nanog mailing list archives
Re: FCC BDC engineer?
From: Matthew Petach <mpetach () netflight com>
Date: Tue, 5 Jul 2022 14:16:20 -0700
On Tue, Jul 5, 2022 at 11:52 AM Bryan Fields <Bryan () 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 PEisnot required.I'd agree. 47 CFR ยง 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
Current thread:
- FCC BDC engineer? KCI Dave Logan via NANOG (Jul 05)
- Re: FCC BDC engineer? Josh Luthman (Jul 05)
- Re: FCC BDC engineer? Tom Mitchell (Jul 05)
- Re: FCC BDC engineer? Brough Turner (Jul 05)
- Re: FCC BDC engineer? Andrew Latham (Jul 05)
- Re: FCC BDC engineer? Jared Mauch (Jul 05)
- Re: FCC BDC engineer? Bryan Fields (Jul 05)
- Re: FCC BDC engineer? Matthew Petach (Jul 05)
- Re: FCC BDC engineer? Glenn Kelley (Jul 05)
- Re: FCC BDC engineer? Brandon Martin (Jul 05)
- Re: FCC BDC engineer? Jay Hennigan (Jul 05)
- Re: FCC BDC engineer? Josh Luthman (Jul 05)
- Re: FCC BDC engineer? Andrew Latham (Jul 05)
- Re: FCC BDC engineer? Josh Luthman (Jul 05)