Skip Do you really think the FCC will put that much effort into this? They really want amateur radio to be self regulating. I think that people who bother the comish with such trivia degrades the hobby. When the administration of our activities become too burdensome, the FCC will be less inclined to support it. I can not see them using valuable engineering time on this.
What the FCC stated was that based on the documentation, the developer claimed it was SS but it was up to the individual amateur to make the determination. They made no ruling or determination, just a carefully worded opinion of a staff member. Part of holding a license is being able to determine which operation is legal. The same thing came up over digital repeaters a few years ago. 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. From: KH6TY <kh...@comcast.net> Reply-To: <digitalradio@yahoogroups.com> Date: Sat, 27 Feb 2010 09:58:58 -0500 To: <digitalradio@yahoogroups.com> Subject: Re: [digitalradio] Re: There is a pattern in the ROS signal when idling Thanks for the clarification, Rein. That agrees with what Steinar sees, and with the Wikipedia discussion, which says in part, "Most pseudorandom generator algorithms produce sequences which are uniformly distributed </wiki/Uniform_distribution_%28discrete%29> by any of several tests. It is an open question, and one central to the theory and practice of cryptography </wiki/Cryptography> , whether there is any way to distinguish the output of a high-quality PRNG from a truly random sequence without knowing the algorithm(s) used and the state with which it was initialized." The differentiating factor in FHSS is apparently whether or not the data is superimposed on the carriers, or if the carrier frequencies are determined by the data. I cannot see that happing in ROS, and I can in all the FSK modes, but maybe I just do not know how to find it for sure. I guess the FCC engineers will probably figure out if ROS is actually spread spectrum as originally claimed, or FSK with FEC as now claimed. It is just hard to imagine that someone as intelligent and capable as Jose could make such a huge mistake after writing seven pages of text and diagrams describing the mode the first time! No wonder the FCC believed him! Will they now believe him, or will they believe that the so-called "technical description" now on the ROS website is just an attempt to get ROS considered legal on HF? Probably they will believe only their own tests now, so we will have to wait for those. The FCC does not care about the "mode", or what it is called, but only what is transmitted on the air. 73 - Skip KH6TY pa0r wrote: > > > > SS uses pseudorandom codes to wag the carrier(s). > EVERY pseudorandom code is repetitive, the length may vary. > > 73, > > Rein PA0R > > --- In digitalradio@yahoogroups.com <mailto:digitalradio%40yahoogroups.com> , > KH6TY <kh...@...> <mailto:kh...@...> wrote: >> > >> > That's a good analysis, Steinar. Is it possible to see if the pattern >> > changes when sending data? That is all the FCC is concerned about. The >> > pattern has to change when sending data and not just remain the same to >> > exclude it from being FHSS. >> > >> > 73 - Skip KH6TY >> > >> > >> > >> > >> > Steinar Aanesland wrote: >>> > > >>> > > [Attachment(s) <#TopText> from Steinar Aanesland included below] >>> > > >>> > > Hi Skip >>> > > >>> > > I have been monitoring a ROS idling over time using DL4YHF's Spectrum >>> > > Lab. Here is the results.You can clearly see a pattern >>> > > >>> > > 73 de LA5VNA Steinar >>> > > >>> > > On 26.02.2010 12:29, KH6TY wrote: >>>> > > > Alan, >>>> > > > >>>> > > > Of course, the FCC rules on SS are outdated and ROS should be allowed >>>> > > > due to its narrow spreading range, but the road to success is not to >>>> > > > just rename a spread spectrum modem to something else and try to fool >>>> > > > the FCC. This is a sure way to lose the battle. The genie is already >>>> > > > out of the bottle! >>>> > > > >>>> > > > Instead, just petition the FCC for a waiver, or amendment, to the >>>> > > > regulations that are a problem, to allow FHSS as long as the >>>> spreading >>>> > > > does not exceed 3000 Hz and the signal is capable of being monitored >>>> > > > by third parties. Do this, and there is not a problem anymore. But, do >>>> > > > not try to disguise the fact that FHSS is being used by calling it >>>> > > > something else, as that undermines the credibilty of the author of the >>>> > > > mode and will make the FCC even more determined not to it on HF/VHF. >>>> > > > >>>> > > > It looks to me that the tone frequencies are clearly being generated >>>> > > > independently from the data and then the data applied to the randomly >>>> > > > generated frequency. There is NO pattern to ROS like there is to FSK >>>> > > > modes, even to 32 tone FSK (Olivia 32-1000) or to 64 tone FSK >>>> > > > (MT63-2000). This is a signature of FHSS. >>>> > > > >>>> > > > “/If/ it walks /like a duck/, quacks /like a duck/, /looks like a >>>> > > > duck/, it must be a /duck/‡. >>>> > > > >>>> > > > It looks like ROS really is FHSS when you look at it on a spectrum >>>> > > > analyzer, and the spectrum analyzer does not lie. >>>> > > > >>>> > > > 73 - Skip KH6TY >>>> > > > >>>> > > > >>>> > > > >>> > > >>> > > >> > > > >
