Re: [digitalradio] Re: ROS - make it legal in USA
Not all radio sevices reference 2.201 so changing part 97 wouldn't be a major problem for the FCC. 73, John KD6OZH - Original Message - From: vinceinwaukesha To: digitalradio@yahoogroups.com Sent: Sunday, February 21, 2010 21:19 UTC Subject: [digitalradio] Re: ROS - make it legal in USA --- In digitalradio@yahoogroups.com, John B. Stephensen kd6...@... wrote: What ROS users should do is email their ARRL representative and have them petition the FCC to change the rules. One solution is to eliminate the emission designators and change the RTTY/data segment of each HF band to 0-500 Hz wide emissions and the phone/image of each HF band to 0-8 kHz wide emissions with 0-20 kHz above 29 MHz. Well, most hams inaccurately believe, as a simplification, that the rule is emission designators ending in A/B go at the bottom of the band, ending in E goes at the top of the band, and ending in D wiggle in between. However, the whole point of the ROS debate is that FCC 97.3(c) does exist, like it or not, and FCC 97.3(c) was way over complicated and is simply obsolete. The FCC is not going to wipe FCC 2.201 because hams don't like emissions designators. A simpler solution than yours, would be to wipe 97.3(c) and replace it with something along the lines of ordering our transmissions based on alphabetical order of the letter at the end of our emissions designators., and then toss something in about 97.101(a) implying that maximizing the amount of cooperation with as many as possible of the thousands of band plans would be defined as good engineering practice. Which would pretty much end up as the status quo, with the added feature of eliminating all future RF engineer lawyer-ing. 73 de Vince N9NFB
Re: [digitalradio] A closer look at ROS]]
The final ARRL petition didn't change the rules in 97.221 for automatic stations: APPENDIX A – AMENDED March 22, 2007 PROPOSED RULE CHANGES Part 97 of Chapter I of Title 47 of the Code of Federal Regulation is proposed to be amended as follows: Section 97.3(a)(8) is amended to read as follows: (8) Bandwidth. For a given class of emission, the width of the frequency band which is just sufficient to ensure the transmission of information at the rate and with the quality required under specified conditions (See the definition of Necessary Bandwidth in Section 2.1 of this Chapter and Section 97.101(a) of this Part). Section 97.3(a)(42) is amended to read as follows: (42) Spurious Emission. For the purposes of this Part, emission on a frequency or frequencies which are outside the allocated frequency band and which may be reduced without affecting the corresponding transmission of information. Spurious emissions include harmonic emissions, parasitic emissions, intermodulation products and frequency conversion products. Section 97.119 is amended to read as follows: § 97.119 Station identification. * (b)… (1) By a CW or MCW emission. When keyed by an automatic device used only for identification, the speed must not exceed 20 words per minute; (2) Where phone emissions are permitted, by a phone emission in the English language. Use of a standard phonetic alphabet as an aid for correct station identification is encouraged; (3) By the same emission as used for the communication. (4) (Deleted) Section 97.305 is amended to read as follows: § 97.305 Authorized emission types. * (b) A station may transmit a test emission on any frequency authorized to the control operator for brief periods for experimental purposes. Test transmissions are authorized in the segments 51-54 MHz, 144.1-148.0 MHz and on all bands above 222 MHz. (c) Pulse emissions are permitted on all bands authorized to the control operator above 902 MHz except in the 23 cm and 3 cm bands. (d) SS emissions are permitted on all bands authorized to the control operator above 222 MHz. (e) A station may transmit the following emission types on the frequencies indicated, as authorized to the control operator, subject to the standards specified in § 97.307(f) of this part; except that on frequencies below 28.0 MHz, a Station having a control operator holding a Novice Class or Technician Class operator license may only transmit a CW emission using the international Morse code. Wavelength band Frequencies Emission Types Authorized Standards, see §97.307(f), paragraph: MF: 160 m Entire band RTTY, data (3) -do- -do- Phone, image (1), (2) HF: 80 m Entire band RTTY, data (3) 75 m Entire band Phone, image (1), (2) 40 m 7.000-7.125 MHz RTTY, data (3) 40 m 7.075-7.100 MHz Phone, image (1), (2), (4) 40 m 7.125-7.300 MHz Phone, image (1), (2) 30 m Entire band RTTY, data (3) 20 m 14.00-14.15 MHz RTTY, data (3) -do- 14.15-14.35 MHz Phone, image (1), (2) 17 m 18.068-18.110 MHz RTTY, data (3) -do- 18.110-18.168 MHz Phone, image (1), (2) 15 m 21.0-21.2 MHz RTTY, data (3) -do- 21.20-21.45 MHz Phone, image (1), (2) 12 m 24.89-24.93 MHz RTTY, data (3) -do- 24.93-24.99 MHz Phone, image (1), (2) (f) Except as otherwise provided in this Section, a station may transmit any emission on any frequency authorized to the control operator subject to the following bandwidth limitations: Wavelength band Frequencies authorized Maximum bandwidth Standards See §97.307(f) paragraph: 10 m 28.00-28.05 MHz 200 Hz -do- 28.05-28.120 MHz 500 Hz -do- 28.120-29.0 MHz 3 kHz (5) -do- 29.0-29.7 MHz 16 kHz 6 m 50.0-50.1 MHz 200 Hz -do- 50.1-50.3 MHz 3 kHz -do- 50.3-54 MHz 100 kHz 2 m 144.0-144.1 MHz 200 Hz -do- 144.1-144.3 MHz 3 kHz -do- 144.3-148.0 MHz 100 kHz 1.25 m 219-220 MHz 100 kHz -do- 222-225 MHz - (6) 70 cm Entire band - (6) 33 cm Entire band - (6) 23 cm Entire band - (6) 13 cm Entire band - (6) 9 cm Entire band - (6)
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] Winlink and Regulation by Bandwidth
Pactor was FSK with a 100% duty cycle (or peak to average power ratio - PAPR), but Pactor-III is OFDM which has a PAPR similar to SSB and much less than SSB with RF clipping so I don't see how its any worse than digital voice or SSTV. Were the two stations in the automated segments fighting or just transferring data in both directions? I just don't see the threat from automated Pactor stations as they are legal on every amateur frequency outside the U.S. and they haven't taken over there. 73, John KD6OZH - Original Message - From: KH6TY To: digitalradio@yahoogroups.com Sent: Monday, February 22, 2010 00:04 UTC Subject: 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.
