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Communication Tower Consultation in Virginia Communication Tower Consultation in Virginia


The U.S. Fish and Wildlife Services (Service) Virginia Field Office believes that individual
project review by this office is not required under certain conditions. The Service submits these
comments in accordance with provisions of the Endangered Species Act (ESA) of 1973 (87 Stat.
884, as amended; 16 U.S.C. 1531 et seq.), the Migratory Bird Treaty Act (MBTA) of 1940 (40
Stat. 755; 16 U.S.C. 703-712), the Bald and Golden Eagle Protection Act (BGEPA) of 1940 (16
U.S.C. 668-688d), and the National Environmental Policy Act (NEPA) of 1969 (83 Stat. 852; 42
U.S.C. 4321 et seq.).

Migratory birds are a Federal trust resource and are protected under the MBTA. Communication
towers and antennas may pose a hazard to migratory birds in flight and may pose a threat to
nesting birds attracted to the site. Risk assessment factors include tower height, physical design,
lighting, and site location relative to migratory corridors and bird concentration areas.

The Service has determined that the following proposed actions are not likely to adversely affect
federally listed species in Virginia, nor have any significant impacts on migratory birds or other
trust resources:

1.

Collocation of new equipment and antennae with an existing structure (tower, power
substation, smokestack, large building, water tank, etc.) where all ground disturbance
occurs within previously disturbed areas and where such activities do not increase the
existing height or require the addition of guy wires;

2.

Routine maintenance of existing tower sites such as painting, antenna or panel
replacement, upgrading existing equipment, etc.;

3.

Repair or replacement of existing towers and/or equipment, provided such activities do
not increase the existing tower height or require the addition of guy wires.

For projects that meet the above criteria, there is no need to contact this office for project
review. This letter may be used as an ESA determination of not likely to adversely affect.

The Service has developed the following guidelines at the national level, which we recommend
project proponents follow in the design and location of communication tower facilities. RECOMMENDATIONS TO AVOID ADVERSE IMPACTS TO MIGRATORY BIRDS,
FEDERALLY LISTED SPECIES, AND OTHER WILDLIFE FROM
COMMUNICATION TOWERS AND ANTENNAE

Wireless communication towers and antennae have greatly increased in number in recent years.
Cumulatively, communication towers have a potentially significant impact on wildlife,
especially migratory birds. All communication towers and antennae requiring authorization from
the Federal Communications Commission (FCC) are subject to the environmental review
procedures required by Section 7 of the Endangered Species Act (ESA) of 1973 (87 Stat. 884, as
amended; 16 U.S.C. 1531 et seq.) and by the National Environmental Policy Act (NEPA) of
1969 (83 Stat. 852; 42 U.S.C. 4321 et seq.). The U.S. Fish and Wildlife Service (Service)
routinely reviews proposed communication projects and provides recommendations to project
proponents and the FCC to avoid adverse impacts to federally listed or proposed endangered and
threatened species, migratory birds, and other wildlife.

All native migratory birds (e.g., waterfowl, shorebirds, songbirds, hawks, owls, vultures, falcons)
are afforded protection under the Migratory Bird Treaty Act (MBTA) of 1918 (40 Stat. 755; 16
U.S.C. 703-712). Migratory birds are a federal trust resource responsibility, and the Service
considers migratory bird concentration areas environmentally significant. Bird concentration
areas include traditional migratory flight corridors (e.g., ridges, shorelines, river valleys);
rookeries and other bird breeding areas; stopover, staging, or resting areas (e.g., land bounding
large bodies of water, wetlands, forests, and natural grasslands); wildlife preserves (e.g.,
National Wildlife Refuges; State Parks, Forests, Wildlife Management Areas, and Natural Areas;
private sanctuaries); and seasonal flight paths (e.g., between feeding and nesting or roosting
areas).

Communication towers pose a collision hazard to birds in flight, especially some 350 species of
night-migrating birds. Cumulatively, communication towers kill an estimated four to five million
birds per year nationwide (Manville 2000). The risk of bird collisions is related to tower height,
design, lighting, and location relative to migratory bird concentration areas. Most documented
bird kills at communication towers involve tall, lighted structures, and birds migrating at night
during inclement weather. During these events, birds attracted by the lights congregate and circle
around the tower, with mortality resulting from collisions with guy wires, other birds, and the
ground, or from exhaustion. However, occurrences of bird collision mortality at communication
towers have also been documented during daytime and fair-weather conditions.

The Service recommends the following steps to avoid or minimize adverse impacts to migratory
birds, federally listed or proposed endangered and threatened species, and other wildlife from
communication towers and antennae:

1.

Collocate communication antennae and other equipment on existing structures
whenever possible to avoid new tower construction. Antennae have been mounted on
rooftops; flagpoles; bell, cross, and clock towers; road signs; silos; and water and
power line towers. Where attachment to an existing non-tower structure is not
feasible, collocate antennae on existing communication towers. Depending on tower
load factors, multiple (6-10) providers may collocate on a single communication
tower. Although usually a preferred option, collocation on certain structures may be restricted, such as historic sites, or silos on farms under State or county deed
restriction for farm preservation, which may prohibit non-agricultural activities.

2.

Construct new towers only if collocation is not feasible. Design new towers to allow
for multiple transmitters to be collocated on a single new tower, no more than 199
feet above ground level (AGL), without lights or guy wires. (Towers taller than 199
feet are normally required by the Federal Aviation Administration [FAA] to employ
aircraft warning lights.)

3.

Consider the impacts of new towers to migratory birds, federally listed species, and
other wildlife, cumulatively as well as individually when siting and designing
networks of towers and antennae.

4.

Site towers away from wetlands; areas with a known high incidence of fog, mist, and
low cloud ceilings; and habitats supporting threatened or endangered species.

5.

Construct taller (>200 feet AGL) towers only if collocation and shorter towers are not
viable options. Use the minimum amount of pilot warning and obstruction avoidance
lighting required by the FAA. Use only white (preferable) or red strobe lights at night
unless otherwise required by the FAA, and employ the minimum number, minimum
intensity, and minimum number of flashes per minute (longest duration between
flashes) permitted by the FAA. Avoid solid red or pulsating red warning lights at
night. (Current research indicates that solid or pulsating (beacon) red lights attract
night-migrating birds at a much higher rate than white strobe lights. Red strobe lights
have not yet been studied.

6.

Construct guyed towers only if other tower designs (e.g., monopoles, lattice towers)
are not viable options. Locate guyed towers away from known raptor and waterbird
concentration areas and daily movement routes, and away from major diurnal
migratory bird movement routes and stopover sites. If a guyed tower must be located
in or near such an area, employ daytime visual markers on the wires. Do not use
artificial lighting to increase visibility of the structure or guy wires; instead use
reflective paint or materials, large balls, or other available technology. (For guidance
on markers, see Avian Power Line Interaction Committee 1994 and 1996.)

7.

Avoid or minimize habitat loss within and adjacent to the "footprint" of new towers
and associated facilities. (However, a larger tower footprint is preferable to the use of
guy wires.) Minimize road access and fencing to reduce or prevent habitat
fragmentation and disturbance, and to reduce above-ground obstacles to birds in
flight.

8.

Avoid siting towers in or near known bird concentration areas (discussed on page 1);
known bird migration or daily movement flyways; and areas known to be used
habitually by significant numbers of breeding, feeding, or roosting birds. If such areas
cannot be avoided, avoid construction during