We received several emails to Radio World regarding the latest Federal Aviation Administration Advisory Circular on obstruction marking and lighting, which was released in August.
The advisory supersedes a 2020 edition. As a result, there are a few updates that radio station operators who own or operate tower structures will want to heed.
“They are important for broadcasters and other tower owners to follow,” Charles “Ched” Keiler, CPBE and chairman of the Society of Broadcast Engineers Alternative Broadcast Inspection Program, told us.
From the Federal Communications Commission perspective, guidelines specified in an FAA determination are mandatory for broadcasters, Keiler said.
Keiler operates his own broadcast engineering firm, E Three Services, in addition to serving as SBE treasurer. He has been instrumental in formulating the SBE self-inspection guides that so many stations rely upon. So we sought his expertise to sort through what actually applies to broadcast facilities.
What applies?
The first aspect a reader asked us about is what the FAA deems as “preconstruction notices.”
For broadcast structures exceeding 200 feet above ground level (AGL), mandatory notification, marking and lighting requirements are standard under Part 77 rules and FAA guidelines. But the updated circular expands rules for short structures standing between 50 and 200 feet AGL, stating that owners and builders must submit detailed preconstruction notices.
However, that specific Part 77 rule change was written for meteorological towers (met towers) and wind energy systems. It does not create an automatic, blanket filing mandate for standard broadcast towers under 200 feet.
For radio stations building or modifying a short tower or STL pole under 200 feet AGL, an FAA Form notice is still required primarily if the site triggers proximity thresholds near an airport runway.
Keiler concurred that while the 50- to 200-foot blanket mandate doesn’t directly force every short radio tower into a filing, checking site parameters preemptively using the online FAA Notice Criteria Tool is still a smart move before starting construction.
Keiler highlighted four key areas addressed in the circular that broadcasters should keep on their radar:
- Preconstruction Notices: Driven by Part 77 updates covering short structures such as meteorological towers, owners and builders of met towers must submit detailed preconstruction notices for structures between 50 and 200 feet AGL. For broadcast towers under 200 feet, preconstruction notice remains required if the structure sits near an airport runway.
- Painting Requirements: Alternating bands of aviation orange and white are required for met towers, or whenever specifically mandated in an FAA Determination of No Hazard for a broadcast site.
- Database Tracking: The FAA maps and tracks newly reported short hazards between 50 and 200 feet AGL in a restricted database, allowing low-altitude pilots to see hazards on digital flight charts.
- Airfield Proximity: Towers within 3 NM (or approximately 4 miles) of a public runway or airfield face additional operational and notification requirements.
For Determinations of No Hazard issued after Oct. 28, the FAA links approval directly to Advisory Circular compliance.
Instead of treating obstruction marking and lighting as independent maintenance tasks, the FAA considers the determination a binding operational blueprint. Engineers filing routine site modifications or structural alterations must follow these marking and lighting specifications strictly to maintain valid authorization, Keiler told us.
Common pitfalls
When we asked him about the most common compliance pitfalls and logging mistakes, Keiler explained that self-inspection failures usually stem from manual tracking gaps rather than hardware faults.
“If a station relies on manual daily inspections, rather than automated network monitoring tools, engineers will then need to frequently perform visual night-checks,” Keiler said.
Auditors reject inspection logs that omit exact time and date stamps or required chief operator sign-offs. The FAA also enforces a strict 30-minute deadline to issue a NOTAM after a top beacon or flashing light failure, regardless of whether repairs are already underway.
Keiler encourages station owners, licensees and broadcast engineers to obtain the SBE and NAB Broadcast Self-Inspection Guides, which address tower compliance and daily logging requirements directly.
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