[BC] to light or not to light

[tom@bosscher.org]

>"The owner is the first line and primary responsible party. The licensees
are ultimately responsible since their licenses also have the
requirements attached."

>From Harolds site:

Sec. 17.6  Responsibility of Commission licensees and permittees.

    (a) The antenna structure owner is responsible for maintaining the
painting and lighting in accordance with this part. However, if a
licensee or permittee authorized on an antenna structure is aware that
the structure is not being maintained in accordance with the
specifications set forth on the Antenna Structure Registration (FCC Form
854R) or the requirements of this part, or otherwise has reason to
question whether the antenna structure owner is carrying out its
responsibility under this part, the licensee or permittee must take
immediate steps to ensure that the antenna structure is brought into
compliance and remains in compliance. The licensee must:
    (1) Immediately notify the structure owner;
    (2) Immediately notify the site management company (if applicable);
    (3) Immediately notify the Commission; and,
    (4) Make a diligent effort to immediately bring the structure into
compliance.
    (b) In the event of non-compliance by the antenna structure owner,
the Commission may require each licensee and permittee authorized on an
antenna structure to maintain the structure, for an indefinite period,
in accordance with the Antenna Structure Registration (FCC Form 854R)
and the requirements of this part.
    (c) ....

Notice that today, a leasee is only required to nofify the FAA IF, and
that is IF they are aware of a problem. The rules then state that IF, and
thats IF, in the case of non-compliance of the tower owner, then and thats
THEN, the Commission MAY require each license to maintain the structure.

   I own no lit towers. If I notice a problem on one of my stations
towers, I notify the landlord. I document that (and the landlord knows
that), and then I keep an eye on it. But I do not stay up at night
worrying about one of four beacon bulbs being out at the 250 foot level
of a 500 foot tower (which is an FAA violation).

    Many folks think that a letter in their paperwork, stating who is in
charge of the tower absolves the problem. That was 73.1213(c), which
no longer exists. Throw those letters away.

tom bosscher