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 Text and Voice Direct: 740-206-9624 IMPORTANT: The contents of this email and any attachments are confidential. They are intended for the named recipient(s) only. If you have received this email by mistake, please notify Glenn Kelley, the sender, immediately and do not disclose the contents to anyone or make copies thereof. On Tue, Jul 5, 2022 at 5:16 PM Matthew Petach <mpetach@netflight.com> wrote:
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 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