Re: [digitalradio] Consensus? Is ROS Legal in US?`
Commercial and military SS systems also use FSK so that not likely alleviate the problem. The pseudorandom movement of the center frequency is the issue. Since the object is to prevent intersymbol interference due to multipath spread, one way around the legal issue is to transmit even symbols on one set of frequencies and odd symbols on another set of frequencies. 73, John KD6OZH - Original Message - From: jose alberto nieto ros To: digitalradio@yahoogroups.com Sent: Tuesday, February 23, 2010 23:00 UTC Subject: Re: [digitalradio] Consensus? Is ROS Legal in US?` Is legal because ROS is a FSK modulation. -- De: ocypret n5...@arrl.net Para: digitalradio@yahoogroups.com Enviado: mar,23 febrero, 2010 21:26 Asunto: [digitalradio] Consensus? Is ROS Legal in US?` So what's the consensus, is ROS legal in the US or not?
Re: [digitalradio] Re: Consensus? Is ROS Legal in US?`
Any petition should reduce regulation rather than increase its complexity by continually adding loopholes. ROS is not the only mode that is currently illegal -- there are single carrier PSK digital modes that U.S. amateurs can't use because of the baud rate limit. U.S. regulations should be harmonized with the rest of the world by eliminating baud rate restrictions and emission designators entirely. Outside the U.S., any form of modulation less than 8 kHz wide is allowed below 29 MHz. If we align our regulations with the rest of the world there will be no more legal problems with software written outside the U.S. 73, John KD6OZH - Original Message - From: KH6TY To: digitalradio@yahoogroups.com Sent: Tuesday, February 23, 2010 22:59 UTC Subject: Re: [digitalradio] Re: Consensus? Is ROS Legal in US?` Next step is to formally petition the FCC to allow SS if the bandwidth does not exceed 3000 Hz, or the width of a SSB phone signal. Mark Miller, N5RFX, has experience in submitting petitions to the FCC, and had one granted. In case anyone wishes to pursue this further, he may be able to help. If ROS is really worth saving for US hams, it is worth fighting for! 73 - Skip KH6TY
Re: [digitalradio] Consensus? Is ROS Legal in US?`
The FCC only requires that a technical description be published: Sec. 97.309 RTTY and data emission codes. (a) Where authorized by Sec. Sec. 97.305(c) and 97.307(f) of the part, an amateur station may transmit a RTTY or data emission using the following specified digital codes: (1) The 5-unit, start-stop, International Telegraph Alphabet No. 2, code defined in ITU-T Recommendation F.1, Division C (commonly known as ``Baudot''). (2) The 7-unit code specified in ITU-R Recommendations M.476-5 and M.625-3 (commonly known as ``AMTOR''). (3) The 7-unit, International Alphabet No. 5, code defined in IT--T Recommendation T.50 (commonly known as ``ASCII''). (4) An amateur station transmitting a RTTY or data emission using a digital code specified in this paragraph may use any technique whose technical characteristics have been documented publicly, such as CLOVER, G-TOR, or PacTOR, for the purpose of facilitating communications. (b) Where authorized by Sec. Sec. 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. [54 FR 25857, June 20, 1989, as amended at 54 FR 39537, Sept. 27, 1989; 56 FR 56172, Nov. 1, 1991; 60 FR 55486, Nov. 1, 1995; 71 FR 25982, May 3, 2006; 71 FR 66465, Nov. 15, 2006] 73, John KD6OZH - Original Message - From: jose alberto nieto ros To: digitalradio@yahoogroups.com Sent: Tuesday, February 23, 2010 23:39 UTC Subject: Re: [digitalradio] Consensus? Is ROS Legal in US?` Hi, KH6. I only i am going to describe in a technicals article how run the mode. If FCC want the code they will have to buy it me, that is obvious. -- De: KH6TY kh...@comcast.net Para: digitalradio@yahoogroups.com Enviado: mié,24 febrero, 2010 00:31 Asunto: Re: [digitalradio] Consensus? Is ROS Legal in US?` Jose, You will have to disclose the algorithm that determines the spreading on ROS (independent of the data), or bandwidth expansion, if that is actually used. You will have to convince technical people that will show your new description to our FCC that your original description was wrong and prove it by revealing your code. I think this is the only way to get the FCC opinion reversed. You now have a difficult task before you, but I wish you success, as ROS is a really fun mode. 73 - Skip KH6TY jose alberto nieto ros wrote: Is legal because ROS is a FSK modulation. De: ocypret n5...@arrl.net Para: digitalradio@ yahoogroups. com Enviado: mar,23 febrero, 2010 21:26 Asunto: [digitalradio] Consensus? Is ROS Legal in US?` So what's the consensus, is ROS legal in the US or not?
