On Tue, Jul 5, 2022 at 11:52 AM Bryan Fields <br...@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 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