Before the

**Federal Communications Commission**

**Washington, D.C. 20554**

In the Matter of )

> )

Streamlining the Commission's Antenna ) WT Docket No. 95-5

Structure Clearance Procedure )

)

and )

)

Revision of Part 17 of the Commission's Rules )

Concerning Construction, Marking and Lighting )

of Antenna Structures )

**MEMORANDUM OPINION AND ORDER AND ORDER ON RECONSIDERATION**

**Adopted: March 1, 2000 Released: March 8, 2000**

By the Commission:

**I. INTRODUCTION**

1\. By this action, we address and resolve various filings concerning
the Commission's antenna structure clearance procedure established and
adopted in the *Report and Order* in WT Docket No. 95-5.[^1]
Specifically, we dismiss as moot a petition for partial reconsideration
filed by the Wireless Cable Association International, Inc. (WCA)[^2];
deny a petition for partial reconsideration filed by Comp Comm, Inc.
(Comp Comm)[^3]; and grant in part and deny in part a petition for
declaratory ruling filed by Teletech, Inc. (Teletech).[^4] The basis for
our actions is set forth below.

**II. BACKGROUND**

2\. Section 303(q) of the Communications Act of 1934, as amended, vests
in the Commission the authority to require painting and/or lighting of
antenna structures that may constitute a hazard to air navigation.[^5]
In this regard, Part 17 of the Commission's Rules sets forth procedures
for identifying those antenna structures that might affect air
navigation and for registering such structures with the Commission. [^6]
In November 1995, the Commission substantially revised this antenna
structure registration process to require owners of antenna structures
(rather than the Commission licensees utilizing those structures) to
register with the Commission those structures that meet the registration
criteria and to exercise primary responsibility for the prescribed
painting and lighting. The Commission also updated its Rules to be
consistent with Federal Aviation Administration (FAA) air safety
recommendations.[^7] Since these revised procedures became effective,
the Commission has registered more than 69,000 antenna structures.[^8]

3\. Based on commenters' support for a standard format for reporting
antenna structure data, the Commission adopted a registration process
wherein owners submit location data in terms of degrees, minutes, and
seconds, and height and elevation data in meters.[^9] The Commission
stated that owners could use surveying tools of differing accuracy to
determine site data -- including maps, Global Positioning System (GPS)
receivers, and GPS receivers with differential corrections -- but left
it to the owner to "evaluate the surveying method being used and round
to the appropriate significant digit."[^10] Because we require the
antenna structure owner to register with the Commission, the antenna
structure registration procedures the Commission adopted also recognized
the fact that data filed for antenna structure registrations might
differ from the technical data previously submitted for radio stations
licensed on those antenna structures. The Commission directed owners to
submit accurate site data without regard to the height and coordinates
listed on tenant licensees' station authorizations, but instructed
licensees whose license data differs from that submitted by the antenna
structure owner to coordinate the correction of their data with the
appropriate licensing branch within the Commission.[^11]

**III. DISCUSSION**

4\. [Accuracy Standard]{.underline}. Comp Comm and Teletech ask that we
require antenna structure owners to certify that their site data is
correct within certain parameters, *i.e.*, that we establish an accuracy
standard for the submission of antenna structure data.[^12] Comp Comm
contends that by allowing an antenna structure owner to choose the
method it uses to obtain site data, the Commission will receive antenna
structure registration data that varies widely in terms of
precision.[^13] Teletech contends that by allowing an antenna structure
owner to choose the means of measurement, the Commission's procedures
allow owners to employ methods with negligible accuracy.[^14] Comp Comm
agrees that owners are likely to use the quickest and easiest methods to
determine site data; and because these methods tend to be the least
accurate the antenna structure database will be less useful as a means
of promoting air safety.[^15] Comp Comm suggests that we require that
the reported coordinate location of an antenna structure be accurate
within one meter and that the structure's reported overall height above
mean sea level be accurate to within three meters.[^16] Similarly,
Teletech suggests a specified accuracy standard of coordinate location
to the nearest whole second and elevation to the nearest whole
meter.[^17]

