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guidelines)have been developed but are not properly implemented. The Service has developed <br /> interim guidelines for new communications towers,which we encourage any company/licensee <br /> proposing a new communications tower to implement in an effort to minimize impacts to <br /> migratory birds:please see Appendix for general recommendations with regard to migratory <br /> birds and communication tower installation. <br /> To minimize bird collisions,we recommend keeping the tower height to less than 200 feet,thus <br /> making lighting unnecessary. You stated in your letter that this is not a possibility at this <br /> location since necessary coverage would not be met; however, we recommend your client also <br /> consider other sites where this would(<200 foot tower)be a possibility. We also recommend <br /> changing the project design to a self-support tower. When attracted to a lit tower,migrating <br /> birds often circle around the tower,colliding with guy wires. Bird diverters(which glow or flash <br /> during both day and night)may also be placed on guy wires to possibly alert birds of guy wire <br /> presence. <br /> If lighting is necessary, we strongly recommend the use of white day/night strobe lights with the <br /> minimum intensity and frequency of flashes allowable. Red steady-burning lights(L-810) <br /> should not be used, as they attract night-migrating birds at a higher rate than white lights. This <br /> lighting system would pose heightened collision risk due to the height of the proposed tower(all <br /> towers>350 feet require 2 sets of steady-burning red lights). Following concerns from the <br /> Service and other organizations, FAA initiated a study evaluating the need for steady burning <br /> lights on towers. FAA researchers concluded through this study that steady burning lights can be <br /> flashed,or in some instances omitted altogether, and still provide sufficient visibility to pilots. <br /> As a result, the agency is proposing to redefine their standards on obstruction lighting so that <br /> steady burning lights will no longer be necessary. Pending the FAA finalizing changes to their <br /> approved lighting systems,we anticipate contacting all tower operators to recommend changing <br /> lighting systems to comply with new approved lighting configurations. Therefore, if lighting is <br /> necessary on your tower,we recommend selecting/installing a more"bird friendly"system now <br /> rather than potentially incurring extra costs once the FAA finalizes changes. Please contact our <br /> office if you will not be able to reduce the tower height to less than 200 feet,thereby <br /> eliminating the need for lighting. The tower, as currently proposed,presents risk to migratory <br /> birds,particularly during migration periods. <br /> Also,we recommend any habitat disturbance(e.g.,tree removal)occur before May 1 or after <br /> August 30 to minimize potential impacts to breeding migratory birds, but please be aware/hat <br /> some species may initiate nesting before May 1. <br /> We appreciate the opportunity to respond. Questions pertaining to these comments can be <br /> directed to Mr. Peter Fasbender 920-866-1725. <br /> Sincerely, <br /> 01,600., W)a/n C -�. <br /> fpiPeter J. Fasbender <br /> Field Supervisor <br />