Date: 201204
Aircraft: No Aircraft
Reporter organization: Other Non-Aviation
Reporter function: Utility Engineer
Anomaly: Airspace Violation All Types; Deviation / Discrepancy - Procedural Published Material / Policy; Deviation / Discrepancy - Procedural FAR
Detector: Person Other Person
When detected: Other Inventory review
Result: General None Reported / Taken
Contributing factors: Environment - Non Weather Related
Primary problem: Environment - Non Weather Related

Narrative: During a review and inventory of electrical power transmission towers; Pacific Gas and Electric Company (PG&E) discovered that for a number of its towers that are greater than or equal to 200 FT in height above ground level (AGL); PG&E has been unable to confirm that it notified the FAA or its predecessor agencies of the construction or modification of those towers. We consulted with an outside attorney familiar with FAA regulations and in April. We were advised that while the construction or alternation of some of these towers appears to be pre-date applicable notification requirements; many of these structures were constructed after such notification requirements took effect and it is not apparent whether the towers fall with an exception to the reporting requirements. We are now in the process of notifying (or re-notifying) the FAA of these structures and are committed to marking and lighting all of these towers in accordance with the FAA's determination of marking and legal requirements. As a cautionary measure; and in furtherance of the safety goals underlying the safety program; we hereby identify the following 80 structures that are greater than or equal to 200 FT AGL; but for which we cannot presently confirm that the construction or modification was reported to the FAA. PG&E is providing the following information regarding each tower: longitude; latitude; PG&E equipment ID; tower number; transmission line name; tower height; adjacent tower marked (with obstruction lighting and marking) if applicable; adjacent tower number and name; adjacent tower height; distance to adjacent tower; and height of adjacent tower. PG&E's analysis of our tower data indicates the following: total of 80 towers; 19 towers just at 200 FT AGL (15 of these are in the vicinity of other towers with obstruction lighting and marking). 61 towers greater than 200 FT AGL (9 of these towers are in the vicinity of other towers with obstruction lighting and marking). Our analysis shows that at least 24 towers may fall into an exception to the reporting requirement due to their proximity to other towers with obstruction lighting but PG&E is reporting these towers here to provide the best information for FAA safety considerations. The 19 towers with a design height of 200 FT AGL are below the reporting requirement of 'more than 200 FT AGL' (14 C.F.R section 77.9); but PG&E is also reporting these towers to provide the best information for FAA safety considerations. PG&E notes that 15 of these 19 towers are in the vicinity of towers with obstruction lighting and marking.

Callback: The reporter stated that the FAA has not yet been notified because the proper authority has not yet been identified because he did not want to overload the system with this volume of information. Analyst gave the reporter an FAA contact phone number to get him started.



Synopsis: PG&E has 80 old and new power transmission towers that are at or above 200 FT; which the FAA may not have been notified about and therefore not charted on aeronautical publications.