Ham
Radio Antenna Support Structures Not Migratory Bird Hazard, ARRL Says
NEWINGTON, CT, Dec 4, 2003--The ARRL has
asked the FCC to specifically exempt Amateur Radio antennas and support
structures less than 400 feet tall from routine environmental processing
relative to their impact on migratory birds. In reply comments filed December
1, the League said there is no scientific evidence that antenna structures
below that height contribute significantly to migratory bird mortality. An FCC Notice of
Inquiry, WT Docket 03-187, released in August seeking information on
the effects of communications towers on migratory birds, drew more than 250
comments. The League told the FCC that the migratory bird issue often arises at
municipal land use hearings and in the drafting of ordinances regulating
antenna structures.
"At public hearings before city, town and
county authorities, those who are opposed to communications antennas for
aesthetic reasons typically raise issues such as migratory bird mortality as
one of several arguments" against permitting antennas or limiting their
placement," the ARRL comments said. "ARRL's research into the scientific
literature reveals that communications towers below 400 feet are almost
universally considered not to be contributors to bird mortality."
 A chipping
sparrow, a migratory bird, visits a feeder in Maine. ARRL told the FCC there's
no scientific evidence that antenna structures shorter than 400 feet contribute
significantly to migratory bird mortality. [Kristen E. Lindquist Photo]
|
Among other studies, the ARRL cited Avian
Mortality at Communication Towers: A Review of Recent Literature, Research and
Methodology, a March 2000 paper prepared by Paul Kerlinger under a
US Fish and Wildlife Service (FWS) contract. Kerlinger's review suggested that
bird kills associated with communications towers "involve tall towers almost
exclusively." Unpublished studies cited by Kerlinger that indicate towers lower
than 400 or 500 feet are not as dangerous to migrating songbirds than towers
above 500 feet.
The League said typical ham radio fixed
antennas and support structures are located mostly in residential areas and
range from 50 to 120 feet--although some may go as high as 200 feet. The ARRL
said amateur antenna installations rarely go any higher than that because of
FAA approval, painting and lighting requirements, not to mention cost and
siting restrictions.
"The comments in this proceeding to date
support the conclusion that communications towers less than approximately 400
feet do not contribute substantially to migratory bird kills," the ARRL said,
adding that no regulatory action is justified beyond what's already in place
for aviation safety.
The ARRL also pointed to FWS guidelines
released in 2000 that urge communications service providers to utilize towers
less than 199 feet above ground level. The FWS concedes, however, that "tower
height alone may not necessarily be a critical issue that results in mortality"
and that bird kills documented at tall TV towers might be due to the effects of
tower lighting rather than height.
Based on the record, the League concluded,
"unlit Amateur Radio antennas cannot be considered candidates for regulation
under any circumstances."
Page last modified: 02:23 PM, 04 Dec 2003 ET
Page author: awextra@arrl.org
Copyright © 2003, American Radio Relay League, Inc. All Rights Reserved.
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