Section C — Overview of Antenna Siting
Section C of this report offers an overview of the antenna siting policies of Canada, Australia, New Zealand, the United Kingdom and the United States of America. The material on Canada's antenna authorization policies is provided as one part of the policy background to the six policy questions addressed within Section D of this report.
The antenna siting policies of the four other developed nations have been included for comparative purposes. This report was written with the premise that the radiocommunication industry and other radio users in Canada should not be subjected to regulatory requirements and transactional costs (related to the establishment of their antenna towers and other visible infrastructure) that are out of line with the regulatory obligations and costs borne by their counterparts located in similar nations. At the same time, if the radio regulators located within nations similar to our own are asking the members of their radio industry and other radio users to meet certain social objectives regarded by Canadian citizens as important or worthwhile, our radio regulator should use its' authority to achieve similar objectives unless compelling reasons exist not to do so.
Antenna Siting Policy in Canada
This subsection of the National Antenna Tower Policy Review provides an overview of four of the antenna-siting/authorization policies of principal interest to those citizens and land-use authorities concerned about antenna towers. These policies relate to assessments of adverse environmental impact, human exposure to radiofrequency fields, land-use consultations at the local or regional level and the aeronautical marking and lighting of antennas and their supporting structures. Each will be examined in turn.
The source of legal authority for these policies and their policy content comes from a variety of sources. These range from primary legislation (such as the Canadian Environmental Assessment Act (CEAA), Radiocommunication Act, Broadcasting Act and Aeronautics Act), to radio licensing conditions (such as those imposed by Spectrum Licence), to Industry Canada's particular licensing policies (such as the Broadcasting Procedure Rules (BPRs), to individual technical standards (such as [aeronautical] Standard 621.19 - Obstruction Markings and Lighting) and to departmental procedural circulars (such as Industry Canada's Client Procedures Circulars (CPC-2-0-03s)).
Land-use officials and members of the public interested in antenna siting issues cannot be expected to piece together all of these regulatory and policy instruments in order to understand antenna authorization in Canada. There exists a policy instrument that attempts to do this. The document is entitled Client Procedures Circular, Environmental Process, Radiofrequency Fields and Land Use Consultation, (CPC-2-0-03-2-0-03).Footnote 7 Its purpose is more than explanatory in that it also establishes procedural policy for the consultation processes that are to occur between those who seek to install (or modify antenna) structures and land-use authorities.
Since the summer of 1990, Canada's principal policy documents used to describe the process for the siting/authorization for most radio antennas and their supporting structures have been CPC-2-0-03-2-0-03, and the client attestation formFootnote 8 annexed to it. The policy circular was first issued in June 1990 and it has since been revised on two occasions. The current edition was published on June 24, 1995. While CPC-2-0-03-2-0-03 has never had the status of law, its contents have been applied consistently by Industry Canada and by its predecessor, the Department of Communications. In tone and content, it is clear that this document was written by the radio regulator for use by the radiocommunication industry and other radio users. By default, it is the only policy document available to inform land use authorities, public interest groups, and citizens as to the criteria for their respective roles within the antenna authorization process in Canada.Footnote 9
CPC-2-0-03-2-0-03 addresses three main policy issuesFootnote 10 related to the siting and authorization of radio antennas and their supporting structures. These policy issues are (1) the potential for adverse environmental effects, (2) the regulation of human exposure to certain radio frequency fields and (3) the requirement for consultations between individual antenna proponents and the appropriate land-use authority in the circumstances. These environmental assessment, RF exposure and land-use consultation requirements can be supplemented by other radio regulatory policies. For example, the Broadcasting Procedure Rules (BPRs) and Broadcasting Procedures (BPs) applicable to the various categories of broadcasting undertakings (e.g. AM, FM and Television undertakings) have further specified the notice requirements that must be met when the applicant for approval of a broadcasting antenna installation consults with a land-use authority.
Due to the particular policy treatment of land-use consultations necessary for the approval of the antenna systems for broadcasting undertakings and cellular/PCS base stations, these are examined separately in this subsection of this report.
Adverse Environmental Effects
As early as 1990, the applicants for most land, coast, earth and broadcasting station licences in Canada were required to perform environmental assessments upon their antenna structure proposals. The legislative provision that imposed those review obligations was located within section 3 of the (former) Environmental Assessment and Review Process Guidelines Order. This subordinate legislation created an environmental review scheme that was administered by the Federal Environmental Assessment Review Office (FEARO). The (then) Department of Communications created the first version of CPC-2-0-03-2-0-03 in 1990, as the guidance document for the performance of these environmental assessments. At the time, the environmental impact caused by the construction or placement of an antenna system, the exposure of humans to radiofrequency fields and the local land-use implications of the proposal were all regarded as environmental matters. The CPC-2-0-03 document was actually called, "Environmental Assessment Process Associated with Spectrum Management Activities."
