80 likes | 191 Views
Tower Registration Compliance. Lawrence Behr, CEO LBA Group, Inc. Greenville, North Carolina. www.Lbagroup.com. What Is Registration?. Mandatory FCC program for tower/antenna structure owners. Registration number required to process any licensee action on non-exempt structure.
E N D
Tower Registration Compliance Lawrence Behr, CEOLBA Group, Inc.Greenville, North Carolina www.Lbagroup.com
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! www.Lbagroup.com
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. www.Lbagroup.com
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 www.Lbagroup.com
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 www.Lbagroup.com
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 www.Lbagroup.com
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! www.Lbagroup.com
Resources • 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 <http://www.fcc.gov/wtb/antenna> • System status • Registration Information Center • Posting guidelines • TOWAIR - sites near airport screening tool • FAA documents • Registration database www.Lbagroup.com