Time for a Checkup!
July 29, 2021

FAA Required Biennial Lens Inspection
Many tower owners with obstruction lighting systems may be unaware, or uninformed, of the facts regarding the FAA’s requirement for biennial lens inspection. Let LumenServe℠
shed some light on the mystery to ensure you are in full compliance.
The Requirement
Let’s start with the requirement which was initiated with revision 1L of the FAA circular governing tower lighting and continues to be included in the most recent circular – 1M . Below is an excerpt from the FAA’s Advisory Circular for Obstruction Lighting and Marking - AC No. 70/7460-1L Change: 1
Date: 10/8/2016 Paragraph 4.5:
Due to the effects of harsh environments, light fixture lenses should be visually inspected every 24 months, or when the light fixture fails, for ultraviolet (UV) damage, cracks, crazing, dirt buildup, etc., to ensure the certified light output has not deteriorated. (See Chapter 2 paragraph 2.4 for reporting requirements in case of failure.) Lenses that have cracks, UV damage, crazing, or excessive dirt buildup should be cleaned or replaced.
By the way, the LumenServe℠ Federal Lighting Regulations Portal
provides an easy to navigate and comprehensive link to key regulatory websites as well as the best graphical illustrations to help simplify things.
The Intent
The intent of the lens inspection requirement is clearly (pun intended) stated to “ensure the certified light output has not deteriorated.” The purpose is to make sure the system is emitting light pursuant to specifications of the manufacturer’s equipment which has been approved by the FAA, and that there is nothing wrong with the lens performance which is causing a degradation of light emission.
What to Look For
The system should be visually inspected which means a tower climb or a high-resolution drone video to each of the lighting fixtures – all beacons and sidelights. The inspection should look for “ultraviolet (UV) damage, cracks, crazing, dirt buildup, etc.” The “etc.” in this instance could include unwanted deposits on the outside of the lens (think bird poop as an example), or unwanted deposits on the inside of the lens. LumenServe℠ has seen instances where material inside a legacy lighting system, such as certain types of tape, are vaporized and then deposited on the inside of the lens. This is a result of a poor installation and must be addressed. Certain older models of lighting lenses are made of older plastics that are affected by UV rays resulting in crazing. Old glass lenses can chip. The bottom line is the inspection relies on the reasonable judgement of the inspector to determine if the lens performance is degraded in some manner and decreasing the system’s certified output. No light meter or measurement is required, just a thorough inspection and reasonable determination of the status of each lens.
How Often to Inspect
The requirement states that “light fixture lenses should be visually inspected every 24 months, or when the light fixture fails.” Failure of the fixture indicates that the fixture must be repaired and thus makes for a good opportunity to inspect the lens, otherwise the lens should be inspected every two years.
How to Document and Record Keeping
The process LumenServe℠ utilizes to document the biennial lens inspection is to photograph three photos of each lens with each photo covering at least 120 degrees arc around the periphery of the lens to ensure that the full 360 degrees of the lens has been documented. The photos are embedded in a Biennial Lens Inspection package which provides all the pertinent information including: site name, ASR, location, FAA Style, inspection notes, inspection technician information, date, etc. This documentation is held for a minimum of two years, but usually longer.
If you need any help with biennial lens inspections, or any other aspect of tower lighting, LumenServe℠ can help you analyze the costs and benefits of all your options. Also, don’t forget, as the nation’s first Tower Lighting as a Service®
company, LumenServe℠ can provide qualified customers with a lighting solution that requires no upfront costs. Let us look at your situation and see if we can give you peace of mind
regarding your tower lighting.
For more information, please contact LumenServe℠
today!