Re: [digitalradio] Consensus? Is ROS Legal in US?`
Convolutional coding and Viterbi decoding may increase the occupied bandwidth but they also decrease the amount of power required to communicate. In some cases, like trellis-coded modulation, the bandwidth stays the same even though the power required decreases by a factor of 2-4. Spread spectrum increases the occupied bandwidth without the decrease in power. 73, John KD6OZH - Original Message - From: W2XJ To: digitalradio@yahoogroups.com Sent: Wednesday, February 24, 2010 01:24 UTC Subject: Re: [digitalradio] Consensus? Is ROS Legal in US?` I have a different take on this. There are a number of modes that uses vertebrae coding which could be mis-described as spread spectrum by some. The problem with part 97 is that it tries to be as broad as possible where technical parameters are concerned. In this case it causes things to be vague. There are many things that can be described as spread spectrum that are not by definition in part 97. FM would be one of them. Anytime information is transmitted in a wider bandwidth than necessary it could be described as spread spectrum. This would include some low noise modes. The problem is that we petitioned the FCC to loosen SS rules and the more vague those rules are made the more open to debate they are. The worst that can happen under the rules if one would be operating ROS in the phone segment would be an order to cease such operation if the comish so ordered. -- From: KH6TY kh...@comcast.net Reply-To: digitalradio@yahoogroups.com Date: Tue, 23 Feb 2010 19:53:53 -0500 To: digitalradio@yahoogroups.com Subject: Re: [digitalradio] Consensus? Is ROS Legal in US?` I am for whatever will succeed, but do not underestimate how difficult it is to convincingly reverse oneself after first originally being so convincing. For myself, even from the beginning, I could not understand how the spreading was accomplished by a code that everyone else automatically had, but that was the claim, so I accepted it. Perhaps there is no spreading code independent of the data, but if so, it must now be proven thus, and not just claimed in what might be seen as an attempt to have something approved that has already been disapproved. Just because I might possess the necessary technical skills does not mean I can individually overrule the FCC with my actions. Even opposing technical experts are called by both parties in a legal argument, and the judge to decide who is correct in this case is the FCC, which has already issued an opinion, even if it may be wrong if given new information, but just saying it is so does not make it so. I believe some concrete proof is required now, and maybe your spectrum analyzer display can be part of such proof. Other's opinions may vary... 73 - Skip KH6TY W2XJ wrote: Skip You are over thinking this. The FCC said as they always do that you as a licensee must possess the technical skill to evaluate whether or not a particular mode meets the rules. On Jose's part a better technical description and some clarification would be very helpful to this end. I think just looking at the output on a spectrum analyzer would also be quite revealing. From: KH6TY kh...@comcast.net Reply-To: digitalradio@yahoogroups.com Date: Tue, 23 Feb 2010 19:03:06 -0500 To: digitalradio@yahoogroups.com Subject: Re: [digitalradio] Consensus? Is ROS Legal in US?` Jose, I am only trying to suggest whatever ideas I can to get ROS declared to be legal. You have made such a strong case for FHSS already, that only saying you were mistaken probably will not convince the FCC. They will assume you are only changing the description so ROS appears to be legal and will demand proof that it is not FHSS to change their minds. This is only my personal, unbiased, opinion, as I would like very much for you to succeed. Essentially, you must PROVE that, spreading is NOT accomplished by means of a spreading signal, often called a code signal, which is independent of the data. How do you do that without disclosing the code? At this point, I doubt that the FCC will believe mere words, because there is so much pressure to allow ROS in HF in this country. Keep in mind the mess that Toyota finds itself by previously denying there is any substantial problem with unattended acceleration or braking of their cars. That may still prove to be true (i.e. not substantial), but the government here is now demanding that Toyota SHOW proof that there is no problem, and not merely saying there is not. This is currently a very hot topic with the government and Congress and on the minds of everyone. So I
Re: [digitalradio] Consensus? Is ROS Legal in US?`
These modes use interleaving and randomize data values by exclusive-ORing with a pseudorandom binary sequence. The methods are used in most commerial products and the FCC and NSA know how to monitor the signals. The FCCs problem is that the military uses FHSS and DSSS to hide the existance and content of their transmissions thus preventing the monitoring that the FCC is required to do of amateur signals. It took AMRAD a long time to get authorization for SS above 222 MHz. They first had to get experimental licenses for test transmissions and satisfy the FCC that they could monitor the signals. 73, John KD6OZH - Original Message - From: Rik van Riel To: digitalradio@yahoogroups.com Sent: Wednesday, February 24, 2010 02:32 UTC Subject: Re: [digitalradio] Consensus? Is ROS Legal in US?` On 02/23/2010 09:00 PM, KH6TY wrote: The distinguishing characteristic of spread spectrum is spreading by a code INDEPENDENT of the data. FM for example, creates carriers depending upon the audio frequency and amplitude. SSB creates carriers at a frequency dependent upon the tone frequency, and RTTY at a pair of set frequencirs depending upon the shift or the tones used to generate shift. In spread spectrum, as Jose has written, an independent code is used for the spreading, one of the requirements to classify it as spread spectrum. One of the requirements - not the single determining characteristic by any means. From a quick look through the fldigi source code, MFSK and Olivia appear to use a pseudo-random code as well, to provide robustness against narrow band interference. From several places in src/include/jalocha/pj_mfsk.h static const uint64_t ScramblingCode = 0xE257E6D0291574ECLL; -- All rights reversed.