Applicants for these broad categories of radio licence had to complete and submit an attestation form, called "Annex D: Radio Licence Application Supplement - Preliminary Environmental Information"Footnote 11 along with their radio licence application ((general) Form 16-16). Annex D contained three short questions related the potential environmental impact of the proposed radio station itself or about its construction. These questions concerned matters such as the impact upon wildlife areas, national or provincial parks, ecologically sensitive areas, culturally sensitive areas and the migratory patterns of animals such as birds and caribou. The licence applicant responded to these questions by answering 'yes' or 'no.' A positive answer would cause the department to follow up to see if the impact could be mitigated by adjusting the proposal. The first stage of this process was called a 'preliminary environmental assessment.'
In January of 1995 the Canadian Environmental Assessment Act (CEAA)Footnote 12 was proclaimed into force and it has established a new legislative approach for determining when an environmental assessment will be required. According to section 5(1)(d) of CEAA:
Not every federal issuance of authority to undertake a project is covered by the Act. The Law List RegulationsFootnote 13 were used to list the federal legislative "powers, duties or functions" that are subject to an environmental review. Of relevance here is that section 13 of these regulations specifically enumerates section 5(1)(f) of the Radiocommunication Act as a federal decision-making power that approves projects that will require an environmental assessment under CEAA. Section 5(1)(f of the Radiocommunication Act contains the power given to the Minister of Industry by Parliament to:
Therefore, the requirement to conduct environmental assessments for radio antenna systems, under the Canadian Environmental Assessment Act, is now tied directly to Industry Canada's regulatory authority to grant approvals for specific sites for radio stations or for specific antennas, towers or other supporting structures.
When CEAA was proclaimed in 1995, Industry Canada had already begun to move away from granting specific antenna site or antenna system approvals for GRS [Citizen Band], most receive-only satellite dishes, and radio amateur installations. When the department updated the content of CPC-2-0-03-2-0-03 that year, it created the designation "Type 1" for all radio stations that required a site-specific or antenna-specific authorization and "Type 2" for those that did not. Thus, Type 2 radio stations were, and continue to be, exempt from the requirements of CEAA.
The 1995 version of CPC-2-0-03-2-0-03 established a two stage environmental review for all Type 1 radio stations, and that process continues today. The applicant for the desired radio station licence must file with Industry Canada answers to seven questions related to the potential for negative environmental effects. These questions are set out in subpart 'B' of "Annex 1" to the CPC-2-0-03 called, "Part B- Preliminary Environmental Information Attestation." This (self-administered) attestation form asks the antenna proponent to check for the close proximity of bodies of water or wetlands (within 30 metres), and whether the proposal antenna will be located within a national park, a protected area or lands to which the Territorial Land Use Regulations applyFootnote 14 Providing a positive answer to one of the questions may lead to a requirement to perform a more complete environmental assessment under the Canadian Environmental Assessment Act. This would be the second stage.
While the following examples of adverse environmental effects do not appear on the attestation form that the proponents of Type 1 radio stations must file with Industry Canada, they are listed in the policy circular itself:Footnote 15
- detrimental effects on water bodies, ground water or soil;
- adverse effects on legislated protected areas such as national parks, historic canals or other protected areas;
- alteration, disruption or destruction of terrestrial and aquatic habitat for wildlife and fisheries;
- changes to current use of lands and/or quality of lands and natural resources for traditional purposes by aboriginal persons;
- [and] alteration of historical, archaeological, paleontological or heritage resources resulting from a change to the environment.
To date, Industry Canada has had almost no experience with the performance of more extensive (stage 2) environmental assessments upon antenna installation proposals. This is because so few proposals have met the environmental impact criteria described in Industry Canada's client attestation form and because, to their credit, antenna proponents have altered their antenna construction plans should those plans trigger a secondary environmental assessment analysis.
As noted above, the antennas and supporting structures of Type 2 radio stations are not subject to any environmental review requirements because no particular ministerial authorization is required under section 5(1)(f) of the Radiocommunication Act in advance of their construction or modification. Recently, there has been a dramatic increase in the number and variety of Type 2 stations. There are two main reasons for this increase.
