Relief For Tower Owners And Migratory Birds


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By Joelle Gehring, Biologist at Federal Communications Commission reprinted by permission from Radio World 8/19/16

migratory joelle gehringAs the biologist for the Federal Communications Commission, I work on issues involving migratory birds and endangered species. I am eager to spread the word about the new Federal Aviation Administration tower lighting recommendations that can reduce your tower maintenance and construction costs, as well as reduce migratory bird collisions.

Every year, millions of birds migrate thousands of miles across North America to Central America and elsewhere as seasons change, following the weather from cooler to more temperate climates and back again.

migratory bird tower

Ducks, geese, sparrows, warblers and other North American migratory birds follow these flight patterns annually. The Arctic Tern, for example, migrates the farthest distance annually, at approximately 44,000 miles round trip.

The FCC has an important protective role to play.  

Communications towers serve as deadly roadblocks on the paths of birds as they travel. Some in broadcasting have expressed doubts that birds collide with communications towers or that bird collisions with towers are a significant threat to bird populations. However, small bird carcasses can be difficult to detect in vegetation and are often quickly removed by scavengers like raccoons and cats. In addition, bird collisions do not occur at every tower on every night, but are instead most common on foggy or rainy nights during spring and fall bird migration.

For more than 50 years, migratory birds have been documented to collide with communications towers, as well as other tall structures. Biologists have conducted focused studies ( and estimate that approximately 7 million birds collide with towers in Canada and the United States every year during their spring and fall migrations. A documented 239 species of birds have collided with towers resulting in fatalities.

Wildlife biologists have concluded that tall, guyed towers are involved in more bird collisions than shorter, self-supported towers.

Most important for towers that have already been constructed, migratory birds are attracted to tower obstruction lights and appear to be more attracted to steady-burning L-810 side-marker lights than to flashing lights. Their attraction to the tower lights results in collisions with tower guy wires and the tower structure itself.


migratory birdsOver the past six years, the FCC has partnered with the Federal Aviation Administration to protect migratory birds by revising the standards used for lighting communications towers, extinguishing non-flashing lights on towers taller than 350 feet above ground level and transitioning from steady-burning tower lights to flashing tower lights on towers 150–350 ft. AGL.

The publication of revised lighting rules last year ( marked the culmination of a multi-year effort to significantly reduce mortality rates of migratory birds resulting from collisions with communications towers. On towers taller than 350 feet AGL, these new FAA tower lighting rules reduce tower construction costs, maintenance costs and energy costs, in addition to minimizing bird collisions by as much as 70 percent. As an added incentive, extinguishing the non-flashing lights on existing towers with red light systems can be completed without climbing the tower.

Going forward, new and altered towers standing more than 350 feet tall may only use flashing lights at night.

Within the next few months, the FAA is expected to promulgate new technical specifications that will similarly enable the use of flashing lights only on towers 150 to 350 feet tall.

In addition, the FCC is encouraging owners to extinguish non-flashing lights ( on towers built before the new FAA standards took effect. In March 2016 the FAA stated, “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.”

Similar to tower obstruction lights, the elimination of continuously burning security lights on the buildings under towers will minimize bird attraction to the site. The FCC encourages the use of motion sensor-triggered security lighting under communications towers, if security lighting is required.

These cumulative efforts will prevent millions of avian fatalities each year in the U.S. and Canada. And extinguishing or eliminating the use of non-flashing lights on towers can save industry construction costs, maintenance costs, energy costs and carbon output with no additional cost to the tower owner.


A “lighting deviation” is required to extinguish or eliminate L-810 steady-burning side lights from an existing registered tower. There is no fee or other charge for requesting a lighting deviation from the FAA, and the FAA typically approves these requests quickly, especially when there is an existing approval for a tower lighting system.

In addition, FAA representatives from each state are available to assist with tower lighting requests. For specific contact information, visit

Below is the step-by-step process for obtaining an FAA lighting deviation determination and updating the FCC’s antenna structure registration database to extinguish red steady-burning lights (download the PDF at

  1. File a Marking and Lighting study electronically with the FAA (online at, requesting the elimination of steady-burning lights (L-810) 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. Please select “MD — Modification” and choose the appropriate FAA Lighting Style. If the FAA grants a lighting deviation referencing an advisory circular other than 70/7460-1L, select “3. Other” and describe the lighting in the field provided. If the FAA issues a new study referencing 70/7460-1L, select the lighting style that corresponds to the lighting in the FAA study. The FCC will typically 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 steady-burning, side-marker, L-810 tower lights can be extinguished. This is typically accomplished in the tower transmission building and does not ordinarily require climbing the tower. Per the FAA requirements, flashing red lights should flash at 30 FPM (+/- 3 FPM).

We hope that you consider taking advantage of this new cost-effective and bird-friendly lighting option.

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