FCC BDC engineer?

Tue Jul 5 21:16:20 UTC 2022

On Tue, Jul 5, 2022 at 11:52 AM Bryan Fields <Bryan at bryanfields.net> wrote:

> On 7/5/22 1:58 PM, Andrew Latham wrote:
> > I read https://docs.fcc.gov/public/attachments/DA-22-543A1.pdf and a PE
> is
> > not required.
>
> I'd agree.
>
> 47 CFR § 1.7004(d)
> "All providers also shall submit a certification of the accuracy of its
> submissions by a qualified engineer. The engineering certification shall
> state
> that the certified professional engineer or corporate engineering officer
> is
> employed by the provider and has direct knowledge of, or responsibility
> for,
> the generation of the provider's Digital Opportunity Data Collection
> filing."

> Note the lack of capitalization of "qualified engineer".  This means it is
> not
> defined in that part, and leaves it open to interpretation.
>

One could even meet the requirement by focusing on the second clause:

"The engineering certification shall state
that the certified professional engineer *or corporate engineering officer*
is
employed by the provider and has direct knowledge of, or responsibility for,
the generation of the provider's Digital Opportunity Data Collection
filing."
(emphasis mine)

So, if you appoint a Corporate Engineering Officer that is employed by the
provider and has responsibility for the generation of the DODC filing,
you've met the requirements without a need for a certified professional
engineer.

Matt
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