5\. We conclude that a specific accuracy standard is unnecessary because
the requirement that antenna structure owners first obtain an
aeronautical study from the FAA insures reliability of the antenna
structure site data and promotes air safety. Before we will grant an
antenna structure registration, the applicant must provide proof of the
FAA's determination of "no hazard" that the FAA issues[^18] when it
studies a proposed antenna structure and determines that it will not
adversely affect air navigation.[^19] Because the FAA in the first
instance determines whether an antenna structure poses a hazard to air
navigation and recommends appropriate painting and lighting,[^20] we
conclude that it is appropriate that the FAA -- and not the FCC --
specify the accuracy of site information that is necessary for the FAA
to make its determination. As a result, we will not process a
registration application in which the specified coordinates differ from
those on the FAA determination by more than one second in latitude and
longitude, or 0.3 meters (one foot) in height.[^21] By requiring that an
applicant for an antenna structure registration submit a valid FAA
determination of "no hazard" that is no more than one second and 0.3
meters different from the coordinates and height listed on the
registration application, we promote the accuracy of our antenna
structure registration database while deferring to the FAA as the expert
agency for air safety in determining the appropriate accuracy for
antenna structure data.[^22]

6\. We agree with Pacific Telesis, who argues that because of the FAA
notification requirements, owners will not determine the antenna
structure site location by GPS receiver alone.[^23] Furthermore, we note
that some of the measurement tools identified in the *Report and
Order*[^24] might be insufficient for the purposes of obtaining a
determination from the FAA,[^25] and therefore will be of minimal
practical use to antenna structure owners. An antenna structure owner
who conducts one set of measurements for purposes of FAA notification
but who uses another measurement tool to obtain data for the purpose of
registering the structure with the Commission very well might obtain
calculations that differ by more than one second in coordinates or one
foot in height. As noted above, we will not process registration
applications with such discrepancies. Accordingly, we will not establish
an FCC-mandated accuracy standard as part of our antenna structure
registration rules, but we will continue to process registration
applications in a manner wholly consistent with the FAA's
procedures.[^26]

7\. [Discrepancies in Registration and MDS and ITFS Licensing
Data]{.underline}. In the *Report and Order*, the Commission recognized
the benefits of requiring antenna structure owners, as opposed to FCC
licensees and permittees, to register with the Commission.[^27] The
Commission also recognized, however, that there would be cases in which
the coordinate and height data for an antenna structure would differ
from the licensing data for pre-existing stations sited on antenna
structures.[^28] In these cases, the Commission established specific
procedures for licensees to correct licensing data.[^29] For Multipoint
Distribution Service (MDS) and Instructional Television Fixed Service
(ITFS) licenses, the Commission required that "such \[data correction\]
filings be made within 30 days of receipt of FCC Form 854-R from the
structure owner."[^30] In its petition, WCA expresses concern that by
allowing the registration of antenna structures at coordinates that
differ from the coordinates specified on pre-existing MDS and ITFS
stations sited on the structures, the filing requirement for tenant
licensees who have to correct their license data will be unduly
burdensome to the wireless cable industry.[^31] Specifically, it
contends that discrepancies between antenna structure registration data
and licensing data will cause many MDS and ITFS licensees to prepare and
submit license modification applications that include extensive
interference analyses. [^32] As a result of these modification
applications, it concludes, the Commission might require these licensees
to take steps to try to avoid harmful interference, such as decreasing
antenna height, reducing power, or employing a directional
radiator.[^33] These measures, WCA states, will impose a significant
burden on the wireless cable industry, and, thus, it proposes that if an
antenna structure is registered within three or fewer seconds of the
coordinates on an MDS or ITFS authorization, the licensee be allowed to
correct its authorization without submitting interference studies or
demonstrating non-interference.[^34]

