FCC Encourages Tall Tower Owners to Snuff L-810, Steady-Burning Lights

The FCC is encouraging owners of towers taller than 350 ft. AGL to take advantage of lighting changes passed by the FAA, to both help save migratory birds and reduce operations costs.   

“Lighting changes on towers taller than 350 ft. AGL involve extinguishing L-810, non-flashing, side-markers and do not require any additional cost or fees,” states a message from the FCC to tall tower owners. “Lighting changes on towers 150-350 ft. AGL involve reprogramming non-flashing, LED, side-markers to flash synchronously with flashing L-864 lights.”

“New tower lighting schemes should now follow the revised guidance, and operators of towers with the old lighting system should submit plans explaining how and when they will transition to the new standards,” according to the FAA in 2016.  

Testing conducted by the FAA determined that birds are not attracted to the flashing lights of towers but are attracted to the non-flashing, steady-burning L-810, side-marker lights. In response to these findings, the FAA determined that extinguishing the L-810, non-flashing lights on towers taller than 350 ft. AGL and reprogramming L-810 lights on towers 150-350 ft. AGL, is safe for aviation. In December 2015, the FAA changed its red tower lighting recommendations to systems without non-flashing L-810 lights and said that minimizes bird collisions by as much as 70 percent and on towers taller than 350 ft. AGL, reduces tower construction, maintenance, and energy costs.  

Extinguishing the non-flashing lights on existing towers taller than 350 ft. AGL can be completed without climbing the structures, according to the FCC. Similarly, the elimination of continuously burning security lights on the buildings under towers will minimize bird attraction to the site. If security lighting is required, the FCC advises using motion sensor triggered security lighting under your tower.

Here’s how to file the necessary paperwork to process the change. A “lighting deviation” can be used to extinguish or eliminate L-810 steady-burning side lights from an existing registered tower taller than 350 ft. AGL and to reprogram L-810 steady-burning side lights to flash on registered towers 150-350 ft. AGL.

What to do:

1. File a Marking and Lighting study electronically with the FAA (https://oeaaa.faa.gov/oeaaa/external/portal.jsp) requesting the elimination or omission of steady-burning lights (L-810) or requesting that steady-burning lights flash with Form 7460-1, Notice of Proposed Construction or Alteration. Designate structure type: “Deviation from Red Obstruction Light Standards.”
2. Once the FAA has approved the request and assigned a FAA Study Number, file Form 854 with the FCC via the Antenna Registration System (ASR). Please select “MD – Modification” and choose the appropriate FAA Lighting Style. The FCC typically will approve the application and modify the registration within 24 hours.
3. Once the lighting change for a tower has been granted by the FCC via ASR, the L-810 steady-burning side lights can be extinguished on towers taller than 350 ft. AGL and reprogrammed to flash in concert with L-864 lights on towers 150-350 ft. AGL. Extinguishing L-810 lights and reprogramming lights are typically accomplished in the tower transmission building and do not ordinarily require climbing the tower. Per the FAA requirements, flashing red lights should flash at 30 FPM (+/- 3 FPM).

January 9, 2018