FCC Waives Quarterly Tower Inspections for American Tower and Global Signal

If your station’s antenna is located on a tower that requires lighting, you should be aware of Section 17.47(b) of the FCC rules stating that tower owners, “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 (sic) that such apparatus is functioning properly.” This isn’t much of a problem for broadcasters with one or two towers, but what if you were responsible for thousands of towers with lighting requirements?

American Tower Corporation and Global Signal Inc. each have thousands of towers requiring inspections. The companies filed a Request for Waiver of the quarterly inspection requirements to allow inspections once a year. They argued that they use monitoring systems, which, as ATC asserted, have self-diagnostic functions that are sufficiently robust to make the quarterly inspections unnecessary to ensure the control, indicator and alarm systems on the towers are working properly.

ATC uses the Eagle Monitoring System developed by Flash Technology. ATC points out that Eagle’s Alarm Response center is contacted by the monitoring system at each tower if there are failures in the tower lighting system. Eagle’s central site polls each site every 24 hours, regardless of the independent on-site lighting system notification, and runs a full diagnosis of the lighting system. In addition to these automated functions, Eagle has a network operations call center, plus a backup site, staffed with trained personnel capable of responding to alarms.

GSI towers are monitored using the MARK system. The MARK system receives and reports alarms generated when the self-diagnostic functions in the obstruction lighting systems determine there is a malfunction. MARK has a Network Operations Center in Sarasota, Fla. to review alarms and interrogate the site for additional information. As with the Eagle system, MARK communicates at least once a day to ensure there is communication between the tower site and the NOC. GSI also maintains a backup NOC in the event of a catastrophic failure at the primary NOC.

The FCC received comments supporting the requests, although AOPA, representing over 406,000 general aviation pilots, opposed ATC’s waiver request indicating that although it favored the introduction of new technology, the quarterly inspection should continue until these technologies have been thoroughly evaluated. AOPA also alleged, “ATC’s history of non-compliance with lighting and inspection requirements” provides a reason for denying its request.

The FCC found the “uncontested evidence submitted in the record by ATC, and corroborated by Flash, establishes that quarterly inspections are unnecessary for those towers using ATC’s Eagle monitoring system. Features of this system provide sufficiently robust monitoring of the control devices, indicators and alarm systems so as to render quarterly inspections unnecessary, thus warranting grant of ATC’s waiver request.” It rejected AOPA’s objections, saying they were not “persuasive in light of the record before us.” The FCC approved GSI’s waiver request as well.

The FCC said, “such advanced technology provides the benefits of more rapid response where there has been a lighting failure, and thus the public interest is served with respect to aircraft safety.”

Details on the arguments for the waiver and the opposition are available in the FCC Memorandum Opinion and Order FCC 07-89.

Doug Lung

Doug Lung is one of America's foremost authorities on broadcast RF technology. As vice president of Broadcast Technology for NBCUniversal Local, H. Douglas Lung leads NBC and Telemundo-owned stations’ RF and transmission affairs, including microwave, radars, satellite uplinks, and FCC technical filings. Beginning his career in 1976 at KSCI in Los Angeles, Lung has nearly 50 years of experience in broadcast television engineering. Beginning in 1985, he led the engineering department for what was to become the Telemundo network and station group, assisting in the design, construction and installation of the company’s broadcast and cable facilities. Other projects include work on the launch of Hawaii’s first UHF TV station, the rollout and testing of the ATSC mobile-handheld standard, and software development related to the incentive auction TV spectrum repack.
A longtime columnist for TV Technology, Doug is also a regular contributor to IEEE Broadcast Technology. He is the recipient of the 2023 NAB Television Engineering Award. He also received a Tech Leadership Award from TV Tech publisher Future plc in 2021 and is a member of the IEEE Broadcast Technology Society and the Society of Broadcast Engineers.