ROS and CHIP deemed illegal below 222 mHz for U.S. amateurs

Discussion in 'Amateur Radio News' started by N3TL, Feb 25, 2010.

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  1. N3TL

    N3TL Ham Member QRZ Page

    It appears as though neither ROS or the older CHIP digital modes are legal for use below 222 mHz by licensed U.S. amateurs.

    On 23 February, 2010, an email was shared on various Web sites in which Dan Henderson of the ARRL reported that the League’s technical staff had determined that the new ROS mode did, indeed, include spread spectrum technology and, as a result, was illegal for use below 222 mHz by licensed U.S. amateurs.

    As a result of that email, I contacted the FCC and formally requested a review of ROS. Here is the full text of my request and the FCC’s response:

    The case you submitted via the FCC has been resolved. The resolution details for Case ID HD0000001311853 are below.

    If you have any questions contact us at (877) 480-3201.

    Thank You!

    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
    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


    On 25 February, 2010, I contacted Mr. Henderson and requested a review of the CHIP mode by the ARRL technical staff. Here is the complete text of that request and Mr. Henderson’s response, which appears first:


    Hi Tim

    We read the information and reviewed the CHIP64 information yesterday and have come to the same place as with ROS - it is spread spectrum and isn't legal below 222 MHz.

    Thanks and 73



    Dan Henderson, N1ND
    Regulatory Information Manager
    ARRL, the national association for Amateur Radio™
    860-594-0236
    dhenderson@arrl.org





    ________________________________________
    From: Tim - N3TL [mailto:n3tl@bellsouth.net]
    Sent: Thursday, February 25, 2010 12:03 PM
    To: Henderson, Dan N1ND
    Subject: Request for technical review
    Importance: High
    Mr. Henderson,

    In light of your recent actions to have ARRL technical staff review the new ROS mode for legality below 222 mHz for licensed U.S. amateurs, I am writing to formally request a similar review by ARRL technical staff of the CHIP mode. To help in that review, I am attaching the PDF document that the mode’s creator - Antonio Porcino, IZ8BLY – currently has posted on his Web site for the mode.

    Based on the FCC response to my inquiry about ROS on Feb. 23rd, it seems clear to me that the CHIP mode also is illegal for use below 222 mHz by licensed U.S. amateurs. As the FCC agent noted in that response, “’ROS’ is viewed as ‘spread spectrum,’ and the creator of the system describes it as that. We assume that he knows what he created.”

    In the attached document, Mr. Porcino clearly and inarguably refers to the CHIP mode as spread spectrum. As a result, it seems to me that if ROS is illegal for U.S. amateurs below 222 mHz, then CHIP also is.

    For that reason, I am asking you to take the same steps with ARRL technical staff that you took earlier this week regarding ROS. I am interested to learn whether the League’s technical staff concurs with the mode’s creator that it is, indeed, using spread spectrum technology. If the answer is no, then I further request a clear explanation of why ROS is SS and CHIP is not.

    Please contact me at your convenience if you have any questions or need additional information. I look forward to hearing from you.

    73,

    Timothy J. (Tim) Lilley – N3TL
    ARRL Member No. 0007027180

    Attachment


    Based on the language of the FCC response, I see no need to seek a similar review of CHIP from the Commission. It makes clear that the FCC assumes that software developers know what they created, and the creator of CHIP clearly describes it in the PDF available on his Web site as using spread spectrum technology.

    I believe it important to share this information with the amateur community. I thank Mr. Henderson and the ARRL – and the FCC – for prompt responses to my requests.

    73,

    Tim – N3TL
     
  2. AD7N

    AD7N Ham Member QRZ Page

    Below is a copy of the technical description, as posted on the program's website.