Re: [digitalradio] Consensus? Is ROS Legal in US?`
The problem is that he said that ROS uses FHSS in the documentation. If the final version doesn't use FHSS, DSSS or any other form of SS and a technical specification is published the FCC will have no objection. 73, John KD6OZH - Original Message - From: Rik van Riel To: digitalradio@yahoogroups.com Sent: Wednesday, February 24, 2010 03:37 UTC Subject: Re: [digitalradio] Consensus? Is ROS Legal in US?` On 02/23/2010 10:22 PM, John B. Stephensen wrote: These modes use interleaving and randomize data values by exclusive-ORing with a pseudorandom binary sequence. The methods are used in most commerial products and the FCC and NSA know how to monitor the signals. However, this does result in carrier placement also being somewhat randomized. Maybe not in exactly the same way as true spread spectrum, since the carrier position is still somewhat dependent on the data content. On the other hand, from the ROS documentation it appears that the carrier location in ROS is also still dependent on data content (as well as a pseudo-random sequence). Carrier location it ROS is, as far as I can tell (Jose will know for sure), dependent on both the data being transmitted and the pseudo-random sequence being used. The FCCs problem is that the military uses FHSS and DSSS to hide the existance and content of their transmissions thus preventing the monitoring that the FCC is required to do of amateur signals. That could be a problem with ROS, as long as the protocol specification is unknown. However, once the protocol has been finalized and the specification made public, monitoring ROS communications will be easy. -- All rights reversed.
Re: [digitalradio] Re: Consensus? Is ROS Legal in US?`
In order for amateurs in the U.S. to use any RTTY/data mode other than Baudot, ASCII or AMTOR over 2FSK they must be able to point to a published technical specification for the potocol that shows that it is legal. It was condition that we all agreed to when we were issued a license. When this is done the problem will be solved. 73, John KD6OZH - Original Message - From: John To: digitalradio@yahoogroups.com Sent: Wednesday, February 24, 2010 03:41 UTC Subject: [digitalradio] Re: Consensus? Is ROS Legal in US?` OK, I am starting to agree with Dave now and with Andy as before ... this is starting to now become circular . It has now been solidly established that ROS is FSK, NOT SS, by the authors own words. The author NEVER approached the FCC for an OPINION about his unfinished work at all. Indeed he made it clear the whole thing was still BETA In the US, when has an OPINION of someone lower than the enforcing authority made anything legal or illegal? It was only an opinion of one of the agents (agent #3820) based on the incomplete data provided to them. had I been that agent, I would have said the same thing under the circumstances of only having incomplete, inaccurate documentation presented to me. Jose, the author, has already indicated he intends to correct the error in his updated documentation which should remove all questions about legality in the US. It is not necessary for him to provide anyone with his algorithm so long as he continues to provide his program so that anyone can monitor the transmissions. The transmissions all fall within FCC guidelines already, that has never been argued. The only real argument has been, is it SS or FSK. If it is FSK, it is NOT illegal. The spread spectrum rule simply does not apply here. What more will the outcome of this discussion ultimately determine? Presently, the FCC is so understaffed due to budgetary constraints, my guess is that they really do not have the resources needed to chase such questionable things as this in the first place. Can anyone imagine our enforcement group is going to expend the kind of resources necessary to enforce something that is likely not really an issue in the first place? They are not there just sitting and waiting to jump on anyone potentially violating such a questionable matter in the first place. As for the requirements of how this software generates or does not generate it's spectrum should no longer even be a question since the only reason it was ever argued in the first place was based on the authors misunderstanding of OUR (the US) definition of SS versus FSK. Once he (the program author) understood the difference in that definition, he immediately noted his program was NOT SS at all, but was in fact FSK. Argument should be over? TRUE? NOT TRUE? Dave, where would we go from here . if we were in your country? John KE5HAM --- In digitalradio@yahoogroups.com, KH6TY kh...@... wrote: It is a NECESSARY AND SUFFICIENT requirement (out of three). The point is that if that is not the way the spreading is done in ROS, ROS is NOT spread spectrum. PROVE, not just claim, that it is not, and the battle is won. 73 - Skip KH6TY
Re: [digitalradio] Re: Consensus? Is ROS Legal in US?`
A member of this group contacted the FCC, got a ruling, and published it here. Just remember that you have no legal defense if the FCC decides to take action. I keep replying to this stuff because some members of this group could led others into losing their licenses. 73, John KD6OZH - Original Message - From: ocypret To: digitalradio@yahoogroups.com Sent: Wednesday, February 24, 2010 03:04 UTC Subject: [digitalradio] Re: Consensus? Is ROS Legal in US?` --- In digitalradio@yahoogroups.com, ocypret n5...@... wrote: So what's the consensus, is ROS legal in the US or not? Wow! What a mess! I think absent a clear ruling from the FCC and as long as I think a plausible argument can be made for its compliance with Part 97, I'm going to use it. I made a contact this afternoon with PC5W on 20 meters. It looks like a good mode to use. Sorry for stirring up the firestorm again - I thought you guys had pretty much argued yourselves out or I wouldn't have posted the question. All the previous posting on this have left my head spinning. Wayne N5BZA
Re: [digitalradio] Consensus? Is ROS Legal in US?`
