1. To achieve effective and efficient lighting while preserving the safety, security, and well-being of County residents and visitors.
2. To protect and enhance the lawful nighttime use and enjoyment of all property through the protection of and access to the dark night skies and to encourage the conservation of energy and other resources.
3. To specify and encourage lighting practices and systems that will minimize the adverse man-made light pollution effects of sky-glow, glare, and light trespass.
4. To ensure that all signs installed in the County are compatible with the County’s largely rural character, are in compliance with the Comprehensive Plan, and ensure that no sign shall be brighter than is necessary for clear and adequate visibility.
   

1. Conformance with Applicable Codes. All outdoor electric illuminating devices shall be installed in conformance with all provisions of these Zoning Regulations, Cochise County Subdivision Regulations, and any applicable building codes where any provision of any of the Arizona Revised Statutes, any Federal Law, or any related Cochise County regulation conflicts with the requirements of this Article, the most restrictive shall govern.
2. Approved Material and Methods of Installation. The provisions of this Article are not intended to prevent the use of any material or method of installation not specifically proscribed by this Article, provided any such alternate has been approved. The County Zoning Inspector may approve any such alternate provided the proposed design, material, or method:
   1. Provides approximate equivalence to those specific requirements of this Article, or
   2. It is otherwise satisfactory and complies with the intent of this Article.
3. Applicability.
   1. New Uses, Buildings, and Additions or Modifications. The requirements of this Article shall apply to all new uses and to additions to existing land uses, developments, buildings, or structures.
      1. If a major addition occurs on a property with a non-residential use, the entire property shall comply with the requirements of this Article. For purposes of this section, major additions are changes of 50 percent or more in terms of additional dwelling units, gross floor area, or seating capacity that have occurred either as single or with cumulative additions or modifications which have occurred since March 3, 1982, the effective date of this provision.
      2. Minor additions (defined as additions or modifications less than 50 percent of existing uses) on a property with a non-residential use shall require the submission of a complete inventory and site plan detailing all existing and any proposed new outdoor lighting. Any new lighting on the site shall meet the requirements of this Article with regard to shielding and lamp type; the total amount of lumens after the modifications are complete shall not exceed that on the site before the modification or that permitted by this Article, whichever is larger.
   2. Change of Use. Whenever the use of any existing building, structure, or premises is changed to new use, all outdoor lighting shall be reviewed and brought into compliance with all provisions of this Article before the new use commences.
   3. Resumption of Use after Abandonment. If a property or use with non-conforming lighting is abandoned as defined in Section 2.57.03, then all outdoor lighting shall be reviewed and brought into compliance with all provisions of this Article before the use is resumed.
4. Special Use Authorization Requirements. Any application or lighting installation not meeting all requirements of this Article, including but not limited to height, shielding, curfew, or lumen caps, shall require a Special Use Authorization pursuant to Article 2.48. At the time of Special Use Authorization submittal, the proposed lighting system design shall be certified by a knowledgeable Arizona Registered professional or other certified lighting specialists as achieving the minimum illuminance level for the specific activity as recommended by the Illuminating Engineering Society of North America (IESNA) and that the design shall conform to all other applicable provisions of this Article and with aiming angles that permit no greater than five percent of the light emitted by each fixture to project above the horizontal. The submittal must contain complete specifications, including total lumen/ nit count, to meet the requirements of off-site glare and light trespass, as specified in this Article, and Arizona Registered professional or other certified lighting specialists shall provide verification that the correct equipment shall be installed and functioning after installation.
   

Abandonment: The discontinuation of use for a period of three years or more.

Class 1 Lighting: All outdoor lighting used for, but not limited to, outdoor sales or eating areas, assembly or repair areas, recreational facilities, and other similar activities where COLOR RENDITION is important. Class 1 lighting includes metal halide, liquid crystal display (LCD), light emitting diode (LED), plasma, quartz halogen, and similar light sources and technologies.

Class 2 Lighting: All outdoor lighting used for, but not limited to, illumination for walkways, roadways, equipment yards, parking lots, and outdoor security where GENERAL ILLUMINATION for safety or security is the primary concern.

Class 3 Lighting: All outdoor lighting used for DECORATIVE effects, including but not limited to architectural illumination, flag and monument lighting, and the illumination of vegetation.

