By Thomas R. Ray, III CPBE, AMD, DRB
Tom Ray Consulting
NEW YORK — This week, I was going to write about a computer program that stations could use to experiment with IP codec transmission. And possibly actually use it on the air. Problem is, I ran into a snag with it and haven’t been able to get it to work correctly. Perhaps next week.
So I’ve decided, since it’s spring, to talk about tower painting and lighting. The FCC has several “hot ticket” items they can get you on if your station is inspected. Tower painting is one of them. So is lighting. As an ABIP inspector, I have a particular interest in these topics.
Tower painting is a big item. Typically, depending on the tower, it can be an expensive item – particularly in California, because of the environmental regulations involved with paint. That being said, it is an important item for your station.
First and foremost, your tower is extremely important to your operation. If you’re an AM, the tower IS your antenna. If you’re an FM, that tower supports your antenna. While having the tower painted is an expensive proposition, I am dismayed at the amount of towers I see around that are showing rust – bad rust. Rust is a tower killer. If that tower were to structurally fail, you lose your antenna. No antenna, no broadcasting. No broadcasting, no income. Why a station would allow its infrastructure to rot away is beyond me.
There are a number of reasons tower painting is important. As stated above, painting the tower will protect it from rust and corrosion. Properly painted and maintained towers simply last longer.
But even more important – tower paint is a life/safety issue. The primary purpose of painting your tower is making it visible to pilots. Yes, the argument can be made that, in many cases, if a plane is flying low enough to hit your tower it is already in big trouble, there are many reasons that plane may be flying low, among them onboard instrument failure. That tower needs to stand out. If it is not painted properly, it will simply look like a black line coming up from the ground and can easily be missed. If you do not have Federal color charts available (mentioned below), take a good look at your tower from a distance and close up. An occasional small rust patch – well, that’s OK. If the tower looks orange and rust, well, you have a problem.
There are numerous manufacturers of paint for towers. While the station normally hires a tower company to paint the tower(s), it is the station’s responsibility to insure the correct colors are used. As a matter of fact, there are Federal standards (and paint chips) available to verify the exact shade of paint used on a tower. When you contract with a company to paint your tower, they should be using Outside White for the white stripes (Federal color number 17875) and Aviation Surface Orange (Federal color number 12197). You should ask to see the cans of paint that will be used to paint the tower(s) to insure, in your mind, that the correct colors are being used. In the case of Aviation Surface Orange, the color is a really dark orange – almost red. It is not red as many believe. And it should not look red.
Discuss with your contractor whether latex based paint or oil based paint should be used. I did not like the latex based paints used in prior years because they faded in under five years and looked red after that time. The newer formulations maintain the correct color and wear quite well. Severely rusted towers need to be properly wire brushed and primed, a labor intensive chore that drives up the cost of painting.
Factors in the costs in involved in painting towers are the cost of the paint (this isn’t the stuff you paint your house with – it is precisely colored and intended to maintain its color and to stick to the surface for many years, so it’s much more expensive per gallon), any environmental issues that need to be addressed depending on local codes, and the labor involved in both applying the paint and preparation, such as the wire brushing mentioned above.
Before having a tower painted (or now, if you’re not sure the tower needs painting), look at it from a distance. I’m not talking 30 yards. Go about ¼ mile away and look at the tower. Does it look orange and white? Can you tell where an orange band ends and a white band begins? Or does it look like a black line? If it looks like a black line and you cannot tell where the transitions are between color bands, the tower most likely needs to be painted.
After painting, you should notice a huge difference observing the tower from the same location.
I once worked for a station with towers on a mountain, easily observable from the studios six miles away. Watching the towers from that distance during painting was quite cool, as you could easily see the change. Tower painters work from the top down, as paint, of course, drips down. So you could literally see the change daily as the tower went from this dull thing on the hill on the horizon to this bright orange and white tower.
But it’s not just paint that makes your tower visible. Chances are that your tower has a lighting system, too.
Your station license will tell you how the tower should be lit. The reason for this is that standards have changed from time to time. If you were to read the current regulations, chances are that your older tower is out of compliance. But your station license will supercede the current regulations. Which is important to remember if the FCC inspects your station – you need to have a copy of the lighting specification for your tower(s) available. Additionally, if you make a change and refile your license application with the FCC, make sure the lighting spec that arrives with the new license is the same as with the license you are replacing. If it isn’t, contact the Commission and have it corrected – otherwise, you will be replacing the lighting system on the tower(s), an extremely expensive proposition.
Unless you have an automated system in place to alert personnel of a lighting problem, tower lights are to be observed once each 24 hour period. If a steady burning top light or any flashing beacon is noted out of service, it MUST be reported to the FAA within 30 minutes of the discovery that the light is out. The national number to call is 877-487-6867. You will be asked your state. You will be asked what the nearest airport is to your tower – helpful to the person on the phone, but if you do not have it handy, they can easily look it up. They will ask for the ASR (Antenna Structure Registration) number of the tower. They should then give you a NOTAM number (Notice To Air Men) which you should log, along with their initials. Some persons at Boeing (that is who answers the phone) may just tell you that you’re all set. You are NOT all set unless they give you the NOTAM number and their initials. Do not let them hang up unless you receive this information! It is your proof that you called in the outage.
You will have 15 days to rectify the situation, ie, get the problem fixed. If you cannot get the problem solved in 15 days, you MUST call and extend the NOTAM for another 15 days. A NOTAM will expire after 15 days. Just because you called it in once does not mean the notification lasts forever.
You are also responsible to cancel the NOTAM when the problem is resolved. One of the worst things you can do is to simply let a NOTAM expire. Every so often, the FCC does check the NOTAM lists. If they find a NOTAM that expired and that was not cancelled, they will assume the problem has not been corrected and you will find yourself with a NAL (Notice of Apparent Liability) to handle for a problem that may, in fact, have been rectified. Again, you will be given a cancellation number and the person’s initials which should be logged. This is your proof you cancelled the NOTAM.
The tower painting and lighting regulations are found in the Federal Code of Regulations, Title 47, Part 17 (do a Google search for 47 CFR Part 17). I have discussed regulations for towers that need to be painted and lighted – some do not. And towers that are galvanized without paint have different regulations for lighting (think strobes). For galvanized towers that are starting to rust, because galvanization does not last forever, a tower crew can paint on a cold galvanizing compound that will restore the tower.
Protecting the Workers
One final note – RF Radiation Compliance regulations will need to be observed for the tower crew doing the painting or lamp replacement. This means your station will most likely need to reduce power or sign off during the work. This is something you will need to negotiate with the tower crew – some of the work may need to be done at night, and this again will drive the cost up. Contrary to popular belief, most tower workers are not “yokels” who don’t know the RFR regulations. Most wear RFR monitors that will alert them if they are inside an unhealthy RF field. So please play by the rules and don’t assume they are stupid.
Don’t forget that your tower is an extremely important part of your transmission system. Please treat it nicely.
Thomas R. Ray, III CPBE, AMD, DRB is president of Tom Ray Consulting and Technical Editor of TALKERS. He can be phoned at 845-418-5065 or emailed at email@example.com. His website is www.tomrayconsulting.com. Meet Tom Ray at TALKERS New York 2013 on Thursday June 6.