New Transport Canada Tower Lighting and Marking Regulations
New Rules for Tower Owners in Canada
Transport Canada has just released new tower lighting and marking regulations which have been eleven years in the process. This has significant implications for owners of communication towers in Canada.
Introduction
The changes affect the way towers will be lit and marked. As well, tower lighting and marking regulations in Canada are now mandatory, and include fines for non-compliance. This involves changes to the federal Aeronautics Act, and Canadian Aviation Regulations CAR 601 and CAR 621.19. Consequently, this will require operational changes for owners of new and existing towers in Canada.
The Aeronautics Act
The Aeronautics Act is Canadian federal legislation governing air transportation in Canada. It covers such items as airports, aircraft, airlines & aviation operations, aviation safety & security, emergencies, and incident reporting & investigation. It also covers Department of National Defence air operations. Most importantly, it covers aerodromes and administers regulations such as CAR 601 and CAR 621.
Introduction to TC CAR 601
CAR 601 is the administrative document for CAR 621.19. The new CAR 601 can be found at: http://canadagazette.gc.ca/rp-pr/p2/2011/2011-12-21/html/sor-dors285-eng.html.
It has the legal backing of subsection 7.6 (1) of the Aeronautics Act.
Transport Canada CAR 601 Revisions
The changes are significant and include:
601.22 - The introduction of monetary penalties for CAR 621.19 non-compliance for corporations and responsible personnel
601.23 - The definition of obstacle to air navigation
601.24 - The obligation to mark and light obstacles to air navigation
601.25 - The obligation to notify the Minister of any new structure or addition to an existing structure and the requirement to mark and light it
601.28 - The marking and lighting prerequisites for continued compliance
601.29 - The prohibition against altering or damaging marking and lighting display
Effect on Tower Owners in Canada
CAR 621.19 (Specification for Tower Marking and Lighting) has now gone from being a voluntary regulation to a mandatory legal requirement. Corporations that own towers and key personnel responsible for day-to-day tower site operations are now each liable for fines for CAR 621.19 non-compliance.
Transport Canada CAR 621.19 Revisions
The new CAR 621.19 can be found at:
http://www.tc.gc.ca/eng/civilaviation/regserv/cars/part6-standards-standard621-3808.htm.
The purpose is to provide standardized day and night tower marking and lighting to enable pilots to safely avoid hazards to air navigation. It clearly outlines tower lighting configurations and fixtures required. For the first time it also introduces the CL-865 rotating beacon with W-W-R-W-W-R pattern. Most importantly it covers new tower specifications and maintenance of existing sites.
New CAR 621.19 Tower Lighting Configurations
There are now six tower lighting configurations. Configurations A, D, E are MI (Medium Intensity), and Configurations B, C, F are HI (High Intensity). Now, for the first time in Canada, MI configurations can be used (with paint) on tall towers (150 - 630m).
New Configurations of Tower Marking and Lighting
The six configurations are as follows:
FAA/TC MI Configuration A uses paint (alternating bands of orange and white) for day marking, and red light (2,000 candela) for night marking. This can now be used on towers up to 630m
FAA/TC MI Configuration D uses no paint, white light (20,000 candela) day, and white light (2,000 candela) night (150m max). This can now be used (with paint) up to 630m
FAA/TC MI Configuration E uses no paint, white light (20,000 candela) day, and red light (2,000 candela) night (150m max). This can now be used (with paint) up to 630m
FAA/TC HI Configuration B uses no paint, white light (270,000 candela) day, white light (20,000 candela) twilight, and white light (2,000 candela) night.
FAA/TC HI Configuration C uses no paint, white light (270,000 candela) day, white light (20,000 candela) twilight, and white light (2,000 candela) night. This type allows an appurtenance on top of the structure (taller than 12m) lit with MI white lighting.
FAA/TC HI Configuration F uses no paint, white light (270,000 candela) day, white light (20,000 candela) twilight, and red light (2,000 candela) night. This type allows an appurtenance on top of the structure (taller than 12m) lit with MI white/red lighting.
New Marking (Paint) Schemes for Towers
Where paint is required, towers continue to have 7 bands of orange and white up to 210m. Above 210m, when used with MI lighting, towers have an increasing number of orange and white bands.
Light Fixture Types for Tower Lighting
The light fixtures for the six configurations are as follows:
FAA/TC Configuration A uses paint (orange and white bands) for day marking. For night lighting, it uses a combination of CL-864 Red Beacon (2,000 candela) and CL-810 Red DOLs (32 candela).