If your tower’s obstruction lighting is required and something goes out, the goal is simple: restore the lighting and close the loop cleanly. The best outcomes come from a repeatable workflow that starts with good documentation and ends with confirmed resolution. If you’re not sure what a NOTAM is, start here: What Is a NOTAM (and Why Tower Owners Should Care) ? Need help building a consistent outage/NOTAM workflow? Book a Call . First: confirm who is responsible (owner vs. operator vs. vendor) Before “filing” anything, confirm who is responsible for origination and cancellation/closure within your organization’s process. FAA policy emphasizes that the party originating the NOTAM is responsible for accuracy and cancellation/closure actions. What you need before you file (gather this first ) Structure details (ASR-first, plus ASN for FAA workflows) • FCC ASR number (primary identifier) • Site/tower name (owner naming or your naming convention) • Location (address and/or coordinates) • Height (as documented) • FAA Aeronautical Study Number (ASN) (often needed for OE/AAA E-file actions) Why both? ASR is the most common operational identifier for tower owners/operators. But the FAA OE/AAA E-file NOTAM workflow in the Desk Reference Guide is driven by ASN. Outage details • What’s out (top beacon, side markers, multiple levels, controller behavior) • When it was first detected (date/time + timezone) • Whether it’s continuous or intermittent • What triggered detection (alarm/monitoring vs. visual confirmation) Repair plan • Who is dispatched • Estimated time to restore (if known) • Any access constraints (site access, climb requirements, weather delays) Contact + recordkeeping • Primary point of contact • Incident log entry (one place where all updates live) Want a predictable process for monitoring + documentation + response? We can help . Filing the NOTAM: Two Common Paths Path A: Your internal / vendor workflow (general) Use your established reporting workflow (owner-managed, vendor-managed, or LumenServe-managed). Keep the incident record current and make sure the administrative closeout is confirmed—not assumed. Path B: FAA OE/AAA “NOTAM E-Notification” via E-file (when required by your FAA determination) If your FAA determination requires NOTAM notification via the OE/AAA process, the FAA Desk Reference Guide indicates this is completed through a registered E-file account. High-level steps (as described in the guide): 1. In your OE/AAA portal, use the Temporary Structure Notification link (under “Off Airport Construction”). 2. Enter the Aeronautical Study Number (ASN) and confirm the case details. 3. Add the supplemental notice (shown as “Add 7460-2”), then select “Request a NOTAM.” 4. Provide the required fields the guide calls out (start date; completion date or number of days; removal date; time of arrival; onsite contact + phone). The guide notes the removal date cannot be in the future. 5. Save/confirm to submit. Important note from the guide: You may also need to complete separate notification to the airport and/or air traffic control tower depending on the conditions in your FAA determination letter. Clearing/Canceling: What “Done” Means Clearing is where teams stumble—because the lights might be back on, but the administrative loop isn’t finished. 1) Verify restoration (don’t assume) Confirm the lighting system is operating correctly (visual when safe, monitoring, and/or technician documentation). 2) Document proof of restoration Log restoration time, what changed, how it was verified, and who verified. 3) Close/cancel through the same workflow you used to initiate In the OE/AAA E-file workflow, the Desk Reference Guide includes a NOTAM Cancellation Notification path and again notes the removal date cannot be a future date. 4) Confirm closure and record it Whatever method you use, don’t stop at “we fixed it.” Record the closure confirmation in your incident log. Want LumenServe to help operationalize this so it’s consistent every time? Book a Call. Common mistakes to avoid • Not capturing detection time consistently • Vague outage descriptions • No single owner accountable for closure • Assuming “restored” automatically equals “cleared” • Thin documentation

If you own or operate communications towers, FAA tower lighting compliance is not optional. Obstruction lighting systems protect aircraft operating in the national airspace. When a tower’s lighting system fails, it can create a hazard to aviation and trigger regulatory obligations for the tower owner. Managing tower lighting compliance is more complex than most operators expect. It typically involves: • Understanding FAA obstruction marking and lighting standards • Monitoring obstruction lights continuously • Detecting and reporting outages within required timeframes • Maintaining daily observation logs and inspection records • Coordinating repairs and maintenance • Maintaining documentation for regulatory compliance This guide explains everything tower owners need to know about FAA tower lighting compliance, including regulations, inspection requirements, outage reporting rules, and operational responsibilities. Why Tower Lighting Compliance Exists Tall structures can present a hazard to aircraft operating at low altitude. To mitigate this risk, the Federal Aviation Administration establishes standards for marking and lighting structures that may affect navigable airspace. These standards are published in FAA Advisory Circular 70/7460-1M – Obstruction Marking and Lighting, which provides guidance for the marking and lighting of structures that may pose hazards to aviation. The goal is simple: Ensure tall structures are