I felt the previous attempt at determining whether crystal swapping was legal or not was one sided, so I sent the following e-mal to the FCC. I also sent a copy to Carl Maroney and Steve Kaluf, the AMA Technical Director. The answers are in posts following this one, due to size restrictions on posts. Since, ultimately, the AMA attorneys have explored this issue, I, personally, accept this as definitive:

“I have a question about an apparent conflict of information relating to Radio Control transmitters. On the FCC website, at http://wireless.fcc.gov/commoperators/wncol.html it is stated that:

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“ Radio Maintenance and Repair
You need a commercial radio operator license to repair and maintain the following:
• All ship radio and radar stations.
• All coast stations.
• All hand carried units used to communicate with ships and coast stations on marine frequencies.
• All aircraft stations and aeronautical ground stations
• including hand-carried portable units) used to communicate with aircraft.
• International fixed public radiotelephone and radiotelegraph stations.
You do NOT need a commercial radio operator license to operate, repair, or maintain any of the following types of stations:
• Two-way land mobile radio equipment, such as that used by police and fire departments, taxicabs and truckers, businesses and industries, ambulances and rescue squads, local, state, and federal government agencies.
• Personal radio equipment used in the Citizens Band, Radio Control, and General Mobile radio services.
• Auxiliary broadcast stations, such as remote pickup stations.
• Domestic public fixed and mobile radio systems, such as mobile telephone systems, cellular systems, rural radio systems, point-to-point microwave systems, multipoint distribution systems, etc.
• Stations that operate in the Cable Television Relay Service.
• Satellite stations, both uplink and downlink of all types.”
However, in the CFR’s Section 95.221 (b) it states:
“You are responsible for the proper operation of the station at
all times and are expected to provide for observations, servicing and
maintenance as often as may be necessary to ensure proper operation.
Each internal repair and each internal adjustment to an FCC certificated
R/C transmitter (see R/C Rule 9) must be made in accord with the
Technical Regulations (see subpart E). The internal repairs or internal
adjustments should be performed by or under the immediate supervision
and responsibility of a person certified as technically qualified to
perform transmitter maintenance and repair duties in the private land
mobile services and fixed services by an organization or committee
representative of users in those services.”

My question, specifically, is whether an end user may change crystals in an Radio Control transmitter. Here, again, there appears to be a conflict, since CFR Section 95.645 (b) states:

“An R/C transmitter which incorporates plug-in frequency
determining modules which are changed by the user must be certificated
with the modules. Each module must contain all of the
frequency determining circuitry including the oscillator. Plug-in
crystals are not considered modules and must not be accessible to the
user.”

Which is correct? May the end user change crystals in a Radio Control transmitter, under the new CFR’s issued in 2002 as implied on the first page sited, or, are the older CFR’s of Section 95, which have not been updated as recently, correct?

Thank you for your prompt attention

JR