Frequently asked questions
Is it necessary to hire outside environmental consultants, scientists, archaeologists or historians to comply with NEPA rules?
Section 106 of the NHPA requires the use of a qualified professional to perform certain aspects of review. Applicants may also need to obtain expert assistance to perform other aspects of environmental review, on a case by case basis.
How long does the NEPA process typically take?
Our experience, processes and procedures typically result in a 90 Day NEPA compared to an industry standard 90-120 days.
When do you have to notify the FAA of tower construction?
Notification is required for any tower construction or alteration of an antenna structure that is registered with the Commission. Towers that meet certain height and location criteria (generally towers more than 200 feet above ground level or located near an airport) require notice to the FAA and registration with the FCC. Prior to completing registration with the Commission, an antenna structure owner must have notified the FAA (via FAA Form 7460-1) and received a final determination of 'no hazard' from the FAA.
How can tower owners reduce or minimize the potential harm to migratory birds?
Because birds are attracted to non-flashing lights but less so to flashing lights, using flashing lights can prevent collisions and save the tower owner money. Non-flashing red lights, such as L-810 side-marker lights, can attract birds when illuminated. This puts the birds at greater risk of collision with guy wires, tower structural members, and antennas that are hard to see in dim light. Birds are much less attracted to flashing lights on towers, such as L-864 (red) or L-865 (white) obstruction lights.
The FAA and the FCC recognize this concern, and have implemented steps to reduce bird collisions through modifications in red tower lighting. The Federal Aviation Administration (FAA) has revised its advisory circular that prescribes tower lighting to eliminate new use of L-810 steady- burning side lights on towers taller than 350 feet (106.7 meters) above ground level (AGL), or to make L-810 lights flash on towers 150 to 350 feet (45.7 -106.7 meters) AGL.
These changes can reduce bird collisions by as much as 70%, particularly for migratory birds. Extinguishing L-810 lights also reduces costs for the tower owner.
As of September 28, 2016, the Federal Aviation Administration (FAA) no longer permits red non-flashing lights on any new tower above 150 feet AGL. The FAA has asked owners of existing towers to submit plans for eliminating the use of non-flashing lights on existing towers; and the FCC and FAA have developed a process by which registrants may do so.
How do I go about changing the lighting on an existing tower?
Tower owners may now request a “lighting deviation” from the FAA that can be used to extinguish or eliminate L-810 steady-burning side lights from an existing registered tower greater than 350 feet AGL and to flash the L-810 lights on towers 150 to 350 feet AGL. Typically, the FAA quickly approves such a request. The steps for making a lighting deviation request are set forth below.
Once approved by the FAA and FCC, the tower owner can implement the approved tower lighting changes. Extinguishing L-810 lights on towers taller than 350 feet AGL usually can be accomplished in the building at the tower base and does not require climbing the tower. Maintenance costs for those lights are immediately eliminated. No costs will be incurred by tenant licensees, and no FCC licenses will need to be reissued, since the FCC Antenna Structure Registration Number specified on those licenses will remain unchanged. For towers 150 to 350 feet tall AGL, reprogramming L-810 lights to flash typically requires use of LED lighting systems.
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