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FCC: Lazy Or Just Lackadaisical? (Part 1)

February 26th, 2010 |

I hate to use a Cavuto-style question as a blog title, but to borrow a Beckian phrase this week I'm feeling like the "question needs to be asked".

Here's an inquiry to the FCC that was posted on the digitalradio 'flector regarding the new ROS rigital rode:

Summary* : Request for clarification of new amateur radio digital mode

Description* : Within the past week, a new digital mode - called ROS - has surfaced on the HR amateur bands. Its creator refers to it as spread spectrum, but there is some debate over whether the mode truly represents spread spectrum as defined by the FCC. I am writing to request a review of the creator's documentation, which I have attached, and a formal ruling on whether this mode is legal for use below 222 mHz by licensed U.S. amateurs. It would be very helpful if the FCC, upon completion of this review, would distribute a public announcement of its determination to appropriate amateur radio and media outlets. Thank you very much in advance for your time and prompt attention to this request. I look forward to hearing from you soon.

Sincerely,

Timothy J. Lilley - N3TL

And here's the response from the FCC:

Solution Details : Dear Mr. Lilley,

Section 97.305 is the rule that specifies where different emission types are allowed to be transmitted on different bands. "ROS" is viewed as "spread spectrum," and the creator of the system describes it as that. We assume that he knows what he created. 97.305 authorizes spread spectrum emission types (defined in Section 97.3) to be transmitted by FCC licensed amateur stations at places we regulate communications only on 222-225 MHz and higher frequency amateur bands. European telecommunication regulatory authorities may authorize amateur stations in Europe to use SS on the HF bands, but this is of no concern to us. The Commission does not determine if a particular mode "truly" represents spread spectrum as it is defined in the rules. The licensee of the station transmitting the emission is responsible for determining that the operation of the station complies with the rules. This would include determining the type of emission the station is transmitting and that the frequencies being used are authorized for that type of emission.

Should you have any further questions, or need additional information, please contact the ULS Customer Support Hotline at (877) 480-3201, selecting option 2.

Sincerely,

Agent 3820

I'm guessing "option 2" routes the caller to an endless audio loop that says "I don't know, you figure it!" or "Sucks to be you! Ha ha ha!". But seriously, how lame is this answer from secret agent 3820? So the FCC just takes for granted whatever the developer determines the mode actually is? I'm sure that they wouldn't take that position in an enforcement case. However, if that's how they roll, I'm developing a new mode that is a digital micro-powered voice communication mode that is Part 15 compliant. It's actual AM running at 100kW, but with my newly developed method of measuring power for this special mode, it's really 1 mW. It says so in the documentation and being the developer of the mode, I should know. What's that? FCC enforcement officers at the door? Tell them to go pound sand! I'm responsible for determining if my emissions comply with the rules, not them. And I live in the Republic of Texas where their laws don't apply. (I redrew the map on my wall.)

I keep asking myself if this whole ROS emissions issue is a hoax. Maybe I'm getting less trustworthy in my old age, but honestly if this was April 1 I'd being laughing instead of sighing.

Part 2 of this series will hopefully be coming out tomorrow. By the way, kudos to N3TL for asking the FCC for an official ruling. At least he tried. I'm going to submit an inquiry in to the FCC Kids Zone. Perhaps Broadband the Cat will release an official ruling.

UPDATE: Now there's an article by N3TL on the 'zed regarding this issue and there's a similar inquiry going on now with CHIP64.

Run ROS, Go Directly To Jail (Do Not Collect QSL Card)????

February 25th, 2010 |

Author: Anthony K3NG

There's been a ruckus over the new ROS digital mode going on in radio amateur blogademia and on radio ramateur reflectors. (Rut-ro!) Apparently ARRL has advised someone that ROS is spread spectrum and therefore is illegal below 222 Mhz in the US. The manual for ROS describes it as "a digital communications software based on a FSK modulation of 144 tones".

