The FCC has announced revisions to update and conform its Antenna Structure Registration (ASR) rules to the current practices of the Federal Aviation Administration (FAA), with which it shares authority for communications towers over 200 feet high or proximate to airport runways.

The changes are to take effect 30 days following publication in the Federal Register and include the following:

  • Marking and lighting specifications will no longer refer to paragraphs of FAA Advisory Circulars, which become outdated, but rather will refer to the specific requirements listed in the FAA's "no hazard" determination for a given tower.  Existing structures will not have to comply with new FAA requirements (including those prompted by relocation of airports) unless the FAA specifically mandates them for a particular tower.
  • Displays of ASRs on site are to be visible to a member of the general public who reaches the closest publicly-accessible location near the tower base (such as on a perimeter fence or access gate), rather than having to be visible near the tower base itself.  Where there are multiple public access points, the ASR information will need to be posted at each location.
  • Quarterly inspections will no longer be required for towers that certify use of network operations center (NOC)-based monitoring systems using self-diagnostic functions and 24-hour staffing by trained personnel.  The certification will have to demonstrate use of an NOC system previously approved by the FCC and maintenance of a facility to receive notifications of failures from the NOC and enable the tower owner to carry out its responsibilities in the event of a failure.
  • Notifications of construction, changes or dismantlement will need to be given within five days rather than one, as was previously required.
  • Notifications of failures are still to be made within 30 minutes but now will need to be repeated as often as necessary (including updates to the expected return-to-service date) once each FAA Notice to Airmen (NOTAM) period expires.  Reports are to be made to the FAA using its toll-free telephone number.  (The prior means was "by telephone or telegraph"!)
  • Repair times are to remain "as soon as practicable," rather than being subject to a specific timeline.  While intended to be flexible, this subjective standard is intended to enable the FCC to assess whether a tower owner exercises due diligence and makes a good-faith effort to achieve a timely repair.
  • Maintenance of painting will use the FAA's "In-Service Aviation Orange Tolerance Chart" as a standard measurement benchmark. Note that FAA visibility guidelines provide for color sampling on the upper half of a structure.
  • Record keeping of lighting extinguishment or malfunction will be limited to two years and must be provided to FCC agents upon request.
  • Accuracy of height and location data is to be within one foot and one second, respectively, and must match those given to the FAA.
  • Tenant copies of ASRs will no longer need to be provided on paper, but can be given in the form of a link to the FCC's on-line ASR system.
  • Voluntary ASRs will still be permitted, but will not be subject to the Part 17 rules that apply to required registrations.

A complete copy of the Report and Order (WT Docket No. 10-88) is available on the FCC's website at: http://transition.fcc.gov/Daily_Releases/Daily_Business/2014/db0808/FCC-14-117A1.pdf.

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