As I previously predicted, an FCC agent has
interpreted FCC Rules, saying ROS is Spread Spectrum.
ARRL staff have also done the same.
In the FCC response to an inquiry
initiated by Timothy J. Lilley - N3TL,
The FCC Agent 3820 stated this:
ROS is viewed as spread spectrum, and the creator
of the system describes it as that. We assume that
he knows what he created.
That statement by FCC Agent 3820 is all any ham
in USA needs to know. Use ROS on HF, and you risk
fines for breaking the FCC Rules.
There is now only 4 options, for USA hams who still
want to use ROS on HF bands:
1. Operate ROS... knowing that you are breaking the
FCC Rules, and roll the dice, hoping you don't get caught.
2. Go on an uphill battle to change the FCC Rules, and
possibly win or lose after a year or more of legal work.
3. When the FCC sends you an enforcement letter
Notice of Apparent Liability, and asks you to
show cause or risk citation and/or payment
of fine, simply tell the FCC please forgive me,
I didn't know it is illegal to use Spread Spectrum
on HF, and honestly I won't do it again.
Several years ago, I started writing about how hams
in USA are falling behind in technology due to
antiquated FCC rules. I pointed to several excellent
modes and methods of operation that USA hams don't
have the freedom to use, but hams in most other countries
are at liberty to use. This situation is all due to
FCC rules that were forged in the 20th century and
based upon old methods of using radio.
Boxed-in by early limitations, there is no way to
think out of the box. Some hams laughed and said:
PSK31 and RTTY is all we need; why should we care?
Why should we want to use any new modes?
Well, USA hams... Welcome to our Technology Jail!
Best Wishes,
Bonnie Crystal KQ6XA
22 Feb 2010, KQ6XA wrote:
Given the fact that ROS Modem has been advertised as Frequency Hopping Spread
Spectrum (FHSS), it may be quite difficult for USA amateur radio operators to
obtain a positive interpretation of rules by FCC to allow use of ROS on HF
without some type of experimental license or waiver. Otherwise, hams will
need an amendment of FCC rules to use it in USA.
Sadly, this may lead to the early death of ROS among USA hams.
If ROS Modem had simply provided the technical specifications of the
emission, and not called it Spread Spectrum, there would have been a chance
for it to be easily adopted by Ham Radio operators in USA.
But, the ROS modem designer is rightfully proud of the design, and he lives
in a country that is not bound by FCC rules, and probably had little or no
knowledge of how his advertising might prevent thousands of hams from using
it in USA.
But, as they say, You cannot un-ring a bell, once it has been rung.
ROS signal can be viewed as a type of FSK, similar to various other types of
n-ary-FSK presently in widespread use by USA hams. The specific algorithms
for signal process and format could simply have been documented without
calling it Frequency Hopping Spread Spectrum (FHSS). Since it is a narrowband
signal (using the FCC and ITU definitions of narrowband emission = less than
3kHz) within the width of an SSB passband, it does not fit the traditional
FHSS description as a conventional wideband technique.
It probably would not have been viewed as FHSS under the spirit and intention
of the FCC rules. It doesn't hop the VFO frequency. It simply FSKs according
to a programmable algorithm, and it meets the infamous 1kHz shift 300 baud
rule.
http://www.arrl.org/FandES/field/regulations/news/part97/d-305.html#307f3
This is a typical example of how outdated the present FCC rules are, keeping
USA hams in TECHNOLOGY JAIL while the rest of the world's hams move forward
with digital technology. It should come as no surprise that most of the new
ham radio digital modes are not being developed in USA!
But, for a moment, let's put aside the issue of current FCC prohibition
against Spread Spectrum and/or Frequency Hopping Spread Spectrum, and how it
relates to ROS mode. Let's look at bandwidth.
There is the other issue of bandwidth that some misguided USA hams have
brought up here and in other forums related to ROS. Some superstitious hams
seem to erroneously think that there is an over-reaching bandwidth limit in
the FCC rules for data/text modes on HF that might indicate what part of the
ham band to operate it or not operate it.
FACT:
There is currently no finite bandwidth limit on HF data/text emission in USA
ham bands, except for the sub-band and band edges.
FACT:
FCC data/text HF rules are still mainly based on content of the emission,
not bandwidth.
New SDR radios have the potential to transmit and receive wider bandwidths
than the traditional 3kHz SSB passband. We will see a lot more development in
this area of technology in the future, and a lot more gray areas of 20th
century FCC rules that inhibit