First, Industry Canada has been experimenting with licensing policy options that reduce the regulatory burden for its clients and for itself by moving away from individualized licensing transactions. These deregulatory licensing options have included 'System Licensing' and 'Spectrum LicensingFootnote 16 which ay include many base stations under one or a few licences. Currently, all Cellular/PCS service providers are authorized by Spectrum Licence and, in consequence, their antenna facilities are exempt from environmental review.Footnote 17
Second, over the past five years or so, the electronics industries have developed many types of consumer and commercial digital wireless apparatus that operates within licence-exempt frequency bands, such as those at 2.4 GHz, 5.8 GHz and 24 GHz. Being licence-exempt does not mean that this apparatus is unregulated. Radio regulators have set rules, standards and specifications for the apparatus to control for interference from and between these wireless devices.Footnote 18 It does mean, however, that their antenna facilities are not subject to environmental assessment because no permission is granted by Industry Canada before they can be established or modified.
The transmission towers and other facilities of broadcasters continue to be subject to environmental assessment so long as the establishment of the undertaking is regulated under the Broadcasting Act.
Human Exposure to Radiofrequency Fields
Safety Code 6Footnote 19 (SC 6 or the Code) is Canada's national standard on human exposure to radiofrequency (RF) electromagnetic fields.Footnote 20 It is a comprehensive document that sets out safety requirements for the installation and use of radiofrequency and microwave devices that operate in the frequency range from 3 kHz to 300 GHz.Footnote 21 The Code provides two sets of RF exposure limits that are based upon the status of the individual who may be exposed: (1) radiofrequency and microwave workers who may be exposed in the course of their daily work, and other persons including the (2) general public who may be exposed at any time or place. Obviously, the exposure limits for the general public are the specifications most relevant to the location and other siting features of radio antennas and their towers.
The Consumer and Clinical Radiation Protection Branch of Health Canada produces Safety Code 6 as a guidance document. It is Industry Canada that has required compliance with it by incorporating SC 6 into radio regulatory provisions dealing with handheld radio apparatus (like cell phones) and antenna installations. Essentially all radio apparatus and stations must be compliant with the Code. It is the nature and extent of the analysis that must be performed to establish compliance that differs by radio authorization or radio apparatus category. These particular specifications are published within the various rules, procedures, standards, specifications and plans used by Industry Canada. For example, Type 1 - Broadcasting undertakings must provide radiofrequency exposure analysis with each application for a broadcasting certificate. The various types of analyses that must be performed are specified by broadcasting service category and set out in Industry Canada's Broadcasting Procedures and Rules (the BPRs).
According to the contents of CPC-2-0-03-2-0-03, both Type 1 and Type 2 radio stations must be "installed and operated in a manner that complies with Safety Code 6."Footnote 22 Since compliance with Safety Code 6 exposure limits is typically imposed by particular licensing condition, and the acceptable means to test for compliance with SC 6 are specified within the policy documents applicable to particular licence categories, the references to the Code within CPC-2-0-03-2-0-03 serve more as policy reminders than as a source for policy content.
Consultation with Land-Use Authorities
Within its introductory paragraph on land-use consultations, CPC-2-0-03-2-0-03 makes the following statements about the importance of community concerns when radio antennas and their supporting structures are established:
CPC-2-0-03-2-0-03 provides a general policy framework for the land-use consultations that are to occur between certain antenna proponents and Canadian land-use authorities when significant antennas and/or supporting structures (including towers) are to be installed or modified.
The CPC-2-0-03 document itself does not create the consultation obligations for the various categories of radio station in Canada.
For the most part, the local consultation requirements applicable to the various categories of radio station are imposed by Industry Canada as conditions of licence. When describing these conditions different approaches and text have been used. Land-use authorities and spectrum users cannot rely upon the text of the CPC-2-0-03 alone. Usually, compliance with all or part of the content of CPC-2-0-03-2-0-03 is required, but the particular licensing conditions and policy documents written for the various categories of radio station (that involve fixed antenna systems) may modify certain elements or stages of the consultation processes set down within this general policy circular. This is especially true for radio stations authorized by particular broadcasting certificates and particular spectrum licences.
Document CPC-2-0-03-2-0-03 contains two land-use consultation models - one is much more structured than the other and the structured model has definite stages and calls for more oversight and involvement by Industry Canada. The structured consultation model is applied to "Type 1 radio stations." These are radio stations that require a site-specific approval before the antenna can be constructed or put into operation. As explained within the previous subsection of this report on 'adverse environmental effects,' this typology was created in 1995 as a consequence of the way in which the obligations to conduct environmental assessments under the Canadian Environmental Assessment Act were imposed. Almost all broadcasting undertakings and certain non-broadcasting land and coast stations require a site-specific certificate or licence.