SS reduces the power spectral density but not the total power per bit for a given error rate. 73, John KD6OZH - Original Message - From: jose alberto nieto ros To: digitalradio@yahoogroups.com Sent: Wednesday, February 24, 2010 10:03 UTC Subject: Re: [digitalradio] Consensus? Is ROS Legal in US?` I see you have not idea waht is the meaning of Spread spectrum. Spread spectrum reduce energy density. -- De: John B. Stephensen kd6...@comcast.net Para: digitalradio@yahoogroups.com Enviado: mié,24 febrero, 2010 03:55 Asunto: Re: [digitalradio] Consensus? Is ROS Legal in US?` Convolutional coding and Viterbi decoding may increase the occupied bandwidth but they also decrease the amount of power required to communicate. In some cases, like trellis-coded modulation, the bandwidth stays the same even though the power required decreases by a factor of 2-4. Spread spectrum increases the occupied bandwidth without the decrease in power. 73, John KD6OZH - Original Message - From: W2XJ To: digitalradio@ yahoogroups. com Sent: Wednesday, February 24, 2010 01:24 UTC Subject: Re: [digitalradio] Consensus? Is ROS Legal in US?` I have a different take on this. There are a number of modes that uses vertebrae coding which could be mis-described as spread spectrum by some. The problem with part 97 is that it tries to be as broad as possible where technical parameters are concerned. In this case it causes things to be vague. There are many things that can be described as spread spectrum that are not by definition in part 97. FM would be one of them. Anytime information is transmitted in a wider bandwidth than necessary it could be described as spread spectrum. This would include some low noise modes. The problem is that we petitioned the FCC to loosen SS rules and the more vague those rules are made the more open to debate they are. The worst that can happen under the rules if one would be operating ROS in the phone segment would be an order to cease such operation if the comish so ordered. From: KH6TY kh...@comcast. net Reply-To: digitalradio@ yahoogroups. com Date: Tue, 23 Feb 2010 19:53:53 -0500 To: digitalradio@ yahoogroups. com Subject: Re: [digitalradio] Consensus? Is ROS Legal in US?` I am for whatever will succeed, but do not underestimate how difficult it is to convincingly reverse oneself after first originally being so convincing. For myself, even from the beginning, I could not understand how the spreading was accomplished by a code that everyone else automatically had, but that was the claim, so I accepted it. Perhaps there is no spreading code independent of the data, but if so, it must now be proven thus, and not just claimed in what might be seen as an attempt to have something approved that has already been disapproved. Just because I might possess the necessary technical skills does not mean I can individually overrule the FCC with my actions. Even opposing technical experts are called by both parties in a legal argument, and the judge to decide who is correct in this case is the FCC, which has already issued an opinion, even if it may be wrong if given new information, but just saying it is so does not make it so. I believe some concrete proof is required now, and maybe your spectrum analyzer display can be part of such proof. Other's opinions may vary... 73 - Skip KH6TY W2XJ wrote: Skip You are over thinking this. The FCC said as they always do that you as a licensee must possess the technical skill to evaluate whether or not a particular mode meets the rules. On Jose’s part a better technical description and some clarification would be very helpful to this end. I think just looking at the output on a spectrum analyzer would also be quite revealing. -- From: KH6TY kh...@comcast. net Reply-To: digitalradio@ yahoogroups. com Date: Tue, 23 Feb 2010 19:03:06 -0500 To: digitalradio@ yahoogroups. com Subject: Re: [digitalradio] Consensus? Is ROS Legal in US?` Jose, I am only trying to suggest whatever ideas I can to get ROS declared to be legal. You have made such a strong case for FHSS already, that only saying you were mistaken probably will not convince the FCC. They will assume you are only changing the description so ROS appears to be legal and will demand proof that it is not FHSS to change their minds. This is only my personal, unbiased, opinion, as I would like very much for you to succeed
Re: [digitalradio] Re: Consensus? Is ROS Legal in US?`
Actually, I'd like to have the regulations changed. However, the more that amateurs ignore existing regulations the less the FCC will trust us. The SS restriction is one of the few provisions that the FCC actually cares about. They have given a legal opinion and can monitor this mailing list to see whether people comply. 73, John KD6OZH - Original Message - From: Dave Ackrill To: digitalradio@yahoogroups.com Sent: Wednesday, February 24, 2010 20:48 UTC Subject: Re: [digitalradio] Re: Consensus? Is ROS Legal in US?` John B. Stephensen wrote: A member of this group contacted the FCC, got a ruling, and published it here. Just remember that you have no legal defense if the FCC decides to take action. I keep replying to this stuff because some members of this group could led others into losing their licenses. On a 1st offence, even in the USA, I would expect a warning at least before the full force of the law was applied. Even over here it's rare for someone to be band for a technical infringement of the rules. I suspect a little over egging the pudding is going on... Maybe by people who, dare I say it, want to frighten others into not using the program? Dave (G0DJA)
Re: [digitalradio] Consensus? Is ROS Legal in US?`
A lawyer with an engineering degree would be the best person to interpret FCC regulations. The ARRL has engineers and lawyers and deals with the FCC so they are the best source of free advice in the U.S. 73, John KD6OZH - Original Message - From: Bob John To: digitalradio@yahoogroups.com Sent: Wednesday, February 24, 2010 19:17 UTC Subject: Re: [digitalradio] Consensus? Is ROS Legal in US?` Asking a lawyer is the last person you would ask for technical advice. Try asking an engineer not a lawyer. Bob, AA8X - Original Message - From: Rik van Riel To: digitalradio@yahoogroups.com Sent: Tuesday, February 23, 2010 4:38 PM Subject: Re: [digitalradio] Consensus? Is ROS Legal in US?` On 02/23/2010 03:26 PM, ocypret wrote: So what's the consensus, is ROS legal in the US or not? There's a few things we all agree on: 1) The legality of a mode depends on the technical details of that mode, not on what the author calls the mode. 2) The FCC's lawyers are the definite authority. K3UK has sent a letter to the FCC to ask for clarification. Once the FCC responds, we'll know for sure :) -- All rights reversed.
