Hello everybody. I've been following this board for several years and have picked up a great deal of information. One thing I have learned is that safety is very important to everyone who flies. The issue of MET towers is, in my opinion, of great concern. I fly ag and also love flying my Citabria low and slow. Here in central and northern Nebraska MET towers are popping up all over and they are very hard to see. This has been an issue with aerial applicators for a few years now and we are finally getting things going on the right track. With everyones voice being heard, we (pilots), are being heard by the FAA. I just wanted to share with BackCountryPilot.org our organizations official stance. I encourage everyone to comment, and in no way am I claiming our stance is the only or the correct position for everyone. But, feel free to take what you want from our comments. Thanks and be careful out there.
NEBRASKA AVIATION TRADES ASSOCIATION
January 19, 2011
Docket Operations, M-30
U.S. Department of Transportation
1200 New Jersey Avenue, SE.,
West Building Ground Floor, Room W12-140
Washington, DC 20590-0001
Subject: Comments on Proposed FAA Guidance “Marking Meteorological Evaluation Towers,” Docket Number 2010-1326
To Whom It May Concern,
The Nebraska Aviation Trades Association (NATA) is pleased to have this opportunity to provide our organization’s official comments on “Marking Meteorological Evaluation Towers” (Docket No: FAA 2010-1326) as presented for stakeholder comment by the Federal Aviation Administration. NATA is the professional organization for agricultural pilots in the State of Nebraska with a membership of about 160 members. The following paragraphs are responses to specific points as solicited in the FAA guidance.
We fully support the painting the met towers in alternating bands of aviation orange and white paint. It is our distinct recommendation that the entire tower be painted in alternating bands rather than just an upper portion.
NATA recognizes the value and supports the usage of spherical marker balls (aviation orange color, 51 cm diameter) on outer guy wires of met towers. We request the usage of spherical marker balls over flag markers because they are a more visible option. The use of only spherical marker balls aids to standardize upon one method of marker identification for greater pilot recognition rather than having two marker options.
High visibility sleeves on guy wires at the ground anchor point further add to the recognition of met towers by pilots. We see great value and recommend using at least 16 feet of sleeves of a florescent orange color on guy wires at the anchor point so that the sleeves reach a height above a given crop.
Strobe lighting, although easily seen by pilots, has strong disadvantages on a temporary structure. Its success depends upon a fully functioning and expensive set of components of solar panel, battery pack, wiring, switches, and a strobe light that can too easily fail. The use of the met tower markers of alternating paint bands, marker balls, and guy wire sleeves are sufficient, can be easily seen, and their failure rate is nearly zero. Determining the entity responsible for strobe light maintenance further complicates the consideration of strobe lighting and may too
easily allow strobe light failures to go uncorrected. NATA does not recommend strobe lighting in the final guidance.
The proposed guidance for the marking of met towers did not address the issue of tower marking maintenance. We see the need for the FAA’s final guidance on met towers to recommend the monitoring and maintenance of markings (as long as the tower remains standing) by the appropriate representative (tower owner, contractor or electrical power entity, etc.) with repair and/or replacement of the marking components as necessary.
NATA requests the FAA to include in its final met tower guidance that markings be placed on new met towers at the time of construction and that markings be added to existing, unmarked towers within six months of the implementation date of this guidance.
As a summary, it is our recommendation and preference that met towers have multiple markings to include 1) alternating bands of aviation orange and white paint on the entire tower, 2) spherical marker balls on guy wires (aviation orange color, 51 cm diameter), and 3) high visibility, fluorescent orange sleeves of at least 16 feet in length on guy wire anchor points. Each of these items is to be used as directed by FAA Advisory Circular 70/7460. We ask that the final FAA guidance include recommendations for responsibility of tower marking maintenance, that new met towers are marked at the time of construction, and that existing, unmarked towers be identified within six months of the implementation of this guidance.
The Nebraska Aviation Trades Association extends its sincere appreciation to the U.S. Federal Aviation Administration for recognizing this important safety of flight issue concerning unmarked met towers. We commend the FAA for taking appropriate steps to minimize aviation risks for the agricultural aviation industry, life flight crews and patients, and aerial fire suppression crews.
Sincerely,
Chip Coslor
President
Nebraska Aviation Trades Association
PO Box 66
St. Paul, NE 68873
Copy: Nebraska Department of Aeronautics
