Updated 04/10/01

Failure To Register Antenna Structures With FCC May Result In Monetary Penalties

In 1995, the Federal Communications Commission adopted rules requiring the owner of an antenna structure, which must receive Federal Aviation Administration (FAA) approval prior to construction, to register their structure with the FCC.

New antenna structures, or structures that were modified in a way that required a new FAA no-hazard determination (e.g., change in coordinates, ground elevation or overall height), were required to be registered upon receipt of the new FAA determination.

Existing antenna structures were required to be registered over a two-year period, beginning July 1996. Upon registration, the FCC issues a registration certificate to the structure owner, who is then required to provide copies of the registration certificate to tenants of the structure and to post the registration number at the antenna structure.

The FCC has indicated that there has been poor compliance with the antenna structure registration requirement, and has warned licensees that antenna structure owners that do not register their structures with the FCC may be subject to penalties.

Over the last few months, the FCC has returned and refused to process applications that involve unregistered antenna structures requiring registration.

More recently, the FCC has been sending out letters to licensees using antenna structures that may require registration and requesting the licensee to provide:

• registration number if the structure is registered,
• the name and address of the structure owner if the structure is owned by someone else, or
• explain why the structure does not require registration.

The letter requests a response within 30 days and indicates that failure to respond may result in penalties.

What Kind of Structures Must be Registered with the FCC?

Any structure that requires FAA review and a determination of no hazard to aircraft prior to construction must be registered with the FCC.

Antenna structures that do not require FAA clearance should not be registered.

The following may provide some guidance:

• Any antenna tower more than 200 feet tall requires FAA clearance.

• Structures involving short antennas (20 feet or less) mounted on buildings normally do not required registration.

For purposes of making this determination, other man-made structures such as water towers, grain elevators that are not built specifically for mounting antennas are treated like buildings.

Keep in mind that even though your own antenna may not trigger the FAA filing and FCC registration requirement, the structure might require registration if another tenant on the tower has an antenna that extends more than 20 feet above the building.

• Ground mounted antennas 20 feet or less above ground normally do not require registration, unless the antenna is mounted on airport property.

• Antenna structures between 20 feet and 200 feet above ground may require registration, depending on:
• distance from the nearest airport,
• the relative elevations of the airport and the antenna structure, and
• the length of the runways at the airport.

The FCC has a program (TOWAIR) on its Internet web site that can be used to determine whether FAA notification, and FCC registration, of the structure is required. The AICC section of CSAA’s Web site, www.csaaul.org, has a link to this section of the FCC Web site.

Who Needs to Register?

The owner of an antenna structure that requires notification to the Federal Communications Commission must register the structure with the Commission.

A tenant on an antenna structure requiring registration may not register.

How to Register

An antenna structure may be registered by completing and filing FCC form 854. A copy of this form is available on the FCC’s forms internet page. The AICC section of CSAA’s Web site, www.csaaul.org, has a link to this FCC page.

Copies may also be obtained by calling the FCC’s Forms Distribution Center at 1-800-418-FORM (3676), or from the FCC’s Fax-on-Demand service by calling (202) 418-0177 from the handset of a fax machine and following the prompts.

The form includes instructions on how and where to file this form.

An antenna structure may also be registered electronically over the Internet. The AICC section of CSAA’s Web site, www.csaaul.org, has a link to this section of the FCC Web site.

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