8\. We deny WCA's petition as moot. Under the antenna structure
registration program, all antenna structures meeting the registration
criteria that were built before July 1, 1996 ("existing structures")
were required to have been registered during a two-year period that
ended on June 30, 1998.[^35] For structures built or modified on or
after July 1, 1996 ("new structures"), the Commission has required
registration prior to construction or alteration.[^36] Under our Rules,
an antenna structure owner is required to "immediately provide a copy"
of the antenna structure registration document to each tenant licensee
and permittee on its antenna structure.[^37] Effective July 1, 1996, the
Commission began requiring each applicant for a new or modified FCC
license or construction permit to list on the relevant license
application the registration number of the antenna structure on which
its facility is sited.[^38] In the case of licensees sited on existing
structures, because nearly a year-and-a-half has elapsed since the
registration period for existing structures ended, we conclude that MDS
and ITFS licensees have had sufficient time to receive a copy of the
registration document from their antenna structure owners, note any
discrepancies, and file for license modifications within the thirty-day
time period.[^39] Licensees proposing facilities on antenna structures
registered after July 1, 1996, or on new structures, have been required
to provide a registration number as a supplement to FCC application
forms. Because these licensees have had the opportunity to obtain
antenna structure registration data prior to completion of the licensing
process and, thus, have had time to identify and correct any differences
before filing license applications with the Commission, there should be
no discrepancy between licensing and registration data in these cases.
Accordingly, because MDS and ITFS licensees no longer face the data
correction burdens described in WCA's petition, we conclude that the
petition is moot.[^40]

9\. We recognize that because the antenna structure registration program
places the primary responsibility on antenna structure owners who might
or might not be Commission licensees, licensees sometimes face
difficulties when coordinating and reconciling FCC licensing data with
the antenna structure data reported by owners. We also recognize that
while antenna structure owners must report accurate site data to both
the Commission and the FAA in order to assure air safety, licensees must
provide the Commission with accurate licensing data in order to assure
efficient frequency coordination, conduct interference studies, and
comply with Commission rules.[^41] We take this opportunity to discuss
our expectations for those situations in which an antenna structure
owner is a different entity from the Commission licensee(s) sited on the
structure.

10\. Appendix C of the *Report and Order* outlined the procedures by
which a licensee can correct its licensing data when it differs from the
data on the antenna structure registration.[^42] Two recent Commission
initiatives have required licensees to re-familiarize themselves with
this process. First, the Wireless Telecommunications Bureau (WTB) has
contacted licensees who appear to be at sites that require registration
but for which the Commission has no record of a registered antenna
structure. We believe that it is reasonable to expect an FCC licensee to
know whether it is sited on a structure that requires registration and,
even if it has not yet had an opportunity to correct its licensing data
as part of a station modification or license renewal application, to be
able to identify the antenna structure owner and registration number.
Second, under the Universal Licensing System,[^43] the WTB implemented a
procedure to dismiss license applications that do not include a
registration number (when the license data equates to a site that
requires registration), or where the registration coordinates do not
match the site coordinates on the license application.[^44] Thus, we
have in place a process by which licensees whose site data differs from
the antenna structure registration data cannot file for modifications at
a licensed site without first correcting the discrepancy.

11\. In the *Report and Order*, the Commission emphasized that it would
not impose administrative sanctions on any licensee or permittee who,
through the registration process, realizes that it has inadvertently
provided incorrect data in obtaining a station authorization or
construction permit, and the Commission stated that it would not require
licensees and permittees to cease operations while seeking to amend
their licenses.[^45] We also recognize that there will be cases where a
licensee disagrees with the site data provided by an antenna structure
owner. Just as we expect licensees to correct data that they discover to
be incorrect, we look to antenna structure owners to modify antenna
structure registration data that they determine (either through their
own actions, from tenant licensees on the site, or by FCC or FAA
notification) to be incorrect. In cases where the correction involves a
change in latitude and/or longitude by more than one second or an
increase in height by more than 0.3 meters, the owner will need to first
obtain a new FAA determination of "no hazard" for the antenna
structure.[^46] To assist antenna structure owners in making these
corrections, tenant licensees and permittees might wish to help owners
with administrative details, such as obtaining and helping to prepare
FAA and FCC forms.[^47]