Under the terms of CPC-2-0-03-2-0-03 the flexible land-use consultation model is reserved for Type 2 radio stations. These are stations or radio apparatus that either: (1) require a radio authorization (typically a licence) that is not site-specific or (2) are licence-exempt but must comply with specified power, frequency and other technical limits. Almost no details are provided within the circular as to how the land-use consultations for Type 2 radio stations are to be conducted.
It is logical to create both structured and flexible land-use consultation requirements for antenna proposals, and to mandate the use of one or the other (structured or flexible) based on assumptions about whether the siting of a particular type of radio station has the potential to produce a high or low impact upon a surrounding community. Other developed nations, such as the United Kingdom, have used similar policy distinctions.
(i) Consultations for Type 1 radio stations
As a starting point, all applicants for broadcasting certificates related to antenna systems are required to consult with the relevant land-use authority as a precondition to the issuance of a certificate by Industry Canada. The land-use authority must be given notice of the intention to install new or modify existing antenna installations and the notice must contain the basic detail of the proposed system or change. The notice is to be served on the land-use authority prior to or at the same time that the application for a certificate is forwarded to Industry Canada.Footnote 24 Also, all applicants for broadcasting certificates must complete and submit to Industry Canada the environmental review and land-use attestation form that is attached to the document, Broadcasting Procedures Rules, Part 1.Footnote 25 As will be discussed within the next subsection of this report, with some procedural modifications, land-use consultations for the antenna installations of broadcasters tend to follow the requirements and steps set out within CPC-2-0-03-2-0-03 for Type 1 radio stations.
When the antennas and supporting structures of Type 1 radio stations other than broadcasting are to be established or modified, a land-use consultation may not be required under the terms of the CPC-2-0-03. It is for the antenna proponent to determine whether the structure or modification will be "significant" in nature.
If the proponent determines that the antenna structure, when constructed or modified, will be insignificant in nature, the proponent may check off this particular option on Part C of the "Preliminary Environmental Information and Municipal/Land-Use Consultation Attestation" formFootnote 26 and submit it to Industry Canada. The CPC-2-0-03 warns that an antenna proponent makes this election "with the acceptance of any consequences of this decision."Footnote 27 The proponent may then proceed to the construction stage and the department will continue to process the application.
Should the proponent of a Type 1 - non-broadcasting radio station determine that the structure or modification is "significant" in nature, land-use consultation is, according to the CPC-2-0-03, required. Such applicants must now disclose their plans to land-use authorities in a timely manner because "early contact ensures an opportunity for full consultation." It is the responsibility of the proponent and the land-use authority to work out a "mutually acceptable agreement" and to "consider each other's requirements and work towards solutions that minimize the impact on the surroundings, including considering existing sites, while not unduly prohibiting the development of the radio facility."Footnote 28
For Type 1 consultations, CPC-2-0-03-2-0-03 states that: "Industry Canada does not play a direct role in the consultation." Rather, the department will ensure that proponents disclose their plans to land-use authorities, ensure that the consultation process occurs in a "timely fashion," provide information to proponents and to land-use authorities, and possibly provide "observations on the validity of land-use by-laws as they relate to radio installations." Industry Canada also will delay the issuance of antenna authorization if it becomes aware that a land-use authority has raised an objection to a proposed antenna or modification. Departmental staff will then ensure that the proponent and the land-use authority have a sufficient opportunity to negotiate a satisfactory resolution. Industry Canada will entertain a petition by the proponent to issue the antenna authorization if the parties have failed to reach a satisfactory resolution.
For Type 1 radio stations, Industry Canada considers that the land-use authority should make its view known to the proponent within 60 days of first contact, accepting that "individual circumstances will vary." There are three possible response scenarios: (i) concurrence, (ii) no response and (iii) non-concurrence. If there is concurrence, Industry Canada will continue to process the application. If no response is given, departmental staff may extend the time for consultations. If there is non-concurrence, Industry Canada may extend the time for consultation activities up to 120 days. In a situation of non-concurrence, it is the responsibility of the applicant to submit a written document to Industry Canada "detailing all actions taken to address the concerns of the land-use authority." The proponent should submit, as a minimum "a chronological summary of all events (letters, meetings, consultations, etc.); the requirement for the establishment of the specific site in question; reasons for the proposed location; and a review of alternative locations considered and reasons for their rejection, including costs and technical analysis."Footnote 29 This analysis may include "pattern coverage maps, Safety Code 6 analysis, or any other engineering study that may be deemed appropriate."
