Hi Dobbs,
look up ATF forms and Form Number: RA 24.2 (b),point 3.
That point merely says that you are not required to
submit a copy of the radio licence in the case of a handheld radio. It does
not say that you don't have to have a licence for a handheld radio, which in fact you
do have to have. All that section is doing is recognising the fact that a particular aircraft may not have a fixed radio installation of its own but a handheld, possibly individually licensed to the owner and not normally part of the aircraft's installed equipment, is used whenever the aircraft is operated.
I emphasize the requirement of the Electronic Communications Act, 2005 (Act No.36 of 2005), read with the current Radio Frequency Spectrum Regulations, 2011, that, with certain exceptions, none of which are applicable to the aeronautical band, all two-way radiocommunication equipment is required to be licensed. If any document not issued by ICASA says or infers otherwise, that document is incorrect and should be disregarded.
Regards,
Peter