Re: [digitalradio] Is ROS Documentation Published?
CHIP64 is legal above 222 MHz -- they're assuming that the user will notice that it's spread-spectrum and act accordingly. 73, John KD6OZH - Original Message - From: jose alberto nieto ros To: digitalradio@yahoogroups.com Sent: Wednesday, February 24, 2010 23:30 UTC Subject: Re: [digitalradio] Is ROS Documentation Published? Hi Bonnie, i saw in the first place of that list: Chip 64 explaining clearly that Chip 64 is Spread Spectrum. Then, what have to say ARRL about it ? They are publishing a SS in his own officcial website. Somebody can explain me what happen here? -- De: expeditionradio expeditionra...@yahoo.com Para: digitalradio@yahoogroups.com Enviado: mié,24 febrero, 2010 23:20 Asunto: [digitalradio] Is ROS Documentation Published? Jose wrote: if anywant know about ROS protocol is Jose Alberto Nieto Ros Hi Jose, Do you plan to publish documentation of a non-Spread Spectrum version of ROS mode? Examples of public documentation: http://www.arrl. org/FandES/ field/regulation s/techchar/ Best Wishes, Bonnie Crystal KQ6XA FCC Rules for amateur radio service in USA §97.309(a)(4) Technical Descriptions (4) An amateur station transmitting a RTTY or data emission using a digital code specified in this paragraph may use any technique whose technical characteristics have been documented publicly, such as CLOVER, G-TOR, or PacTOR, for the purpose of facilitating communications.
Re: [digitalradio] Is ROS Documentation Published?
A published technical specification proving that it is not SS and meets all other requirements in the FCC regulations will allow use below 222 MHz in the U.S. The FCC requires the published specification to allow use of any RTTY or data mode on any frequency. Non-use of SS is just an additional requirement for frequencies below 222 MHz. They also have baud rate limits that vary by frequency. 300 baud is the maximum on most HF bands. It really is necessary to read Title 47 part 97 of the U.S. Code of Federal Regulations to develop this kind of software for use in the U.S. (see http://wireless.fcc.gov/index.htm?job=rules_and_regulations). 73, John KD6OZH - Original Message - From: jose alberto nieto ros To: digitalradio@yahoogroups.com Sent: Wednesday, February 24, 2010 23:52 UTC Subject: Re: [digitalradio] Is ROS Documentation Published? And ROS is legal because is not a SS modulation. -- De: John B. Stephensen kd6...@comcast.net Para: digitalradio@yahoogroups.com Enviado: jue,25 febrero, 2010 00:47 Asunto: Re: [digitalradio] Is ROS Documentation Published? CHIP64 is legal above 222 MHz -- they're assuming that the user will notice that it's spread-spectrum and act accordingly. 73, John KD6OZH - Original Message - From: jose alberto nieto ros To: digitalradio@ yahoogroups. com Sent: Wednesday, February 24, 2010 23:30 UTC Subject: Re: [digitalradio] Is ROS Documentation Published? Hi Bonnie, i saw in the first place of that list: Chip 64 explaining clearly that Chip 64 is Spread Spectrum. Then, what have to say ARRL about it ? They are publishing a SS in his own officcial website. Somebody can explain me what happen here? De: expeditionradio expeditionradio@ yahoo.com Para: digitalradio@ yahoogroups. com Enviado: mié,24 febrero, 2010 23:20 Asunto: [digitalradio] Is ROS Documentation Published? Jose wrote: if anywant know about ROS protocol is Jose Alberto Nieto Ros Hi Jose, Do you plan to publish documentation of a non-Spread Spectrum version of ROS mode? Examples of public documentation: http://www.arrl. org/FandES/ field/regulation s/techchar/ Best Wishes, Bonnie Crystal KQ6XA FCC Rules for amateur radio service in USA §97.309(a)(4) Technical Descriptions (4) An amateur station transmitting a RTTY or data emission using a digital code specified in this paragraph may use any technique whose technical characteristics have been documented publicly, such as CLOVER, G-TOR, or PacTOR, for the purpose of facilitating communications.
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
Re: [digitalradio] Does ROS spectrum match the specification?
A new technical description was published so you should see what it describes -- fixed start and stop sequences using 16 tones with convolutionally coded data using 128 tones in between. 73, John KD6OZH - Original Message - From: Steinar Aanesland To: digitalradio@yahoogroups.com Sent: Saturday, February 27, 2010 16:48 UTC Subject: Re: [digitalradio] There is a pattern in the ROS signal when idling Hi Skip Here is the new ROS signal. It is idling with two gruops of 25 sec of X's . As you can see the pattern change when sending data. http://home.broadpark.no/~saanes/bilder/ROS_X_2.JPG 73 de LA5VNA Steinar .
