking a doctor to prescribe medications for a patient he has never seen or even heard of, but some friend of the patient heard a rumor that the patient might feel bad. How could the doctor prescribe from that? I did not really want to get back into this but it seems certain erroneous parts of this discussion just will not die. If there is another agenda, please state it plainly for all to see. Else let's let the man try to work on his program rather than keep responding to these false innuendos created by folks with their own motives. I have no axe to grind, no dog in this fight, no trees to burn, etc etc etc. But Trevor is right. The FCC did NOT rule on anything at all. It does not matter what WAS in Jose's original documentation. Just because his original documentation may have said spread spectrum did not make it so. Jose NEVER asked ANYONE, let alone the FCC for their opinion. If someone else fouled the water for him, then as was suggested earlier, I suggest that Jose file his own lawsuit if that seems to be what is needed. IMHO John KE5HAM --- In digitalradio@yahoogroups.com, Trevor . m5...@... wrote: --- On Fri, 26/2/10, DaveNF2G d...@... wrote: File a federal lawsuit stating that the FCC's determination that ROS is SS and therefore unlawful on HF bands in the USA is arbitrary and capricious, based on the My interpretation from over on this side of the Atlantic is that the FCC DID NOT say ROS was unlawful on HF. In fact in the response at http://groups.yahoo.com/group/digitalradio/message/34812 they specifically do not state the Commissions View on ROS saying: The Commission does not determine if a particular mode truly represents spread spectrum as it is defined in the rules. The sentence: ROS is viewed as spread spectrum, and the creator of the system describes it as that. Is NOT giving the Commissions determination of the mode. They are simply noting what is said in the original Request for clarification, which was basically some that Radio Amateurs view it as SS, hence the debate, and the author of the mode did indeed describe it as such. The FCC simply say it is up to the Operator to make a decision as to whether a mode is in breach of regulations. It is worth remembering that US Amateurs have been using CHIP64 on HF for 5 years, a long time. It is a Direct Sequence Spread Spectrum mode and described as such on the ARRL website. I am not aware of the FCC having had a problem with Amateur usage of that mode on HF. Out of curiosity what is the initial response of the FCC if an Amateur where to breach one of the regs ? Is it to sent them a letter informing them of the
Re: [digitalradio] Re: The FCC's definition of Spread Spectrum
In fact, a person named Timothy J. Lilley - N3TL wrote to FCC in my representation without ask me previously, saying what he would think that ROS was, after to read an incomplete document. Here I think each person does their personal guesses as he believes that ROS works, without prior reading any documents. And when in doubt, it is best to go about preaching the forums that is illegal. 500 years ago I had been burned at the stake De: John ke5h...@taylorent.com Para: digitalradio@yahoogroups.com Enviado: sáb,27 febrero, 2010 00:39 Asunto: [digitalradio] Re: The FCC's definition of Spread Spectrum I have to agree with Trevor. Not only did the FCC not declare or rule ROS in any way, but the author NEVER asked for any clarification whatsoever. Also of note, once the author understood the difference in the way spread spectrum was being interpreted, he immediately changed the reference to it in ALL of his documentation. AGAIN, the author NEVER approached anyone to seek ANY opinion about it. That was the result of someone else doing so of their own volition. The FCC did say they viewed it as spread spectrum, not because of any technical inspection by them, but solely upon the documentation presented to them, and they qualified THAT by saying they assumed the author knew what he had written. There should be no further argument, and Andy asked that it stop, but it seems certain folks still have an axe to grind over it. Seems some want Jose to publish his code. That is just plain wrong on so many levels. For someone to even ask that is beyond ludicrous in the first place. It is in effect penalizing the preacher and his sermon because the janitor asked a policeman if the grass was cut correctly. The two just do not belong in the same discussion. Jose has clearly stated, and shown in the technical specifications this is NOT spread spectrum, no matter how some want to try to declare it so. Sorry Skip, but a spectral display does not necessarily show if a signal is spread spectrum or not. Jose shows that there are FEC bytes in the signal that are generated even if there is no signal present. He is still the author of the program and should know by now what the differences in spread spectrum