How to File ASR Registration with the FCC and FAA

Filing an Antenna Structure Registration (ASR) with the FCC and FAA is a sequenced process: submit FAA Form 7460-1 first to trigger the aeronautical study, then file FCC Form 854 in stages while completing local and national environmental notice, and finalize the FCC application once the FAA determination and notice periods are complete. Construction cannot begin until the FCC issues an ASR number.¹

Confirm You Need to Register

The registration duty is tied to FAA notification requirements under 47 CFR 17.7. The clearest trigger is height: anything taller than 200 feet (60.96 meters) above ground level, measured from the site to the highest point of the antenna, lightning rods, and lighting fixtures included, must be registered.²

Shorter structures still need registration if they pierce the imaginary surfaces that slope outward from nearby airports and heliports:

100 to 1, extending 20,000 feet from airports whose longest runway is longer than 3,200 feet.
50 to 1, extending 10,000 feet from airports whose longest runway is 3,200 feet or shorter.
25 to 1, extending 5,000 feet from the nearest landing area of a heliport.

These slopes apply to public-use airports listed in government flight information publications, military airports, airports operated by federal agencies, and any airport or heliport with at least one FAA-approved instrument approach procedure.² The FAA can also request notification for construction in an instrument approach area whenever information suggests the structure might exceed obstruction standards, regardless of height.

If the FAA exempts your structure from notification under 47 CFR 17.7(e), it is also exempt from FCC registration. Owners of structures below the mandatory thresholds can still file voluntarily by flagging Form 854 as a voluntary registration. Voluntarily registered structures are not subject to the marking and lighting requirements that attach to mandatory registrations.¹

Step One: File FAA Form 7460-1

Before opening the FCC’s system, file FAA Form 7460-1 (Notice of Proposed Construction or Alteration) through the FAA’s Obstruction Evaluation/Airport Airspace Analysis (OE/AAA) portal.³⁴ This initiates the aeronautical study.

Have the following ready, because you’ll reuse it on Form 854:

Exact geographic coordinates of the site.
Height above ground level (AGL).
Height above mean sea level (AMSL) based on site terrain elevation.
Structure type, such as guyed mast, self-supporting lattice tower, or monopole.
Owner’s legal name and contact information.

The FAA reviews whether the structure would create a hazard to air navigation and issues a determination. A “No Hazard” finding lets the structure proceed as proposed; a “Conditional No Hazard” finding accepts the structure only if specified marking and lighting conditions are met. The FCC will not grant registration without that final FAA determination, so any delay in the aeronautical study delays the entire project.

Step Two: Start Form 854 and Run the Environmental Notice

The FCC’s online Antenna Structure Registration System is the only way to submit Form 854, and you’ll need an FCC Registration Number (FRN) and password to log in.¹⁵ The filing is split into parts: submit an initial application, complete the environmental notification steps, then return to finalize the submission. There is no filing fee.⁶

Local Public Notice

After submitting a partially completed Form 854, notify the local community about the proposed tower. Acceptable methods are publishing in a local newspaper or following the local zoning public notice process. Posting on a website does not satisfy this requirement unless the site is both specifically local and well-known to area residents as the equivalent of a newspaper of general circulation.⁷

The notice must include the Form 854 file number, the structure’s geographic location, type, height, and anticipated lighting, along with instructions for accessing the application and filing environmental concerns with the FCC. Report the local notice date in Part 2 of the Form 854 filing. If local notice hasn’t been published before your requested national notice date, amend the submission to push the national notice date back.⁷

Environmental Assessment Triggers

Most antenna structures qualify for a categorical exclusion from the National Environmental Policy Act (NEPA) and don’t require a full Environmental Assessment (EA). An EA is required when the proposed structure may have a significant environmental impact under 47 CFR 1.1307. The triggers include:

Location in a designated wilderness area or wildlife preserve.
Potential effects on endangered species or their critical habitats.
Impacts on sites listed or eligible for listing in the National Register of Historic Places.
Proximity to Indian religious sites.
Placement in a floodplain without adequate elevation above the base flood level.
Construction involving significant surface changes like wetland fill or deforestation.
High-intensity white lights in residential neighborhoods.