I haven't been able to find any ARRL article or official statement on it, however this supposed communication from ARRL was posted on the digitalradio reflector:

"From: Henderson, Dan N1ND
Subject: RE: Spread Spectrum
To: [deleted for privacy]
Date: Tuesday, February 23, 2010, 7:13 AM

Hi Fred:

I ran this by our technical experts. They concur that ROS is a spread spectrum mode and as such is not allowed by the FCC on bands below 222 MHz. Remember that approved emissions vary from IARU Region at times as well as between countries. So while the IARU Band Plan for Region 2 would allow it, SS is not permitted on the HF bands by the FCC/

Thanks and 73

Dan Henderson, N1ND
Regulatory Information Manager
ARRL, the national association for Amateur Radio™ "

But is ROS really spread spectrum? Just what is spread spectrum? Let's ask our friend, Part 97.

§97.3(c)
(8) SS. Spread-spectrum emissions using bandwidth-expansion modulation emissions having designators with A, C, D, F, G, H, J or R as the first symbol; X as the second symbol; X as the third symbol

That's incredibly vague, but basically spread spectrum is taking a signal and spreading out its bandwidth in order to improve interference immunity and/or obscure the intelligence. There are two primary methods, direct sequence and frequency hopping. With direct sequence the intelligence is mixed with a pseudo-random bit sequence at transmit and demodulated in the receiver with the same pseudo-random sequence. With frequency hopping, the signal simply rapidly hops around a predetermined band. Apparently it's assumed that ROS is frequency hopping spread spectrum.

One key difference I see between ROS and commonly accepted frequency hopping spread spectrum systems is that there's no modulation on the ROS carriers. The intelligence in a frequency hopping spread spectrum system is not determined by the frequency of the carrier at any given moment, it's determined by the modulation on the carrier itself. (OK, if you're using QAM modulation there is a frequency modulation component, but that's totally independent of the frequency hopping.) In ROS the intelligence is carried by the frequency of the carrier in time. The only difference between ROS and MKSK, besides the symbol rate and bandwidth is that ROS has only one tone on at a time and MFSK can have multiple. But let's assume for a moment that ROS is frequency hopping spread spectrum. RTTY also frequency hops. It hops between two frequencies. This hopping does expand the bandwidth, so therefore using this same interpretation that has been applied to ROS, RTTY is also spread spectrum and therefore it is illegal below 222 Mhz.

I hope ARRL realizes that ROS is frequency shift keying and not spread spectrum and reverses this initial finding. We need to have common sense prevail and not turn this into another unnecessary rule interpretation quagmire like the whole emcomm and employers issue has become. If ROS stays within the bandwidth allowed for other HF digital signals, what does it matter? Let's use it and move on.

Hot news: ROS digital mode illegal in USA

February 23rd, 2010 |

Author: Julian G4ILO

Hot from the K3UK Sked page. “Breaking news from ARRL. They concur that ROS is a spread spectrum mode and as such is not allowed by the FCC on bands below 222 MHz.”

I had just been giving ROS another try with my K3 and 40W this time, and managed to complete contacts on 20m with Alabama and Washington State. Neither of these are locations I would expect to work under current conditions using another mode. As soon as the announcement was posted on the site it all went quiet.

My sympathies to my fellow digimode enthusiasts in the USA. It has always struck me as ironic that hams in the land of the free have to operate under more rigid controls than those of us in “socialist” Europe.

ROS – the chaos continues

February 23rd, 2010 |

Author: Julian G4ILO

Attempts to use the newly developed ROS weak signal mode are resulting in more chaos and frustration this morning as an increasing number of people pile on to the same frequencies. And attempts to decide frequencies to use with the mode seem to indicate total ignorance of other band users and modes. The latest list of recommended frequencies includes:

7.040 – which is going to interfere with the now long-established WSPR weak signal mode
10.140 – which will also interfere with WSPR’s established frequency on that band
14.100.9 – which does not avoid the long established 24/7 packet network which has already complained about interference by this mode, and is also within the range reserved for beacons.

There are a total of three frequencies suggested for 30m, in ignorance of the fact that 30m is supposed to be used only for narrow band modes.