    I should note Agent 3820 did not rule conclusively that ROS is spread spectrum unequivocally. He included in his letter:

    The FCC also did not disclose how they reached their conclusion. Was it merely a glance at the provided documents? Did they do extensive spectral analysis? The text outlined in red above simply emphasizes that the FCC is giving a "hands off" approach to this issue. I say the issue is a delicate one ,involving a close examination of the exact algorithm used

    Below is text from the currently available technical description found on the program author's site under "ROS Technical Description v1.0″

     
  3. XV4TUJ

    XV4TUJ Ham Member QRZ Page

    What about HamDRM

    Hi.

    I don't precisely know the technology under ROS/CHIP, but given the description it is similar to HamDRM which use COFDM multiplex.
    Does someone know how is considered this transmission mode by ARRL ?

    73,
    Yan - XV4TUJ.
     
  4. K5OKC

    K5OKC Ham Member QRZ Page

    OFDM is legal in the USA on HF. ROS is legal, because it is MFSK. CHIP64 is legal, because the RF is n't spread-spectrum, only the audio uses a spread-spectrum technique.
     
  5. XV4TUJ

    XV4TUJ Ham Member QRZ Page

    Agree

    Hi K5OKC.

    I agree with you, it is audio spread spectrum not baseband spread spectrum. The modulation by itself is still SSB.
    The problem could be when people don't set their AF gain in a good manner creating splatter because of an overdriven PA.
    But this also occurs in phone SSB sometime... (I have some "neighbours" wasting 10KHz when they turn on their 1kw amplifier).

    73,
    Yan.
     
  6. N3TL

    N3TL Ham Member QRZ Page

    KE7HQY wrote: "Below is a copy of the technical description, as posted on the program's website."

    The ORIGINAL technical document carried this Title:
    “INTRODUCTION TO ROS: THE SPREAD SPECTRUM”

    Further that document included this statement: “ROS uses a Spread Spectrum technique known as Frequency-hopping spread spectrum (FHSS).”


    If KE7HQY – or anyone else reading this – cares to email me (address is good on my page here at QRZ.com), I will gladly provide a copy of that ORIGINAL technical description of the mode, which Jose removed from his Web site after the ARRL and FCC weighed in on ROS a few days ago.


    Further, please note the following from the first page of the description of CHIP64 provided by its creator, Antonino Porcino, IZ8BLY, on the Web site he created for that mode: "Chip64 uses the so called Direct Sequence Spread Spectrum (DSSS)."

    KE7HQY wrote: "The FCC also did not disclose how they reached their conclusion."
    I respectfully disagree. Please read again this comment from the text of the FCC response:
    "'ROS' is viewed as 'spread spectrum,' and the creator of the system describes it as that. We assume that he knows what he created."


    I posted this information to QRZ.com because:

    1 - FCC rules obligate licensed U.S. amateurs to operate a station that complies with the rules.

    2 - That compliance includes responsibility for determining that the frequency in use is legal for U.S. amateurs, and that the mode transmitted on that frequency is legal for use on that frequency by U.S. amateurs.

    3 - FCC rules outlaw the use of spread spectrum modes below 222 mHz.

    4 - The creators of ROS and CHIP specifically refer to them - or have referred to them - as using spread spectrum technology.

    Because of Nos. 1 and 2 above, I consider it my responsibility to operate the N3TL station within the FCC rules, and to make sure the modes I transmit are legal for use on the frequency I choose.

    Each of us must decide whether ROS or CHIP is legal for us to use in transmissions from our respective stations on frequencies below 222 mHz.

    Because of the information I have obtained over the past week from the FCC and the ARRL, I am not operating ROS or CHIP below 222 mHz here at the N3TL station. When it comes to potentially risking my amateur license, I choose to err on the side of caution.

    That is MY choice. YOUR choice may differ, and you are entitled to it.

    73 to all,

    Tim - N3TL
     
  7. N3TL

    N3TL Ham Member QRZ Page

    I encourage you to contact the ARRL and FCC with this, and formally request further review of their previous decisions.

