FCC BDC engineer?

Glenn Kelley glenn at connectivity.engineer
Tue Jul 5 22:27:55 UTC 2022


I fully expect this to come down to someone needing to be an "engineer."

I went through some hell using the name Connectivity Engineer in Virginia.
So much so that I tend not to take jobs there if I can help it.

Other states - not a problem.

I have a ton of certifications with the name engineer in them one way or
another - but sadly to some in government this means something different
than what you might expect.

Time will tell


*Glenn S. Kelley, *Connectivity.Engineer
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On Tue, Jul 5, 2022 at 5:16 PM Matthew Petach <mpetach at netflight.com> wrote:

>
>
> 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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