(ii) Consultations for Type 2 radio stations
For Type 2 radio stations, no prior approval is required from Industry Canada before the establishment or modification of the antenna systems is undertaken and there are no attestation forms to submit to the department. CPC-2-0-03-2-0-03 puts the onus on the antenna proponent/owner to consider the reaction that may be anticipated from the community before erecting or altering the antenna system. Consultation with the land-use authority is required if it is "felt that community concerns could be raised..." about the proposal. Should the proponent determine that the antenna installation or modification "is insignificant" the proponent may proceed with the proposal but it must be "with the acceptance of any consequences of this decision."Footnote 30 As discussed below, Industry Canada may review the appropriateness of Type 2 antenna installations or modifications after they are completed.
Should consultations be initiated by the (Type 2) antenna proponent, it is for the proponent and the land-use authority to determine the nature of the consultations conducted, the extent of accommodations offered in response to potential or actual community concerns, and the sufficiency and duration of the consultations. CPC-2-0-03-2-0-03 states that there is "no specific procedure for this consultation." While the policy circular offers little procedural guidance, Industry Canada has set out its expectations of Type 2 station proponents and land-use authorities. The CPC-2-0-03 provides that "Where required, it is expected that the parties will propose and examine alternatives and in so doing, will give consideration to each other's needs."Footnote 31 In addition, the CPC-2-0-03 stipulates that: "Industry Canada expects Type 2 radio station owners to address the concerns of the community in a responsible manner, and to consider seriously all requests put forward by the land-use authority."
Since the owners/proponents of Type 2 radio stations do not require prior authorization from Industry Canada for the installation or modification of their antenna systems, there is nothing to stop proponents from proceeding with their respective antenna installation or alteration at any time. As a compliance mechanism, Industry Canada has reserved the right to review Type 2 antenna structures after their establishment and if the department believes that a particular installation "is not appropriate within its surroundings, it may request submissions explaining why the structure should not be altered or removed." The Minister of Industry has the legislative authority under the Radiocommunication Act to order that an antenna installation be altered or dismantled.
(iii) Consultations for Cellular/PCS service providers
On April 1, 2004 the analogue cellular licences from the 1980s and the PCS (digital cellular) licences from the 1990s were converted into the same type of Spectrum Licence that was awarded to the successful bidders in the PCS spectrum auctions held in 2001.Footnote 32 The result of this regulatory action by Industry Canada is that all forms of cellular operator in Canada now hold a 'Cellular/PCS Spectrum Licence.'
According to the conditions of licence that were affixed to this new category of radio authorization the licensees must engage in "meaningful consultation" with "all local municipalities or land-use authorities" regarding the installation of each radio station "with the aim of developing consensus solutions." Should consultations with the relevant municipal or land-use authority reach an impasse, the conditions of licence provide:
Thus, while these radio stations would be regarded as Type 2 stations under the terms of CPC-2-0-03-2-0-03, these licensing conditions have created a new land-use consultation model to which the CPC-2-0-03 appears to have no application. The requirement to consult for every radio station appears to apply to the installation of the antenna structures and not to subsequent modifications.
(iv) Consultations for Broadcasting Undertakings
Broadcasters must submit an application to Industry Canada for a broadcasting certificate and an application to the Canadian Radio-television and Telecommunications Commission (CRTC) for a broadcasting licence. The technical issues of the certificate (antenna frequency, power, location, height etc.) must be approved by Industry Canada before a broadcasting licence will be considered.Footnote 33 There is no mandatory obligation to consult with the public, however, some broadcasters do consult the public in the area where the transmitters will be located. Industry Canada generally does not become involved in land-use consultations unless the parties reach an impasse.
According to the consultation requirements contained within CPC-2-0-03-2-0-03, land-use consultation is mandatory for Type 1- Broadcasting undertakings. Antenna proponents must "disclose their plans to land-use authorities," complete and submit a Municipal/Land Use Consultation Attestation form with their application to Industry Canada, and consult "regarding the location" of all proposed antenna towers.