    I have nothing against either ROS or CHIP. On the contrary, I wish the modes - especially ROS - were legal for HF use in the U.S. I started this post only to assure that U.S. amateurs had this information from the ARRL and the FCC as they decided whether to use either mode below 222 mHz at their stations.

    Again, I encourage you (or anyone who shares your view) to do what I did - contact the ARRL and FCC, and formally request further review of their determinations.

    73,

    Tim - N3TL
     
  8. K3NG

    K3NG Ham Member QRZ Page

    As far as I can tell neither ARRL or the FCC did their technical due diligence. They both basically assumed because the ROS creator says the mode is spread spectrum that it is, therefore it's illegal below 222 Mhz. End of story. I can write a specification for a mode that is technically AM and call it CW, but that doesn't make it CW or legal in CW bands.

    ROS is clearly MFSK. With what is commonly accepted as a frequency hopping spread spectrum system, the frequency of a particular hop instance or the hop sequence itself doesn't carry intelligence. With ROS it clearly does. In FHSS the modulation on the hopping carrier carries the intelligence. As far as I can tell, with ROS the carrier itself isn't modulated. Using the same logic that has determined ROS is spread spectrum, RTTY would be considered spread spectrum, too.

    I'm disappointed in ARRL. I am with the FCC as well, however that's been par for the course with them on the technical side of the house for years.

    I think this whole issue is much ado about nothing. If someone uses a digital mode however it modulates, if it stays within a given bandwidth, what does it matter? I know there's been angst over ROS interfering with the beacon network and ROS on ROS QRM, but that's not a function of the modulation.

    If one looks at Part 97, the language on just what is spread spectrum is incredibly vague. I doubt the intent of the language prohibiting SS on frequencies below 222 Mhz was to keep a 2 khz or so wide digital mode off of HF.

    For the record I've never tried ROS and I doubt I will, I just see this as being a technicality fishing expedition that's not going to have any benefit. It's great that we're self-policing and hopefully that will continue for years to come. It's clear from the FCC non-answer that we should probably just let sleeping dogs lie. Perhaps I'm wrong, but I think FCC staffers are out of touch with amateur radio and we need to forge our own path ahead, and avoid involving the FCC wherever possible.

    73
    Goody
    K3NG
     
  9. N3TL

    N3TL Ham Member QRZ Page


    I ask you, sir, to do what I did - contact the League and the Commission; state your case; and formally request review and clarification. A lot of people are offering arguments here and elsewhere concerning the potential legality of ROS, in particular, and CHIP below 222 mHz for U.S. amateurs.

    However, since no one has added, with those arguments, that they intend to present them to either ARRL or the FCC, I can't accept them and change my decision to not operate the modes below 222 mHz.

    We are, indeed, self-policing; but we do not set the rules.

    73,

    Tim - N3TL
     
  10. KD6KXR

    KD6KXR Ham Member QRZ Page

    In the best case, the ROS emission type is SSB using 128 channels to convey data, J7D, which is not a specifically authorized data mode according to Part 97.3(c)(2) of the Rules, so it would not qualify as 97.309(b) unspecified data code, and is 97.307(f)(8) data, only authorized on 1.25m and above by 97.305(c). Based on the description of ROS provided, it appears to be a multiplex emission which could be JXX spread spectrum. However, automatic transmission power adjustment needed to reduce co-channel interference is not addressed as required by 97.311(d), so ROS wouldn't meet the FCC requirements for even that emission type.

    Anyone else read the rules differently?
     
    Last edited: Feb 27, 2010
  11. AB3MV

    AB3MV Ham Member QRZ Page

    MFSK is a signaling technique that uses one of M orthogonal tones to encode one log2(M) bit symbol. In the case of 128FSK, each symbol is log2(128) = 7 bits wide. This symbol width correlates with Jose's claim that he is encoding data using 7-bit Gray codes. However, that explanation only covers 128 of the possible 144 tones that will fit into 2250 Hz. ROS would have to send an additional 16FSK symbol in parallel with the 128FSK symbol to use 2250 Hz of bandwidth.

