Do you own or service a tower or structure that less than 200’ AGL?

Do you plan of constructing one in the near future?


The requirements of the tower lighting may increase with the newly signed H.R. 636 “FAA Extension, Safety and Security Act of 2016” on July 15, 2016.  Previously, owning a tower less than 200’ AGL meant that the FAA did not typically consider it a hazard to air navigation, thus no requirement to purchase and maintain Obstruction Lighting equipment.


The HR 636 was passed to extend the FAA’s operations for another 12 months through September 2017.  The three main sections are Title I – FAA Extension, Title II – Aviation Safety Critical Reforms, and Title III – Aviation Security.  Within Title II Subtitle A – Safety, Section 2110 details that the FAA must enact new Tower Marking within one year of enactment of the HR 636 for “covered towers”.  These guidelines require that a “covered tower” be “clearly marked” per AC 70/7460/1L, dated December 4, 2015.


The real question becomes, What is a Covered Tower? There are guyed towers and self-support towers, but what is a covered tower? Here is the definition of a covered tower per the HR 636, Section 2110.d.1.A.i:

   i. Is a self-supporting or supported by guy wires and ground anchors;

  ii. is 10 feet or less in diameter at the above-ground base, excluding concrete footing;

 iii. at the highest point of the structure is at least 50 feet above ground level;

 iv. at the highest point of the structure is not more than 200 feet above ground level;

  v. has accessory facilities on which an antenna, sensor, camera, meteorological instrument, or other equipment is mounted; and

 vi. is located—

        a)      outside the boundaries of an incorporated city or town; or

        b)      on land that is (i) undeveloped; or (ii) used for agricultural purposes.


With all that, the act does provide some exclusions:

    (I) is adjacent to a house, barn, electric utility station, or other building;

    (II) is within the curtilage of a farmstead;

    (III) supports electric utility transmission or distribution lines;

    (IV) is a wind-powered electrical generator with a rotor blade radius that exceeds 6′

    (V) is a street light erected or maintained by a Federal, State, local, or tribal entity.