visible to pilots both day and night. Obstruction lighting systems allow pilots to identify towers and avoid collisions during: • Night operations • Low visibility conditions • Agricultural aviation • Helicopter operations • Low-altitude flight corridors Many modern lighting systems now also include infrared (IR) capability to ensure visibility for aircraft using night-vision equipment. Which Towers Require Obstruction Lighting? Not every tower requires aviation lighting. Under 14 CFR Part 77 – Safe, Efficient Use, and Preservation of the Navigable Airspace certain structures must be reported to the FAA for evaluation. Specifically, structures exceeding 200 feet above ground level (AGL) must be reported to the FAA using FAA Form 7460-1. After reviewing the structure’s height, location, and potential impact on aviation operations, the FAA issues a determination specifying whether the structure must be: • Marked • Lighted • Both marked and lighted Even structures below 200 ft AGL may require lighting if they penetrate protected airspace surfaces near airports. Types of FAA Obstruction Lighting Systems The FAA recognizes several obstruction lighting configurations depending on tower height, location, and aviation visibility requirements. Lighting standards and configurations are described in FAA Advisory Circular 70/7460-1M – Obstruction Marking and Lighting. Red Obstruction Lighting Systems Red lighting systems are one of the most common tower lighting configurations. These are typically found on Type A towers. Characteristics include: • Flashing or steady-burning red lights • Used primarily during nighttime operations • Installed at multiple elevations on the structure Common equipment types include: • L-810 low-intensity red lights • L-864 medium-intensity flashing red beacons These systems provide nighttime visibility without bright daytime flashes. Hight-Intensity White Lighting High-intensity white systems use flashing white strobes during daytime hours. These are typically found on Type B, C, and D towers. Characteristics include: • High-visibility daytime strobes • Reduced need for tower paint markings • Lighting installed at multiple tower elevations Typical equipment classification: L-865 flashing white obstruction lights Dual Mode Lighting Systems Dual mode lighting systems combine two lighting modes: • White strobes during daytime • Red obstruction lights during nighttime This configuration provides strong daytime visibility while minimizing nighttime glare. These are typically found on Type E, F, and G towers.

In the final chapter of our educational series, we'll discuss the benefits of moving away from incandescent and Xenon lights for your towers. If you'd like to watch the video, check it out here on our YouTube channel. For decades, incandescent tower lights were the standard for aviation obstruction lighting. While effective for basic visibility, these systems were inefficient, fragile, and costly to maintain. Xenon strobe lighting followed, offering longer life and improved efficiency. However, xenon systems still relied on flash-tube technology and continued to experience reliability issues, especially in harsh outdoor environments. The transition to LED tower lighting systems revolutionized the industry. Today, LEDs are the preferred solution for telecom towers, broadcast towers, wind turbines, and utility structures requiring FAA and FCC compliance. Why LED Technology Changed Everything Unlike glass bulbs or flash tubes, LEDs are solid-state semiconductors with: • No filaments • No corrodible contacts • No fragile internal components This makes LED systems highly resistant to shock, vibration, and temperature extremes—conditions towers face year-round. Structural Benefits: Smaller, Lighter, and Safer One of the most overlooked advantages of LED obstruction lighting is its low-profile physical design. Traditional incandescent and xenon lighting systems use large housings that increase the Effective Projected Area (EPA)—the surface exposed to wind loading. This adds stress to tower structures. LED tower lights are compact and lightweight, reducing: • Structural load • Wind resistance • Long-term fatigue on tower steel This improves tower safety and lowers engineering concerns. Proven Performance in High-RF Environments Modern towers operate in dense radio frequency (RF) environments. Older lighting technologies were vulnerable to interference and premature failures. LED tower lighting systems are engineered to perform reliably in high-RF conditions, making them ideal for today’s telecommunications infrastructure. Key Benefits of LED Tower Lighting Systems 1. Extended Operational Life Lighting Type Average Lifespan - Incandescent = < 1 year - Xenon = 2–4 years - LED = 10+ years Fewer replacements mean fewer tower climbs, lower labor costs, and reduced safety risk. 2. Up to 90% Energy Savings With efficacy exceeding 300 lumens per watt, LED obstruction lighting can: • Reduce electrical consumption by up to 90% • Lower monthly utility bills • Decrease lifetime operating costs This also supports sustainability and carbon reduction initiatives. 3. Community-Friendly Light Control Advanced LED optics provide precise beam control, allowing towers to: • Remain visible to pilots • Reduce glare in nearby neighborhoods • Minimize light pollution in urban and suburban environments 4. Environmentally Responsible Design LED systems: • Generate fewer lifetime emissions • Contain fewer hazardous materials • Support avian protection by reducing disorienting light patterns This aligns with modern environmental and regulatory standards. The Bottom Line: LEDs Are the New Standard LED tower lighting is not just a technology upgrade, it is a strategic investment in compliance, safety, and long-term cost control. LED obstruction lighting is: • Safer • More energy efficient • Structurally lighter • RF-resilient • Environmentally responsible • Many have the latest IR capabilities for improved night safety. For tower owners and operators, LED systems represent the future of aviation obstruction lighting. Thank you for reading the final chapter in our Educational Series. If you missed the previous ones, you can check them out now: Episode 1 Episode 2 Episode 3 Episode 4 Episode 5

