Re: [digitalradio] A closer look at ROS
The attachments are a good illustration why the rules should be changed. Olivia and ROS use a similar amount of spectrum so the FCC shouldn't be calling one legal and the other illegal based on how they were generated. 73, John KD6OZH - Original Message - From: Tony To: digitalradio@yahoogroups.com Sent: Sunday, February 21, 2010 08:20 UTC Subject: [digitalradio] A closer look at ROS [2 Attachments] [Attachment(s) from Tony included below] All, It would appear that ROS-16 is not much different than say Olivia 128 / 2K. The number of tones may differ, but they both use MFSK modulation with sequential tones running at 16 baud. The question is how can ROS be considered a SS frequency hoping mode while Olivia and it's derivatives are not? A closer look shows that they are quite similar (see attached). Tony -K2MO
Re: [digitalradio] A closer look at ROS]
I have spent the last hour looking through part 97. I find nothing that would prohibit ROS in the HF bands subject to adhering to those segments where the bandwidth is allowed. In fact the rules would appear to support such operation: (b) Where authorized by §§ 97.305(c) and 97.307(f) of this part, a station may transmit a RTTY or data emission using an unspecified digital code, except to a station in a country with which the United States does not have an agreement permitting the code to be used. RTTY and data emissions using unspecified digital codes must not be transmitted for the purpose of obscuring the meaning of any communication. When deemed necessary by a District Director to assure compliance with the FCC Rules, a station must: (1) Cease the transmission using the unspecified digital code; (2) Restrict transmissions of any digital code to the extent instructed; (3) Maintain a record, convertible to the original information, of all digital communications transmitted I also do not see anything in the part 97 subsection on spread spectrum ( if in fact ROS was really determined to be an SS mode) that would make ROS non compliant. Part 97 technical standards mostly harmonize US rules with ITU international treaties They are written to be quite broad in order to permit experimentation. So long as the coding technique is public and can be received by anyone, the real restriction is based on allowable bandwidth and power allocated for a given frequency. John B. Stephensen wrote: The attachments are a good illustration why the rules should be changed. Olivia and ROS use a similar amount of spectrum so the FCC shouldn't be calling one legal and the other illegal based on how they were generated. 73, John KD6OZH - Original Message - From: Tony To: digitalradio@yahoogroups.com Sent: Sunday, February 21, 2010 08:20 UTC Subject: [digitalradio] A closer look at ROS [2 Attachments] [Attachment(s) from Tony included below] All, It would appear that ROS-16 is not much different than say Olivia 128 / 2K. The number of tones may differ, but they both use MFSK modulation with sequential tones running at 16 baud. The question is how can ROS be considered a SS frequency hoping mode while Olivia and it's derivatives are not? A closer look shows that they are quite similar (see attached). Tony -K2MO
Re: [digitalradio] A closer look at ROS]
If ROS did not use FHSS then only the rules that you quote would apply. The problem is that the table in 97.305(c) authorizes SS only above 222 MHz. The FCC rules are much more restrictive than ITU treaties. Other countries specify only maximum occupied bandwith in their amateur radio regulations. 73, John KD6OZH - Original Message - From: w2xj To: digitalradio@yahoogroups.com Sent: Sunday, February 21, 2010 19:17 UTC Subject: Re: [digitalradio] A closer look at ROS] I have spent the last hour looking through part 97. I find nothing that would prohibit ROS in the HF bands subject to adhering to those segments where the bandwidth is allowed. In fact the rules would appear to support such operation: (b) Where authorized by §§ 97.305(c) and 97.307(f) of this part, a station may transmit a RTTY or data emission using an unspecified digital code, except to a station in a country with which the United States does not have an agreement permitting the code to be used. RTTY and data emissions using unspecified digital codes must not be transmitted for the purpose of obscuring the meaning of any communication. When deemed necessary by a District Director to assure compliance with the FCC Rules, a station must: (1) Cease the transmission using the unspecified digital code; (2) Restrict transmissions of any digital code to the extent instructed; (3) Maintain a record, convertible to the original information, of all digital communications transmitted I also do not see anything in the part 97 subsection on spread spectrum ( if in fact ROS was really determined to be an SS mode) that would make ROS non compliant. Part 97 technical standards mostly harmonize US rules with ITU international treaties They are written to be quite broad in order to permit experimentation. So long as the coding technique is public and can be received by anyone, the real restriction is based on allowable bandwidth and power allocated for a given frequency. John B. Stephensen wrote: The attachments are a good illustration why the rules should be changed. Olivia and ROS use a similar amount of spectrum so the FCC shouldn't be calling one legal and the other illegal based on how they were generated.
