FCC Antenna Registration System (ASR): About ASR: Posting Guidelines

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Posting Guidelines

Section 17.4(g) of the Commission's Rules, 47 C.F.R. 17.4(g) states that, with the exception of certain historic structures, "the Antenna Structure Registration Number must be displayed in a conspicuous place so that it is readily visible near the base of the antenna structure. Materials used to display the Antenna Structure Registration Number must be weather-resistant and of sufficient size to be easily seen at the base of the antenna structure."

A site owner who is considering whether the Registration Number is properly posted will want to keep in mind the following principles. In addition to providing general guidance, they serve as the foundation for the answers to the hypothetical situations listed below.

The Rules do not prohibit multiple postings of a Registration Number. An owner still unsure whether the structure is in compliance may wish to post the Registration Number at several points along a perimeter fence, or at both the gate to the access drive and adjacent to the base of the antenna structure.

Because the purpose of the Rule is to aid in the ready identification of antenna structures, owners are strongly encouraged to identify the number as the FCC Registration Number.

The owner should rely on common sense when posting the number. Ask "is this readily visible to someone who doesn't have access to the site?" If a location is conspicuous enough to post a "No Trespassing" sign or the owner's name and logo, then it is likely an appropriate place to post the Registration Number.

Hypothetical Situations

Situation #1

A site located on a large acreage has a metal chain link fence surrounding the transmitter building and antenna structure. The base of the antenna structure is not visible, even with binoculars. The roadway leading to the structure is accessible up to a locked gate in the perimeter fence.

Resolution: It would be appropriate to place the Registration Number (a) at the point of entry of the gate, or (b) the point where the roadway leading to the tower intersects the gate. In both these locations, the Registration Number is clearly visible.

Situation #2

A station painted the Registration Number on the concrete base of the tower. If this can be readily seen, is it appropriate? When the Rule requires the use of weather resistant materials, does that include weather resistant paint on concrete?

Resolution: If it is readily visible, the painted number is appropriate. Regardless of the materials used to post the number, the number should be re-posted or repainted when a reasonable person cannot read the numbers due to weathering. Because the Commission has not specified particular paints or posting materials to be used, the owner must assess the "weather resistance" of the materials used to post the Registration Number. This will only become an issue if the number cannot be read due to weathering.

Situation #3

The base of the antenna structure is surrounded by a 60-foot by 60-foot locked fence. Because of the placement of the transmitter building, the antenna structure base is not visible from the entrance gate. To see the base of the tower, one has to walk around the fencing (through weeds) to the back. At this point, the leg of the antenna structure is about 10 feet from the base fencing. Posted about four feet above the ground is about a 2-inch by 4-inch sign. The words "FCC Antenna Structure Registration Number" can be barely seen with binoculars while the number itself is not readable because it is faded.

Resolution: The location, size, and weathering makes this posting neither readily visible nor legible. It would be appropriate to post the Registration Number (a) on the gate to the perimeter fence, (b) on the transmitter building so that it is visible from the front gate, or (c) near the base of the antenna structure, but within the line of sight from the gate. In general, the type size should be larger the further away from the entrance gate the Registration Number is posted -- but a 2-inch by 4-inch sign is too small in any location.

Situation #4

The antenna structure is surrounded by a 70-foot by 70-foot locked fence. The view of the base of the antenna structure from the entrance gate is blocked by the transmission building. The Registration Number is posted near the base of the antenna structure, which is approximately 30 feet from the side of the fence. The 10-inch by 10-inch sign, posted about 10 feet above the ground, is visible only from the side of the perimeter fence. A person with good eyesight could probably make out the numbers without the aid of binoculars.

Resolution: If there is any doubt about the legibility of the sign, larger type size should be used. Additionally, this sign should be placed so that it is visible from the front entrance gate. If an outbuilding blocks the view of the antenna structure, the Registration Number may be posted (a) on the building, or (b) on the entrance gate.

Situation #5

The structure is located approximately 1/5 mile off a public road. A perimeter fence surrounds the site. In addition, a locked gate is located where the access drive intersects the public road. The base of the antenna structure is not visible from the public road. The Registration Number is posted at the base of the tower, but is not visible from the public road.

Resolution: Here, the posting is neither visible nor legible without trespassing on the site. If the access drive gate is always kept locked, the owner should post the Registration Number on the gate so that the number is visible from the public road. If the Registration Number can be posted on or adjacent to the structure or transmitter building in large enough type size to be visible from the public roadway without the aid of binoculars, this would also satisfy the posting requirement. If the Registration Number is NOT VISIBLE from a point of public access, Enforcement Bureau personnel may have to set up an on-site inspection to insure compliance with the Commission's regulations.

Situation #6

The structure is surrounded by a locked fence. A 2-foot by 2-foot sign, attached to one leg of the structure approximately 10 feet from the ground, reads "FCC ID # 0000000." The sign is readable from the gravel drive that leads to the perimeter fence.

Resolution: This is in full compliance with the posting requirement. The number is readily visible. A member of the public who discovers a lighting problem at the site could easily notify the Commission and identify the structure and the Commission could in turn quickly notify the owner.

Situation #7

An antenna structure is located atop a large building. The Registration Number is posted at the base of the antenna structure, not at the base of the building. The number is only visible from the building rooftop.

Resolution: This is acceptable. In the Report & Order, the Commission "clarified the rules to require that the registration number be posted at the base of the antenna structure, not the base of the building." If the base of the antenna structure is on a part of the building to which the public does not have access, the owner should, upon reasonable demand by representatives of the Commission, the FAA, or other requestors, (1) provide the Registration Number, or (2) provide access to the site so that the requester can observe the Registration Number. Either option would be acceptable.

Situation #8

Section 17.4(g) of the Commission's rules requires posting of the ASR number, but does not specify when this posting requirement takes effect. At what point during construction must an owner post the ASR number?

Resolution: Because the ready identification of an antenna structure is critical in the event of a light outage or malfunction, we interpret the posting requirement to require an owner to post the ASR number no later than the point of construction where lighting (permanent or temporary) is first required. In the case of a structure that is not assigned lighting, an owner must post the number no later than the time at which the structure is topped out.

We realize that the construction site may be such that it is not practical to erect the permanent sign - either because it will be blocked from view or may be damaged during construction. In this case, an owner may want to post the number on a temporary sign during construction, and may want to consider putting it on the gate or fence, if that is practical. Otherwise, use of a ground-mounted sign - similar to the "for sale" signs typically posted outside houses - would satisfy the requirement. An owner may also wish to consider posting a copy of the 854R (the registration document) with those documents (such as building permits) that must be posted at the site during construction.

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Last reviewed/updated on

8/16/2001.