FAA TOWER MARKING AND LIGHTING REGULATIONS

1. FAA TOWER MARKING AND LIGHTING REGULATIONS RICHARD G. HICKEY DIRECTOR OF BUSINESS DEVELOPMENT UTILITY INFRASTRUCTURE SPX FLASH TECHNOLOGY BRUCE BEARD AIR TRAFFIC, OBSTRUCTION EVALUATION GROUP SUPERVISOR, U.S. OPERATIONS FAA

2. TOPICS TODAY • Introduction (addressing structures up to 500’ AGL) • The FAA / FCC relationship • Tower Filing Requirements • Monitoring Requirements • “New Rules” • FAA A1, A2, A3 Lighting and Marking • Limiting Your Exposure to Liabilities • Question and Answer

3. FAA / FCC- HOW IT WORKS • The FCC authorizes the FAA to establish lighting and marking regulations in Title 47 Code of Federal Regulations • FAA regulations apply to all man-made structures • FAA regulations on non-RF structures are enforced by the United States Federal Court • Fines are imposed for improper marking, lighting, and monitoring. Utilities are no exception. See enforcement (note the number of utilities and municipalities) actions at: https://www.fcc.gov/eb/broadcast/asml.html • The FAA Notice Criteria Tool:https://oeaaa.faa.gov/oeaaa/external/gisTools/gisAction.jsp?action=showNoNoticeRequiredToolForm

4. FILING REQUIREMENTS • AGL / AMSL • MAXIMUM HEIGHT FILING REQUIREMENT • CIRCULATION • DETERMINATION • “GRANDFATHER” CLAUSE (EXISTING TOWERS) • CONSTRUCTION NOTAM (NEW CONSTRUCTION) • SURROUNDING STRUCTURES OR TERRAIN • “UTILITY WAIVER?” • THE “NEW RULES”

5. FAA REGULATIONS – ADVISORY CIRCULARS AND OTHER INFORMATION • Obstruction Marking and Lighting- AC 70/7460-1K Chg 2 • Parameters for Obstruction Lighting and Marking- AC 150/5345-43F • Regulations for Certification of Obstruction Lighting- AC 150/5345-53C • Listing of ETL Certified Lighting Products- AC 150/5345-53C Addendum • Certification is not required, but is often the single most important factor in liability suits.

6. MONITORING REQUIREMENTS FAA AC70/7460-1K Change 2, Chapter 2, Paragraph 23, Section b: • Any failure or malfunction that lasts more than thirty (30) minutes and affects a top light or flashing obstruction light, regardless of its position, should be reported immediately to the appropriate flight service station (FSS) so a Notice to Airmen (NOTAM) can be issued. Section a states: • Failure of a steady burning side or intermediate light should be corrected as soon as possible, but notification is not required. Footnote concerning NOTAMs: • 1. When the primary lamp in a double obstruction light fails, and the secondary lamp comes on, no report is required. However, when one of the lamps in an incandescent L-864 flashing red beacon fails, it should be reported. • 2. After 15 days, the NOTAM is automatically deleted from the system. The sponsor is responsible for calling the nearest FSS to extend the outage date or to report a return to service date. Paragraph 24 Notice of Restoration: • As soon as normal operation is restored, notify the same FSS that received the notification of failure. The FCC advises that noncompliance with notification procedures could subject its sponsor to penalties or monetary forfeitures.

7. MONITORING REQUIREMENTS FAA AC70/7460-1K Change 2, Chapter 4: • 47. MONITORING OBSTRUCTION LIGHTS Obstruction lighting systems should be closely monitored by visual or automatic means. It is extremely important to visually inspect obstruction lighting in all operating intensities at least once every 24 hours on systems without automatic monitoring. In the event a structure is not readily accessible for visual observation, a properly maintained automatic monitor should be used. This monitor should be designed to register the malfunction of any light on the obstruction regardless of its position or color. When using remote monitoring devices, the communication status and operational status of the system should be confirmed at least once every 24 hours. The monitor (aural or visual) should be located in an area generally occupied by responsible personnel. In some cases, this may require a remote monitor in an attended location. For each structure, a log should be maintained in which daily operations status of the lighting system is recorded.