Re: [digitalradio] A closer look at ROS]
In most legal documents, specific references override general ones. In this discussion, only the FCC attorneys can decide what is allowed and what is not. Until then, the specific regulations regarding SS are assumed to be the law in this country, no matter how badly it is desired to use the new mode, and what rationalizations are made for being able to use it. This road has been traveled before! 73 - Skip KH6TY w2xj wrote: I have spent the last hour looking through part 97. I find nothing that would prohibit ROS in the HF bands subject to adhering to those segments where the bandwidth is allowed. In fact the rules would appear to support such operation: (b) Where authorized by §§ 97.305(c) and 97.307(f) of this part, a station may transmit a RTTY or data emission using an unspecified digital code, except to a station in a country with which the United States does not have an agreement permitting the code to be used. RTTY and data emissions using unspecified digital codes must not be transmitted for the purpose of obscuring the meaning of any communication. When deemed necessary by a District Director to assure compliance with the FCC Rules, a station must: (1) Cease the transmission using the unspecified digital code; (2) Restrict transmissions of any digital code to the extent instructed; (3) Maintain a record, convertible to the original information, of all digital communications transmitted I also do not see anything in the part 97 subsection on spread spectrum ( if in fact ROS was really determined to be an SS mode) that would make ROS non compliant. Part 97 technical standards mostly harmonize US rules with ITU international treaties They are written to be quite broad in order to permit experimentation. So long as the coding technique is public and can be received by anyone, the real restriction is based on allowable bandwidth and power allocated for a given frequency. John B. Stephensen wrote: The attachments are a good illustration why the rules should be changed. Olivia and ROS use a similar amount of spectrum so the FCC shouldn't be calling one legal and the other illegal based on how they were generated. 73, John KD6OZH - Original Message - From: Tony To: digitalradio@yahoogroups.com mailto:digitalradio%40yahoogroups.com Sent: Sunday, February 21, 2010 08:20 UTC Subject: [digitalradio] A closer look at ROS [2 Attachments] [Attachment(s) from Tony included below] All, It would appear that ROS-16 is not much different than say Olivia 128 / 2K. The number of tones may differ, but they both use MFSK modulation with sequential tones running at 16 baud. The question is how can ROS be considered a SS frequency hoping mode while Olivia and it's derivatives are not? A closer look shows that they are quite similar (see attached). Tony -K2MO
Re: [digitalradio] A closer look at ROS]
Please provide a citation from part 97 that prohibits ROS even if it were deemed to truly be spread spectrum. KH6TY wrote: In most legal documents, specific references override general ones. In this discussion, only the FCC attorneys can decide what is allowed and what is not. Until then, the specific regulations regarding SS are assumed to be the law in this country, no matter how badly it is desired to use the new mode, and what rationalizations are made for being able to use it. This road has been traveled before! 73 - Skip KH6TY w2xj wrote: I have spent the last hour looking through part 97. I find nothing that would prohibit ROS in the HF bands subject to adhering to those segments where the bandwidth is allowed. In fact the rules would appear to support such operation: (b) Where authorized by §§ 97.305(c) and 97.307(f) of this part, a station may transmit a RTTY or data emission using an unspecified digital code, except to a station in a country with which the United States does not have an agreement permitting the code to be used. RTTY and data emissions using unspecified digital codes must not be transmitted for the purpose of obscuring the meaning of any communication. When deemed necessary by a District Director to assure compliance with the FCC Rules, a station must: (1) Cease the transmission using the unspecified digital code; (2) Restrict transmissions of any digital code to the extent instructed; (3) Maintain a record, convertible to the original information, of all digital communications transmitted I also do not see anything in the part 97 subsection on spread spectrum ( if in fact ROS was really determined to be an SS mode) that would make ROS non compliant. Part 97 technical standards mostly harmonize US rules with ITU international treaties They are written to be quite broad in order to permit experimentation. So long as the coding technique is public and can be received by anyone, the real restriction is based on allowable bandwidth and power allocated for a given frequency. John B. Stephensen wrote: The attachments are a good illustration why the rules should be changed. Olivia and ROS use a similar amount of spectrum so the FCC shouldn't be calling one legal and the other illegal based on how they were generated. 73, John KD6OZH - Original Message - From: Tony To: digitalradio@yahoogroups.com mailto:digitalradio%40yahoogroups.com Sent: Sunday, February 21, 2010 08:20 UTC Subject: [digitalradio] A closer look at ROS [2 Attachments] [Attachment(s) from Tony included below] All, It would appear that ROS-16 is not much different than say Olivia 128 / 2K. The number of tones may differ, but they both use MFSK modulation with sequential tones running at 16 baud. The question is how can ROS be considered a SS frequency hoping mode while Olivia and it's derivatives are not? A closer look shows that they are quite similar (see attached). Tony -K2MO
Re: [digitalradio] A closer look at ROS]