FAA/TC Configuration D uses CL-865 White Beacon (20,000 candela) day, and CL-865 White Beacon (2,000 candela) night.
FAA/TC Configuration E uses CL-865 White Beacon (20,000 candela) day, and for night it uses a combination CL-864 Red Beacon (2,000 candela) and CL-810 Red DOLs (32 candela).
FAA/TC Configuration B uses CL-856 White Beacon (270,000 candela) day, CL-856 White Beacon (20,000 candela) twilight, and CL-856 White Beacon (2,000 candela) night.
FAA/TC Configuration C uses CL-856 White Beacon (270,000 candela) day, CL-856 White Beacon (20,000 candela) twilight, CL-856 White Beacon (2,000 candela) night. On top of the appurtenance it uses CL-865 White Beacon (20,000 candela) day, and CL-865 White Beacon (2,000 candela) night.
FAA/TC Configuration F uses CL-856 White Beacon (270,000 candela) day, CL-856 White Beacon (20,000 candela) twilight, and for night it uses a combination of CL-864 Red Beacon (2,000 candela) and CL-810 Red DOLs (32 candela). On top of the appurtenance it uses CL-865 White Beacon (20,000 candela) day, and CL-864 Red Beacon (2,000 candela) night.
Introducing a New MI Light Fixture: the CL-865 Rotating Beacon
Unlike other CL-865 beacons that flash, the rotating beacon uses a steady-burning HID bulb in conjunction with a motor-driven lens carousel, with a pattern of W-W-R-W-W-R. Like all other CL-865 beacons, the rotating beacon is required to have two modes (20,000 candela day and 2,000 candela night) controlled by a photocell.
New Tower Construction under a TC CAR 621.19 Enforcement Regime
In Canada, the tower owner (not the lighting manufacturer) has always been responsible to meet CAR 621.19. Now, with a mandatory CAR 621.19 enforced by fines, it becomes even more important for the tower owner to ensure that lighting for new towers is truly CAR 621.19 compliant. Unfortunately, in the past, with CAR 621.19 compliance being voluntary, some tower lighting companies had a rather liberal interpretation of what compliance meant. As a result, tower owners should not rely on certification documents provided by tower lighting companies.
Ensuring that Tower Lighting Meets CAR 621.19
One way to be certain of compliance is to obtain a sample of the proposed tower lighting and take it to a recognized test lab (such as Lighting Sciences of Waterloo ON, or Intertek ETL of Cortland NY). Subsequent new samples of the lighting supplier's products should also be tested on a quarterly basis to ensure continuing compliance. FAA and TC tower lighting standards are virtually identical (due to the USA-Canada Air Navigation Treaty). In addition to enforcement, FAA requires tower lighting manufacturers to maintain records of photometric tests for each light fixture, to undergo compliance testing at their nationally recognized test lab ETL, and to periodically provide production samples for follow up testing.
The Easy Way to Ensure Compliance
FAA posts a list of certified tower lighting products at their "List of Approved Products" website: http://www.faa.gov/documentLibrary/media/Advisory_Circular/150_5345_53c_addendum.pdf
The FAA document is called AC 150-5345-53C Airport Lighting Equipment Certification. For example, if tower owners want to find approved suppliers of L-865 white/white light fixtures, they just scroll through the document to the L-865 page, and choose a supplier listed there. FAA and ETL do all the work of testing the lighting products and ensuring continued compliance by the listed lighting manufacturers. This allows tower owners to focus on their core business, free of concern about CAR
621.19 light fixture compliancy.
Existing Site Tower Lighting Under a CAR 621.19 Enforcement Regime
Transport Canada CAR 621.19 inspectors will soon be visiting tower owners' existing sites. An inventory of existing site lighting will be required. All existing site lighting not listed on the FAA "List of Approved Products" website will need to be tested at an accredited test lab. Any lighting found not in compliance with CAR 621.19 will require replacement.
Existing Tower Day Marking (Paint) Under a TC CAR 621.19 Enforcement Regime
All existing painted towers will need to be checked against the FAA/TC Paint Colour Tolerance Chart.
Towers not complying with the chart will need to be repainted or retrofitted with FAA/TC Configuration D or E tower lighting (paint not required under 150m).
Summary
Transport Canada CAR 621.19 is now mandatory, and tower owners and key personnel will be fined for non-compliance. Tower owners need to ensure that their current tower lighting suppliers' products comply with CAR 621.19. Tower owners need to make an inventory of tower lighting and marking on all existing towers and ensure that it complies with CAR 621.19.