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Tower Registration Compliance. Lawrence Behr, CEO LBA Group, Inc. Greenville, North Carolina. What Is Registration?. Mandatory FCC program for tower/antenna structure owners. Registration number required to process any licensee action on non-exempt structure.

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tower registration compliance

Tower Registration Compliance

Lawrence Behr, CEOLBA Group, Inc.Greenville, North Carolina

what is registration
What Is Registration?
  • Mandatory FCC program for tower/antenna structure owners.
  • Registration number required to process any licensee action on non-exempt structure.
  • Requires, but doesn’t replace, FAA Determination of No Hazard
  • Lets out all location, height, marking and lighting requirements.
  • Penalty for non-compliance - BIG FINES!

what must be registered
What Must Be Registered?
  • Every antenna structure higher than 200 ft. above ground level - including buildings!
  • Every antenna structure within 5 miles of an airport
    • Analysis can exclude non-aviation impact structures
  • No grandfather provision after 7-1-98
  • Existing antenna structures not now registered are in violation of FCC Rules.

how to register
How To Register
  • FCC Form 854
    • Electronic or mail filing
    • No FCC fees
    • Requires taxpayer ID number (TIN)
  • Data must conform exactly to FAA Determination of No Hazard
    • Location accuracy of one minute latitude and longitude (approximately ±50 ft.)
    • Heights and ground elevation to nearest one foot
    • Hand held GPS fixes no good!
  • Data doesn’t match? Get new FAA DNH on FAA Form 7460-1

owner and licensee responsibilities
Owner and Licensee Responsibilities
  • Structure owner cannot delegate responsibility to tenants licensees
  • All lighting, marking, outage notification is owner responsibility
  • Tenant licensees should not register structures
  • Licensee tenants have “back-up” responsibility if owner fails
  • Owner must post §54R and provide copies to all tenants
  • Owner must conspicuously post registration number at site

hot topics
  • FCC believes as many as 28% of required structure registrations not yet filed!
  • Recent LBA site assessment project - 70% not filed, or in error!
  • FCC announces “No Tolerance” policy for unregistered antenna structures!
  • FCC implements new procedures (6-99)
  • Registration errors now automatically dismiss ULS applications!
  • FAA Advisory Circulars adopted into FCC Rules

surprises for owners and licensees
Surprises for Owners and Licensees
  • Environmental assessments required
    • Owner must make NEPA assessment
    • Existing structures must be assessed
    • Certification required on Form 854
  • “Window” applications cannot be filed without Registration - will be dismissed!
  • Registrations cannot be filed or granted without final FAA Determination of No Hazard
  • Antenna structures may not be constructed on FAA DNH - must have issued Registration
  • Lighting and marking requirements supercede existing licensee requirements
    • Watch out for 7460-1J!
    • Major changes on tower may be mandated!

  • Do it yourself difficult
    • FCC specifically permits service firms to file for licensees
    • Site assessments required to avoid inaccurate filings
    • Must be coordinated with tenant/user licensing and FAA
  • FCC on-line information available
  • Antenna Structure Registration <>
    • System status
    • Registration Information Center
    • Posting guidelines
    • TOWAIR - sites near airport screening tool
    • FAA documents
    • Registration database