and FSK are. I, for one believe that if this gentleman is intelligent enough to write this code, he is also savvy enough to recognize if it is spread spectrum or not. He has nothing to gain by falsifying it since the program and his efforts are free, just like many other programs out there for us hams to use and experiment with. I am having a great deal of difficulty understanding why this The FCC has ruled continues on. The FCC has NOT RULED on anything at all. PERIOD. An AGENT at the FCC answered a request for opinion' from an individual with no standing in the case as yet, and was presented with unfinished documents. That is like asking a doctor to prescribe medications for a patient he has never seen or even heard of, but some friend of the patient heard a rumor that the patient might feel bad. How could the doctor prescribe from that? I did not really want to get back into this but it seems certain erroneous parts of this discussion just will not die. If there is another agenda, please state it plainly for all to see. Else let's let the man try to work on his program rather than keep responding to these false innuendos created by folks with their own motives. I have no axe to grind, no dog in this fight, no trees to burn, etc etc etc. But Trevor is right. The FCC did NOT rule on anything at all. It does not matter what WAS in Jose's original documentation. Just because his original documentation may have said spread spectrum did not make it so. Jose NEVER asked ANYONE, let alone the FCC for their opinion. If someone else fouled the water for him, then as was suggested earlier, I suggest that Jose file his own lawsuit if that seems to be what is needed. IMHO John KE5HAM --- In digitalradio@ yahoogroups. com, Trevor . m5...@... wrote: --- On Fri, 26/2/10, DaveNF2G d...@... wrote: File a federal lawsuit stating that the FCC's determination that ROS is SS and therefore unlawful on HF bands in the USA is arbitrary and capricious, based on the My interpretation from over on this side of the Atlantic is that the FCC DID NOT say ROS was unlawful on HF. In fact in the response at http://groups. yahoo.com/ group/digitalrad io/message/ 34812 they specifically do not state the Commissions View on ROS saying: The Commission does not determine if a particular mode truly represents spread spectrum as it is defined in the rules. The sentence: ROS is viewed as spread spectrum, and the creator of the system describes it as that. Is NOT giving the Commissions determination of the mode. They are simply noting what is said in the original Request for clarification , which was basically some that Radio Amateurs
Re: [digitalradio] Re: The FCC's definition of Spread Spectrum
The FCC didn't do anything arbitrary or capricious. They read a specification provided by the author of the software that stated that ROS is a spread-spectrum mode. They then told the person asking for the FCC's opinion that they should go by what the author wrote and not use ROS on HF. The author now states that his original document was incorrect and ROS is not spread-spectrum but has not published a new specification. If it isn't SS, the new specification will clear the way for U.S hams to use the mode. FCC regulations don't state that the FCC has any obligation to make determinations about a new mode. They state that the author must publish a specification and each amateur must look at that and determine the legality. 73, John KD6OZH - Original Message - From: DaveNF2G To: digitalradio@yahoogroups.com Sent: Friday, February 26, 2010 13:26 UTC Subject: [digitalradio] Re: The FCC's definition of Spread Spectrum And, the response from the FCC doesn't provide any FCC position or interpretation of ROS, and further says The Commission does not determine if a particular mode truly represents spread spectrum as it is defined in the rules. Forget the petitions for waivers. File a federal lawsuit stating that the FCC's determination that ROS is SS and therefore unlawful on HF bands in the USA is arbitrary and capricious, based on the above statement that they have abdicated their statutory responsibility to make a technical examination of the proposed mode to see whether or not it fits their regulations. Yeah, I know, filing suit is an inherently unfriendly act. The FCC has been unfriendly to anything that is not a major corporate money maker for quite some time now. Time to start pushing the Commission back on track. 73 de Dave, NF2G
[digitalradio] Re: The FCC's definition of Spread Spectrum
hello Tim it sure is hell when you try to do a good deed, keep it up. david/wd4kpd
[digitalradio] Re: The FCC's definition of Spread Spectrum
AMEN to your last Trevor. and this is why i continue to operate ROS. thank you for some sanity. david/wd4kpd
[digitalradio] Re: The FCC's definition of Spread Spectrum
you got it right John perhaps c u on the bands via ROS. david/wd4kpd