Consultation obligations for different types of undertakings are contained within Canadian Broadcasting Procedures Rules (BPRs). Local municipalities must be notified of applications for a new AM/FM/TV broadcast undertaking or changes to existing undertakings "to provide the municipality authority with an opportunity to consider the implication of the proposed antenna and structure site."Footnote 34 The notice shall include a sketch of the building, antenna(s) and tower(s), and be detailed enough to give a visual representation of the total structure. Notice must be filed with enough time for the municipal authority to consider the impact of the proposal. The municipal authority and the applicant are to resolve any problems. "Failing this, the Department will consider all factors pertaining to the application, as well as the municipal comments, and render a final decision." BPR-III s. C-5.5.2. provides for notification of and consultation with municipal land use authorities regarding proposed FM stations.Footnote 35 The consultation procedures are also the same for low power FM stationsFootnote 36 and very low power FM stations in small remote communities.Footnote 37 BPR-IV s. C-5.5.2 stipulates the notification and consultation procedures for TV broadcasting stations. They are virtually identical to that of AM stations.Footnote 38 The procedures for low power TV,Footnote 39 low power TV stations in small remote communitiesFootnote 40 and MDS-TVFootnote 41 are virtually the same as that of FM stations.
For the antennas and supporting structures of cable TV operators, BP 23 s. 6.11Footnote 42 requires that the applicants for the appropriate broadcasting certificate provide the local municipality, or other affected authority, with early notice that an antenna structure is planned for that area. The notice must describe the location and physical characteristics of the proposed structure and associated buildings. The notice must also indicate whether the tower or supporting structure will be equipped with high intensity strobe lights.
It is a significant policy feature of Industry Canada's broadcasting rules that broadcasters are expected to comply with any municipal by-laws that may require accommodations for the siting, painting or screening of antennas or antenna structures."Footnote 43 Municipal restrictions are acceptable to Industry Canada as long as the cost involved is reasonable and the restrictions do not impair the operating capacity of the antenna.
Marking and Lighting of Towers for Aeronautical Purposes
Under the authority of the federal Aeronautics Act and the Canadian Aviation Regulations (CARs) it is the responsibility of the Minister of Transport to assess buildings and structures to determine if they constitute a hazard to air navigation. As a consequence of such an assessment, the Minister may require marking or lighting, or both, of the building or structure in accordance with published standards. Currently, the principal standard is designated as Standard 621.19 - Obstruction Markings and Lighting. Simply stated, the purpose of this standard is to ensure that, in all cases and for 24 hours a day, an obstruction to air navigation remains visible to air traffic at a range sufficient to permit a pilot to take appropriate evasive action. The current visibility requirement is that the obstruction be visible at a distance sufficient for a pilot to see and avoid the obstruction by not less than 300 metres vertically within a horizontal radius of 600 metres from the obstruction.
According to Standard 621.19 the principal means of achieving this basic visibility requirement is through the lighting and/or painting of the obstruction, and decisions about each, or both, must consider the characteristics of the obstruction and all of the surrounding circumstances at its actual or proposed location.Footnote 44 Lights, or beacons, are characterized under the standard by colour (red and/or white), intensity (low, medium and high), signal type (flashing or steady burning), flash rate (from 20 to 60 flashes per minute (fpm)) and sequence of flash (to achieve the visibility necessary for the particular structure). The number and placement (top, mid and lower sections of the structure) of beacons must be determined for each obstruction. For those lights required to produce a beam of light, the width of the beam and the vertical aim of the beam (to shine it toward anticipated air traffic) are described within the standard.
Standard 621.19 lists painting specifications by the intensity and hue of the two colours, (aviation) orange and white, and by the pattern of the application of those colours (in alternating bands of colour or in a checkerboard pattern). When painted, antenna towers are coated in alternating bands of orange and white.
The federal Department of Transport operates six Regional Offices and those seeking to have a potential obstruction processed must fill out and submit an "Aeronautical Obstruction Clearance Form." This form requires basic information about the structure including its height, dimensions, type of structure, and location by longitude and latitude.
At one time, Industry Canada would not issue most types of antenna authorization until the airspace safety branch of the Department of Transport had 'cleared' the proposed the structure. Today, the issuance of radio authorizations is no longer conditional upon prior air navigation clearance. Instead, the onus is placed upon individual antenna proponents to determine and comply with all Department of Transport aeronautical obstruction requirements. The one exception to this rule is for those seeking broadcasting certificates. These proposals must be pre-approved by Transport Canada prior to technical evaluation by Industry Canada.Footnote 45
Comparative Regulatory Material: Antenna Siting in Australia, New Zealand, The United Kingdom and The United States Of America.
[please refer to Appendix F].