[Lowfer] Looking for 73 kHz band modes to try...

[Charlie , W5COV]

Found this :

**
Solution Details : Dear Mr. Nieto,

As I reported Timothy J. Lilley, the licensee of the station 
transmitting the emission is responsible for determining that the 
operation of the station complies with the rules.

According to the technical paper and the audio file attached, we 
conclude that ROS can not be viewed as Spread Spectrum and it would be 
encompassed within the section 97.309 (RTTY and data emissions codes).

FCC Committee will remain outside of any legal action you decide to take.

Should you have any further questions, or need additional information, 
please contact the ULS Customer Support Hotline at (877) 480-3201 (877) 
480-3201, selecting option 2.
Sincerely,
Agent 3820

**
On 12/5/2013 8:38 PM, jrusgrove at comcast.net wrote:
> It's ROS mode that's involved in the spread spectrum controversy. 
> OPERA mode is simply on off keying.
>
> Jay W1VD  WD2XNS  WE2XGR/2  WG2XRS/2
>
>
> ----- Original Message ----- From: "JD" <listread at lwca.org>
> To: "Discussion of the Lowfer (US, European, &amp;UK) and MedFer 
> bands" <lowfer at mailman.qth.net>
> Sent: Thursday, December 05, 2013 8:06 PM
> Subject: Re: [Lowfer] Looking for 73 kHz band modes to try...
>
>
>>>> Opera is not legal to tx in the US, FCC thinks it is a 
>>>> spread-spectrum mode.
>
> Actually, Cliff, that's what its own, er, inventor called it, way back 
> when.
> Perhaps they took his word for it.  It's not really SS, of course.  It 
> uses
> no energy-spreading techniques; it's merely frequency agile.
>
> But it's still not legal below 50 MHz in the US amateur service for a 
> much
> more fundamental reason...the same reason WSPR and PSK31 and others 
> *do not*
> meet the published Part 97 requirements on HF, either!
>
> In 160m and all relevant segments of the HF bands through 12 meters where
> RTTY and data are permitted by Sec. 97.305, Note 3 of 97.307(f) also
> applies:  "Only a RTTY or data emission using a specified digital code
> listed in §97.309(a) of this part may be transmitted. The symbol rate 
> must
> not exceed 300 bauds, or for frequency-shift keying, the frequency shift
> between mark and space must not exceed 1 kHz."  (At 10m, it's Note 4
> instead, which is exactly the same except for a 1200 baud symbol rate.)
>
> Well, obviously the baud limits and the maximum frequency shift are 
> not the
> problem.  But if you follow on to 97.309(a), you find that there are only
> three coding methods specified for RTTY and data emissions...5-level 
> Baudot,
> AMTOR, and ASCII.  That's all!
>
> Unspecified codes _are_ permitted by Notes 5 and 6, but those notes apply
> only within bands above 50 MHz.  Thus, OPERA and the other aforementioned
> modes are legal up there, with a few restrictions.  And, Part 5 licensees
> are not under the requirements of 97.309(a) at all, so there's 
> presently no
> problem using any of these modes in the US at LF and VLF.
>
> (QRSS employs International Morse, the coding method explicitly 
> defined for
> CW in 97.3(c)(1) and permitted virtually everywhere in the ham bands by
> 97.307(a).  Hellschreiber is an image mode, on which few specs are 
> stated in
> the Rules other than bandwidth limits, so no problem there either.)
>
> But assuming we do someday get 2200 and/or 630 meters in the amateur
> service, one of two things will need to happen before it's legitimate 
> to use
> popular digital modes in those bands:  (1) there will need to be yet 
> another
> new slow mode that does, in fact, utilize one of the currently specified
> codes; or else, (2) developers of this sort of software will need to get
> together and agree on a nice, efficient varicode they can all get behind,
> publish it, and then petition the FCC to include it in the specified 
> codes
> of 97.309(a).  I have no doubt most of us here would gladly support 
> such a
> petition.  Then some variant of each of these worthwhile digimodes 
> would be
> legitimate for American ham use in all bands.
>
> 73
> John
>
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