§97.305 Authorized emission types is the regulation that authorizes SS for 222 Mhz and above only. 73 - Skip KH6TY w2xj wrote: Please provide a citation from part 97 that prohibits ROS even if it were deemed to truly be spread spectrum. KH6TY wrote: In most legal documents, specific references override general ones. In this discussion, only the FCC attorneys can decide what is allowed and what is not. Until then, the specific regulations regarding SS are assumed to be the law in this country, no matter how badly it is desired to use the new mode, and what rationalizations are made for being able to use it. This road has been traveled before! 73 - Skip KH6TY w2xj wrote: I have spent the last hour looking through part 97. I find nothing that would prohibit ROS in the HF bands subject to adhering to those segments where the bandwidth is allowed. In fact the rules would appear to support such operation: (b) Where authorized by §§ 97.305(c) and 97.307(f) of this part, a station may transmit a RTTY or data emission using an unspecified digital code, except to a station in a country with which the United States does not have an agreement permitting the code to be used. RTTY and data emissions using unspecified digital codes must not be transmitted for the purpose of obscuring the meaning of any communication. When deemed necessary by a District Director to assure compliance with the FCC Rules, a station must: (1) Cease the transmission using the unspecified digital code; (2) Restrict transmissions of any digital code to the extent instructed; (3) Maintain a record, convertible to the original information, of all digital communications transmitted I also do not see anything in the part 97 subsection on spread spectrum ( if in fact ROS was really determined to be an SS mode) that would make ROS non compliant. Part 97 technical standards mostly harmonize US rules with ITU international treaties They are written to be quite broad in order to permit experimentation. So long as the coding technique is public and can be received by anyone, the real restriction is based on allowable bandwidth and power allocated for a given frequency. John B. Stephensen wrote: The attachments are a good illustration why the rules should be changed. Olivia and ROS use a similar amount of spectrum so the FCC shouldn't be calling one legal and the other illegal based on how they were generated. 73, John KD6OZH - Original Message - From: Tony To: digitalradio@yahoogroups.com mailto:digitalradio%40yahoogroups.com mailto:digitalradio%40yahoogroups.com Sent: Sunday, February 21, 2010 08:20 UTC Subject: [digitalradio] A closer look at ROS [2 Attachments] [Attachment(s) from Tony included below] All, It would appear that ROS-16 is not much different than say Olivia 128 / 2K. The number of tones may differ, but they both use MFSK modulation with sequential tones running at 16 baud. The question is how can ROS be considered a SS frequency hoping mode while Olivia and it's derivatives are not? A closer look shows that they are quite similar (see attached). Tony -K2MO
Re: [digitalradio] A closer look at ROS]
On 02/21/2010 02:17 PM, w2xj wrote: Part 97 technical standards mostly harmonize US rules with ITU international treaties They are written to be quite broad in order to permit experimentation. So long as the coding technique is public and can be received by anyone, the real restriction is based on allowable bandwidth and power allocated for a given frequency. Speaking of coding technique, is there a detailed spec of ROS available? Say, one that would allow other developers to implement ROS in their programs. I saw the architecture paper on ROS, but have not found any details on what coding is used under the hood, what the pseudo-random sequence is, etc... -- All rights reversed.
Re: [digitalradio] A closer look at ROS]
Ok so what if it is... This is not the first time (nor will it be the last time) that this has happen. My question is where do they all come from? Why would someone take the time to write the program if it can't be used?
Re: [digitalradio] A closer look at ROS]
John Becker, WØJAB wrote: Ok so what if it is... This is not the first time (nor will it be the last time) that this has happen. My question is where do they all come from? Why would someone take the time to write the program if it can't be used? Probably because, in other countries, it isn't illegal and we are quite happily using it. Seeing the following on 80M at 1 Baud. RX: 20:47 UTC 0.5 Hz. IW7DF= DL5SDG JN48KQ OOO STOP RX: 20:51 UTC 1.5 Hz. CQ DL5SDG JN48KQ STOP RX: 20:52 UTC 2.4 Hz. DL5SDG TF3HZ HP94AD OOO STOP RX: 20:54 UTC 2.0 Hz. TF3HZ D RX: 20:55 UTC -25.4 Hz. CQ DF2JP JO31JG STOP RX: 20:57 UTC 2.4 Hz. DL5SDG TF3HZ HP94AD OOO 73 STOP Dave (G0DJA)
Re: [digitalradio] A closer look at ROS]
On 02/21/2010 02:17 PM, w2xj wrote: I have spent the last hour looking through part 97. I find nothing that would prohibit ROS in the HF bands subject to adhering to those segments where the bandwidth is allowed. In fact the rules would appear to support such operation: Lets look at it in another way. Part 97.3 is quite specific about what modes are considered spread spectrum: (8) SS. Spread-spectrum emissions using bandwidth-expansion modulation emissions having designators with A, C, D, F, G, H, J or R as the first symbol; X as the second symbol; X as the third symbol. ROS has no ITU designator marking it as spread spectrum. Furthermore, from part 97.307 places this limitation on any data mode transmitted in the HF bands: (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. ROS follows this rule. In short, ROS has not been ruled to be a spread spectrum mode by the FCC or the ITU, and fits within the bandwidth of a phone communications signal on HF. It also follows the common sense rule of not causing any harm on the HF bands. It really is not much different from the other data modulations out there. JT65, Throb and RTTY also have empty space between carrier positions. I would certainly try out ROS, if it weren't for the fact that I don't have a Windows PC and ROS does not seem to run anywhere else... -- All rights reversed.
