The placement of antenna structures is a significant issue for ACA members, especially in rural areas that require installation and maintenance of tall masts capable of receiving broadcast signals that originate dozens of miles from a cable headend,
Many ACA members also use antennas to backhaul multichannel video programming and other services across distances that permit serving customers in areas where burying lines underground or stringing them across poles would be impractical because of remoteness, terrain, rights of way, and cost.
To illustrate the importance of antenna technology to small cable operators, 107 ACA members responded to an ACA survey stating that that their company owns one or more antenna structures. Of these ACA members, about 50% said they have one or more antenna structures that are less than 200 feet above ground level, and around 13% indicated that they owned at least one antenna structure more than 450 feet above ground level. With regard to their towers, approximately 37% responded that they use guy wires or steady-burning lights and 13% reported that they have structures located on ridgelines, coastal areas, bird staging areas or near the nesting areas of Golden or Bald eagles.
In the draft PEA, the FCC concluded that the ASR program does not cause significant impact on migratory birds. However, to the extent that there might be an overlooked local concern, the FCC assumed that it would be made known by requiring a 30-day public notice period before any antenna structure required to be registered through the ASR can be constructed. Although the public notice requirement is a significant change from current rules, it should remedy procedural and substantive deficiencies found by a court in reviewing prior ASR-related rulings by the FCC.
ACA noted in its comments that some alternatives to the FCC's preferred approach could result in significant burdens on ACA members. One of these alternatives would require an Environmental Assessment [EA] for all antenna structures, and another would require EAs for those on ridgelines, coastal areas, bird staging areas or near the nesting areas of Golden or Bald eagles. These alternatives would raise ACA members' costs substantially and delay projects to the point where many new or improved antenna structures would likely not be constructed, regardless of the need to deploy services to unserved areas. Moreover, these added costs and delays in all likelihood would not appreciably reduce migratory bird death.
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