Re: [digitalradio] There is a pattern in the ROS signal when idling
The FCC will say that it up to each licensee to check the legality by reading the new technical specification. Unless someone shows that the spectrum doesn't match the specification U.S.hams should feel safe using ROS. 73, John KD6OZH - Original Message - From: Dave Ackrill To: digitalradio@yahoogroups.com Sent: Saturday, February 27, 2010 17:31 UTC Subject: Re: [digitalradio] There is a pattern in the ROS signal when idling KH6TY wrote: Looks like good news Steinar! If the data changes the frequencies, it does not qualify as FHSS as Jose originally claimed. I am sure the FCC will find the same during their tests and expect them to say it can be used on HF and VHF. When they do, please let me know so that I can let people over here who have only read the 'it's illegal in the USA' message know. Thanks - Dave (G0DJA)
Re: [digitalradio] Spectrum Spreading
Chapter 8 of the 2010 handbook has a short overview of spread-spectrum techniques that could be applied to either analog or digital modulation. The original signal cold be anything (BPSK, FSK, FM...) and is phase or frequency modulated by a pseudorandom sequence in order to spread the signal over a wider range of frequencies. In frequency hopping spread spectrum (FHSS) the receiver and transmitter just shift between a predefined set of frequenies during the transmission. Direct sequence spread-spectrum (DSSS) applies an additional level of phase modulation with a pseudorandom sequence to spread the original signal over a wider range of frequencies. DSSS often just exclusive-ORs (modulo-2 adds) the data with a spreading sequence at a rate that is a multiple of the original symbol rate. Error-correcting codes sometimes increase the bandwidth of a signal, but they do so by increasing the redundancy in the original signal. This could just be sending additional copies of the original data or adding parity bits to the data in block codes or multiplying the current data values with previous data values in convolutional coding. For example the current data value could be added to the previous two values and interleaved with the current value added to the second previous value. 73, John KD6OZH - Original Message - From: Rud Merriam To: digitalradio@yahoogroups.com Sent: Sunday, February 28, 2010 00:11 UTC Subject: [digitalradio] Spectrum Spreading I avoided most of the discussion in the last week or so but finally decided to see what the ARRL Handbook had to say. At first I thought it was totally unhelpful but after it sank in a bit found it some help. What I gleaned is that many digital modes use spectrum spreading techniques. The handbook seemed quite clear on this point. I am still trying to understand what spectrum spreading means. There is an implication in there of using more spectrum than.. something. For analog, i.e. voice, this is somewhat clear. If you are sending voice up to 2.5kz then the spectrum 'something' is around 2.5 kHz SSB, or double that for AM. Spectrum spreading would utilize some additional spectrum. Consider a hypothetical mode where you took the voice signal, spread the audio by 4 times to generate a 10 kHz signal, and used that audio to modulate the RF. That would be a spectrum spreading technique. I simply cannot get a handle on what spreading means for a digital signal. Is the base 'something' CW and PSK31? From the Handbook, and I gather from the discussion here, there is another aspect which concerns the way in which the signal is encoded. In my hypothetical analog mode you might somehow invert or fold the frequency spectrum. The reverse technique would be required to decode the signal. It is my sense that some types of encoding are not allowed, while others would be acceptable. Not trying to start the entire debate but hoping to get a better understanding of the meaning of all this. - 73 - Rud Merriam K5RUD ARES AEC Montgomery County, TX http://mysticlakesoftware.com/
Re: [digitalradio] ROS Technical description for the FCC in the US
There is a technical descrption at http://rosmodem.wordpress.com/. I doesn't describe the start and stop tone sequences or completely describe the mapping from the convolutional encoder to the 128 tones used for data. However, it's more compete than some of the technical specifications on the ARRL web site. Perhaps he can add more detail in the future. 73, John KD6OZH - Original Message - From: jbh...@bluefrog.com To: digitalradio@yahoogroups.com Cc: AE5IL Sent: Saturday, February 27, 2010 20:27 UTC Subject: [digitalradio] ROS Technical description for the FCC in the US §97.309(a)(4) Technical Descriptions This is a one-stop Web site for technical characteristics called for in FCC rules § 97.309(a)(4), which reads: (4) An amateur station transmitting a RTTY or data emission using a digital code specified in this paragraph may use any technique whose technical characteristics have been documented publicly, such as CLOVER, G-TOR, or PacTOR, for the purpose of facilitating communications. Documentation should be adequate to (a) recognize the technique or protocol when observed on the air, (b) determine call signs of stations in communication and read the content of the transmissions. Click on names of the techniques already documented: A technical description from you about ROS would help us in the US a lot. For other technical descriptions go to www.arrl.org/FandES/field/regulations/techchar/.
Re: [digitalradio] Re: There is a pattern in the ROS signal when idling
The problem is that the FCC regulations are overly complex and people need a specialized engineering background to interpret some of them. 99% of the licensees probably can't interpret every word in the regulations so they ask for help in this forum when something is not clear. 73, John KD6OZH - Original Message - W2XJ wrote: Skip An FCC staff member told an interested group at Dayton that if they were qualified to hold their license, they should have the ability to read and interpret the rules and figure it out for themselves. That's what the old Radio Communication Agency used to do in the UK as well. The problem then was that some people thought they had the authority to tell other Radio Amateurs what they could, and could not, do.
Re: [digitalradio] Re: There is a pattern in the ROS signal when idling
The portions that are causing problems here aren't in the regulations in other countries. 73, John KD6OZH - Original Message - From: W2XJ To: digitalradio@yahoogroups.com Sent: Monday, March 01, 2010 01:14 UTC Subject: Re: [digitalradio] Re: There is a pattern in the ROS signal when idling A good portion of the FCC rules is almost cut and paste from ITU standards which apply worldwide. -- From: John B. Stephensen kd6...@comcast.net Reply-To: digitalradio@yahoogroups.com Date: Mon, 1 Mar 2010 01:02:44 - To: digitalradio@yahoogroups.com Subject: Re: [digitalradio] Re: There is a pattern in the ROS signal when idling The problem is that the FCC regulations are overly complex and people need a specialized engineering background to interpret some of them. 99% of the licensees probably can't interpret every word in the regulations so they ask for help in this forum when something is not clear. .
