> 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
