This article provides information on the procedures for environmental compliance when an antenna structure requires registration in the Antenna Structure Registration (ASR) system and the same antenna structure is referenced on a service-specific application.
Any Environmental Assessment (EA) that is required for the antenna structure must be filed in the ASR system. A broadcast applicant or earth station applicant must also file a copy of the EA with its service-specific application.
Service-Specific Applications for Wireless Licenses Filed in the Universal Licensing System (ULS)
To accommodate the environmental notification process, you now have two options when filing a service-specific license application on the FCC Form 601 (Form 601) in the Universal Licensing System (ULS) for an antenna structure that also requires registration in the ASR system:
- You can provide the ASR Registration Number on the Form 601, if the Form 854 application has already been granted; or
- If the Form 854 application has not yet been granted, you can provide the ASR File Number on the Form 601 if the following conditions are met:
- You obtained an FAA No Hazard Determination and included the FAA Study Number on the Form 854;
- You provided local notice of the proposed antenna structure; and
- The proposed tower has been posted on the FCC's website pursuant to the environmental notification process.
If you file your Form 601 application with an ASR File Number, your application cannot be granted until the associated Form 854 application has been granted and you have amended the Form 601 to replace the ASR File Number with the ASR Registration Number. During the pendency of the Form 854 application, you must amend the Form 601 at least every 60 days from the date the Form 601 was filed and provide an exhibit that includes the reason(s) why the Form 601 remains pending. The exhibit must be uploaded to the Form 601 by using a new Attachment Type called “Status of Environmental Review.” Failure to provide the status update may result in dismissal of the Form 601 application. This requirement does not apply while action on the environmental notification submission is pending at the Commission.
If you file your Form 601 application with an ASR File Number and the Form 854 includes an EA, you must answer yes to the environmental question on the Form 601. If you add an EA to the Form 854 after initially submitting the Form 601, you must amend the Form 601 to change the response to the environmental question from no to yes.
Note: The environmental question on the Form 601 is question 26 on Schedule D, question 22 on Schedule I, and question 48 on Schedule M.