8. MONITORING REQUIREMENTS • FCC Title 47 – Part 17.47, Code of Federal Regulations – CFR • § 17.47 Inspection of antenna structure lights and associated control equipment. • The owner of any antenna structure which is registered with the Commission and has been assigned lighting specifications referenced in this part: • (a)(1) Shall make an observation of the antenna structure’s lights at least once each 24 hours either visually or by observing an automatic properly maintained indicator designed to register any failure of such lights, to insure that all such lights are functioning properly as required; or alternatively, • (2) Shall provide and properly maintain an automatic alarm system designed to detect any failure of such lights and to provide indication of such failure to the owner. • (b) Shall inspect at intervals not to exceed 3 months all automatic or mechanical control devices, indicators, and alarm systems associated with the antenna structure lighting to insure that such apparatus is functioning properly. • [61 FR 4363, Feb. 6, 1996]

9. “New Rules” Concerning L-810 “Marker” Lights(Are they rules yet?) • PROPOSED: • Below 200’ (A-0): No Change • 200’ to 350’ A-1 & E-1: Markers to flash, synchronized with L-864, 30 FPM (flashes per minute) • 350’ + A-2 / E-2 & above: Markers may be eliminated if L-864s flash at 30 FPM

10. FAA DESIGNATION “A” • Required configurations for red lighting consist of Medium Intensity flashing (L-864) and steady-burn red obstruction lighting (L-810, commonly called “side markers”), or only the L-810 steady-burn lighting depending on the AGL height of the tower. • NOTE: The FAA only accepts Aviation Orange and White alternating paint bands or white strobe lighting for Day Marking. Red lighting is not accepted as a day marking. • Aviation Orange and White painting is addressed in the AC 70/7460-1K Chg 2, chapters 3 and 12. • The number of paint bands required depends on the overall AGL height of the tower. The top and bottom bands are always orange. • The paint must be maintained. Fines for faded paint are commonplace and have ranged from $5,000 to $13,000 over the past year. • The “Hale Color Chart” is normally used as a guideline for determining the compliance of the paint. See www.halecolorcharts.com

11. FAA DESIGNATION “A” A0, A1, A2 (Red Lights and Paint)

12. FAA DESIGNATION “A” TECHNOLOGIES • L-864: Red Beacon • Flashing- LED, Xenon, or Incandescent- 2,000 cd output

13. FAA DESIGNATION “E” • White strobe for day, red strobe for night. LED or Xenon, may have incandescent for night. FAA designation L-864/L-865 with L-810 markers. • Side markers normally required • Paint is not normally required • Day intensity- 20,000 cd • Night intensity- 2,000 cd • May be preferred in areas near populace due to the red lighting at night and the general public aversion to overspray or “mitt precipitation” from tower painting. • Normally not recommended by the FAA for structures <200’ in height AGL. • Towers >150’ to 350’ are normally required to have one or more flashing L-864 and L-865 beacons at the top and at least two L-810 steady-burn side marker lights at the intermediate level (E1). • Towers >350’ to 700’ should have one or more flashing L-864 and L-865 beacons at the top, two flashing L-864 and L-865 beacons at the mid-point (no lower than 200’), one level of steady-burn L-810 side markers at the mid-point between the two levels of flashing lights, and one level of steady-burn L-810 side markers at the mid-point between the lowest tier of flashing beacons and the ground (tower base). At each marker level, there should be one L-810 on each leg of the tower.

14. FAA DESIGNATION “E” E1 and E2 Dual (Red/White) Lighting Systems

15. FAA DESIGNATION “E” TECHNOLOGIES • May be a combination of LED, Xenon, and incandescent (red only) technologies • L-864/L-865: White and Red Flashing Strobe Beacons, 2,000 cd night / 20,000 cd day • L-810 Side Marker Lights required

16. FAA DESIGNATION “D” • White strobe only, LED or Xenon. FAA designation L-865. • No side markers • Paint is not normally required • Day intensity- 20,000 cd • Night intensity- 2,000 cd • Always flashing. No steady burn option. • Normally found in rural locations since white lighting is more obtrusive to the human eye than red. • Normally not recommended by the FAA for structures <200’ in height AGL. • Towers 200’ to 350’ AGL (D1) normal configuration is one or more L-865 strobes at the top of the tower. Towers >350’ to 500’ AGL (D2) normal configuration is one or more L-865 strobes at the top of the tower and two or more L-865 strobes at the mid-point (but no lower than 200’.

17. FAA DESIGNATION “D” D1 and D2 White Lighting Systems

18. FAA DESIGNATION “D” TECHNOLOGIES • L-865: White Strobe Beacon • Flashing- LED or Xenon. • Output- 2,000 cd night / 20,000 cd day

19. EXPOSURE TO LIABILITY • “Utility companies are manna from heaven to an attorney in a wrongful death suit.” Hatcher Freis, Esq.

20. EXPOSURE TO LIABILITY • Monitor • Maintain logs • Audit your sites • There is no “small stuff” • Trust the facts, not the hearsay • Use reputable service companies • Be diligent

21. Q&A QUESTIONS?