Curv Aero Cell Tower FAA Notice and FCC ASR: How They Fit Together
Communication towers sit under two federal agencies. The FAA decides whether a tower is a hazard to air navigation and how it must be marked and lit. The FCC requires towers that need FAA notice to be registered, then enforces the marking and lighting. This guide shows where the two processes connect, how rooftop antennas and colocations are treated, and what tower owners owe after the tower is built.
Updated November 7, 2026 · Based on 14 CFR Part 77, 47 CFR Part 17 and AC 70/7460-1N
Step 1: Does the tower need FAA notice?
The test is the same for towers as for any structure. A tower needs notice if its overall height, including antennas, lights and lightning rods:
exceeds 200 ft AGL; or
exceeds the 100:1, 50:1 or 25:1 notice surface within 20,000, 10,000 or 5,000 ft of a qualifying airport or heliport; or
stands on a qualifying airport.
The FCC's rules in 47 CFR 17.7 repeat these criteria, so one screening answers both agencies' questions. The FCC's TOWAIR tool also screens structures under 200 ft against the airport slopes and tells you whether registration is required.
In practice, most rural macro towers in the 150–199 ft range away from airports need neither FAA notice nor FCC registration, while any tower over 200 ft needs both. The middle ground is towers near airports and helipads, where a 120 ft monopole can need notice. See Do I need to file Form 7460-1? for the full decision walk-through.
Step 2: File the 7460-1, with the right timing
The general deadline is 45 days before construction or a permit application. Towers have an extra rule:
If the structure is also subject to FCC licensing, notice must reach the FAA on or before the date the FCC application is filed (14 CFR 77.7(c)). The FAA's lighting circular adds that the FCC advises applicants to file with the FAA well ahead of the 45 days.
Tower-specific items on the form
Item 7 · Marking and lighting preferred
Choose red lights and paint, dual, or medium-intensity white. The choice affects community acceptance and maintenance costs, so decide it deliberately. White lights are not normally recommended on structures under 200 ft or within 3 nautical miles of an airport, and high-intensity white lighting in residential areas triggers FCC environmental requirements.
Item 8 · FCC ASR number
For alterations to an already-registered tower.
Item 17 · Height
The top of the highest antenna, whip, light or lightning rod, rounded up.
Item 21 · Description
Frequencies, maximum effective radiated power, antenna types and centers of radiation, and microwave azimuths. The FAA checks for interference with its own radio systems as well as for physical obstruction.
Step 3: FCC Antenna Structure Registration (ASR)
Under 47 CFR 17.4, the owner of any proposed or existing antenna structure that requires FAA notice must register it with the FCC. Key points:
- Register before construction of a new tower or an alteration that needs FAA notice.
- The FAA determination comes first. Form 854 is filed with the FAA study number and a Determination of No Hazard, and the FCC checks the data against the FAA's.
- Environmental notice. New registrations generally go through the FCC's environmental notification process, with public notice, before the registration is granted. Some minor filings, such as ownership changes, are excepted.
- The ASR number goes on the tower, in every later FCC filing, and on any future 7460-1 for that structure.
- Voluntary registration is possible for towers that don't require it; since 2014 such registrations must be marked as voluntary and aren't subject to Part 17 lighting rules.
If the FAA exempts an antenna structure from notice, it is also exempt from FCC registration.
- FAA
- Form 7460-1 → Determination
- FCC
- Form 854 → ASR number
- Order
- FAA first, FCC before construction
Rooftop antennas and colocations
The 20-foot exemption
Under 77.9(e)(4), an antenna structure of 20 ft or less doesn't need notice, unless it increases the height of another antenna structure. A 15 ft mast on a rooftop is usually exempt. A 25 ft mast is tested: building height plus mast height, against the 77.9 criteria.
Adding antennas to an existing tower
An alteration that raises a tower's overall height, even by a few feet of new whip or extension, is a new alteration for 77.9 purposes and usually needs a new filing if the result meets a criterion. Changes to frequency or power on a studied structure can also need FAA review. The 7460-1 instructions list side-mounted antennas and power or frequency changes as alterations.
New panels at the same height don't change the tower's obstruction profile, but watch the lights. AC 70/7460-1N warns against nesting: new, larger antennas must not block the obstruction lights. Anything placed in front of a light (other than an L-810) should be no wider than 7/8 inch, and lights should be raised or moved if new equipment blocks them.
After construction: what tower owners owe
Form 7460-2. Part 1 before construction as the determination specifies (typically at least ten days ahead), and Part 2 within 5 days of reaching full height. For structures over 200 ft, supplemental notice is required by 14 CFR 77.11.
Marking and lighting as determined. Since October 28, 2026, the conditions in new determinations are mandatory, and the FCC enforces lighting and marking on registered towers.
Monitoring. Lights must be checked visually every 24 hours, or by an automatic monitor whose status is confirmed every 24 hours, with a daily log.
Outage reporting. Any failure of a top light or flashing light lasting more than 30 minutes must be reported to the FAA so a NOTAM can be issued, with the ASR number, and reported again when restored. The FCC can penalize failures to notify.
Repainting when orange-and-white marking fades noticeably.
Dismantling. Notify the FAA within 5 days, and update the ASR.
Common tower filing mistakes
- 01
Filing the FCC application before the FAA notice. The FAA notice has to come first or the same day.
- 02
Leaving the lightning rod off the height. Even a few feet can change the lighting configuration or push the tower over 200 ft.
- 03
Forgetting nearby helipads. Hospital heliports with instrument approaches carry 25:1 notice surfaces within 5,000 ft.
- 04
Treating a colocation as "no change" when the new antennas extend above the tower top.
- 05
Letting the determination expire before construction. It lasts 18 months from its effective date; extensions must be requested at least 15 days before it lapses.
Screen tower sites in bulk
For carriers and tower companies checking many candidate sites, the CurvAero Part 77 Report shows for each coordinate whether FAA notice (and therefore ASR) is needed, which airport or heliport controls, and the maximum height before notice is triggered. When notice is required, we can prepare and file the 7460-1 and track the case to determination.
Frequently asked questions
Does every cell tower need FAA approval?
No. Only towers meeting a 77.9 criterion need notice. Many towers under 200 ft away from airports need neither FAA notice nor FCC registration.
Can I use TOWAIR instead of filing with the FAA?
TOWAIR tells you whether FCC registration is required for structures under 200 ft. It doesn't replace an FAA filing when notice is required.
Who reports a lighting outage, the carrier or the tower owner?
The structure owner is responsible under FCC rules, even when a tenant or contractor maintains the lights.
Does a small cell on a utility pole need a 7460-1?
Usually not, unless the pole is near an airport or helipad and the pole plus equipment exceeds a notice surface, or the work is on an airport.