This guide is for the owner of a tower, not the owner of the land under one. The record it describes belongs to the structure, and the structure's owner is the one who has to keep it right.
Before a buyer calls you back, they have read your tower's registration. The FCC's antenna structure database is public, searchable in a minute, and it is the first document a buyer opens, because it says in the government's own words who owns the tower, how tall it is, where it stands, and whether the FAA has signed off on it. If the record and the tower agree, the buyer moves on to the leases. If they disagree, the buyer has a diligence item before the conversation has started. This guide walks through the record field by field: what it says, what a buyer makes of it, and what to fix before you go to market.
Which towers are registered
Not every tower has a record. The FCC requires registration of any structure that needs notice to the FAA, and the FAA needs notice for any structure more than 200 ft above the ground at its site. Nearer an airport the ceiling drops: an imaginary surface slopes up from the runway, and anything that pokes through it needs notice too, which can mean a tower well under 200 ft within a few miles of a public airport. The rule works the other way as well. If the FAA exempts a structure from notice, the FCC exempts it from registration. So a 150 ft monopole in open country may have no record at all, and that is not a defect. An owner can register such a tower voluntarily, and some have, but a missing record on a short tower away from an airport is the rule, not an oversight.
What a buyer wants to know is which case yours is. A tower over 200 ft with no record is a problem. A tower under 200 ft with no record is a question about airports, and a buyer's engineer answers it in an afternoon.
Finding the record
The FCC's antenna structure registration search (opens in a new tab) finds a record three ways: by the registration number, by the owner's name, or by coordinates. The number is the fastest. The rules require it to be posted where it can be read from the public road or path nearest the base, on the perimeter fence or the access gate where there is one, so the quickest route to your own record is to walk to the gate and read the sign. If the sign is missing, search by the name on the ground lease or on the tenant leases, and then by the names of any previous owners, because the record may still be in one of theirs.
The search results list each record's number, status, file number, owner name, coordinates, city and state, and overall height above ground. Open the record itself for the rest.
What a buyer reads
Seven fields carry most of the weight.
Owner. The name and FCC registration number (FRN) of the owner of record. A buyer checks this against the name on your ground lease and your tenant leases. If the three agree, the chain of title starts clean.
Status. Granted means the FCC approved the registration before construction. Constructed means the owner later reported the tower built, and the record shows the date. Dismantled means the owner reported it taken down. A buyer expects a standing tower to read constructed. A tower that still reads granted was never reported complete, and a tower that reads dismantled while it stands in the field is a conversation.
Overall height above ground. The record gives it in meters, measured to the highest point including lighting and lightning protection, so a 150 ft tower reads 45.7. A buyer compares this figure with the drawings, the structural analysis, and what the engineer measures on site.
Coordinates. Latitude and longitude in NAD83, with the address and county beside them. The buyer plots them against the parcel in the ground lease. A tower that sits on the wrong parcel in the record is a title question.
FAA study and issue date. The FAA's study number and the date of its determination that the structure, at that height and place, is no hazard to air navigation. The determination fixes a height. The as-built tower has to match it.
Painting and lighting. The FAA chapters the determination requires, which the rules then oblige the owner to follow. A buyer's site visit checks that the lights the record calls for are there and working.
Last action. The record's most recent filing: what it was for, when it was received, and when it was entered. A record whose last action is years old is not wrong on its face, but it tells the buyer how long it has been since anyone looked.
The first thing a buyer takes from all this is not any one field. It is whether the record describes the tower in front of them.
When the record and the tower disagree
Four mismatches come up, and each means something different in diligence.
The owner is someone else. The most common one. The tower changed hands, and nobody filed the change, or the seller's company was renamed, merged, or dissolved. The rules require the owner to notify the FCC of any change in ownership information within 5 days by filing Form 854, and since 2019 the filing takes two steps: the current owner of record and the new owner each sign in and complete their part. That second step is why a stale record is slow to fix after the fact. If the previous owner has gone out of business, the new owner has to show the FCC the chain of title another way. A buyer lists a stale owner as a diligence item, not a reason to pass, but the time it takes to cure sits inside the diligence clock, and it is far quicker to cure before the sale than during it.
The height is different. A change of one foot or more in overall height needs the FAA's prior approval and a modified registration. If the tower grew when a tenant added a lightning rod or a taller top mount, or shrank when a section came down, and the record was never updated, the buyer has an open regulatory item that touches the FAA determination as well. This one needs an engineer's measurement and a filing, and the buyer will want to see both.
The coordinates are off. A difference of one second or more in latitude or longitude also needs FAA approval and a modified registration. A small error is usually a transcription from decades ago. A large one can mean the record describes a different site. Either way the buyer checks the record against a survey.
The status is wrong. A standing tower that reads granted was never reported constructed. The rules ask for that report within 5 days of completion. A record that reads dismantled for a tower still standing is rarer and worse, because somebody filed it. Both are fixable with a filing, and the buyer wants them fixed before closing.
The common thread: none of these is a reason a tower cannot sell. All of them cost days, and days at the end of a sale cost more than days at the start.
Keeping it current
Four habits keep the record where a buyer wants it.
File ownership changes when they happen, in both directions. If you bought the tower, confirm the record is in your name now, not when you decide to sell. If you are selling, plan the filing as part of closing, because the buyer cannot complete the two-step change without you.
Tell the tenants. When a registration is issued, the rules require the owner to give every tenant licensee the registration number and a link to the FCC's site. Tenants' own licenses reference it, and a carrier's lease administrator will ask for it.
Keep the sign up. The number on the gate is a rule, and it is also the first thing a buyer's contractor photographs on a site visit.
Read the record once a year. It takes a minute, and the four mismatches above are all cheaper to fix in a quiet year than in a sale.
Ownership of the record is not the same as ownership of the tower. A deed, a bill of sale, and the leases decide who owns the structure. But the record is the public version of that fact, and a buyer reads it first. From first call to close explains where in the five steps the record gets checked, and what the fix costs you in time if it is wrong.
Start with the facts
Send the tower's ASR number if you have it, along with the structure, the height, who is on it, and whether the land is owned or leased. We read the record before we answer, and the written answer tells you whether anything in it needs attention before an offer. If there is no record and the tower is under 200 ft, say so; that is usually fine, and the engineer confirms the airport question. The FAA determination and the registration are the two public documents every sale rests on, and both are easier to put right now than later. Submit a site.
Sources
- FCC, Antenna structure registration search (opens in a new tab)
- eCFR, 47 CFR Part 17: sections 17.4 (registration, posting, and changes in height or coordinates), 17.7 (structures requiring notice to the FAA), 17.21 and 17.23 (painting and lighting), and 17.57 (reports of construction, dismantlement, and ownership change) (opens in a new tab)
- eCFR, 14 CFR 77.9: construction or alteration requiring notice to the FAA (opens in a new tab)
- FAA, Form 7460-1, Notice of Proposed Construction or Alteration (opens in a new tab)
- Wireless Estimator, FCC admits to and fixes ASR flaw that allowed 40-plus illegal tower ownership changes (February 12, 2019) (opens in a new tab)