In this installment of our YouTube video series review, we'll cover the actual costs of ensuring your tower is lit correctly. Tower lighting is a critical part of aviation safety and federal compliance, but the true cost of tower ownership extends far beyond the obvious price of the lights themselves. To illustrate this, let’s break down the real monthly cost of operating a 300-foot painted FAA medium-intensity A1 tower using a legacy incandescent lighting system. To keep the analysis practical and budget-friendly, all costs are expressed on a monthly basis, which reflects how most operators track operational spending. Hard Costs: The Direct, Visible Expenses These are the line items that appear on invoices and budgets. 1. Lighting System Reserve • System purchase & installation: $17,980 • Depreciation: 12 years • Monthly cost: $125 2. Tower Painting Reserve • 300 ft painted tower • Cost: $40 per linear foot • Paint life: 7 years • Monthly cost: $140 3. Repairs & Compliance Documentation • One repair per year: $1,900 (parts + tower climb) • FAA paint card inspection & documentation: $233 annually • Monthly cost: $178 4. Quarterly On-Site Inspections • Required for compliance • Monthly cost: $89 5. Electrical Power • Legacy incandescent system • Average commercial electricity rates • Monthly cost: $60 6. Compliance Monitoring & Data • Monitoring unit installed: $1,900 • Depreciated over 7 years • Monthly service fee: $30 • Secure data plan: $10 • Monthly cost: $72 Total Hard Costs: $667 per Month This equals $8,004 per year for a single medium-intensity painted tower. Soft Costs: The Hidden Operational Burden Soft costs don’t show up on invoices, but they consume time, staff, and internal resources: • Coordinating tower climbs and repairs • Managing vendor schedules and contracts • Procurement and logistics • Site access and safety coordination • Documentation and recordkeeping • Internal compliance management These administrative burdens quietly inflate the real cost of tower ownership. Risk Costs: The Unpredictable Financial Exposure Even well-managed towers face uncontrollable risks: • Inflation: Rising labor, parts, and energy costs • Compliance risk: Missed inspections or documentation gaps • Capital shocks: Sudden lighting system replacements • Catastrophic events: Storm damage, equipment failures, accidents These risks can rapidly exceed annual budgets and disrupt operations. The Bottom Line: Ownership Is More Expensive Than It Looks Hard costs alone average $8,000 per year for a single FAA A1 medium-intensity painted tower. Once soft costs and risk exposure are included, the true financial burden is significantly higher. There Is a Smarter Way There is another model that can reduce your tower lighting costs by up to 50% while eliminating risk, compliance stress, and operational complexity. To learn more, explore our solution series or visit LumenServe.com to see how Tower Lighting as a Service® changes the economics of compliance. For more compliance guidance, check out our other educational series blog posts: 1. Tower Lighting Compliance Checklist: How to Stay FAA & FCC Compliant 2. What is a NOTAM? 3. Tower Lighting Inspections: FCC & FAA Requirements Every Tower Owner Must Know 4. Why Some Towers Rely on Paint Instead of Lights
Ever wonder why some towers are painted red (or aviation orange) and others are not? Here is part 4 of our educational YouTube series that helps you learn all about it! Not all towers use lighting systems for daytime visibility. Towers marked with alternating bands of aviation orange and white are classified under FAA Style A marking. Instead of relying on lights, these structures depend on high-contrast paint to remain visible to aircraft during daylight hours. Maintaining this marking is not optional, it is a federal requirement. What the FAA Requires According to FAA Advisory Circular AC 70/7460-1: “Antenna structures requiring painting shall be cleaned or repainted as often as necessary to maintain good visibility.” To determine whether a tower remains compliant, owners must evaluate the paint condition using the FAA In-Service Aviation Orange Tolerance Chart. Why Paint Fails Over Time Environmental exposure gradually degrades tower paint: • UV radiation • Wind abrasion • Rain and weather extremes This causes fading, which reduces contrast and aviation visibility. Once faded beyond tolerance limits, the tower is no longer compliant and must be repainted or cleaned.

We extend our condolences to the families impacted by the recent helicopter crash in Houston’s Second Ward. While the cause is still under investigation, this tragedy is a reminder of how crucial obstruction lighting is for aviation safety. At LumenServe ℠ , we are dedicated to delivering innovative solutions that ensure your towers meet federal compliance standards, operate at peak efficiency, and ultimately protect lives. With cutting-edge technology, including Infrared (IR)-capable LED lighting systems, we help you stay ahead in safety and compliance without compromising on quality or cost.

