by Harold Hallikainen
San Luis Obispo, CA - In November 1995, the FCC released a Report and Order on WT Docket 95-5. This R&O totally changed the way the FCC deals with insuring that antenna structures are not a hazard to air navigation. The FCC has a very complete group of web pages at http://www.fcc.gov/wtb/antenna/Welcome.html. This group of pages includes the Report and Order adopting the rules, clarifications of the rules, provisions for registering towers online or on paper, and frequently asked questions. The FCC did an excellent job in providing resources on the web!.
Prior to this rulemaking, the Commission kept track of the tower painting and lighting requirements for 900,000 licensees. On average, a tower is used by 12 licensees. Therefore, any change in a tower resulted in notices of the modification by the 12 licensees instead of just one notification by the tower owner. There were about 17,000 of these notifications and applications in 1993. The Commission was looking forward to reducing this number by a factor of 12.
Several interesting questions were raised in the rulemaking. For example, should all towers be registered, or just those requiring FAA notification (generally those close to an airport or more than 60.96 meters tall)? A few argued that all towers should be registered, resulting in a single comprehensive tower database. The Commission, on the other hand, was concerned only with air safety and decided to register only those towers requiring FAA notification. This reduced the number of tower to be registered from 500,000 down to 75,000.
Why is this necessary, since the FAA already has the data? Although it might make sense for the FAA to track hazards to air navigation, according to the Report and Order, the FAA does not retain or compile structure notifications for future reference. Further, the FAA does not have statutory authority to mandate the painting or lighting of antenna structures.
Should each tower of an AM array be registered separately? Yes, the Commission decided that each tower in an array should have a separate registration. This simplified the registration data (requiring just location and height data on a tower instead of trying to identify the several towers of an array). Further, some towers in an array might not require registration (probably because of height) or may have different lighting and marking requirements. A separate registration for each tower simplifies this.
Since only structures in Texas remain to be registered (as of May 1, 1998), let's have a look at how the registration process is proceeding. Email correspondence with FCC staff indicates that the process is going smoothly. The FCC CIB regional offices have been conducting extensive educational efforts to inform tower owners of the registration requirements. The CIB will initiate an ASR (antenna structure registration) compliance measurement program after the last filing window closes on June 30.
The Commission staff notes that some people are sending in registrations prior to receiving an FAA Determination. This would appear to only be a problem on new structures... existing structures requiring FAA notification should have an existing FAA Determination. However, finding a copy of that Determination may be difficult for a tower that has existed for many years. The FCC Fact Sheet (at the above web URI) indicates that the Commission realizes that stations may not have a copy of the FAA Determination from long ago. The FCC then requires as much information as possible regarding the structure, such as the FAA Study Number, FAA office notified, and previously assigned FCC painting and lighting paragraphs. From this information, the FCC should be able to verify that the structure was previously cleared by the FAA. If they cannot, however, they will require a new FAA Determination.
Some structure owners have found discrepancies between the location of the tower on the FAA Determination, the location specified on FCC licenses, and the actual location as newly determined. If the latitude or longitude changes by more than one second, or the height is increased by more than one foot, a new FAA Determination is required. If the newly determined tower location listed on the tower registration differs from that listed on the station license, or if the HAAT differs by more than two meters, the station must file a form 301 or form 340 to modify the license. This filing must be done within 30 days of receiving a copy of the tower registration (FCC Form 854-R) from the tower owner.
The FCC is making more and more of their data available on the Internet. Tower registration data will be available on the net. Tower owners have been able to file electronically, either through email or through a special computer program the FCC provided. At the time the tower registration program was being set up, the FCC did not have an adequate Internet firewall to allow tower tower registration using a standard web browser. As of March 6, they have received 25,694 registrations on paper and 17,165 electronic.
The biggest problem, according to FCC staff, has been with posting of the tower registration number. Note that section 17.4(g) requires the tower registration number to be "displayed in a conspicuous place so that it is readily visible near the base of the antenna structure. Materials used to display the Antenna Structure Registration Number must be weather-resistant and of sufficient size to be easily seen at the base of the antenna structure." There is an exception if the posting would detract from the appearance of a historic landmark, as defined by federal, state, or local government.
Email correspondence with stations generated some interesting comments. In general, the electronic filing went smoothly while those filing by paper had to wait a while for their registration numbers. Another station found that over the years the towers "grew" 8 feet and managed to move 50 feet for one tower and 250 feet for another tower. The filing of the paperwork went smoothly, however.
One person person who registered ten towers found that the lighting had been removed from one several years earlier. The station had the FCC telegram authorizing removal of the lights, but no FAA authorization could be found. A records search was conducted in Washington with no FAA record found. Finally, the station found the original letter from the FAA in an old box of records. The station may have had to relight the tower. Never throw anything away!
From here, it looks like the tower registration program is going pretty smoothly! It will be interesting to see how the FCC review of the program goes. It will certainly be simpler to track towers instead of having each licensee responsible for a shared tower. It seems that the FAA would've done this long ago!
Harold Hallikainen is president of Hallikainen & Friends, a firm specializing in electronic design and technical writing. He is also an avid contra dancer. He can be reached at +1 805 541 0201 (voice/fax), harold@hallikainen.com (email), and http://hallikainen.com (World Wide Web).