Color Rendition: The ability of a light source to faithfully reproduce the colors seen in an object.

Correlated Color Temperature (CCT): This temperature best indicates the colors of light shining from a bulb or lamp. CCT is listed with all new lighting sources (lamps and bulbs), and by standard, the temperature is given in degrees Kelvin. Low Kelvin numbers represent “warm light, and higher numbers represent “cool light.”

Decorative: Class 3 lighting, which is used for non-utilitarian purposes such as lighting building exteriors, fountains, flags, landscaping, and holiday and seasonal decorations.

Developed Site: Acreage refers to the developed area of the site, including, but not limited to the area used for buildings, structures, storage and service areas, parking, loading, driveway areas, required setback areas, and required landscaping related to the use, but not areas that are only cleared.

Foot-candle, average: A unit of illumination produced on a surface, measured by a light meter at an average point of illumination between the brightest and darkest areas. The measurement can be made at the ground surface or at four to five feet above the ground. For the purpose of this Article, one foot-candle is equivalent to one lumen per square foot.

General Illumination: Outdoor lighting used for, but not limited to, illumination for walkways, roadways, equipment yards, parking lots, and outdoor security where safety or security of the grounds is the primary concern.

IESNA: Illuminating Engineering Society of North America.

Illuminance: The amount of light striking a surface area, measured in footcandles or lux. For conversion purposes, 1 footcandle (fc) is equal to 10.76 lux (lx).

Installed: The attaching or assembling in place of any outdoor light fixture.

Lamp: A generic term for a source of “light” often called a “bulb,” “tube,” “diode,” “module,” “display,” or an “array.”

LED (Light Emitting Diode): A semiconductor diode or bulb that emits light when voltage is applied to it and is used in electronic devices.

Light Fixture, Fully Shielded: A light fixture constructed, installed, and maintained in such a manner that all light emitted by the fixture, either directly from the lamp or indirectly by reflection or refraction from any part of the fixture, is projected below a horizontal plane running through the lowest part of the fixture.

A practical way to determine if a fixture or tube is fully shielded: if the lamp or tube, any reflective surface, or lens cover (clear or prismatic) is visible when viewed from above or directly from the side, from any angle around the fixture or tube, the fixture or tube is not fully shielded.

Light Fixture, Outdoor: A complete lighting assembly (including the lamp, housing, reflectors, lenses, and shields), less the support assembly (pole or mounting bracket). Includes luminous tubes, lamps, or similar devices, permanently installed or portable, used for illumination, decoration, or advertisement.

Light Meter: A device used to measure the amount of light on a surface.

Light Trespass: Stray electric light in excess of the levels specified in Section 2.45.050(1) falling where it is not wanted or needed. Direct or reflected light that has its source on one side and illuminates areas beyond the property boundaries. Light trespass is typically produced by stray light from unshielded or misdirected outdoor lighting and includes glare from direct viewing.

Lumen: A unit used to measure the total amount of light that is produced by a lamp. For the purpose of this code, one lumen is equivalent to a one-foot candle.

Luminaire: A light fixture, including the complete lighting assembly (including lamps, housings, reflectors, lenses, and shields), but excluding the support assembly.

Nit: A unit of luminance measured as one candela per meter-squared.

Opaque: Opaque means a material that does not transmit light from an internal illumination source.

Outdoor Light Fixtures: Outdoor electric illuminating devices, outdoor fixtures, lamps, and other devices; searchlights, spotlights, flood lights, permanently installed or portable, used for illumination, emergency, security, or commercial purposes. Such devices shall include but are not limited to lights for:

1. Parking lots
2. Roadways
3. Buildings and structures
4. Recreational areas and facilities
5. Landscaping decorative effects
6. Billboards and signs (advertising and other)
7. Product display areas
   

Outdoor Recreational Facility: An area designed for active recreation, whether publicly or privately owned, including but not limited to parks, baseball or softball diamonds, soccer and football fields, golf courses, tennis courts, and roping/equestrian arenas.

Person: Shall mean any private individual, tenant, lessee, owner, or any commercial entity, including but not limited to companies, partnerships, joint ventures, or corporations.

Residential Lighting: Residential refers to outdoor lighting for single household dwellings.

Searchlight: A lighting assembly designed to direct the output of a contained lamp in a specific tightly focused direction (a beam) with a reflector located external to the lamp and with a swiveled or gimbaled mount to allow the assembly to be easily redirected. Such lights are commonly used to sweep the sky for advertisement purposes.

