FCC License - Handheld Radios
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SEE:  https://www.fcc.gov/wireless/bureau-divisions/mobility-division/commercial-radio-operator-license-program

The above link should be the definitive source for an answer to my question.   Maybe I am slow on the uptake, but my specific question appears to be left without a clear answer.

WHY THE QUESTION:   Our local flying club, which is operating from a privately owned, Non-Controlled / NO TOWER airfield, will today for the first time have four aircraft in the air at around the same time.   We have been making it a standard practice to use our handheld radios to communicate from the ground to our aircraft overhead.   I think this is not allowed without the operator of the handheld on the ground holding a Commercial Operator FCC radio license. 

REFERENCES PLEASE: If your reply can be supported with a quote and your technical source being sited along with your rationale and interpretation, that is better.   

To make the issue crystal clear, I will put my question this way:

SCENARIO:  A CFI uses a handheld radio to communicate with a student who is doing solo pattern work.  This is ground to air communication by someone who is clearly NOT the PIC.  
Should not matter if it is a Towered or Non-Towered airport. 

QUESTION:   Is the CFI required to have an FCC issued Commercial Operator radio license to conduct such communication?   

RELATED QUESTIONS:   
(1)  Does the answer differ if there is a specific assigned CTAF for a non-towered field and you are on the ground with your handheld and are on site as an observer only and just want to chat with the pilot flying?
(2)  Does the answer change if your non-towered field uses MULTICOM 122.9 as its CTAF and you are on the ground with your handheld as an observer only?

 


Thanks
2 Replies
Votes
Thank you.   Clear and concise response -- unlike CFR 47 Part 87.    I am quite used to reading regulations but this Aviation Services code is truly thick as a brick.   

Here are two links for a more general and plain English discussion.   Hopefully helpful for others.

TECHNIQUE: WHAT'S THE FREQUENCY? FINDING A CHANNEL ON CROWDED COMS 
https://www.aopa.org/news-and-media/all-news/2018/january/pilot/technique-whats-the-frequency

AND

REQUIREMENTS FOR 760 CHANNEL VHF RADIO FOR AERONATICAL OPERATIONS -- FAA AC 90-50D
https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_90-50D.pdf
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1021 Posts
You need to read 47 CFR Part 87 for the basis of the answers to your questions   The short answer is no Radiotelephone Operator Certificate is required any more than one is required for someone speaking to an aircraft on an airport's UNICOM, although like that UNICOM station, an Aeronautical Ground Station license is required.  These stations are on VHF and not outside the USA. The only difference in the related questions is that when there's no CTAF, you use 122.9 MULTICOM (see the AIM -- the FCC has delegated frequency assignments in the aviation radio band to the FAA). 

That said, in your scenario, at a non-towered airport, if you don't bother with the FCC station license, nobody will notice or care.  OTOH, at a tower-controlled airport, you'd better get the Tower Chief to approve anything you want to do like that, especially if the CFI will be in the movement area.  And in that case, you'll be using the Tower frequency.

The Grumman Owners and Pilots Association has gone through this process dozens of times for the flying operations at its annual conventions.