Re: [digitalradio] A closer look at ROS]
That is part of the story but SS in that context is specifically defined in 97.3. KH6TY wrote: §97.305 Authorized emission types is the regulation that authorizes SS for 222 Mhz and above only. 73 - Skip KH6TY w2xj wrote: Please provide a citation from part 97 that prohibits ROS even if it were deemed to truly be spread spectrum. KH6TY wrote: In most legal documents, specific references override general ones. In this discussion, only the FCC attorneys can decide what is allowed and what is not. Until then, the specific regulations regarding SS are assumed to be the law in this country, no matter how badly it is desired to use the new mode, and what rationalizations are made for being able to use it. This road has been traveled before! 73 - Skip KH6TY w2xj wrote: I have spent the last hour looking through part 97. I find nothing that would prohibit ROS in the HF bands subject to adhering to those segments where the bandwidth is allowed. In fact the rules would appear to support such operation: (b) Where authorized by §§ 97.305(c) and 97.307(f) of this part, a station may transmit a RTTY or data emission using an unspecified digital code, except to a station in a country with which the United States does not have an agreement permitting the code to be used. RTTY and data emissions using unspecified digital codes must not be transmitted for the purpose of obscuring the meaning of any communication. When deemed necessary by a District Director to assure compliance with the FCC Rules, a station must: (1) Cease the transmission using the unspecified digital code; (2) Restrict transmissions of any digital code to the extent instructed; (3) Maintain a record, convertible to the original information, of all digital communications transmitted I also do not see anything in the part 97 subsection on spread spectrum ( if in fact ROS was really determined to be an SS mode) that would make ROS non compliant. Part 97 technical standards mostly harmonize US rules with ITU international treaties They are written to be quite broad in order to permit experimentation. So long as the coding technique is public and can be received by anyone, the real restriction is based on allowable bandwidth and power allocated for a given frequency. John B. Stephensen wrote: The attachments are a good illustration why the rules should be changed. Olivia and ROS use a similar amount of spectrum so the FCC shouldn't be calling one legal and the other illegal based on how they were generated. 73, John KD6OZH - Original Message - From: Tony To: digitalradio@yahoogroups.com mailto:digitalradio%40yahoogroups.com mailto:digitalradio%40yahoogroups.com Sent: Sunday, February 21, 2010 08:20 UTC Subject: [digitalradio] A closer look at ROS [2 Attachments] [Attachment(s) from Tony included below] All, It would appear that ROS-16 is not much different than say Olivia 128 / 2K. The number of tones may differ, but they both use MFSK modulation with sequential tones running at 16 baud. The question is how can ROS be considered a SS frequency hoping mode while Olivia and it's derivatives are not? A closer look shows that they are quite similar (see attached). Tony -K2MO
Re: [digitalradio] A closer look at ROS]
Rik, Did you see the recent post by K3DCW? The closest you get to a true definition in Part 97 is in section 97.3 Definitions, Para C, line 8: /(8) SS/. Spread-spectrum emissions using bandwidth-expansion modulation emissions having designators with A, C, D, F, G, H, J or R as the first symbol; X as the second symbol; X as the third symbol. ROS uses SSB so the first designator is J (this meets the definition) and it uses bandwidth-expansion. (this meets that definition as well) Thus, taking this definition literally, it is indeed Spread Spectrum and is thus illegal below 222MHzat least that the conservative interpretation that I'll stick with until we get a ruling otherwise. Dave K3DCW Obviously, with such a new mode, there has been no ITU description of ROS. If it used bandwidth expansion (i.e. frequency hopping), it is obviously to be classified as spread spectrum. Whether or not modes like MT63 and Olivia are essentially the same is debatable. The problem seems to be the direct reference to bandwidth expansion (but within the width of a phone signal), which, until ruled otherwise (and I hope it will be) is spread spectrum according to the current FCC rules, and is currently legal only above 222 Mhz. 73 - Skip KH6TY Rik van Riel wrote: On 02/21/2010 02:17 PM, w2xj wrote: I have spent the last hour looking through part 97. I find nothing that would prohibit ROS in the HF bands subject to adhering to those segments where the bandwidth is allowed. In fact the rules would appear to support such operation: Lets look at it in another way. Part 97.3 is quite specific about what modes are considered spread spectrum: (8) SS. Spread-spectrum emissions using bandwidth-expansion modulation emissions having designators with A, C, D, F, G, H, J or R as the first symbol; X as the second symbol; X as the third symbol. ROS has no ITU designator marking it as spread spectrum. Furthermore, from part 97.307 places this limitation on any data mode transmitted in the HF bands: (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. ROS follows this rule. In short, ROS has not been ruled to be a spread spectrum mode by the FCC or the ITU, and fits within the bandwidth of a phone communications signal on HF. It also follows the common sense rule of not causing any harm on the HF bands. It really is not much different from the other data modulations out there. JT65, Throb and RTTY also have empty space between carrier positions. I would certainly try out ROS, if it weren't for the fact that I don't have a Windows PC and ROS does not seem to run anywhere else... -- All rights reversed.