12\. We also recognize that there may be extraordinary circumstances
where an antenna structure owner and tenant licensee(s) may not be able
to agree on the coordinates for a site -- for example, when the owner
and licensee use different survey methods to determine site coordinates.
In these cases, the licensee may request a waiver of the policy that
licensing data must match registration data and ask WTB to review the
situation.[^48] We emphasize that we consider this requested relief to
be an extraordinary situation, and we will expect the licensee to fully
describe the steps it has taken to negotiate with the owner and explain
in detail why it will not or cannot agree with the coordinates the owner
has used.[^49]

13\. [Application of Antenna Structure Requirements to Specific
Situations.]{.underline} Finally, Teletech requests that we clarify how
the registration procedures relate to multiple antenna structures on
building rooftops and to antenna towers that are increased in
height.[^50] Teletech first notes that in some cases, multiple antennas
are mounted atop building rooftops, and that these antennas can
sometimes be clustered at nearly the same coordinates (*e.g.*, when
antennas are mounted atop a tall building with a limited surface area,
such as the top of a skyscraper), or mounted at distinct coordinates on
a sprawling building (*e.g.*, antennas located on opposite ends of an
industrial warehouse).[^51] Teletech asks (1) whether each antenna
structure atop a building or only the tallest antenna structure must be
registered with the Commission; and (2) which coordinates should be used
for registering the antenna structure.[^52]

14\. Our Part 17 rules expressly state that "the owner of *any* proposed
or existing antenna structure that requires notice of proposed
construction to the Federal Aviation Administration must register the
structure with the Commission."[^53] Thus, in cases of multiple antenna
structures mounted atop buildings, we expect the owner of each antenna
structure to determine if that structure requires registration and, if
so, we expect the owner to register that structure with the Commission
regardless of what other antenna structures are sited in close
proximity. Furthermore, we stress that our Rules require the owner of
the antenna structure -- not the building owner, if the two are
different entities -- to determine whether registration is necessary and
to secure a valid FAA determination of "no hazard" for the
structure.[^54] As with all registrations, the antenna structure owner
must use the specific coordinates and elevation for each structure, not
the general or centerpoint coordinates for the building on which it is
mounted.

15\. Second, Teletech seeks guidance on who must file an application for
antenna structure registration when a third party erects an antenna atop
a tower [^55] that causes a tower, that previously did not require
registration, to meet the registration criteria, or increases the
overall height of a previously registered tower.[^56] In both
situations, the owner of the tower, and not the party authorized to
erect the surmounting antenna, is responsible for filing or amending an
antenna structure registration. Section 17.2(a) of our Rules defines an
"antenna structure" to include "the radiating and/or receive system, its
supporting structures and any appurtenances mounted thereon*.*"[^57] The
"antenna structure owner" (*i.e.*, the one who must register the
structure under Section 17.4 of our Rules) is "the individual or entity
vested with ownership, equitable ownership, dominion, or title to the
antenna structure."[^58] Because our registration procedures envision a
single registration for each antenna tower, we conclude that the
"antenna structure owner" in those situations where two or more entities
own different components of the antenna structure is the owner of the
support tower structure who allows the third party to add a surmounting
antenna. Any painting and lighting assigned to the antenna tower will
apply to the tower as a whole and not to the surmounting antenna
exclusively. We believe that the tower owner is in the best position to
comply with our registration requirements and is the entity we will hold
responsible for complying with our registration requirements.
Additionally, because the tower owner can control whether it will let a
third party site on its tower, we believe that it can take into account
any registration burdens when establishing an agreement with the third
party for use of its structure.

**IV. CONCLUSION**

16\. For the reasons stated herein, we deny as unnecessary the requests
of Comp Comm and Teletech that the Commission specify an accuracy
standard for antenna structure site data. In addition, we deny as moot
WCA's request for relaxed procedures for MDS and ITFS licensees whose
license coordinate and height data differs from the data on the antenna
structure registration. We also clarify some of the responsibilities of
the various parties when the licensee and the antenna structure owner
are not the same entity. By resolving these outstanding petitions, we
reaffirm our antenna structure registration procedures adopted in WT
Docket 95-5. We will continue to work with the FAA to ensure

that antenna structures regulated by the Commission do not pose a hazard
to air safety, and will rely on our antenna structure registration
program to fulfill our statutory responsibilities in this area.

