Transcript FAA/FCC Presentation by Wireless Applications.

FAA/FCC Presentation by
Wireless Applications Corp.
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The process of current filing method.
I don’t need to file….
Required filings of FAA and FCC.
Going into the Opinion letter details.
Timelines to expect.
Towair, AM towers.
What is airspace.
Glide slopes, charts, approaches, routes.
Painting and Lighting, not always simple.
What it has cost some.
PRODUCT & SERVICES
OVERVIEW
Wireless Applications, Corp., is your solution for GIS mapping, Analysis, and
FAA/FCC filing issues. We offer consulting services and customized
intranet-based software products for addressing your specific needs. We
offer microwave path design, microwave terrain profiling, microwave
protection, microwave keyhole analysis, frequency coordination, FCC filing,
FAA filing, co-locate tower search, Carey contours, geographic mapping, RF
design, RF propagation, call center customer trouble ticket management
and project management services for cellular, PCS and broadband wireless
technology.
Experience
For our business and in our employees’ individual pasts, we have processed FAA and
FCC work for nearly 15 years.
Since early employment days of McCaw
Communications and Western Wireless Corp (later splitting to VoiceStream/T-Mobile)
we have designed, analyzed, and filed FAA and FCC regulatory on thousands of sites
nationwide.
This gained us a very strong relationship with all the FAA regions and with FCC. We
learned through visits what their process was and modified our paperwork and
submittals to best fit and streamline their work load. By doing this we clearly saw our
filings moved to the top of the incoming stack of FAA proposals.
Due to our relationships and very clean paperwork, we saw a direct timeline change for
the build-outs of nearly 50%. Some were even to the point of getting signed while at
the FAA local office !
Our relationships with FAA Regional offices, DOT and FCC continue today and we
pride ourselves on clean, professional filings.
The importance of having the correct “X on the Map” and associated documentation
has become a business necessity in both marketing and regulatory.
I don’t need to file…..
• The overall myth is “I don’t need to file until I’m 200ft or more.” Wrong.
• All types of structures that ‘may have’ impacts to airspace are required.
• I got my final determination and built it, I’m good: Did it require a 7460-II for a notice of
construction? How about one for reaching its greatest height? Determinations have expiration dates.
• FCC registration number? If it was also required, there will be a notice of construction required. It
is this that triggers an FAA so that it doesn’t expire.
• My lights are out on the tower, I’ll get a crew out there: You have 24 hours to notify the local airport
authorities, the crew is second. FAA authorities are very cool with getting these and quite the opposite
when not. One airplane is all it takes to run into the structure and you are in the news…with your
lawyers.
• Oh no, the FAA is going to fine us! : FAA produces the data for somebody else to fine or sue you.
FCC is the leader; they look for issues and non-compliance, and then trap you with questions.
Answering the first few are easy, then the next couple set you up. It is ALWAYS best to admit and fix
as soon as YOU see it, and not to wait for the letter.
• In the last 9 years the FAA has grown into monitoring frequencies and require you to have them on
your filings…and the FCC? They look for painting and lighting and FAA non-compliance.
• My company changed names, what now? Oddly enough, the FAA doesn’t want it and in almost ALL
cases will no longer accept an update. FCC, however, requires it and all your FRN data and associated
corporate structure forms (if a carrier), for full disclosure.
Structures requiring notification
(Absolutes)
• Any construction of more than 60.96 meters (200 ft)
AGL at its base.
• Any construction that would exceed the imaginary
surface of a public-use airport at 1 of the following
slopes:
• 100 to 1 (6.1 km/20,000 ft)
• 50 to 1 (3.05 km/10,000 ft)
• 25 to 1 (1.52km/5000 ft)
FCC Antenna Structure Registration
• An Antenna Structure Registration is a 7 digit number
used to identify a structure with the FCC.
• All structures in excess of 60.96 meters (200 ft) AGL are
required to be registered with the FCC.
• A structure cannot be registered with the FCC, without
first being filed with the FAA.
• The ASR number must be posted in a conspicuous place
so that it is readily visible.
• The ASR may be amended as necessary, as site data
changes.
Timelines
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It is typical for the FAA to take between 30- 45 days to evaluate a requested structure, once
it has been evaluated a Determination of No Hazard to Air Navigation or a Notice of
Presumed Hazard will be issued. WAC has seen as little as a week, although since the FAA
has changed its internal processes they seem more consistent with the longer times.
The FAA will require submittal of a 7460-2, Notice of Actual Construction or Alteration, on
all structures of greater than 60.06 meters (200 ft) AGL.
A structure may take longer than 45 days to evaluate, contingent upon any issues that the
FAA may discover, i.e. within an airport imaginary surface or terminal procedure.
If a Notice of Presumed Hazard is issued, the tower owner has the option to lower the
structure or proceed with the Extended study process, which adds 90-120 days to the
process and entails circularization to the public for comment, before the approval can be
issued. The FAA cannot predict the outcome of the extended study prior to Public
Circularization.
