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


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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