**V. ORDERING CLAUSES**

17\. Accordingly, IT IS ORDERED pursuant to Sections 4(i) and 303(q) of
the Communications Act of 1934, as amended, 47 U.S.C. §§ 154(i) and
303(q), and Sections 1.2, 1.3 and 1.429 of the Commission's Rules, 47
C.F.R. §§ 1.2, 1.3 and 1.429, that the petition for partial
reconsideration filed by of Comp Comm, Inc., on February 24, 1996, IS
DENIED.

18\. IT IS FURTHER ORDERED that the petition for partial reconsideration
filed by the Wireless Cable Association International, Inc., on March 6,
1996, IS DISMISSED AS MOOT.

19\. IT IS FURTHER ORDERED that the relief requested in the petition for
declaratory ruling filed by Teletech, Inc., on June 4, 1996, is GRANTED
in part and is DENIED in part.

20\. IT IS FURTHER ORDERED that the petition for emergency stay filed by
Teletech, Inc., on June 4, 1996, IS DENIED.

FEDERAL COMMUNICATIONS COMMISSION

> Magalie Roman Salas
>
> Secretary

[^1]: Streamlining the Commission's Antenna Structure Clearance
    Procedure, *Report and Order*, WT Docket No. 95-5, 11 FCC Rcd 4272
    (1995) (*Report and Order*).

[^2]: Wireless Cable Association International, Inc., *Petition for
    Partial Reconsideration* (filed March 6, 1996) (WCA Petition).

[^3]: Comp Comm, Inc., *Petition for Partial Reconsideration* (filed
    Feb. 20, 1996) (Comp Comm Petition).

[^4]: Teletech, Inc., *Petition for Declaratory Ruling* (filed June 4,
    1996) (Teletech Petition). Teletech also requested that we stay
    implementation of the revised antenna structure registration rules
    pending consideration of its petition. *See* Teletech, Inc.,
    *Petition for Emergency Stay* (filed June 4, 1996) (Stay Petition).
    Given that the revised antenna structure registration rules took
    effect prior to our reconsideration of the Teletech Petition, we
    consider the Stay Petition to have been denied.

[^5]: 47 U.S.C. § 303(q).

[^6]: 47 C.F.R. Part 17.

[^7]: The Commission assigns painting and/or lighting requirements based
    on the FAA's recommendation as to what painting and/or lighting (if
    any) is necessary to promote air safety. *Report and Order*, 11 FCC
    Rcd at 4275 ¶ 5. The Commission has adopted procedures for the
    registration of antenna structures that are consistent with the
    FAA's procedures, by which antenna structure owners must provide the
    FAA with notification of any proposed construction or alteration.
    The FAA's notification requirements are contained in 14 C.F.R. §§
    77.13-17, and are reprinted on FAA Form 7460-1, "Notice of Proposed
    Construction or Alteration."

[^8]: The Commission has continued to look for ways to streamline and
    coordinate the antenna registration process while meeting its
    statutory obligations. For example, we have, among other things: (1)
    revised our registration form to better collect information in a
    format that is consistent with the information which is required by
    the FAA; (2) deployed software that allows automatic evaluation and
    grant of most applications without staff processing, thereby saving
    time; and (3) provided additional means to access registration
    information and application filings. The Commission will continue to
    pursue the streamlining of this process.

[^9]: *Report and Order*, 11 FCC Rcd at 4286 ¶ 33.

[^10]: *Id*.

[^11]: *Id.* at 4287 ¶ 35. Licensees will generally not be required to
    cease operations during this period. *Id.*

[^12]: Comp Comm Petition at 1; Teletech Petition at 9.

[^13]: Comp Comm Petition at 2.

[^14]: Teletech Petition at 6-7.

[^15]: Comp Comm Petition at 2.

[^16]: *Id*.

[^17]: Teletech Petition at 6-7.

[^18]: Section 1501 of the Federal Aviation Act authorizes the FAA to
    require that persons proposing to erect a

    structure -- including an antenna structure -- provide notice to the
    FAA when such notice will promote air safety.