Someone responded to my earlier comment that a body like the IARU should decide which modes can work where, by saying that the IARU does not recommend frequencies for specific modes as that would interfere with experimentation. However I still think they should. When left to individual amateurs you simply get a fight between one group of people who don’t have a clue and another group, users of existing modes, who have strong views about where they should NOT go. Without some overseeing arbitrator this will just end up as a mode war.

I think it is arguable that there just isn’t room for a 2.2KHz wide weak signal mode on the HF bands at all. But if true, who is going to make that decision?

February 23rd: U.S. Amateur Radio Liberation Day

February 22nd, 2010 |

Author: Anthony K3NG

On February 23rd 2007, amateur radio in the U.S. was liberated from the tyranny of a minority of radio amateurs. They said amateur radio would be destroyed. The foundations of amateur radio were being dismantled, eliminating all that was good and wholesome, ruining decades of innovation and service. Hiram would be turning over in his grave. Cats would be sleeping with dogs. Rupaul would be sleeping with women. The bands would be silent as a long cherished traditional would be outlawed. The CBers would be dancing in the streets and invading our bands, polluting and pillaging our precious frequencies. Old men would have to talk about something other than the early dinner specials at Dennys. It was a grim and apocalyptic picture they painted in those days leading up to the great event.

So celebrate this February 23rd, U.S. Amateur Radio Liberation Day, a most joyous amateur radio holiday, by operating CW....not because someone made you take a test, but because you enjoy it.

3830 Claimed Scores | 2010 ARRL International DX CW | International Low Power

February 22nd, 2010 |

Author: Scot KA3DRR

Single Operator All Band.

J88DR (G3TBK) | 3423 Qs | 261 Mults | 34hrs13mins | 2,677,860 Points [Chiltern DX Club].
LU5FF | 2115 Qs | 233 Mults | 29hrs | 1,477,686 Points [LU Contest Group].
P40LE (K2LE) | 1267 Qs | 224 Mults | 15hrs | 851,428 Points [OBONY].

n = 21 scores submitted in this category.

Multi-Single.

C6AWL | 4199 Qs | 309 Mults | 48hrs | 3,892,473 Points.
5W0OU | 2339 Qs | 250 Mults | 48hrs | 1,754,250 Points [WVDXC].

n = 2 scores submitted in this category.

A thank you to each international low power operator who populated North American logs this weekend. This was a stoked event especially when 100-watt stations were logged inside shackadelic. How about 10 meters? One can accomplish the RadioSport impossible within this spectrum space.

Congratulations Dave Cree, G3TBK who operated J88DR to a 3830 Top Score and for providing a new DXCC counter as well.

73 from the shackadelic on the beach.

3830 Claimed Scores | 2010 ARRL International DX CW | North America Low Power

February 22nd, 2010 |

Author: Scot KA3DRR

US | VE Single Operator All Band.

N4YDU | 1942 Qs | 330 Mults | 41hrs | 1,922,580 Points [PVRC].
N9CK | 1768 Qs | 335 Mults | 34hrs | 1,772,820 [SMC].
VE9DX | 1580 Qs | 317 Mults | 1,502,580 Points.

n = 97 scores submitted in this category.

US | VE Multi-Single.

N7DS (@NE7D) | 466 Qs | 164 Mults | 25hrs38mins | 228,780 Points [WVDXC].

n = 1 scored submitted in this category.

Cycle 24 provided an activity stimulus package this weekend surprising some and pleasing many. It’s not the peak for sure however the long sunspot recession is finally over. Event numbers suggest phenomenal effort and stellar returns within all categories.

Nathan Moreschi, N4YDU leads the low power pack before log adjudication and he is one to watch as an emergent RadioSport athlete. His station configuration is definitely low power Box potential. Congratulations Nathan on a job well done while leading the Potomac Valley Radio Club, to yet, another banner week.

Low power multi-single remains as a category waiting for a few innovators. I would venture to say it is under capitalized with lots of great opportunity for the future of RadioSport.

Believe in your signal!