    OFDM sends data in parallel using multiple carriers. Jose claims to be using 128FSK with continuous phase modulation (CPFSK), which rules out OFDM. His specification has many holes that need to be filled before we can accurately classify the protocol.
     
    Last edited: Feb 27, 2010
  12. K5OKC

    K5OKC Ham Member QRZ Page

    The rules have to be interpreted, and there is some lee-way for error. The bottom line for me, is that the scheme not be used to create privacy. If the protocol allows any ham to monitor the transmission (even if they have to buy a specialized modem), then the scheme is not designed to hide communication.

    Secondly, I think the author screwed-up. I have no idea why he claimed spread-spectrum, other than to confuse people. He seems to be sensitive to people commercializing his invention. Small remarks here and there. I wonder if he was trying to be clever, but then he just confused everybody.

    He calls it 144FSK now. So he is combining 128 data symbols with 16 sync symbols. It is a serial tone modem (11 bits per symbol).

    If I were to whistle into my microphone - low, high, low high - would that be spread-spectrum? If I used a frequency generator and sent 128 tones in serial, would that be spread-spectrum? I don't think so.

    Please: don't call or write the FCC. They have severe manning issues. If you are in doubt, then just don't run the modem. Go do something else.

    My opinion is, this modem is of limited amateur benefit. Not many will use it. I believe other modems are much more powerful in that amount of bandwidth.
     
  13. KD6KXR

    KD6KXR Ham Member QRZ Page

    The ROS mode is decoded by a frequency-domain dFFT, the tone hops around, the relatively low data rate takes up relatively more bandwidth than narrower data modes, there's a time division synchronizing element; I can see how it would scream Spread Spectrum to the ARRL.
     
  14. K5OKC

    K5OKC Ham Member QRZ Page

    When you see your frequency display changing as the modem hops, then you'll know it is frequency hopping spread-spectrum (FHSS).
     
  15. K3NG

    K3NG Ham Member QRZ Page

    RTTY hops between two frequencies, so therefore it's FHSS and illegal below 222 Mhz.

    In CW the carrier is amplitude modulated. Therefore it's AM and you can't use it in the CW bands.
     
  16. K5OKC

    K5OKC Ham Member QRZ Page

    Careful now, you might get everyone to write the FCC for permission to use CW... They might raise their hands for permission to go to the bathroom.
     
  17. AG4CZ

    AG4CZ Ham Member QRZ Page

    There is no specific authorization in Part 97 to use the bathroom. Is it also SS?

    Personally, I think this all boils down to an error in translation by the author. Being bi-lingual, I can see where the author came up with his FHSS while not realizing the technical meaning of the phrase. Moral of this story is mean what you write down.

    AG4CZ -John
     
  18. K3NG

    K3NG Ham Member QRZ Page

    I think I just left a spurious emission.
     
  19. KE4FSL

    KE4FSL Ham Member QRZ Page

    No, it's SR (Spread Rectum) :eek: :D
     
  20. KB4QAA

    KB4QAA XML Subscriber QRZ Page

    1. With all due respect (and tongue in cheek) the gent who asked the FCC for a ruling should be soundly thrashed about the head and shoulders with a rolled up newspaper!

    2. "Never ask a question you don't want to know the answer to". Now we are jammed and can't use the mode on HF.

    3. Nevertheless, I see that the matter is still open for interpretation, seeing as the FCC stated that they did NOT review the technical aspects of the mode, and left it up to the designers statement/judgement. Therefore, the FCC should be equally open to accept Other amateurs judgement who have equal or better education and experience to the designer that the mode is not spread spectrum.

    4. As described so far, this mode is NOT SS. The description makes no mention of shifting the center frequency, retuning the radio etc. It uses no more bandwidth that the majority of ham modes in use today.

    5. To the scopes men, the scopes!
     
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