Six towers in Oklahoma and one in New Mexico were the subject of Notices of Violation (NOV) earlier this month after FCC agents noted that the paint on the towers was faded and chipped. Some of the NOVs also noted that the respective structure owners had failed to post the Antenna Structure Registration Number (ASRN) at the gate of the surrounding fence, and that any signage at the base of the structure was not visible from the gate of the fence.

In accordance with the rules of the FCC, owners of antenna structures must regularly inspect those structures to ensure the structures continue to comply with all FCC requirements. Indeed, the rules require owners to inspect the antenna structure’s lights (manually or by automatic indicator) at least once every 24 hours, and to inspect all lighting control devices, indicators and alarms every three months. Owners must also maintain a record of any lighting malfunctions, including the nature of the malfunction, the date and time of the malfunction, the date and time of FAA notification, and the date, time and nature of repairs.

As this month’s NOVs explicitly note, the FCC is free to take further steps against the tower owners, including issuing fines, and often does. Tower owners should therefore be careful to ensure that:

  • The ASRN is conspicuously displayed so that it is readily visible from the base of the structure;
  • Materials used to display ASRN are weather-resistant and large enough to be easily seen from the base of the structure;
  • Where the tower is surrounded by a fence, the ASRN is posted where it will be readily visible from the fence gate;
  • Antenna structures exceeding 200 feet are painted and lighted according to FAA specifications; and
  • Antenna structures are cleaned or repainted as often as is necessary to maintain good visibility.