2.2 License Requirements (Key Topic 2)

2.2 License Requirements (Key Topic 2)

Quick Answer: Fixed-tuned ship radar operated only from external controls needs no radio operator authorization. Aircraft stations need an MP or higher on frequencies below 30 MHz that are not allocated exclusively to aeronautical mobile. Inability to send and receive spoken English by telephone bars a commercial operator license. GMDSS passenger ships need two GMDSS (or Restricted GMDSS) operators by sea area; the Great Lakes Radio Agreement minimum is an MP; the operator on duty must have the original license or a photocopy posted or in personal possession.

Operator licenses versus equipment endorsements

Key Topic 2 is about who may sit the watch, not about which radio is certified. 47 CFR Part 13 classifies commercial radio operator licenses. 47 CFR Part 80 states when a ship station must carry a particular class of operator. 47 CFR Part 87 states the aircraft-station minimums. The FCC types-of-licenses page (Marine Radio Operator Permit) matches those ship and aviation carriage rules in plain language: MPs are required to operate radiotelephone stations aboard certain Great Lakes vessels, vessels of more than 300 gross tons, vessels carrying more than six passengers for hire in the open sea or any U.S. tidewater area, and certain aviation and coast radiotelephone stations.

A GROL (PG) conveys all operating authority of the MP under 47 CFR 13.8(d). A GMDSS Radio Operator’s License (DO) also conveys MP authority under 13.8(e). A Restricted GMDSS Radio Operator’s License (RG) conveys MP authority as well on the FCC types page, limited to voyages that remain within 20 nautical miles of shore for GMDSS operating privileges. Those “higher license already includes MP” rules matter when a company asks whether a second MP card is required. They do not change the GMDSS passenger-ship manning rule below: two GMDSS-qualified operators, not two MP holders, are what that ship must carry.

Fixed-tuned ship radar: no operator authorization

47 CFR 80.177(a)(3) is the radar exception Element 1 tests. No radio operator authorization is required to operate a ship radar station if both of the following are true:

1. The radar frequency is determined by a nontunable, pulse-type magnetron or other fixed-tuned device; and
2. The radar is capable of being operated exclusively by external controls.

That is the everyday navigational X-band or S-band radar on the bridge: the watchstander ranges, switches sea clutter, and adjusts gain from the pedestal or display. No MP, no GROL, and no Ship Radar Endorsement is required merely to operate that radar.

The Ship Radar Endorsement is a different credential. 47 CFR 13.7(c)(1) affixes it to a Radiotelegraph Operator License, GROL, or GMDSS Radio Maintainer’s License. The FCC types-of-licenses page states that only persons whose commercial radio operator license bears this endorsement may repair, maintain, or internally adjust ship radar equipment. Element 8 is the examination for that endorsement. Do not treat “radar on the bridge” as a reason to demand an MP, and do not treat a Ship Radar Endorsement as the license needed to switch the set on.

80.177 lists other no-license operations that are useful context but are not the Key Topic 2 radar item: shore radar and shore radionavigation, survival craft stations and EPIRBs, on-board stations, and a ship station operating in the VHF band on a voluntarily equipped ship on a domestic voyage. 80.177(d) also allows unlicensed installation of radar on a voluntarily equipped ship when a step-by-step manual is included and no internal adjustments are made. Installation without a license is not the same fact as operation of a fixed-tuned external-control radar, which is the pool target.

Aircraft stations: when the MP is the aviation minimum

Element 1 includes one aviation operator fact because the FCC types-of-licenses page and 47 CFR 87.89 both place the MP on certain aircraft radios. 87.89(b) sets aircraft-station minimums by frequency and allocation:

The live Element 1 item is the second row: an MP or higher is required when the aircraft is operating on frequencies below 30 MHz that are not allocated exclusively to aeronautical mobile services. Those are shared or maritime-type HF channels, not the exclusive aero mobile allocations. The opposite statement — MP required on frequencies below 30 MHz that are exclusive aero mobile — is the trap. Exclusive aero mobile below 30 MHz is an RP minimum, not an MP minimum. VHF aero telephony on domestic frequencies generally needs no commercial operator license under 87.89(d)(4).

87.91 adds an operating limit that MP and RP holders must remember if they do use an aircraft radio on maritime mobile frequencies: they may perform only transmitter operations controlled by external switches, they may not internally adjust frequency-determining elements, and on maritime mobile frequencies the carrier power must not exceed 250 watts (A3E) or 1000 watts (R3E, H3E, or J3E).

English-language ineligibility

47 CFR 13.9(a)(4)(iii) is the eligibility bar Element 1 tests. No person is eligible to be issued a commercial radio operator license when that person is afflicted with complete deafness, complete muteness, or complete inability for any other reason to transmit correctly and to receive correctly by telephone spoken messages in English.

The FCC types-of-licenses page states the same qualification in affirmative form for the MP: the applicant must be able to receive and transmit spoken messages in English, and must be a legal resident of (or otherwise eligible for employment in) the United States. Independent Element 1 study treats the negative form as the tested fact: inability to send and receive spoken English correctly by telephone makes the person ineligible.

