Yes, but I think they've erred on the side of caution. Looking at 80.203, I can understand why. Meeting the requirements of paragraph 4 may be difficult if that software is floating around out there. Probably a corporate decision.
§ 80.203 Authorization of transmitters for licensing.
(b) The external controls, of maritime station transmitters capable of operation in the 156-162 MHz band and manufactured in or imported into the United States after August 1, 1990, or sold or installed after August 1, 1991, must provide for selection of only maritime channels for which the maritime station is authorized. Such transmitters must not be capable of being programmed by station operators using external controls to transmit on channels other than those programmed by the manufacturer, service or maintenance personnel.
(1) Any manufacturer procedures and special devices for programming must only be made available to service companies employing licensed service and maintenance personnel that meet the requirements of
§ 80.169(a) and must not be made available with information normally provided to consumers.
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(3) Except as provided in
paragraph (b)(4) of this section, programming of authorized channels must be performed only by a person holding a First Class Radiotelegraph Operator's Certificate, Second Class Radiotelegraph Operator's Certificate, Radiotelegraph Operator License, or General Radiotelephone Operator License using any of the following procedures:
(i) Internal adjustments of the transmitter;
(ii) Use of controls normally inaccessible to the station operator;
(iii) Use of external devices or equipment modules made available only to service and maintenance personnel through a service company; and
(iv) Copying of a channel selection program directly from another transmitter (cloning) using devices and procedures made available only to service and maintenance personnel through a service company.
(4) Notwithstanding paragraph (b)(3) of this section, authorized channels may be programmed via computerized remote control by any person, provided that the remote control operation is designed to preclude the programming of channels not authorized to the licensee.