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Consulting Engineers Get Specific About Tower Rules

AFCCE: 'Immediate' notification of lights-out needs more explaining

Consulting broadcast engineers have several suggestions about the FCC’s proposed changes to modernize and clarify the antenna marking, lighting and construction rules.

The commission has proposed (PDF) relaxing rules that require daily tower observation and the reporting of tower lighting problems within 30 minutes. Also proposed is having broadcasters report changes in antenna configuration, frequency or wattage to the FAA.

In a filing to Docket WT 10-88, the Association of Federal Communications Consulting Engineers proposes that “previously authorized lighting/marking configurations be ‘grandfathered’ unless clear and convincing public safety issues can be demonstrated to be mitigated by requiring a major upgrade as a result of changed FAA recommendations.” It notes that existing towers may have lighting systems that are 50 years old and that changing them to conform to new rules could be really expensive “with little or no enhanced safety benefit to the public.”

Currently, licensees must observe their tower lighting at least every 24 hours. If they see problems requiring FAA notification, that must be made immediately. The consulting engineers say the “immediate” notification can “yield widely differing results.”

The association gave this example: “A routine tower lighting functionality observation, if made just before twilight on Sunday, with no reportable condition observed, is followed minutes later by a system failure. It may go undetected for nearly 24 hours until Monday evening; use of an automated monitoring system might result in immediate observation of the problem and ‘immediate’ notification to the FAA followed by timely issuance of a [Notice to Air Men]” about an aviation hazard.

AFCCE recommends that the commission consider requiring that tower licensees install monitoring systems that would provide prompt notification of failures and provide a way to grant waivers “when back-communication channels do not exist or are impractical to establish and/or where economic or other technical factors make establishment of the feature impractical.”

Finally, it says, the commission in consultation with the FAA should develop language that gives more guidance for notification other than “immediately.”

Reply comments are due in WT Docket No. 10-88 on Aug. 19.