State DOT notification is required for the following states: Idaho, Indiana, Kentucky,
Maryland, Massachusetts, Michigan, Ohio, Oregon, Pennsylvania, South Dakota, Virginia &
Wisconsin. The DOT is notified of an application at the same time as the FAA.
The State DOT can overrule the FAA determination. In these instances, you must abide by
the DOT decision rather than the FAA determination.
Each DOT has a different method of notifying approval or denial of an application.
FCC TOWAIR
• TOWAIR is the FCC’s online evaluation tool for
proposed/existing structures.
• TOWAIR should not be used as the sole method of
evaluation for a new structure, as the FCC admits it can
produce errors when evaluating a structures FAA
notification requirements. (remember, they fine per what the
FAA told you to do)
AM Station Proof of Performance
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Any tower that is within 0.62 mi (1.0 km) of omni AM stations and 1.99
mi (3.2 km) of directional AM stations are required by the FCC to run a
Proof of Performance measurement before and after construction.
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This requires a study be done on sufficient field
strength measurements for at least 10 locations
along 8 equally spaced radials for an omni antenna,
prior to the installation of any appurtenances on the
tower.
The tower owner shall be responsible for
installation and maintenance of any de-tuning
necessary to prevent adverse effects to the radiation
pattern of an AM station.
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The Opinion Letter
What is important ?
Aren’t they all the same ?
Structure height versus
Tip height.
Surveys – 1A and 2C are
very important, especially
with impacting airspace.
In cases where the
structure could impact the
terminal procedures, the
FAA will require one.
The invisible Airspace
The actual airport
IFR Routes and Sectionals
VOR transmitters (hats)
Transmitters are fixed and
off limits to structures
being next to them.
They send highly
directional RF channels for
the planes to track.
Flip chart maps and runway details
Must look at all runways, glide slopes and
the impacts the structure may have into it.
Approaches
• Impacts of structures can
happen at a variety of areas.
• Approaches, Horizontal and
Conical surfaces get hit the
most.
•These invisible lines are
highly protected and if a
structure was built impacting
it without filing, they have
been known to have it
dismantled.
•The orange Approaches are
the most protected.
•Extended Studies can be filed
to get possible approvals of
structures impacting the
airspace. Depending on the
request, area, etc, these
applications can take an
additional 90-120+ days.
•Public Airports are protected
by the FAA, Private Airports
are not.
Glide Slopes, Horizontal/Conical Surfaces
• These yellow and blue
surfaces are easier for us to
get structures of exceeding
heights granted.
•If under, there is a very high
likelihood of a final
determination.
•7460-II can be required for
nearly all filing within this
area.
Instrument Approaches / IFR, VFR segments
• The red and green reflect
Instrument Approaches.
•The blue elevated lines the
IFR segments. Transmitted
via the ‘hats’.
•These are protected 1 mile
across and 1000ft thick.
Getting a structure height
that may impact the bottom
edge of this can easily get
denied.
•Both are impact areas but
are hit less frequently with
structures.
•Terrain factor – Mountains
or other high elevated areas
may and have been impacted
with structures miles away
from airports. This can mean
a 60ft structure needing
lights on a mountain top 11
miles away.
Climb and descent areas (VFR traffic pattern airspace)
• If an airplane needs to
circle back from aborting a
landing, or is looking at
other climb and descent
issues, they must follow
close to the overlaid darker
blue square outlines.
•These areas are very seldom
impacted with structures but
are still part of the areas we
must look at when
reviewing.
Towers and Heights
• Existing Structures show
the majority under the
airspace caps with a few that
got granted extended
variations.
Towers and Heights
(Zoomed)
Microwave
• Other issues that come up
that can be impacted by
airspace.
•We have had to perform a
number of engineering
studies showing the paths
and if they would be
impacted by airplanes in the
airspace areas.
Painting and Lighting
•Many types and standards
•Different structure types can
require special painting and
lighting.
•Tight tolerances to
‘approved’ lighting and
painting.
Marking and Lighting Requirements
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Any tower that would exceed 60.96 meters (200 ft) AGL requires marking and Lighting
for aviation safety.
The 2 most common types of Marking and Lighting requirements are Painted w/Red
Lights and Med Dual (steady burning white lights during the day/flashing red beacon at
night) Lighting.
All lighting systems must be alarm monitored and require notification on any lighting
outage of more than 30 minutes in length.
A NOTAM (Notice to Airmen) must be filed for all lighting outages of more than 30
minutes on an antenna structure. The NOTAM will remain open for 15 days and it can
be extended once for another 15 days. If the lighting issue is not resolved and the
NOTAM closed after this time, the registered tower owner can be fined by the FCC
Enforcement Bureau.
A structure that does not require Marking or Lighting can be lit voluntarily without
notifying the FAA, as long as the Marking and Lighting is installed and maintained in
accordance with the most recent FAA Advisory Circular specifications (70/7460-1 K,
Change 2).
Painting and Lighting
We have built a special output just for the variations and heights for each lighting element.
Posting the ASR
• The FCC ASR number must be displayed in an obvious manner
so that it is readily visible at the base of the antenna structure.
