FCC BDC engineer?

Brandon Martin lists.nanog at monmotha.net
Wed Jul 6 02:49:18 UTC 2022

On 7/5/22 18:27, Glenn Kelley wrote:
> I fully expect this to come down to someone needing to be an "engineer."

The term "Professional Engineer" is a protected term in all 50 US states 
to my knowledge.  It requires the qualifications and licensure you'd 
expect with the typical path being ABET engineering curriculum, passing 
the FE, interning for some number of years, attribution of character 
from some existing PEs, then passing the PE exam and receiving the 
state-adorned license.

The use of the term "engineer" is much more vauge and generally 
unprotected in the USA.  Lots of people have job titles with the word in 
it that wouldn't even fall under typical professional engineering 
guidelines in the most aggressive interpretation.  However, the PE board 
in some states can be pretty aggressive about the whole "practicing 
professional engineering without the proper license", and part of the 
guidelines they use to make that determination is if you use the term 
"engineer" to describe yourself.

The feds have quality steered clear of the whole PE thing in codes/laws 
since it's essentially entirely state-run.  The use of the term here 
might be an oversight that should be corrected as it doesn't seem that 
they intended to require a state-licensed "Professional Engineer", at 
least if the person doing the approval of the report is an agent of the 
company submitting it, nor did they define the term as such.

A lot of "engineering" happens under the so-called "industrial 
exemption" where things are going to cross state lines and therefore 
aren't under the purview of the state licensing board, but 
infrastructure-based/wireline comm systems would likely not fall under 
that, so it comes down to if your state defines the operation of such 
systems (not necessarily the physical design and emplacement of them) as 
an engineering activity.

Note that I am not a PE, though I have passed the FE.  This shouldn't be 
construed as legal advice much less advice to your specific situation.

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