Re: [digitalradio] A closer look at ROS]]
There are two very common misconceptions in that theory. The first is that SS is unto itself not always a fully digital mode. and A, F, or J in that case indicates the nature of the narrow band signal being spread. So SS with a J designator would be an SSB signal digitally spread by the PN code. When received, it is de-spread to an analog SSB signal. Sound card modes are not necessarily SSB. We use the SSB process as a convenient easy to deploy up converter when operating in these modes, the modulation occurs in the computer code and could be transmitted with varying degrees of ease by other means. CW via sound card is still CW as is the case with RTTY. ROS is no exception. It is quite possible to drive a DDS chip on frequency and accomplish the exact same result only at the expense of greater complexity. KH6TY wrote: Rik, Did you see the recent post by K3DCW? The closest you get to a true definition in Part 97 is in section 97.3 Definitions, Para C, line 8: /(8) SS/. Spread-spectrum emissions using bandwidth-expansion modulation emissions having designators with A, C, D, F, G, H, J or R as the first symbol; X as the second symbol; X as the third symbol. ROS uses SSB so the first designator is J (this meets the definition) and it uses bandwidth-expansion. (this meets that definition as well) Thus, taking this definition literally, it is indeed Spread Spectrum and is thus illegal below 222MHzat least that the conservative interpretation that I'll stick with until we get a ruling otherwise. Dave K3DCW Obviously, with such a new mode, there has been no ITU description of ROS. If it used bandwidth expansion (i.e. frequency hopping), it is obviously to be classified as spread spectrum. Whether or not modes like MT63 and Olivia are essentially the same is debatable. The problem seems to be the direct reference to bandwidth expansion (but within the width of a phone signal), which, until ruled otherwise (and I hope it will be) is spread spectrum according to the current FCC rules, and is currently legal only above 222 Mhz. 73 - Skip KH6TY Rik van Riel wrote: On 02/21/2010 02:17 PM, w2xj wrote: I have spent the last hour looking through part 97. I find nothing that would prohibit ROS in the HF bands subject to adhering to those segments where the bandwidth is allowed. In fact the rules would appear to support such operation: Lets look at it in another way. Part 97.3 is quite specific about what modes are considered spread spectrum: (8) SS. Spread-spectrum emissions using bandwidth-expansion modulation emissions having designators with A, C, D, F, G, H, J or R as the first symbol; X as the second symbol; X as the third symbol. ROS has no ITU designator marking it as spread spectrum. Furthermore, from part 97.307 places this limitation on any data mode transmitted in the HF bands: (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. ROS follows this rule. In short, ROS has not been ruled to be a spread spectrum mode by the FCC or the ITU, and fits within the bandwidth of a phone communications signal on HF. It also follows the common sense rule of not causing any harm on the HF bands. It really is not much different from the other data modulations out there. JT65, Throb and RTTY also have empty space between carrier positions. I would certainly try out ROS, if it weren't for the fact that I don't have a Windows PC and ROS does not seem to run anywhere else... -- All rights reversed.
Re: [digitalradio] A closer look at ROS]
On 02/21/2010 04:16 PM, KH6TY wrote: Did you see the recent post by K3DCW? The closest you get to a true definition in Part 97 is in section 97.3 Definitions, Para C, line 8: /(8) SS/. Spread-spectrum emissions using bandwidth-expansion modulation emissions having designators with A, C, D, F, G, H, J or R as the first symbol; X as the second symbol; X as the third symbol. ROS uses SSB so the first designator is J (this meets the definition) and it uses bandwidth-expansion. (this meets that definition as well) Thus, taking this definition literally, it is indeed Spread Spectrum and is thus illegal below 222MHzat least that the conservative interpretation that I'll stick with until we get a ruling otherwise. http://life.itu.ch/radioclub/rr/ap01.htm If you look at the list there, it would appear that ROS is J2D (under the SSB interpretation) or V2D. Not AXX CXX DXX FXX GXX HXX JXX or RXX. You can read the rules as strictly as you want and limit your activities that way, but I believe some common sense questions like does this mode take more bandwidth than other modes? and does this mode cause more interference than already allowed modes? will carry more weight than the choice of a single word in the description of the modulation. Modes that jump around inside an SSB passband according to a pseudo-random number sequence are already legal, and in fairly widespread use, on the HF amateur bands. Modes that send a data stream across multiple sub carriers inside an SSB passband are already legal, and in widespread use, on the HF amateur bands. ROS is not doing anything different. The only thing different is one single word in the creator's description of the modulation. If you want to limit your own activities on the HF bands, feel free to give more importance to that single word than to the technical details of the ROS modulation. -- All rights reversed.