All placards noting the ASR number must be weather resistant
and of sufficient size to be easily seen.
• There can be multiple postings of the ASR number, such as on
any gating or fencing around the tower, and there should be one
at the ‘last public access point’ along any roads that would lead
to a tower not readily accessible.
• This is one area the FCC physically looks for in the field.
• ASR signage should be checked regularly for damage or
missing signs. If something happens to a sign that is posted and
the FCC audits it, they WILL issue a forfeiture notice.
Why is all this important to us?
You do NOT want to be on the FCC Forfeiture Orders list. It is not only costly, but
once on it, you are watched. This also is an impact to public statements, investors, etc.
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Titan Towers, LP – fined $2,000 for failure to post its
ASR number so that it is readily visible in a
conspicuous place near the base of the antenna tower.
Tidewater Communications LLC – fined $10,000 for
failure to exhibit obstruction lighting on their ASR.
Western Slope Communications, LLC – fined $13,000
for failure to supply a NOTAM for a lighting outage
that had been in effect for ‘several weeks’.
AAT Communications Corporation – Fined $10,000 on
a structure that had chipped and faded paint and was
partially obscured with black cabling.
ACS Wireless – fined $3,000 for failure to perform an
Ownership change on a structure.
Crown Communication, Inc – fined $8,000 for
unpainted cabling obscuring tower visibility from the
air.
SpectraSite Communications, Inc – fined $120,500 for
failure to register 4 antenna towers of greater than
60.96 meters (200 ft) AGL.
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Exosphere Broadcasting, LLC – fined $10,000 for
failure to maintain obstruction lighting from sunrise to
sunset on a tower.
Crown Castle GT Company LLC – fined $10,000 for
failure to exhibit required obstruction lighting during
daytime hours.
Gresham Communications, Inc – fined $10,000 for
failure to continuously exhibit red obstruction lighting
and failure to register tower with the FCC.
Cumulus Licensing Corp – fined $10,000 for failure to
clean and re-paint tower to maintain good visibility.
Threshold Communications – fined $8,000 for failure
to exhibit the structure’s red obstruction lighting from
sunrise to sunset.
Pinnacle Towers LLC – fined $3,000 for failure to
notify of tower ownership change.
Fun Media Group, Inc. – fined $8,000 for failure to
clean and re-paint tower to maintain good visibility.
FCC Forfeiture Orders (continued)
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Aquila, Inc. – fined $10,000 for failure to exhibit
lighting from sunrise to sunset on a tower.
Lotus Communications Corp – fined $10,000 for
failure in maintaining lighting monitoring and
notification requirements on lighting outages.
Mega Communications of St. Petersburg, LLC –
fined $10,000 for failure to maintain prescribed
antenna structure painting and lighting
specifications.
Vector Communications Inc. – fined $20,000 for
failure to exhibit red obstruction lights on 3
antenna structures.
Dead Air Broadcasting Company, Inc. fined
$3,000 for failure to register antenna tower.
Lycom Communications, Inc. – fined $3,000 for
failure to register antenna tower.
MCC Georgia LLC – fined $10,000 for failure to
exhibit lighting from sunrise to sunset on a tower.
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SpectraSite Communications, Inc. – fined $30,000
for failure to maintain required antenna obstruction
lighting.
Clear Channel Broadcasting, Inc. – fined $10,000 on
a structure that had chipped and faded paint.
AAT Communications Corp –fined $10,000 for
failure to maintain prescribed antenna structure
painting and lighting specifications.
Signal One, LLC – fined $10,000 for failure to
continuously exhibit all medium intensity obstruction
lighting on its tower during daylight hours.
Max Media of Montana, LLC – fined $8,800 for
failure to address lighting outages in a timely manner
on a tower.
Best Country Broadcasting, LLC – fined $3,000 for
failure to register tower.
Midwest Partners, LLC – fined $10,000 for failure to
clean and re-paint its antenna structure as often as
necessary to maintain good visibility.
Morris Communications, Inc. – fined $3,000 for
failure to register tower.
FCC Forfeiture Orders (continued)
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Gold Coast Broadcasting Company – fined
$10,000 for failure to maintain specified painting
on its antenna structure.
East Tennessee Radio Group, L.P. – fined $2,400
for failure to notify of tower ownership change.
Verizon Wireless (VAW) LLC – fined $10,000 for
failure to clean and re-paint its antenna structure as
often as necessary to maintain good visibility.
South Central Communications Corp. – fined
$8,000 for failure to maintain an automatic alarm
system to detect lighting outages and provide
notification to the registered tower owner.
AT&T Wireless Service, Inc. – fined $117,000,
including 1 instance of failing to register a
structure, 3 instances of failure to post an ASR
sign in a conspicuous location, 1 instance of
failure to maintain good visibility of painted
antenna structures and 2 instances of failure to
have proper lighting on an antenna structure.
Voicestream PCS I License, L.L.C. – fined $8,000
for failure to exhibit all high and medium intensity
obstruction lighting on an antenna structure.