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2004 and 2006 Biennial Regulatory Reviews - Streamlining and Other Revisions of Parts 1 and

17 of the Commission’s Rules Governing Construction, Marking and Lighting of Antenna

Structures, WT Docket No. 10-88, Amendments to Modernize and Clarify Part 17 of the

Commission’s Rules Concerning Construction, Marking and Lighting of Antenna Structures,

RM 11349

For some time now, the wireless topics getting the most press attention tend to involve

the upcoming AWS-3 and voluntary incentive spectrum auctions. We expect that these auctions will help

the commercial wireless industry meet the explosive demand, for mobile services. We also anticipate that

the auctions will jump start broad based economic growth, because the wireless industry is a key driver

when it comes to job creation and manufacturing.

Less written about, however, are the Commission’s rules concerning infrastructure deployment

such as the Part 17 requirements for antenna tower registration and maintenance. But spectrum allocation

and infrastructure policy are linked. If we want the upcoming spectrum auctions to yield the greatest

benefits for mobile consumers and our economy, we must review and where possible streamline our

infrastructure deployment policies. We must make sure that our licensees meet their public interest

obligations. But our focus should also be on removing any unnecessary rules. Instead of spending finite

resources on compliance with needless rules, the wireless industry and the regulators, should retarget

those resources on investments in improved networks that cover larger service areas.

Antenna tower registration and maintenance requirements are necessary to ensure these structures

do not jeopardize aviation safety, but some of these rules are decades old and are now outdated. One

example is the requirement for quarterly physical inspections of tower monitoring systems, which have

cost some of the larger tower companies millions each year. Advances in technology now allow for

remote monitoring to ensure that those towers have the proper lighting required by our rules. Therefore, I

am pleased this Order will exempt tower owners from a quarterly inspection requirement, if they use a

Network Operations Center based monitoring system that is staffed with trained personnel, who can

respond to alarms 24 hours a day. Today’s Order also improves our lighting outage notification

requirements, standardizes repair timelines, and harmonizes other maintenance requirements, with current

FAA guidelines.

So I commend the parties, such as PCIA, for their advocacy on these issues and also thank Roger

Sherman, Sue McNeil, Michael Smith and the other members of the Wireless Bureau, who worked hard

to bring forth, this excellent item.

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