    49 U.S.C. § 44718. Persons seeking a "no hazard" determination must
    describe the proposed location in accord with the following
    instructions:

    > Enter the relationship of the structure to roads, airports,
    > prominent terrain, existing structures, etc. Attach an 8-1/2" x
    > 11" non-reduced copy of the appropriate 7.5 minute U.S. Geological
    > Survey (USGS) Quadrangle Map MARKED WITH A PRECISE INDICATION OF
    > THE SITE LOCATION. To obtain maps, Contact USGC at 1-800-435-7627
    > or via Internet at http://mapping.usgs.gov. If available, attach a
    > copy of a documented site survey with the surveyor's certification
    > stating the amount of vertical and horizontal accuracy in feet.

[^19]: 47 C.F.R. § 17.4(b).

[^20]: 14 C.F.R § 77.13.

[^21]: *See* Wireless Telecommunications Bureau Announces Unified Policy
    for Dismissing and Returning Applications and Dismissing Pleadings
    Associated with Applications, *Public Notice*, 14 FCC Rcd 5499 (WTB
    1999); "Questions/Answers on the Policy" (available on-line at
    http://www.fcc.gov/wtb/uls/policy.html) (Q&A Document). *See also*
    Antenna Structure Registration Number Required as Supplement to FCC
    Application Forms Effective July 1, 1996, *Public Notice*, Mimeo No.
    63540 (rel. June 13, 1996).

[^22]: We note that the one second/one foot tolerance for the submission
    of antenna structure data is consistent with the FAA's policy of
    allowing modifications to site data that do not exceed the
    coordinates and heights listed on the FAA determination by more than
    one second or one foot. *See Report and Order*, 11 FCC Rcd 4287
    n.52.

[^23]: Pacific Telesis *Reply Comments* at 2 (filed May 7, 1996).

[^24]: For example, the *Report and Order* identified GPS receivers
    without differential correction as a possible means of obtaining
    site data. *Report and Order*, 11 FCC Rcd at 4286 ¶ 33. Teletech
    contends that uncorrected GPS receivers may by accurate to plus or
    minus 3.3 seconds of latitude and/or longitude, and plus or minus
    156 meters in vertical height. Teletech Petition at 4.

[^25]: FAA rules require owners of structures that require notice to the
    FAA to file such notice on FAA Form 7460-1. 14 C.F.R. § 17.17(a).
    FAA Form 7460-1, question 20, requires a specific description of the
    location including submission of a USGS 7.5-minute map with the
    precise site marked. An antenna structure owner who used the
    surveying tools identified in the *Report and Order* exclusively
    would be unable to complete FAA Form 7460-1, and thus would not be
    able to obtain a valid FAA determination for the structure.

[^26]: We find it unnecessary to require the use of U.S. Geological
    Survey maps, as Pacific Telesis suggests, because it is already
    required by the FAA on FAA Form 7460-1, the form antenna structure
    owners use to give the FAA notice of proposed construction or
    alternation of antenna structures. *See* Pacific Telesis Reply
    Comments at 4.

[^27]: These benefits include, *inter alia*, an estimated 12-to-1
    reduction in filings related to changes in antenna structure
    specifications and the identification of a single point of contact
    for FCC and FAA investigations into reported light outages or other
    problems at specific antenna structures. *Report and Order*, 11 FCC
    Rcd at 4278-49 ¶¶ 12-13.

[^28]: *Id.* at 4286 ¶ 34. For example, an owner might re-survey the
    structure and determine that the coordinates are different from
    those the licensee used when applying for its station authorization,
    or in the case of multiple licensees sited on the same structure,
    each licensee might have used different data when applying for its
    individual authorization.

[^29]: *Id*.

[^30]: *Id* at 4304.

[^31]: WCA Petition at 4-5.

[^32]: *Id.* at 3-4.

[^33]: *Id.*

[^34]: *Id.* at 5. *See also* Pacific Telesis Reply Comments at 6-7
    (supporting the WCA Petition).

[^35]: *Report and Order*, 11 FCC Rcd at 4281 ¶ 19. *See also*
    Registration Period Closing for Antenna Structures, *Public Notice*,
    13 FCC Rcd 6414 (1998).

