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