Concerning Avian Death due to Collision with Communications Tower the main question seems to be where are these dead birds? As an (still) active tower climbing technician I have never seen masses of dead birds at any of the thousands of towers sites I?ve visited during my career. I may have seen ten dead birds during my entire thirty-five year career but no more and never more than one at a time. I once had a discussion with a broadcast engineer who wanted to create some tower climber safety rule for a large client of his. When I pointed out to him that his rule didn't address any real problem and that no one had ever been hurt during the activity he was describing his reply was, "just because no one has been hurt doesn?t mean we shouldn?t make a rule". Is this what FCC NRPM WT Docket No. 03-187 is attempting to do? There is no proof however there ?might? be a problem so we need to create new rules to cover the eventuality regardless of the cost? It would seem the proper thing to do would be to base rule making on documented factual data not on a special interest group?s agenda. I have seen only a small bit of well documented data concerning bird deaths around towers and that bit of data was created around a tower site I?ve visited many times during the last 20 years, WSMV-TV in Nashville Tennessee. This study was conducted from 1960 (three years after the 1368 foot tall tower was constructed) until 1997. The data collected in Nashville was gathered primarily by the efforts of three dedicated female volunteers with the complete cooperation of the tower?s owners. Their data indicated over 11,000 birds killed in 1960 yet that number had fallen steadily to 606 by 1980. This data is available on the internet at http://towerkill.com/statereports/TNR/TNdata1a.html a web site that is issuing the alarming cry that birds are dying all over the US from collisions with communications towers. However this particular study provides virtually the only verifiable information that the authors of the site can provide. It is possible to search by state for similar data on the http://towerkill.com web site. Doing so produces no data in all but a hand full of localities and those studies can?t begin to compare to the WSMV study. Clearly, if the US Fish and Wildlife Service see Avian mortality due to collision with communications towers as a significant problem they should commission a true study of the problem using unbiased observers. Personally, I have seen no large numbers of dead birds around or in the vicinity of tower sites at any time during my thirty-five years of tower work but I?d be more than happy to report any findings I might have in the future to a bona fide organization investigating the issue. It might be concluded that as a professional tower technician I might keep such information to myself if I had noticed but I can assure you that I would be joining those who clamber for rule changes if I had ever seen large numbers of dead birds at or around communications tower sites. My deceased mother was a long time president of her local Ornithological society and quite active as a Tennessee Ornithological Society member. A love of birds lies deep within me. A week ago I was privileged to see a Hawk take off from an antenna mount at 300 feet above the ground. He hadn?t been aware that I was ascending and I hadn?t been aware he was perched atop the tower. What a beautiful site he was. My wife and I have four bird feeders which we keep stocked with food for any and all hungry birds. Like many in my field I have no desire to see communications towers become death traps for any animal feathered or furry. However I see no problem requiring a fix. John Hettish 615-418-7011 Middle Tennessee Two-way Inc.