Shield: A device that is attached to or inserted into a luminaire to alter the direction of light being emitted. A luminaire that has a shield attached or inserted is considered to be “shielded.”

Sign, Digital: A type of unshielded electronic display that can show programming, menus, information, advertising, and other messages. Digital signs are lighted and utilize technologies such as Liquid Crystal Display (LCD), (Light Emitting Diodes) LED, plasma displays or projected images to display content.

Sign Illuminated: For the purposes of this Article, a sign lighted by or exposed to artificial lighting either by lights within the sign or directed toward the sign.

Sky-Glow: The undesirable and unnecessary emission of light rays, directly or indirectly, into the night sky.

Uplighting: A lamp or light designed or positioned to cast its light upwards.

Use, Non-Residential: The use of land for a purpose other than single-household dwelling units.

Watt: The unit used to measure the electrical power consumption (not the light output) of a lamp.

1. Applications.
   1. Any individual applying for a building or a use permit under these Zoning Regulations intending to install outdoor light fixtures shall, as a part of said application, submit evidence that the proposed work will comply with this Article.
   2. All other individuals intending to install, replace or improve any outdoor light fixture shall comply with the provisions of this Article, and if a permit is required by these Zoning Regulations or Building Codes, submit an application to the County Zoning Inspector providing evidence that the proposed work will comply with this Article.
2. Contents of Application or Submission. The following plans and descriptions shall be sufficiently complete to enable the County Zoning Inspector to readily determine whether the project will be in compliance with the requirements of this Article. If such plans and descriptions are not sufficient to enable this ready determination by reason of the nature or configuration of the devices, fixtures, or lamps proposed, the applicant shall submit evidence of compliance prepared by a certified illumination engineer. The submission shall contain:
   1. Plans indicating the location on the premises, the type of all illuminating devices, existing and proposed, as well as total lumens or nits emitted.
   2. Description of the existing and proposed illuminating devices, fixtures, lamps, supports, and other devices, and the initial lumen output. This description shall include but is not limited to manufacturers’ catalog cuts, photographs, diagrams, and/or drawings.
3. Issuance of Permits. Upon compliance with these lighting provisions, as well as the other requirements for permit issuance, the County Zoning Inspector shall issue a permit. The appeal procedures of these Zoning Regulations for decisions of the County Zoning Inspector shall apply in the event of any dispute as to the application of this Article.
4. Amendment to Permit. Substitution of outdoor light fixtures or lamps after a permit has been issued requires County Zoning Inspector approval prior to installation. Amendments to permits for the installation of outdoor light fixtures require adequate information to assure compliance with Paragraph 2 of this Article.
5. Accessibility for Inspections. The Applicant will provide a means to safely inspect any digital sign over five-feet tall from the ground.
   

