When a regulation is based on a vague phrase like using bandwidth-expansion
modulation emissions, the FCC should *expect* to hear from amateurs trying
to determine whether or not a mode is legal. There are certainly many
situations where amateurs can indeed be expected to sort it out
themselves; this isn't one of them.
73,
Dave, AA6YQ
-Original Message-
From: digitalradio@yahoogroups.com [mailto:digitalra...@yahoogroups.com]on
Behalf Of W2XJ
Sent: Tuesday, July 13, 2010 4:35 PM
To: digitalradio@yahoogroups.com
Subject: [digitalradio] Re: [digital radio] Re: Random data vs Spread
Spectrum
The creator of ROS does not present himself as a very nice or honest person
but I also believe there are cultural and language issues that add to the
problem. Before all this started several months ago, I did not believe the
initial presentation that it was really spread spectrum but rather something
written by someone with a bad grasp of the English language.
That being said, Skip, you are also misrepresenting the situation by stating
the FCC made an analysis. Read the documentation and it is clear they made a
fairly non committal statement based on the published material. The FCC
does not like being involved in such matters. This is like the Dstar
controversy a few years back when an FCC official publicly told hams at
Dayton that if they were qualified to hold a license they should be able to
sort it out themselves. The commission will not do the thinking that hams
themselves should be doing for them selves. Please keep the sandbox fights
away from the FCC it will ultimately destroy the hobby. With the hunt for
more spectrum to sell be careful or there may not be any frequencies above
222 MHZ to even worry about spread spectrum.
On 7/13/10 3:23 PM, KH6TY kh...@comcast.net wrote:
Rein,
I said I would not comment further on ROS, but look at it in perspective.
The author defined ROS as spread spectrum and produced a two page document
to that effect. He is the only one who knows for sure if it is spread
spectrum or not.
When it was posted that spread spectrum was not legal below 222 Mhz, he
conveniently (for his benefit) tried to redefine ROS as FSK, in an apparent
attempt to change the FCC opinion, which originally was based on his own
two-page declaration, which he wanted us to believe.
The FCC then made their own analysis and concluded it was not FSK but
truly spread spectrum. This was communicated to us by the ARRL as is usually
the case.
The author, if he would have disclosed his code, could have proven
whether or not the randomization is for spread spectrum purposes or for
some other reason, but he steadfastly refused to disclose the code, which
would either have resulted in it being OK for us to use, or prove it was
truly FHSS. Perhaps he decided to try and bluff the FCC because it would be
determined, on the basis of his code, to really be FHSS, in agreement with
his first description, and in disagreement with the second description he
wrote, obviously just to try to get approval.
It is just not reasonable to think that a person of his ability, as the
author of the software, could make such a huge mistake in his first
characterization of
ROS as spread spectrum and then completely revise the characterization as
something else which he knew would be usable by US hams.
You can imagine how the FCC feels about that attempted deception, and to
top it off, he posts a phoney statement of FCC approval besides! I seriously
doubt that the FCC is going to want to revisit the question, since the
author simply cannot be believed. I met Dan Henderson at a hamfest right
after all this happened and he had been in contact the FCC, and opined that
it was highly doubtful that any further reconsideration would be done.
The ONLY way for us to ever use ROS on HF is to petition the FCC to amend
the rules to allow limited spread spectrum below 222 Mhz, citing enough good
reasons why it will not harm existing operations of lesser bandwidth.
Instead of constantly arguing that the FCC made a mistake, or we should
interpret the rules as we wish they were, I suggest that either a petition
be filed, or the code released to prove the author's contention that it is
not spread spectrum. Of course the submitted code would have to be
recompiled and tested to prove it is really the original code, and another
attempted deception by the author.
Understand that I am NOT against ROS, and never have been, even though I
strongly dislike the author's behavior and suspect his motives. I would keep
using it on HF if it were legal for me to do so. I do respect the FCC
regulations, even those that I do not like, and follow them as best I can,
because in the overall picture, they protect the weak from the strong for
the benefit of everyone, until revised in a non-harmful way.
This will be my (final) final word on this subject, so please do not ask
me to comment any further.
If you want