Towers over 450 feet AGL face an additional trigger: any new construction, substantial modification, or addition of lighting at that height automatically requires an EA, largely because of migratory bird concerns.⁸ State and local environmental regulations may impose additional requirements on top of the federal standards.

Tribal and Historic Preservation Notice

The FCC’s Tower Construction Notification System (TCNS) handles Section 106 review under the National Historic Preservation Act by distributing tower project notifications to federally recognized Indian Tribes, Native Hawaiian Organizations, and State Historic Preservation Officers. Those parties can respond directly with concerns.⁹ You can combine the ASR local notice with the Section 106 notice in a single publication, provided the combined notice covers both processes and explains the participation procedures for each.

When Environmental Notice Can Be Skipped

The environmental notification process is not required for certain low-impact filings, including changes filed solely to report an ownership transfer, updated contact information, or dismantlement. It’s also not required for height reductions, removal of lighting or switching to a more preferred lighting style, or replacement of a structure at the same location that doesn’t substantially increase in size.¹ Temporary structures in place for 60 days or less that are under 200 feet, need no marking or lighting, and involve no excavation also qualify for the exception.

Step Three: Finalize the Registration

Once the FAA determination is in hand and the local and national notice periods have run, return to the ASR system to finalize Form 854. The FCC checks the submission for completeness and verifies the FAA determination, including any marking and lighting conditions specified there. When approved, the FCC issues the ASR number. Construction cannot legally begin until that number has been granted.¹

After Construction: Close Out the FAA Study and Keep the Record Current

When construction finishes, file FAA Form 7460-2 (Notice of Actual Construction or Alteration) to close out the aeronautical study.¹⁰ Missing this step doesn’t invalidate the ASR itself, but it leaves an open record with the FAA that can complicate future modifications.

Any later change to the structure, its ownership, or the owner’s contact information has to be reported through an updated Form 854.¹ Common updates include:

Structural modifications such as height changes or different lighting types.
Ownership transfers, with the new owner’s legal name and contact details.
Contact updates, including new mailing address, phone number, or responsible party.
Dismantlement of the structure.

What Registration Commits You To

Registration is the start of an ongoing obligation, not the end. Registered structures must be painted and lit according to the specifications in the FAA’s Advisory Circular AC 70/7460-1M (currently Change 1, dated October 2024), and the FAA determination letter specifies the required lighting style for each structure.¹¹

Owners must inspect all automatic and mechanical control devices, indicators, and alarm systems associated with the structure’s lighting at intervals no longer than three months, unless the structure uses a monitoring system the Wireless Telecommunications Bureau has determined has adequate self-diagnostic features.¹² When a top steady-burning light or any flashing obstruction light fails and can’t be fixed within 30 minutes, notify the FAA immediately with the lighting condition, cause of failure, estimated repair date, ASR number, structure height, and reporter’s contact information. If repairs extend beyond the FAA’s initial Notice to Airmen (NOTAM) period, keep extending the outage date with the FAA until the lights are back in service. Side intermediate light failures don’t require FAA notification but must still be repaired as soon as practicable.¹³

1
eCFR. 47 CFR 17.4 – Antenna Structure Registration
2
eCFR. 47 CFR 17.7 – Antenna Structures Requiring Notification to the FAA
3
Federal Aviation Administration. 14 CFR Part 77 – Notice of Proposed Construction or Alteration
4
Federal Aviation Administration. Obstruction Evaluation/Airport Airspace Analysis
5
Federal Communications Commission. Filing a New Antenna Structure Registration in the Antenna Structure Registration (ASR) System
6
Federal Communications Commission. FCC Form 854 – Application for Antenna Structure Registration
7
Federal Communications Commission. Environmental Notification Process for the Registration of Antenna Structures – Local and National Notice
8
eCFR. 47 CFR 1.1307 – Actions That May Have a Significant Environmental Effect
9
Federal Communications Commission. Tower Construction Notifications
10
Federal Aviation Administration. Form FAA 7460-2 – Supplemental Notice
11
Federal Aviation Administration. Advisory Circular AC 70/7460-1M Change 1 – Obstruction Marking and Lighting
12
eCFR. 47 CFR 17.47 – Inspection of Antenna Structure Lights and Associated Control Equipment
13
eCFR. 47 CFR 17.48 – Notification of Extinguishment or Improper Functioning of Lights