Re: [digitalradio] FCC comments further on ROS
I had no doubt that it would once the document that the FCC requires was published. Since European hams don't normally read FCC regulations, it might be useful for the IARU or RSGB to publish an article about U.S. regulations so this doesn't happen again. 73, John KD6OZH - Original Message - From: Leigh L. Klotz, Jr WA5ZNU le...@wa5znu.org To: digitalradio@yahoogroups.com Cc: Andy obrien k3uka...@gmail.com Sent: Tuesday, March 02, 2010 02:53 UTC Subject: Re: [digitalradio] FCC comments further on ROS On 03/01/2010 04:06 PM, Andy obrien wrote: Thank goodness sanity has prevailed! Try Hamspots, PSKreporter, and K3UK Sked Page http://www.obriensweb.com/skedpskr4.html Suggesting calling frequencies: Modes 500Hz 3583,7073,14073,18103, 21073,24923, 28123 . Wider modes e.g. Olivia 32/1000, ROS16, ALE: 14109.7088. Yahoo! Groups Links * To visit your group on the web, go to: http://groups.yahoo.com/group/digitalradio/ * Your email settings: Individual Email | Traditional * To change settings online go to: http://groups.yahoo.com/group/digitalradio/join (Yahoo! ID required) * To change settings via email: digitalradio-dig...@yahoogroups.com digitalradio-fullfeatu...@yahoogroups.com * To unsubscribe from this group, send an email to: digitalradio-unsubscr...@yahoogroups.com * Your use of Yahoo! Groups is subject to: http://docs.yahoo.com/info/terms/
Re: [digitalradio] What is SS?
The document that the author of ROS originally published, Introduction to ROS: The Spread Spectrum, contains a good description of frequency-hopping spread-spectrum (FHSS) techniques. Section 4 describes taking a 250 Hz wide mode (MFSK16) and spreading it over 2 kHz by shifting the center frequency in a pseuorandom sequence. The receiver changes frequencies in the same sequence and the logic used to detect a special tone sequence to obtain synchronization is described in section 5. The amount of spectrum occupied increases by a factor of 8. FHSS is one way to minimize the effects of multipath spread but there are also other techniques that occupy less spectrum. Note that the author of ROS published a second doucument,ROS Technical Description, that contains elements of the original but does not mention FHSS and omits any description of how data is mapped to tones. Users comparing the original and later versions of the code haven't seen a difference in the transmitted spectrum. 73, John KD6OZH - Original Message - From: Rein A To: digitalradio@yahoogroups.com Sent: Friday, March 05, 2010 19:16 UTC Subject: [digitalradio] What is SS? Here is a reprint that for my limited mental capacities defines the core quite well. I have asked Mike the author for some references, no lack of trust though. - -Original Message- From: n4qlb n4...@... Sent: Mar 5, 2010 1:15 PM To: rosdigitalmodemgr...@yahoogroups.com Subject: [ROSDIGITALMODEMGROUP] Re: How do you like ROS Now? Thank You for your comments Sig. Let me explain what SS is. Spread spectrum is a method by which a bank of channels (Frequencies)are designated between a Transmitter and Receiver and are shared or (Frequency Hopped) to facilitate a clear Transmisson. The Transmitter actually signals the Receiver to Hop from one frequency to another. A good example is a 900mhz digital cordless telephone or a 800Mhz digital radio truncking system. (Motorla Astro). A frequency in Ham radio consist of a 3kh wide channel. Ros does not signal a receiver to hop outside of that channel (3 Khz) therefore it is not SS and is just like anyother FSK mode used in the amatuer radio service. The ease of obtaining a License in the U.S. by people that are not technically qualified to hold one is the main culprit regarding the controversy over new modes such as ROS. I am confident that all variations of ROS are perfectly legal in the U.S.
Re: [digitalradio] A question about spread spectrum
The HSMM working group never proposed the use of spread spectrum. It was interested in getting the maximum data rate into limited bandwidths. SS does the opposite of what the HSMM WG was interested in. It spreads limited amounts of data over the maximum bandwidth. The actual proposal was to create small segments in the 80, 40, 20 and 15 meter bands for emissions up to 16 kHz wide -- matching what existed in the 10 meter band but on a much smaller scale. Many of us wanted that limited to 9 kHz -- the same as the ARRL allowed for AM. The goal was to preserve the priveledges that currently exist in the phone/image segments (AM equivalent bandwidth) as the ARRL was shrinking bandwidths in the RTTY/data segments (currently unlimited bandwidth). 73, John KD6OZH - Original Message - From: KH6TY To: digitalradio@yahoogroups.com Sent: Saturday, March 06, 2010 14:01 UTC Subject: Re: [digitalradio] A question about spread spectrum The other possible problem is wide-spreading spread spectrum. There was a failed attempt about 5 years ago by the ARRL HSMM (High Speed Multi-Media) proponents to allow spread spectrum on the HF bands with the argument that the signal is spread so widely, each carrier appears at any given frequency only a short time, so it would not significantly interfere with other users of the frequency, and could, for example, be allowed to cover the entire 20m band.
Re: [digitalradio] Re: 1976 FCC - Delete all Emission Types from Part 97
I assumed that people kept using FSK because paths to Europe can have 20-30 Hz of Doppler spread. 73, John KD6OZH - Original Message - From: KH6TY To: digitalradio@yahoogroups.com Sent: Tuesday, March 09, 2010 19:08 UTC Subject: Re: [digitalradio] Re: 1976 FCC - Delete all Emission Types from Part 97 It is probably all of these things that keeps PSK63 from replacing RTTY for contesting, as well as there being no need for an interface since most transceivers have FSK built in these days. That is my best guess anyway. 73 - Skip KH6TY