Re: [digitalradio] A closer look at ROS]]
The FCC is only concerned with what happens to the resultant RF energy and what is done with it, not how that RF is generated. In the case of ROS, if the data is applied to an RF carrier and the frequency then hopped, that would classify it as spread spectrum. The rules are FCC rules and currently specifically specify spread spectrum to be used only at 222Mhz and above. If it were not for that specific reference and the statement by Jose that frequency hopping is used, then the rules might be subject to interpretation. As it presently is, Jose would have a tough time in a court of law to prove he does not use frequency hopping or spread spectrum, as he has already claimed. Our best chance to legally use ROS in the US is for the FCC to issue a ruling. As amateurs, and not even lawyers, we are not competent to second-guess the FCC's lawyers and as long as there are so many previous claims that ROS is spread spectrum, we are stuck with that definition. Our best hope is to get the FCC to amend the regulations, or make an exception, to allow spread spectrum as long as it is capable of being monitored by third parties and does not exceed the bandwidth of a phone signal, and ROS would meet all of those conditions. There are those who think that regulation by bandwidth would solve everything, but there are also those who would love that chance to take over the HF bands with automated messaging services so they do not have to worry about crowding anymore. You can be thankful for regulations that both protect, and also allow, with limitations, and that cannot be changed without a sufficient period of public comment from all users so that all sides can be heard from. The FCC adheres to such a process. 73 - Skip KH6TY w2xj wrote: There are two very common misconceptions in that theory. The first is that SS is unto itself not always a fully digital mode. and A, F, or J in that case indicates the nature of the narrow band signal being spread. So SS with a J designator would be an SSB signal digitally spread by the PN code. When received, it is de-spread to an analog SSB signal. Sound card modes are not necessarily SSB. We use the SSB process as a convenient easy to deploy up converter when operating in these modes, the modulation occurs in the computer code and could be transmitted with varying degrees of ease by other means. CW via sound card is still CW as is the case with RTTY. ROS is no exception. It is quite possible to drive a DDS chip on frequency and accomplish the exact same result only at the expense of greater complexity. KH6TY wrote: Rik, Did you see the recent post by K3DCW? The closest you get to a true definition in Part 97 is in section 97.3 Definitions, Para C, line 8: /(8) SS/. Spread-spectrum emissions using bandwidth-expansion modulation emissions having designators with A, C, D, F, G, H, J or R as the first symbol; X as the second symbol; X as the third symbol. ROS uses SSB so the first designator is J (this meets the definition) and it uses bandwidth-expansion. (this meets that definition as well) Thus, taking this definition literally, it is indeed Spread Spectrum and is thus illegal below 222MHzat least that the conservative interpretation that I'll stick with until we get a ruling otherwise. Dave K3DCW Obviously, with such a new mode, there has been no ITU description of ROS. If it used bandwidth expansion (i.e. frequency hopping), it is obviously to be classified as spread spectrum. Whether or not modes like MT63 and Olivia are essentially the same is debatable. The problem seems to be the direct reference to bandwidth expansion (but within the width of a phone signal), which, until ruled otherwise (and I hope it will be) is spread spectrum according to the current FCC rules, and is currently legal only above 222 Mhz. 73 - Skip KH6TY Rik van Riel wrote: On 02/21/2010 02:17 PM, w2xj wrote: I have spent the last hour looking through part 97. I find nothing that would prohibit ROS in the HF bands subject to adhering to those segments where the bandwidth is allowed. In fact the rules would appear to support such operation: Lets look at it in another way. Part 97.3 is quite specific about what modes are considered spread spectrum: (8) SS. Spread-spectrum emissions using bandwidth-expansion modulation emissions having designators with A, C, D, F, G, H, J or R as the first symbol; X as the second symbol; X as the third symbol. ROS has no ITU designator marking it as spread spectrum. Furthermore, from part 97.307 places this limitation on any data mode transmitted in the HF bands: (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
RE: [digitalradio] A closer look at ROS]]
AA6YQ comments below -Original Message- From: digitalradio@yahoogroups.com [mailto:digitalra...@yahoogroups.com]on Behalf Of John B. Stephensen Sent: Sunday, February 21, 2010 6:14 PM To: digitalradio@yahoogroups.com Subject: Re: [digitalradio] A closer look at ROS]] The current restrictions on automatic stations can stay in place with regulation by bandwidth so this shouln't be an impediment. In the ARRL's proposal to regulate by bandwidth (RM-11306), the current restrictions on semi-automatic stations would have been eliminated. This and other aspects of the ARRL's proposal generated a large negative reaction, which resulted in the ARRL retracting its proposal before the FCC acted upon it. 73, Dave, AA6YQ
Re: [digitalradio] A closer look at ROS]]
ROS is one voice channel wide, it seems to have been conceived for a 3 kHz wide voice channel, as usual with SSB radios. Its width is comparable with accepted modes like MT63 or Olivia xx:2000. It is not an automated mode, it is meant for keyboarding. Its spectrum spreading is hardly the way WiFi works, nor the hopping mode of some HF tactical radios. It is not the way spread spectrum is defined in my paper bound 1986 ARRL Handbook or Operating Manual. There is nothing secret with it as far as I have seen, if you have the public program. I have not seen the specs, but I have watched it in a loopback connection using Spectran. I have the pictures stored in my HD. Limits in nowadays technology are more complex, or fuzzier, perhaps. But ROS is neither wider than a voice channel nor an automated mode. Of course, it is ALWAYS a 3 kHz wide channel, and should be accomodated accordingly, say, like Olivia xx:2000. And I agree that in legalese, the wording is extremely important. A badly worded claim may do more damage than obtaining meager benefits. 73, Jose, CO2JA
Re: [digitalradio] A closer look at ROS]]