Distractors on this topic include a blanket ban on “handicapped persons,” a requirement that foreign maritime operators hold an IMO certificate, and a ban on U.S. military operators still on active duty. None of those is the 13.9 ineligibility rule. Restrictive endorsements relating to physical disability, English language, or literacy waivers can be affixed under 13.7(c)(3), but the complete inability to handle spoken English by telephone remains a bar to issuance.

Employment eligibility is a separate 13.9(a)(1) gate for most commercial licenses, including the MP. Persons not legally eligible for employment may still qualify in narrow cases for a Restricted Radiotelephone Operator Permit–Limited Use (RL) under 13.7(d)–(e) and 13.9(a)(2)–(3) (FAA or reciprocal pilot certificate, or holder of an FCC station license operating only that station). That RL path is not an MP, and it does not erase the English radiotelephone requirement.

GMDSS passenger ships: two GMDSS operators by sea area

47 CFR 80.159(d) states the passenger-ship GMDSS manning rule. Each passenger ship equipped with a GMDSS installation in accordance with Subpart W shall carry at least two persons holding an appropriate GMDSS Radio Operator’s License or, if the passenger ship operates exclusively within 20 nautical miles of shore, at least two persons holding either a GMDSS Radio Operator’s License or a Restricted GMDSS Radio Operator’s License, as specified in 47 CFR 13.7.

The Element 1 wording is the same idea in pool language: two operators on board must hold a GMDSS Radio Operator License or a Restricted GMDSS Radio Operator License, depending on the ship’s operating areas. Restricted GMDSS (RG) is the near-shore credential. The FCC types-of-licenses page limits RG GMDSS operating authority to voyages that remain within 20 nautical miles of shore. A ship that leaves sea area A1 needs two full GMDSS Radio Operators (DO), not two RGs.

80.1073 repeats the two-person structure for GMDSS ships generally: at least two persons holding GMDSS Radio Operator’s Licenses, with a primary operator and a designated backup, except that a vessel operating exclusively within 20 nautical miles of shore may designate restricted GMDSS radio operators for those roles. MP, RP, and GROL are the wrong answers for a GMDSS passenger ship. GROL conveys MP operating authority; it does not by itself qualify a person as a GMDSS radio operator. Element 7 (or 7R) is the GMDSS operating examination. Element 1 alone produces an MP, not a DO or RG.

Great Lakes Radio Agreement: MP is the minimum

47 CFR 80.161 is short and currently dated November 9, 2023: each ship subject to Subpart T of Part 80 (vessels on the Great Lakes) must have on board an officer or member of the crew who holds a marine radio operator permit or higher class license. That is the Element 1 Great Lakes Radio Agreement minimum: Marine Radio Operator Permit, not an RP, not a GROL-only requirement, and not a radiotelegraph certificate.

The FCC types-of-licenses page says the same thing in program language: MPs are required to operate radiotelephone stations aboard certain vessels that sail the Great Lakes. A GROL or GMDSS operator license satisfies “or higher.” A Restricted Radiotelephone Operator Permit does not. Subpart T watch rules in 80.308 (Channel 16 and Channel 13 watches by length, towing, and passenger count, with a VTS exception) assume that a qualified operator is on board. The qualification that Element 1 tests is the MP.

Posting and personal possession while on duty

47 CFR 13.19(c) is the document rule every commercial operator uses on watch. When the operator is on duty and in charge of transmitting systems, or performing service, maintenance, or inspection functions, the license or permit document, or a photocopy thereof, or a copy of the application and PPC(s) received by the FCC, must be posted or in the operator’s personal possession, and available for inspection upon request by an FCC representative.

The Element 1 fact compresses that sentence: the original license or a photocopy must be posted or in the operator’s personal possession and available for inspection. A PPC sitting in the station file is not a substitute once the license has been issued. FCC Form 605 in a desk drawer is not the posted license. Supplying a copy only to a supervisor is not the 13.19(c) method. During the 90-day conditional operating window in 13.9(e), a copy of the application and the PPC received by the FCC can stand in; that is the third document 13.19(c) names, and it is not the routine answer after the MP grant appears in ULS.

13.19(d) relieves the operator of the log-signature details in 13.19(b) at a station of one licensee at a single location where the operator is regularly employed and the license or a photocopy is posted. It does not erase the duty to have the document available. In practice on a ship: post a photocopy at the principal radiotelephone operating position and carry the original or another photocopy on your person. Either location satisfies the tested requirement so long as an FCC representative can inspect it while you are on duty and in charge of the transmitting system.

License-requirement map for Key Topic 2

Carry that table into the exam room as six separate facts. The radar exception is easy to over-license. The GMDSS passenger-ship item is easy to under-license by answering MP. The Great Lakes item is easy to under-license by answering RP. The posting item is easy to over-complicate with PPCs and Form 605. Match the fact to the situation and stop.