1. Light Trespass and Glare.
   1. All fixtures and lamps shall be located, installed, directed, shielded, and maintained to avoid light trespass and to minimize direct light and/or glare on neighboring properties and roadways. Accent lighting shall be directed onto the building or object and not toward the sky or onto adjacent properties.
   2. The level of light trespass shall not exceed 0.2-foot-candles at the property line of a residential property. For a receiving non-residential property, the level of light trespass shall not exceed 0.5-foot-candles under the same parameters.
2. Height.
   1. Residential Sites. The overall height of lighting fixtures (including the base) shall not exceed 20 feet above ground level, except for residential sites with a minimum parcel size of four-acres or larger, lighting fixtures which are located 50 feet or more from any property line shall not exceed 30-feet in height (including the base) above ground level.
   2. Non-Residential Sites. Except as provided herein for specific uses, the overall height of lighting fixtures (including the base) on all non-residential sites shall not exceed 30 feet above ground level, except in the GB, LI, and HI Zoning Districts, the overall height of lighting fixtures located at least 100-feet from any property line shall not exceed 35-feet in height above ground level (including the base). Digital signs shall meet all requirements per Section 2.54.070(2) of Article 2.54.
3. Lighting Types, Shielding, and Curfew Requirements.
   1. Lighting Types.
      1. All streetlights shall be fully shielded.
      2. Low-Pressure Sodium lamps are the preferred lamp type for minimizing adverse effects on astronomical observations.
   2. General Shielding Requirements.
      1. All light fixtures required to be fully shielded shall be installed and maintained in a fashion that maintains the fully shielded characteristics.
      2. All up lighting is prohibited, except
         1. The lighting of one flagpole. The light shall be focused on the flag and shall not exceed 2,000 lumens. Off-site glare and light trespass shall be eliminated using shielding. Flags that include advertising, business trademarks or symbols, or other forms of commercial communication may not be uplighted at any time.
         2. Low voltage or solar landscape lighting not exceeding 150 lumens per fixture.
   3. Shielding Requirements for Residential Uses.
      1. For residential uses, all permanently used lamp types shall be fully shielded.
      2. Lighting for multiple household dwellings is not considered Residential and must comply with all requirements for non-residential lighting, including but not limited to lumen caps and curfews for decorative lighting
      3. Unshielded lighting for residential uses under roof or porch overhangs shall be considered compliant, provided such lighting meets the light and trespass glare requirements of Paragraph 1.
      4. Seasonal decorations using typical unshielded low-lumen incandescent lamps shall be permitted from Thanksgiving to January 15.
   4. Shielding and Curfew Requirements for Non-Residential Uses.
      1. All non-residential light fixtures except for unshielded signs shall be fully shielded.
      2. Any Class 1 (Color Rendition), Class 2 (General Illumination), or Class 3 (Decorative Illumination) lamp type shall be shielded in accordance with Table 2.45.050.
      3. All Class 1 (Color Rendition) and Class 3 (Decorative Illumination) lighting shall be extinguished between 11 p.m. (or when the business closes, whichever is later) and sunrise, except:
         1. Seasonal decorations using typical unshielded low-lumen incandescent lamps shall be permitted from Thanksgiving to January 15.
         2. Low voltage landscape lights are rated at 150 lumens or less, provided the total unshielded lumens do not exceed 1,000 lumens.
         3. Self-contained solar lights rated at 10 watts or less.
      4. All light fixtures located within 25 feet of the property line adjacent to residential use shall use fully shielded luminaires.
4. Total Outdoor Light Output.
   1. Total outdoor light output, including that for all signs, shielded or unshielded, shall not exceed the limits in Table 2.45.050. The values in this table are upper limits and not design goals; design goals should be the lowest levels that meet the requirements of the task to reduce glare and reduce energy costs.
   2. Shielded flood lights, properly aimed down, at no more than 45 degrees, not to exceed 2,000 lumens per bulb, and controlled by a motion sensor device shall be exempt from lumen caps, provided fixtures remain on for short periods only and not to remain on over 10 minutes after the area has been vacated.
   3. Low voltage seasonal decorations, permitted between Thanksgiving and January 15, are not counted toward these limits.
   4. Total outdoor light output for various Zoning Districts is specified in Table 2.45.050. These maximums are referred to as lumen caps.
      
      TABLE 2.45.050 Maximum Outdoor Light Output
      
      

      All Uses in Commercial and Industrial Zoning Districts (NB, GB, LI, HI) 5
      Total shielded	150,000 lumens per acre of developed site 1 4 5
      Total Unshielded	3,000 lumens per acre of developed site 2 3 5
      Non-Residential Uses in Residential and Rural Zoning Districts 6
      Total shielded	75,000 lumens per acre of developed site 1 4 5
      Unshielded	3,000 lumens per acre of developed site 2 3 5
      Residential Uses in Residential and Rural Zoning Districts - Lots one acre or larger
      Shielded	20,000 lumens per acre of developed site 5
      Residential Uses in Residential and Rural Zoning Districts - Lots less than one acre
      Shielded	10,000 lumens per acre of developed site 5
      Digital Signs
      Limited to one sign per developed site with a maximum of 200 nits per site
      Correlated Color Temperature (CCT)
      Maximum CCT of 3,000K permitted for non-residential lamps

      ¹ Lumens for all signs are to be included in these caps except as provided in Section 2.45.070(2). ² Any lamp with an output of 1,000 lumens or more shall be fully shielded. ³ Does not include the 2,000-lumen lighting exception for flagpoles (Paragraph 3) and floodlights on a motion sensor (Paragraph 4). ⁴ All lighting except for safety lighting (Class 2) shall be extinguished between 11 p.m. (or close of business, whichever is later) and sunrise. ⁵ Acreage refers to the developed area of the site, including, but not limited to, an area used for buildings, structures, storage and service areas, parking, loading, driveway areas, required setback areas, and required landscaping related to the use, but not areas that are only cleared.
      