[^36]: *Report and Order*, 11 FCC Rcd at 4281 ¶ 19. *See also* 47 C.F.R.
    § 17.4(a).

[^37]: 47 C.F.R §17.4(f).

[^38]: Antenna Structure Registration Number Required as Supplement to
    FCC Application Forms Effective July 1, 1996, *Public Notice*, Mimeo
    No. 63540 (rel. June 13, 1996).

[^39]: Moreover, it is clear that any licensee who has yet to receive a
    copy of the registration since the June 30, 1998, deadline had
    reason to question whether the antenna structure owner was carrying
    out its registration responsibilities, and, thus, was obligated to
    have contacted both the owner and the Commission pursuant to Section
    17.6(a) of our Rules, 47 C.F.R. §17.6(a).

[^40]: We further note that WCA did not ask that we stay our rules
    pending evaluation of its petition. A stay of our Rules is permitted
    in accordance with 47 C.F.R. §§ 1.43, 1.44 (e).

[^41]: *See, e.g., Ex Parte* Comments of National Spectrum Managers
    Association at 2 (filed Nov. 6, 1998).

[^42]: *Report and Order*, 11 FCC Rcd at 4303-5.

[^43]: The Universal Licensing System is the integrated database and
    automated processing system developed by the WTB to facilitate
    electronic filing of wireless applications, licensing information,
    and public access to such information for all wireless radio
    services. *See, e.g.,* Commission Adopts Rules to Implement
    Universal Licensing System for Wireless Services, *Public Notice*,
    Report No. 98-34, Rel. Sept. 17, 1998. Additional information about
    ULS is available on the Commission's internet website at
    http://www.fcc.gov/wtb/uls.

[^44]: *See* Q&A Document. *See also* Antenna Structure Registration
    Number Required as Supplement to FCC Application Forms Effective
    July 1, 1996, *Public Notice*, Mimeo No. 63540 (rel. June 13, 1996).

[^45]: *Report and Order*, 11 FCC Rcd at 4303.

[^46]: The FAA issues determinations on the condition that any change in
    height or coordinates voids the determination. This is consistent
    with FAA rules requiring a study for any construction or alteration
    that meets the notification criteria. *See* 14 C.F.R. §§ 77.5(b),
    77.11(a), 77.13(a), and 77.33(a). Under a longstanding FAA-FCC
    agreement, the FAA will not require a new determination for an
    existing, registered antenna structure if, in relation to the
    pre-existing determination, the height increases by one foot (i.e.
    0.3 meters) or less or if the coordinates differ by one second or
    less in latitude or longitude. *See also Report and Order*, 11 FCC
    Rcd 4287 n.52.

[^47]: Although third parties can assist with administrative work, we
    nonetheless reiterate that the antenna structure owner must request
    the new FAA determination and sign FCC Form 854 to request the
    registration modification.

[^48]: *See* Q&A Document at 6.

[^49]: It should be noted, however, that it is extremely unlikely that
    we would authorize operation from a structure for which the licensee
    cannot provide a determination of "no hazard" issued by the FAA.
    *Id*.

[^50]: Teletech Petition at 12, 13.

[^51]: *Id.* at 9-10.

[^52]: *Id.* at 12.

[^53]: 47 C.F.R. §17.4(a) (emphasis added).

[^54]: In many cases, the FAA determination for the building on which
    the antenna is mounted will be for a height that is less than the
    overall height of the building with the antenna structure, or for
    coordinates that do not match the portion of the rooftop on which
    the antenna will be mounted. In these situations, the antenna
    structure owner must obtain a new FAA study before attempting to
    register the structure with the Commission.

[^55]: A "tower" is an antenna structure type that is a freestanding or
    guyed structure built exclusively for communications purposes. *See*
    FCC Form 854 Instructions at 7. Towers are the most common antenna
    structures registered with the Commission.

[^56]: Teletech Petition at 21.

[^57]: 47 C.F.R. § 17.2(a).

[^58]: 47 C.F.R. § 17.2(c).