Question for discussion...
Programming your own Part 90 radios into Part 95 service, and front panel programming... Is this legal?
This may be another area that needs further clarification from the FCC, or perhaps I just cannot find the rule that applies, but in the past, all type-accepted radio transmitters had to be set up and aligned by (or under supervision of) a licensed technician before they were legal to use. Radio owners/operators were never allowed to modify their radios in any way. A licensed technician used to be defined as "the holder of a valid Commercial General-Class Radio-telephone Operator's License."
Today, we are all programming our own radios for the frequencies we would like to use, and some even modify radios for front-panel programming. Is this even legal?
The only laws I can find about this today are:
95.319 (b.) Internal repairs. Internal adjustments and repairs to Personal Radio Services transmitters must be performed by or under the supervision of an individual who is qualified to maintain and repair transmitters.
95.337 No person shall modify any Personal Radio Service transmitter in a way that changes or affects the technical functioning of that transmitter such that operation of the modified transmitter results in a violation of the rules in this part. This includes any modification to provide for additional transmit frequencies, increased modulation level, a different form of modulation, or increased transmitter output power (either mean power or peak envelope power or both). Any such modification voids the certified status of the modified transmitter and renders it unauthorized for use in the Personal Radio Services. Also, no person shall operate any Personal Radio Service transmitter that has been so modified.
I had never really considered this before, since I do hold a Commercial GROL, and I am a qualified technician, but what about others programming their own radios with eBay cables? What about those internal modifications that allow the front panel to essentially be used as a VFO? This is fine for ham use, but can that possibly be legal at all for GMRS?
Open for discussion.....