1. Searchlights, Laser Lights. The operation of searchlights, laser lights, or any similar high-intensity light for outdoor advertising or commercial purposes is prohibited.
2. Recreational Facilities. No outdoor recreational facility, public or private, including those with non-conforming lighting, shall be illuminated after 11 p.m. except to conclude a specific scheduled event that was unable to conclude before the curfew due to unusual circumstances.
3. Mercury Vapor. The installation of new mercury vapor outdoor light fixtures is prohibited. The use of legal, non-conforming (installed prior to March 3, 1982) mercury vapor light fixtures is prohibited after January 1, 2011.
   

1. External Illumination. External illumination for signs shall conform to the shielding restrictions and lumen caps of Table 2.45.050. All upward-directed sign lighting is prohibited.
2. Internal Illumination.
   1. Outdoor internally illuminated signs are considered unshielded and shall be adequately sealed and maintained to prevent light leakage.
   2. Neon signs shall be treated as internally illuminated signs for the purpose of this Article. Neon lighting extending beyond the sign area shall be considered Class 3 decorative lighting and shall be subject to the standards applicable for such lighting, including, but not limited to, the shielding standards and lumen caps of Table 2.45.050.
   3. Digital signs that meet the standards as listed in Article 2.54 are permitted. Digital signs shall be considered unshielded and restricted to the total lumen cap per Table 2.45.050. Applicant must supply documentation indicating maximum nit capability for each segment of a digital sign and demonstrate the ability to meet the total nit cap per Table 2.45.050.
3. Other Illuminated Panels. Other internally illuminated panels or decorations not considered to be signage according to this Article, such as illuminated canopy margins or building faces, shall be considered Class 3 Lighting and shall be subject to the standards applicable for such lighting, including, but not limited to, the shielding standards and lumen caps of Table 2.45.050.
4. Curfew.
   1. Illumination for advertising signs, both externally and internally illuminated, shall be turned off at 11 p.m. or when the business closes, whichever is later. Signs subject to curfews are encouraged to have automatic shut-off timers.
   2. Digital signs shall be permitted from sunrise to sunset, except as permitted in Article 2.54.
      

1. Nonconforming Fixtures. Except as provided in Section 2.45.020(3), all outdoor light fixtures existing and legally installed after March 3, 1982, and prior to December 1, 2005, with the exceptions found in Section 2.45.060(2) (curfew for outdoor recreation facilities) and 2.45.060(3) (mercury vapor), may remain “non-conforming” indefinitely; provided, however, that no change in use, fixture replacement, structural alteration, or restoration after the abandonment of outdoor light fixtures shall be made unless it thereafter conforms to the provisions of this Article.
2. Fossil Fuel Fixtures. The light produced by the combustion of natural gas or other utility-type fossil fuels is exempt from the lumen cap and shielding requirements of this Article.
3. Equipment and Signal Lights. Equipment and signal lights necessary for agricultural equipment or required by State or Federal regulations shall be by the least obtrusive means that meets the applicable operating or regulatory requirements.
4. Federal and State Facilities. Those facilities and lands owned, operated, or protected by the U.S. Federal Government or the State of Arizona are exempt by law from all requirements of these provisions. Voluntary compliance with the intent of this Article at those facilities is encouraged.
5. Emergency Lighting. Temporary lighting to facilitate immediately necessary repairs or similar emergencies, such as actions of a public or private utility company necessary to continue or resume service, shall be allowed. Lights shall be arranged to reflect light away from and prevent glare to adjoining residential properties and public rights of way to the extent feasible.
6. Agricultural Operations. Those agricultural operations that meet the minimum requirements for zoning exemption are also exempt from this article.
7. Special Exemption. The zoning inspector may grant a special exemption to the requirements of this article only upon a written finding that there are extreme geographic or geometric conditions warranting the exemption and that there are no conforming fixtures that would suffice.
   

