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Like all tower owners, you know that the government lays out strict requirements for the monitoring of your obstruction lighting systems.
Authority flows from Congress to the FCC, guided by the FAA
As the FCC's media release describes:
The FCC has been given the authority by Congress to require the painting and/or illumination of antenna towers when it determines that such towers may otherwise constitute a menace to air navigation... The FCC's rules governing antenna tower lighting and painting requirements are based upon the advisory recommendations of the FAA... the FCC's rules make the standards mandatory.
In the United States, legislators in Congress can write laws to authorize the creation and empowerment of executive agencies. In this case, there are two in play.
The FAA is the agency that has expertise about hazards to air navigation. That is why they have created guidelines for the proper marking and lighting of antenna structures and other buildings.
However, the FCC (responsible for communications) is where the enforcement mechanisms must lie. It would be cumbersome for the FAA to issue enforcement actions against non-compliant tower owners.
The FCC always requires an FAA determination that an antenna tower will not pose an aviation hazard before it will grant permission to build that antenna tower.
One fascinating interplay occurs when the aviation hazard may be due to communication interference rather than an aircraft collision with a terrestrial structure:
(When, however, the FAA determines that there is an aviation hazard due to possible radiofrequency interference with aviation communication signals, the FCC makes an independent analysis of who will be responsible for resolving possible conflicts, and may not automatically defer to the FAA determination as to what party should bear the cost of any needed equipment changes.)
In this case, there's an acknowledgement that both the FCC and the FAA are involved in radio-frequency communication. The resolution of spectrum conflicts is necessary to keep the aviation system functioning properly, but it is not quite the same as whether or not pilots can see obstructions like antenna towers.
In the event of such a conflict, the FAA will represent the aviation community, tower owners will represent their own interests, and the FCC will have to determine an appropriate balance.
Let's see what the FCC has to say about your obligation to install and maintain a viable tower light monitoring system:
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 be 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.
There are a few things to pick apart here.
First, you technically have the ability to pay someone to monitor your tower lights each and every day (including weekends and holiday). I've heard of informal agreements made with farmers living near each tower site. That might satisfy the law, but I wouldn't want my liability to hinge on something so obviously prone to human error.
Fortunately, you have a second option. That's really the only one I can recommend in 2022 and beyond. You're never had more options for monitoring your tower lights efficiently. A small remote monitoring solution that picks up simple dry contacts can do this job. It will have none of the reliability issues of a human, and any failures will be detected within seconds instead of hours or days.
Do also note that you are required to inspect your monitoring system every 3 months to ensure that it has not failed.
All of the above falls under the heading of "a failure can only be your fault." Note the following additional notice from the FCC:
However, the owner is further advised that even if they delegate this responsibility to a second entity, such as a tower lighting monitoring company, the owner remains responsible to ensure that all of the information required under FCC rules is provided.
That's one more reason why a simple monitoring device that you manage yourself can be superior to a third-party monitoring service. Seeing as the government refuses to let you discharge your legal obligation, you might as well make sure you're compliant yourself.
A Remote Telemetry/Terminal Unit (RTU) is an excellent way to collect basic status from your tower obstruction lighting system. It is the kind of device called out in the FCC requirements as an "automatic alarm system".
The "alarm" part is accomplished by both detection and notification. It's most common to wire your RTU into a simple contact closure from your lighting system. You an also get a bit fancier by monitoring the power flow through your lights. If there's no (or reduced) power draw, something is wrong.
Once the RTU knows your lights are dark, "notification" is the next step. A good RTU can do this in two ways.
If you only have a few towers, the best option is usually to receive an email (or an SMS text message) alert to advise that you have a tower light failure. You can then observe the failure yourself (another requirement) and notify the FAA to issue a NOTAM (Notice to Airmen).
If you have many towers, managing your growing fleet of individual RTUs will get out of hand. I usually advise my clients that, upon reaching about 10 monitored locations, it's time to think about some kind of central server. You can choose a standards-compliant SNMP manager, including one like the T/Mon.
Compared to other monitoring requirements I've dealt with for things like building fire alarms, the FCC's rules are really pretty simple. Your challenge is to choose a proven solution that you can install and not have to constantly worry about.
Give me a call today to discuss your options. Even if you decide to choose a different product, I'll help you get your bearings so you can make an informed decision.
You can reach me at 1-800-693-0351 or email@example.com