Station Compliance›Field Notes

Most FCC obligations are about paperwork, and it is fair to treat them with the seriousness paperwork deserves. Tower lighting is not one of them. The rule exists because unlit structures and aircraft occupy the same sky, and the enforcement record reflects that.

It is also, for a small station, one of the easiest obligations to be quietly failing — because a tower two miles out of town at 3am is not something anybody looks at.

The three obligations

Observe the lights, at least once every 24 hours. § 17.47 requires the structure owner to make an observation of the antenna structure's lights at least once each 24 hours — either visually, or by monitoring a properly maintained automatic indicator designed to register any failure.

Alternatively, you may provide and properly maintain an automatic alarm system designed to detect a failure and indicate it to the owner. That is the option nearly every station should be taking, because it converts a daily human task nobody performs into equipment that pages you.

Inspect the monitoring equipment quarterly. Separately from the daily observation, § 17.47 requires inspection at intervals not exceeding three months of all automatic or mechanical control devices, indicators and alarm systems, to confirm they are working properly. Certain certified self-diagnostic systems are exempted.

This is the obligation people miss entirely. An alarm system you never test is a compliance story, not a safety measure — and the FCC anticipated exactly that.

Report failures to the FAA. § 17.48 requires the owner to report immediately to the FAA any observed or known extinguishment or improper functioning of any top steady-burning light or any flashing obstruction light, regardless of its position on the structure, that is not corrected within 30 minutes.

The 30-minute clock

Read that threshold carefully, because it is commonly misremembered as a grace period. It is not permission to ignore a dark beacon for half an hour. It is the point at which a fault stops being something you are fixing and becomes something aviation needs to know about.

Two further pieces:

• You must report again when it is fixed — immediately upon resumption of normal operation.
• If repairs run past the FAA's NOTAM period, you must contact the FAA to extend the outage notice and give an updated return-to-service date, repeating until the repair is done. A NOTAM that silently expires while your tower is still dark is the failure mode here.

Side intermediate steady-burning lights are treated differently: they require corrective action as soon as practicable but do not trigger the FAA notification.

The record

§ 17.49 requires the observations and the notifications to be recorded. The practical shape of a defensible record is a log showing what was observed or monitored, when, what failed, when the FAA was notified, the NOTAM number, when it was repaired, and when the FAA was told it was back.

This log is what turns "we handled it" into something demonstrable eighteen months later, when nobody remembers the night in question.

Painting, briefly

§ 17.50 requires marked structures to be cleaned or repainted as often as necessary to maintain good visibility. There is no fixed interval — the standard is the condition of the paint, not the date of the last job. A faded orange-and-white tower is out of compliance regardless of when it was last done.

What this has actually cost stations

The enforcement record here is more active than most broadcasters assume, and the amounts are not nominal:

Field inspections continue. In 2025 the Commission's New York field office inspected a New Jersey AM station's Pennsylvania towers and found that while each structure showed its red beacon, none of the required side marker lights were operational — lights the ASR specifically called for at the one-third and two-thirds levels. A Chicago field office inspection in November 2025 found a structure whose ASR required medium-intensity white obstruction lighting, including a top strobe and two mid-level strobes, dark except for a single low-intensity non-strobing white light.

The audit that takes twenty minutes

1. Look up your own ASR. Pull the registration in the FCC's ASR database and read the lighting specification. Not what you remember — what it says.
2. Compare it to what is actually lit. After dark, in person. Count the levels. Check whether strobes are strobing and whether steady lights are steady.
3. Confirm your monitoring actually reaches a human. An alarm wired to a panel in an unstaffed building is not an indication to the owner. Where does the alert go at 3am, and to whose phone?
4. Test the alarm. This is the quarterly obligation. Pull a light and confirm the alarm fires.
5. Find your log, or start one.
6. Check the paint while you are there.

The honest framing

Every other item on a station's compliance list is a question of exposure to a regulator. This one is a question of exposure to an aircraft, and the FCC's willingness to issue five-figure forfeitures against companies far larger than a small-market radio station reflects that difference.

If your tower monitoring is an assumption rather than a tested system, that is the single highest-consequence gap in your compliance posture, and it is fixable in an afternoon.

The compliance calendar covers the recurring obligations, and RF exposure covers the other rule that lives at the tower site.