Tower 39 was the first built after the gap between Pett Level and St. Leonard's, and was mentioned in the 1863 Coast Guard inspection. In February 1864, the Prince of Wales visited and inspected the Tower, which was later described in 1873 as being in a critical position. Its seaward side subsequently collapsed in a storm in March 1876, which also undermined part of the Coast Guards' boathouse. The tower was finished off by Royal Engineers' explosives. It stood near the site of the demolished swimming baths at West Marina.
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| Tower 38 | Tower 40 |