Tower Registration Posting

Radio World - 5 August 1998

by Harold Hallikainen

San Luis Obispo, CA - As discussed in the last article in this series, the FCC adopted the Antenna Structure Registration program in November 1995 with Docket 95-5.  The web resources on this program are excellent.  Extensive information is available at http://www.fcc.gov/wtb/antenna/Welcome.html .  I find it interesting, however, to follow the requirements as the FCC describes them as we move farther and farther from the Report and Order.  It seems a bit like the children's game "telephone" where the meaning of the message changes slightly each time it is repeated.  I find contradictions in a fair number of FCC policies and the rules as written, or the rationale for adopting the rule, as described in the Report and Order.  In this instance, the rules seem fairly clear as to where the antenna structure number must be posted.  However, FCC inspectors and FCC checklists seem to be requiring something different.
 

The Rule

 17.4(g) states "Except as described in paragraph (h) of this section, the Antenna Structure Registration Number must 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."  Paragraph (h) provides an exemption if the sign would detract from the appearance of an historic landmark.  Clear enough!  The number must be displayed in a conspicuous place so it is readily visible near the base of the antenna structure.

FCC Posting Guidelines

The FCC ASRN posting guidelines (http://www.fcc.gov/wtb/antenna/antguide.html) state: "A site owner who is considering whether the Registration Number is properly posted will want to
keep in mind the following principles. In addition to providing general guidance, they serve as the
foundation for the answers to the hypothetical situations listed below.

"The Rules do not prohibit multiple postings of a Registration Number. An owner still unsure
whether the structure is in compliance may wish to post the Registration Number at several
points along a perimeter fence, or at both the gate to the access drive and adjacent to the base of  the antenna structure.

"Because the purpose of the Rule is to aid public identification of antenna structures, owners are
strongly encouraged to identify the number as the FCC Registration Number.

"The owner should rely on common sense when posting the number. Ask "is this readily visible to
someone who doesn't have access to the site?" If a location is conspicuous enough to post a "No
Trespassing" sign or the owner's name and logo, then it is likely an appropriate place to post the
Registration Number."

Somehow, we got from the clarity of the rule (post it at the base of the tower) to something about posting at points along a perimeter fence and gate to property.  The suggestion about posting along the fence seems to apply to owners "still unsure whether the structure [registration number posting] is in compliance."  Those who are sure the posting is conspicuously visible at the base of the tower seem (to me!) to be sure they are in compliance.

Further, note that the Guidelines specify the purpose of the rule as "to aid  public identification of antenna structures."  However, the Report and Order adopting the rules lists the purpose as "By these actions, the Commission seeks to reduce the number of filings to the Commission regarding changes to antenna structures, to expedite application and notification processing, to unify and streamline federal painting and lighting regulations, to ease the public and governmental
burdens associated with filing and processing certain applications, and to increase safety in air
navigation."  The Report and Order makes no mention of "aiding the public identification of antenna structures."

Self Inspection Checklists

The FCC's AM and FM Self Inspection Checklists have similar wording: "Once a tower (or towers in the case of an AM Directional station) is registered, then the registration number(s) is to be displayed in a conspicuous place so that it is readily visible near the base of the antenna structure(s). When the tower is located where the number cannot be seen without access to the property on which it is located, then the number should also be placed on the gate or fence leading to the tower where an outside observer can see it."  Note, however, the use of the word "should."  This appears to be a way to tell stations to do something beyond what the rules require.

The Empire State Building

Paragraph 36 of the Report and Order answers concerns raised by the owners of the Empire State Building.  They were concerned that the rules would require the registration number be posted at the base of the building.  However, this paragraph states (in part), "Therefore, in the case of antenna structures located on top of buildings, we will clarify the rules to require that the registration number be posted at the base of the antenna structure, not the base of the building."  Since the public does not have access to the base of the antenna structure (on the roof of the building), it appears identification of the tower by the general public was not a major concern in the rulemaking.

An Inspector Speaks

In the June 24 issue of Radio World, FCC inspector Ronald Ramage writes, "The rules indicate only that it is to be posted near the base of the tower.  Unfortunately, in many cases the tower base is not visible from the entrance gate to the property.  I do not climb fences.  The purpose is that people can identify the owner of the tower, so use common sense and your best judgment.  Post the number where it can be seen easily."  During an inspection, I would expect a station representative to accompany the inspector and unlock any gates necessary for access to the base of the tower, where the registration number should be readily visible.  I wonder... are stations cited for complying with the rule?

An FCC Attorney Speaks

In researching this story, I emailed the FCC and ended up in a telephone conversation with an attorney at the FCC.  Our conversation was "on background."  He stated that the FCC suggests that the ASRN should be posted where it is readily available to the public, but only requires that the number be readily visible near the base of the tower.  The FCC would like the public, the FCC, and the FAA to be able to identify a tower without having to get access to the site to readily report tower lighting and marking problems to the FAA.  He also said the word conspicuous in the rules might be interpreted as preventing the registration number from being posted on a tower pedestal behind a locked gate at the base of a tower.  Thus, it appears the FCC is requesting an action beyond what the rules require, but will not actually require that action.  It will be interesting to see how the rule is enforced.

Who Cares?

The research in this rule was prompted by stations being concerned that a sign with the tower registration number would identify to vandals that yes, this indeed is the gate to go through to get to that tower.  My reading of the Report and Order indicates that the ASRN posting is a bit like posting a serial number on a piece of equipment.  When you are at the base of the tower, you can positively identify the tower in the FCC database.  If you are in a field with several towers (such as an AM directional array), the registration number posting at the base of each tower positively identifies which tower is which.


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).   See the FCC Rules Online at http://hallikainen.com/FccRules .