This is correct. ULS automatically checks all Part 101 applications and any that fail TOWAIR are red lighted - the application cannot be filed without additional information, such as documentation that it passes FAA Notice Criteria (TOWAIR sometimes fails things that the FAA passes), an FAA application file number or determination, an ASR file number, or other documentation showing the tower is below surrounding structures or towers. Coordinators do not require ASRs and only ask for them when it will become an obstacle to filing the FCC application (due to failed TOWAIR or FAA Notice Criteria tool). From a liability standpoint, it would seem prudent to run the FAA tool on every tower - takes about 1 minute. The 200’ requirement is the most prevalent, but there are many others that require ASRs as detailed on the FAA site:
The requirements for filing with the Federal Aviation Administration for proposed structures vary based on a number of factors: height, proximity to an airport, location, and frequencies emitted from the structure, etc. For more details, please reference CFR Title 14 Part 77.9 <http://www.ecfr.gov/cgi-bin/text-idx?rgn=div5&node=14:2.0.1.2.9>. You must file with the FAA at least 45 days prior to construction if: your structure will exceed 200ft above ground level your structure will be in proximity to an airport and will exceed the slope ratio your structure involves construction of a traverseway (i.e. highway, railroad, waterway etc...) and once adjusted upward with the appropriate vertical distance would exceed a standard of 77.9(a) or (b) your structure will emit frequencies, and does not meet the conditions of the FAA Co-location Policy <https://oeaaa.faa.gov/oeaaa/downloads/external/content/CVCC_FR_2007.pdf> your structure will be in an instrument approach area and might exceed part 77 Subpart C your proposed structure will be in proximity to a navigation facility and may impact the assurance of navigation signal reception your structure will be on an airport or heliport filing has been requested by the FAA > On Aug 9, 2020, at 2:00 PM, Ken Hohhof <af...@kwisp.com> wrote: > > I think equipment needing an FCC license invokes federal authority, which > triggers checking for things like whether the tower needed FAA approval, as > well as other things like environmental, historical, native Americans, etc. > The FAA approval should probably have been done all along, and I think it’s > diligence on the part of the frequency coordinator that finds you needed to > submit to the FAA. But part of that process gets an ASR assigned. I don’t > know if that happens if you are on a wetland, historical site, Indian burial > ground, etc. I was told you can submit for the FCC license once you get the > FAA determination, you don’t actually need the ASR number. > > From: AF <af-boun...@af.afmug.com <mailto:af-boun...@af.afmug.com>> On Behalf > Of ch...@wbmfg.com <mailto:ch...@wbmfg.com> > Sent: Sunday, August 9, 2020 12:27 PM > To: AnimalFarm Microwave Users Group <af@af.afmug.com > <mailto:af@af.afmug.com>> > Subject: Re: [AFMUG] FAA determination ... finally > > I only do ASR if I am over 199’ > > From: Mark Radabaugh > Sent: Sunday, August 9, 2020 11:20 AM > To: AnimalFarm Microwave Users Group > Subject: Re: [AFMUG] FAA determination ... finally > > We have lots of them that do not have ASR’s. I would guess that only about > 20% of our locations have ASR’s since the majority are grain legs and water > tanks. > > Mark > > >> On Aug 9, 2020, at 8:32 AM, Matt Hoppes <mattli...@rivervalleyinternet.net >> <mailto:mattli...@rivervalleyinternet.net>> wrote: >> >> I was always under the impression and I thought I even read in law that if >> you had any licensed transmitter of any sort you had to have an antenna >> structure registration number to make it legal? >> >> Basically it was the way that the FCC managed the tower because they didn’t >> really have management power over unlicensed frequencies. >> >> >>> On Aug 9, 2020, at 8:12 AM, Lewis Bergman <lewis.berg...@gmail.com >>> <mailto:lewis.berg...@gmail.com>> wrote: >>> >>> >>> Maybe things have changed but an ASR was never required for licensed >>> transmitters by the FCC. A lot of coordinators required them because it >>> makes their job easier, but they weren't required by the FCC. >>> >>> On Sat, Aug 8, 2020 at 9:15 AM Kurt Fankhauser <lists.wavel...@gmail.com >>> <mailto:lists.wavel...@gmail.com>> wrote: >>>> How were you able to put up two 18ghz links on that tower before you were >>>> able to get an ASR number from the FCC? >>>> >>>> On Fri, Aug 7, 2020 at 12:18 PM Ken Hohhof <af...@kwisp.com >>>> <mailto:af...@kwisp.com>> wrote: >>>>> Good news, FAA finished their determination on a 45 foot tower that has >>>>> been there for 20 years, and which isn’t higher than the power poles >>>>> between us and the airport. >>>>> >>>>> It only took them 4 months. >>>>> >>>>> Not sure what I would have done if they had denied it. We already put up >>>>> two 18 GHz links off the tower (replacing 5 GHz). >>>>> -- >>>>> AF mailing list >>>>> AF@af.afmug.com <mailto:AF@af.afmug.com> >>>>> http://af.afmug.com/mailman/listinfo/af_af.afmug.com >>>>> <http://af.afmug.com/mailman/listinfo/af_af.afmug.com> >>>> -- >>>> AF mailing list >>>> AF@af.afmug.com <mailto:AF@af.afmug.com> >>>> http://af.afmug.com/mailman/listinfo/af_af.afmug.com >>>> <http://af.afmug.com/mailman/listinfo/af_af.afmug.com> >>> >>> >>> -- >>> Lewis Bergman >>> 325-439-0533 Cell >>> -- >>> AF mailing list >>> AF@af.afmug.com <mailto:AF@af.afmug.com> >>> http://af.afmug.com/mailman/listinfo/af_af.afmug.com >>> <http://af.afmug.com/mailman/listinfo/af_af.afmug.com> >> -- >> AF mailing list >> AF@af.afmug.com <mailto:AF@af.afmug.com> >> http://af.afmug.com/mailman/listinfo/af_af.afmug.com >> <http://af.afmug.com/mailman/listinfo/af_af.afmug.com> > > -- > AF mailing list > AF@af.afmug.com <mailto:AF@af.afmug.com> > http://af.afmug.com/mailman/listinfo/af_af.afmug.com > <http://af.afmug.com/mailman/listinfo/af_af.afmug.com>-- > AF mailing list > AF@af.afmug.com <mailto:AF@af.afmug.com> > http://af.afmug.com/mailman/listinfo/af_af.afmug.com > <http://af.afmug.com/mailman/listinfo/af_af.afmug.com>
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