1. Requests for Temporary Exemptions. Any individual as defined herein may submit a written request to the county zoning inspector for a “temporary exemption” to the requirements of this article. Such exemption will be valid for 30-calendar days, renewable at the discretion of the county zoning inspector. The request for temporary exemption shall contain at least the following:
   1. Specific exemptions are requested.
   2. Specific reasons why the requirements listed in this article cannot be met.
   3. Type and use of exterior light involved.
   4. Duration of time for requested exemption.
   5. Type and number of lamps and calculated lumens.
   6. Total lumens of lamp or lamps.
   7. Proposed location and height of exterior lights.
   8. Previous temporary exemptions, if any.
   9. The physical size of exterior light and type of shielding provided.
   In addition to the data above, the county zoning inspector may request any additional information to allow a reasonable evaluation of the request for temporary exemption.
2. Appeals for Temporary Exemptions. The county zoning inspector, within 15-calendar days from the date of the properly completed request for temporary exemption, shall approve or reject the request in writing. If rejected, the individual making the request shall have the right of appeal to the appropriate board of adjustment as any other appeal of the county zoning inspector’s determinations.
3. Private Security Lighting/Lighting Installed by an Electric Utility. Non-compliant lighting that was installed in good faith by an electric utility shall be brought into conformance with this article within five years of adoption; however, individual light fixtures which are the subject of a citizen complaint or county enforcement action shall be brought into conformance within 30-calendar days of notification of the property owner.
   

1. Outdoor Recreational Facilities.
   1. Shielding: all outdoor recreational facilities shall utilize fully shielded luminaires that are installed in a fashion that maintains the fully shielded characteristics.
   2. Height: the maximum height for pole-mounted luminaires for outdoor recreational facilities is 40-feet.
   3. Lighting for public and private outdoor athletic fields, courts, tracks, or arenas, shall be considered class 1 (color rendition).
   4. Facility lighting shall meet shielding, lumen caps, height limits, and all other restrictions of this article.
      
      If meeting all requirements is infeasible, pursuant to Section 2.45.020(4), a special use authorization is required.
   5. Off-site trespass: the facility shall limit off-site trespass to the maximum extent possible and shall not cause light trespass onto residentially zoned or developed properties.
   6. Curfew: all events shall be scheduled to complete the activity before 11 p.m. Illumination of the playing field, court, or track shall be permitted after the curfew only to conclude a scheduled event that was unable to conclude before the curfew due to unusual circumstances.
   7. All lighting not directly associated with the playing field (e.g., Parking lot lighting, concession stand lighting, etc.) Shall use class 2 lighting and shall conform to all requirements of Section 2.45.050 of this article.
2. Outdoor Display Lots. Lighting for display lots shall be considered class 1 (color rendition) and shall be in compliance with the following standards:
   1. Shielding: all display lot lighting shall utilize fully shielded luminaires that are installed in a fashion that maintains the fully shielded characteristics.
   2. Height: the maximum height for pole-mounted luminaires for outdoor display lots is 40 feet.
   3. Display lot lighting shall meet shielding, lumen caps, height limits, and all other restrictions of this article.
      If meeting all requirements is infeasible, pursuant to Section 2.45.020(4), a special use authorization is required.
   4. Curfew: display lot lighting shall be turned off between 11 p.m. And sunrise or within 30 minutes after the closing of the business, whichever is later. Lighting in the display lot after this time shall be considered class 2 lighting and shall conform to all restrictions of this article, including the lumen caps in Table 2.45.050.
   5. Off-site trespass: the facility shall limit off-site trespass to the maximum extent possible and shall not cause light trespass onto residentially zoned or developed properties.
3. Service Station Under Canopy Lighting. Lighting for service station canopies shall be considered class 1 lighting (color rendition) and shall be subject to the curfew requirements in Section 2.45.050(3) of this article.
   1. Shielding: all luminaires are to be flush with or recessed into the lower surface of service station canopies and shall be fully shielded and utilize flat lenses.
   2. Total under-canopy output: the total light output used for illuminating service station canopies is defined as the sum of all under-canopy initial bare lamp outputs in lumens and shall not exceed 40 lumens per square foot of canopy. Twenty-five percent of the lumens from fully shielded outdoor lighting fixtures installed under canopies shall be counted toward the lumen caps in table 16.1.
   3. Illuminated canopy margins shall be considered class 3 (decorative) lighting.
4. Wireless Communications Towers. If tower lighting is required, it shall be the least obtrusive that meets FAA requirements.