Response 1) from Steve Kaluf, though Carl Maroney:

The CFR's 95.221 and 95.222 have NOT changed at all looking at the Oct 2003 edition (newest) all the way back to 1997. Nor has subpart E. The argument that has been tested in the past was that Crystals are not "plug in modules which were certificated as part of your R/C transmitter" as indicated by 95.222 as an allowable user change. I can remember this question being bounced to the attorney who came back with the same interpretation we've always had.
That said trying to find out who is really authorized to make changes always proves challenging. The CFR states:
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.
Certainly lots can be argued as to who is really qualified to plug a different crystal in. However, my recollection is that the attorneys determined the end user is not so qualified.


Response 2) From Steve Kaluf, in response to the e-mail sent to the FCC:

I wrote the original response that Carl copied to you. My position has not changed on that. The CFR's have not changed.

What you quote from the web site is probably not technically incorrect however the provisions and regulations within the CFR's would take precedence over anything of this nature, our part of the CFR's clearly state that these "Plug-in crystals are not considered modules and must not be accessible to the user." Additionally as I stated in the first response Carl copied to you, some time ago we had our attorneys that represent us before the FCC evaluate this, they too feel changing crystals is not acceptable when done by the end user.


Response 3) from Steve Kaluf:

This issue continually comes up. In the ten years I've been with AMA I probably deal with it five or six times per year. Forums and newsgroups are wonderful things, but, unfortunately they tend to spread misinformation rather fast and fail to spread the correct information equally as fast.

Thanks for passing the FCC's response along. It's nice to see them actually respond with the correct information for a change too.



(NOTE: these responses are excerpts, names and e-mail addresses have been altered, other than the FCC one.)