) 5 cm Entire band - (6) 3 cm Entire band - (6) 1.2 cm Entire band - (6) 6 mm Entire band - (6) 4 mm Entire band - (6) 2.5 mm Entire band - (6) 1 mm Entire band - (6) - Above 275 GHz - Section 97.307(f) is amended to read as follows: § 97.307 Emission standards. * (f) The following standards and limitations apply to transmissions on the frequencies specified in § 97.305(e) and (f) of this Part. (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. (3) The bandwidth of a RTTY or data emission must not exceed 3 kHz. (4) Phone and image emissions may be transmitted only by stations located in ITU Regions 1 and 3, and by stations located within ITU Region 2 that are west of 130° West longitude or south of 20° North latitude. (5) The 3 kHz maximum bandwidth does not apply to double-sideband amplitude-modulated phone A3E emissions. (6) No specific bandwidth limitations apply except that the entire emission must be within the allocated band to meet the requirements of §97.307(d). Section 97.309 is amended to read as follows: § 97.309 RTTY and data emission codes. (a) Where authorized by §97.305(e) and (f), an amateur station may transmit a RTTY or data emission using published digital codes for the purpose of facilitating communications. (b) When deemed necessary by the FCC’s Enforcement Bureau to assure compliance with the FCC Rules, a station must: (1) Restrict transmissions of any digital code to the extent instructed; and (2) Maintain a record, convertible to the original information, of all digital communications transmitted. 73, John KD6OZH - Original Message - From: Dave AA6YQ To: digitalradio@yahoogroups.com Sent: Sunday, February 21, 2010 23:24 UTC Subject: RE: [digitalradio] A closer look at ROS]] AA6YQ comments below The current restrictions on automatic stations can stay in place with regulation by bandwidth so this shouln't be an impediment. In the ARRL's proposal to regulate by bandwidth (RM-11306), the current restrictions on semi-automatic stations would have been eliminated. This and other aspects of the ARRL's proposal generated a large negative reaction, which resulted in the ARRL retracting its proposal before the FCC acted upon it.
Re: [digitalradio] A closer look at ROS]]
John, The principle of regulation by bandwidth that was fostered by Winlink through the ARRL was that any mode would be allowed in a particular segment of bandwidths as long as the bandwidth was the same or similar. No restriction on content or operating methods.This would have meant that the messaging stations would have full access to all of the phone bands with no restrictions. For example, Pactor-III which has about 100% duty cycle (modulation), compared to 30% average for uncompressed phone, could easily displace any phone QSO and the phone operator would not even be able to identify the interfering station because he would not be operating Pactor-III. The result would have been dominance by messaging systems with no place left to have phone QSO's without the possiblity of being interfered with by an automatic messaging station. Messaging stations are run with ARQ so they fear competition of their own kind and you can often see two automatic stations battling automatically for a frequency. As a result they want to spread out over the band as much as possible to avoid interference from each other instead of sharing frequencies on a first-come-first-served basis like everyone else. If you modify regulation by bandwidth to limit certain incompatible modes or operating methods, then it is no longer regulation by bandwidth, but back to regulation by mode (perhaps also with some regulation by operating method thrown in for protection of some interests), but the FCC is happy with the regulation by mode we currently have, and they have seen no good reason to change what works for most communications already. Note that there is phone (wide) and CW and PSK31 (narrow) only to deal with now and digital operators are in the distinct minority, so there is little incentive to upset the apple cart to accomodate a minority of new modes. They may, in time, but only after careful consideration of all the arguments and proposals. As a result of opposition from everyone else except the messaging stations, the ARRL was forced to withdraw the petition and the FCC continues with regulation by mode instead of merely by bandwidth. As it stands, if spread spectrum were allowed without any limitation on bandwidth or requirement for third party copying, since there is no limitation on bandwidth on the HF bands, the band could be filled with spread spectrum stations covering wide bandwidths and once there are many spread spectrum stations, the fact that a single station will not interfere very long becomes a huge multitude of frequency-hopped signals that in the aggregate, that could cover many frequencies at once. What we hope is that the FCC will someday allow spread spectrum as long as it is limited in bandwidth to 3000 Hz and copiable by third parties for frequency mediation and identification when necessary. To do this, it will be necessary for the FCC to consider all arguments pro and con and decide whether or not to allow a limited form of spread spectrum on HF and VHF. The impact of a single spread spectrum station only cannot be the only consideration, but instead the impact of a multitude of spread spectrum stations, all transmitting at the same time on different frequencies. This obviously complicates the decision enormously, so the FCC needs to act carefully in order not to make a mistake. BTW, I have been monitoring 14.101 for several hours and ROS just froze in Windows 7 with an error message, Run-time error 5. Invalid procedure call or argument 73 - Skip KH6TY John B. Stephensen wrote: The current restrictions on automatic stations can stay in place with regulation by bandwidth so this shouln't be an impediment. 73, John KD6OZH - Original Message - *From:* KH6TY mailto:kh...@comcast.net *To:* digitalradio@yahoogroups.com mailto:digitalradio@yahoogroups.com *Sent:* Sunday, February 21, 2010 22:30 UTC *Subject:* Re: [digitalradio] A closer look at ROS]] There are those who think that regulation by bandwidth would solve everything, but there are also those who would love that chance to take over the HF bands with automated messaging services so they do not have to worry about crowding anymore. You can be thankful for regulations that both protect, and also allow, with limitations, and that cannot be changed without a sufficient period of public comment from all users so that all sides can be heard from. The FCC adheres to such a process.
Re: [digitalradio] A closer look at ROS]]
The last thing you want is a ruling. Please be careful what you wish for. The FCC has written rules that permit a lot of experimentation. Please do not push them to over regulate. To date, we have lost more than gained by forcing the FCC to get involved. From: KH6TY kh...@comcast.net Reply-To: digitalradio@yahoogroups.com Date: Sun, 21 Feb 2010 17:30:50 -0500 To: digitalradio@yahoogroups.com Subject: Re: [digitalradio] A closer look at ROS]] The FCC is only concerned with what happens to the resultant RF energy and what is done with it, not how that RF is generated. In the case of ROS, if the data is applied to an RF carrier and the frequency then hopped, that would classify it as spread spectrum. The rules are FCC rules and currently specifically specify spread spectrum to be used only at 222Mhz and above. If it were not for that specific reference and the statement by Jose that frequency hopping is used, then the rules might be subject to interpretation. As it presently is, Jose would have a tough time in a court of law to prove he does not use frequency hopping or spread spectrum, as he has already claimed. Our best chance to legally use ROS in the US is for the FCC to issue a ruling. As amateurs, and not even lawyers, we are not competent to second-guess the FCC's lawyers and as long as there are so many previous claims that ROS is spread spectrum, we are stuck with that definition. Our best hope is to get the FCC to amend the regulations, or make an exception, to allow spread spectrum as long as it is capable of being monitored by third parties and does not exceed the bandwidth of a phone signal, and ROS would meet all of those conditions. There are those who think that regulation by bandwidth would solve everything, but there are also those who would love that chance to take over the HF bands with automated messaging services so they do not have to worry about crowding anymore. You can be thankful for regulations that both protect, and also allow, with limitations, and that cannot be changed without a sufficient period of public comment from all users so that all sides can be heard from. The FCC adheres to such a process. 73 - Skip KH6TY w2xj wrote: There are two very common misconceptions in that theory. The first is that SS is unto itself not always a fully digital mode. and A, F, or J in that case indicates the nature of the narrow band signal being spread. So SS with a J designator would be an SSB signal digitally spread by the PN code. When received, it is de-spread to an analog SSB signal. Sound card modes are not necessarily SSB. We use the SSB process as a convenient easy to deploy up converter when operating in these modes, the modulation occurs in the computer code and could be transmitted with varying degrees of ease by other means. CW via sound card is still CW as is the case with RTTY. ROS is no exception. It is quite possible to drive a DDS chip on frequency and accomplish the exact same result only at the expense of greater complexity. KH6TY wrote: Rik, Did you see the recent post by K3DCW? The closest you get to a true definition in Part 97 is in section 97.3 Definitions, Para C, line 8: /(8) SS/. Spread-spectrum emissions using bandwidth-expansion modulation emissions having designators with A, C, D, F, G, H, J or R as the first symbol; X as the second symbol; X as the third symbol. ROS uses SSB so the first designator is J (this meets the definition) and it uses bandwidth-expansion. (this meets that definition as well) Thus, taking this definition literally, it is indeed Spread Spectrum and is thus illegal below 222MHzat least that the conservative interpretation that I'll stick with until we get a ruling otherwise. Dave K3DCW Obviously, with such a new mode, there has been no ITU description of ROS. If it used bandwidth expansion (i.e. frequency hopping), it is obviously to be classified as spread spectrum. Whether or not modes like MT63 and Olivia are essentially the same is debatable. The problem seems to be the direct reference to bandwidth expansion (but within the width of a phone signal), which, until ruled otherwise (and I hope it will be) is spread spectrum according to the current FCC rules, and is currently legal only above 222 Mhz. 73 - Skip KH6TY Rik van Riel wrote: On 02/21/2010 02:17 PM, w2xj wrote: I have spent the last hour looking through part 97. I find nothing that would prohibit ROS in the HF bands subject to adhering to those segments where the bandwidth is allowed. In fact the rules would appear to support such operation: Lets look at it in another way. Part 97.3 is quite specific about what modes are considered spread spectrum: (8) SS. Spread-spectrum emissions using bandwidth-expansion modulation emissions having designators with A, C, D, F, G, H, J or R
