Re: FCC BDC engineer?

[Jay Hennigan]

On 7/5/22 15:27, Glenn Kelley wrote:

I fully expect this to come down to someone needing to be an "engineer."


From an FCC standpoint, at one time an FCC-issued  operator license was 
required to maintain licensed radio equipment. First Class for radio and 
television broadcasting, Second Class for commercial two-way, marine, 
aircraft, etc. Even radio DJs had to have a license, at least Third 
Class with broadcast endorsement. The Third Class was a fairly easy 
test, more about rules and regulations than the technical stuff.


The title of "Broadcast Engineer" or "Chief Engineer" was common in the 
industry for an FCC-licensed individual in a technical capacity and 
written into the FCC regulations at the time.


They later simplified it to a "General Radiotelephone" which was pretty 
much the same as the Second Class license.


About the same time FCC dropped the requirements requiring licenses for 
personnel working on at least most licensed equipment, leaving it up to 
the station licensee to ensure that they employed competent people and 
that the station complied with the technical requirements.


FCC still issues the licenses but the actual testing is no longer done 
at FCC field offices. Radio and TV stations still call their head 
technical person "Chief Engineer".


I don't know if an FCC-licensed individual would qualify, but there's 
history of FCC recognizing the title of engineer for people that the FCC 
itself vetted.


--
Jay Hennigan - j...@west.net
Network Engineering - CCIE #7880
503 897-8550 - WB6RDV

Re: FCC BDC engineer?

[Brandon Martin]

On 7/5/22 18:27, Glenn Kelley wrote:

I fully expect this to come down to someone needing to be an "engineer."


The term "Professional Engineer" is a protected term in all 50 US states 
to my knowledge.  It requires the qualifications and licensure you'd 
expect with the typical path being ABET engineering curriculum, passing 
the FE, interning for some number of years, attribution of character 
from some existing PEs, then passing the PE exam and receiving the 
state-adorned license.


The use of the term "engineer" is much more vauge and generally 
unprotected in the USA.  Lots of people have job titles with the word in 
it that wouldn't even fall under typical professional engineering 
guidelines in the most aggressive interpretation.  However, the PE board 
in some states can be pretty aggressive about the whole "practicing 
professional engineering without the proper license", and part of the 
guidelines they use to make that determination is if you use the term 
"engineer" to describe yourself.


The feds have quality steered clear of the whole PE thing in codes/laws 
since it's essentially entirely state-run.  The use of the term here 
might be an oversight that should be corrected as it doesn't seem that 
they intended to require a state-licensed "Professional Engineer", at 
least if the person doing the approval of the report is an agent of the 
company submitting it, nor did they define the term as such.


A lot of "engineering" happens under the so-called "industrial 
exemption" where things are going to cross state lines and therefore 
aren't under the purview of the state licensing board, but 
infrastructure-based/wireline comm systems would likely not fall under 
that, so it comes down to if your state defines the operation of such 
systems (not necessarily the physical design and emplacement of them) as 
an engineering activity.


Note that I am not a PE, though I have passed the FE.  This shouldn't be 
construed as legal advice much less advice to your specific situation.

Re: FCC BDC engineer?

[Glenn Kelley]

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  wrote:

>
>
> On Tue, Jul 5, 2022 at 11:52 AM Bryan Fields 
> 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
>
>
>

Re: FCC BDC engineer?

[Matthew Petach]

On Tue, Jul 5, 2022 at 11:52 AM Bryan Fields  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

Re: FCC BDC engineer?

[Josh Luthman]

As of last week our discussions with the FCC have still not determined the
official ruling.  Again, my personal opinion is that it will not require a
PE stamp but rather depend on an individual to be a professional engineer.

On Tue, Jul 5, 2022 at 3:39 PM Andrew Latham  wrote:

> Josh, you are correct, I linked to the wrong document.
>
> On Tue, Jul 5, 2022 at 1:36 PM Josh Luthman 
> wrote:
>
>> Andrew,
>>
>> Where does it say that it is or is not required?  This is a request for
>> clarification filed by the CCA.
>>
>> On Tue, Jul 5, 2022 at 1:59 PM Andrew Latham  wrote:
>>
>>> I read https://docs.fcc.gov/public/attachments/DA-22-543A1.pdf and a PE
>>> is not required.
>>>
>>> On Tue, Jul 5, 2022 at 9:47 AM KCI Dave Logan via NANOG 
>>> wrote:
>>>
 Hi all.  We operate a small regional ISP in Colorado, but no size is
 too small to ignore the FCC, as you all know.

 We're really struggling to find the required engineer for the filing,
 and we're small enough that we don't have an officer with engineering
 credentials.

 Any pointers in the CO/WY/NE/KS area would be great, on or off list.

 I sure hope we're the only org with this problem still, and all the
 rest of you are good to go.

 Thanks,
 dave

 --

 Dave Logan
 Kentec Communications, Inc.
 970-522-8107


>>>
>>> --
>>> - Andrew "lathama" Latham -
>>>
>>
>
> --
> - Andrew "lathama" Latham -
>

Re: FCC BDC engineer?

[Andrew Latham]

Josh, you are correct, I linked to the wrong document.

On Tue, Jul 5, 2022 at 1:36 PM Josh Luthman 
wrote:

> Andrew,
>
> Where does it say that it is or is not required?  This is a request for
> clarification filed by the CCA.
>
> On Tue, Jul 5, 2022 at 1:59 PM Andrew Latham  wrote:
>
>> I read https://docs.fcc.gov/public/attachments/DA-22-543A1.pdf and a PE
>> is not required.
>>
>> On Tue, Jul 5, 2022 at 9:47 AM KCI Dave Logan via NANOG 
>> wrote:
>>
>>> Hi all.  We operate a small regional ISP in Colorado, but no size is too
>>> small to ignore the FCC, as you all know.
>>>
>>> We're really struggling to find the required engineer for the filing,
>>> and we're small enough that we don't have an officer with engineering
>>> credentials.
>>>
>>> Any pointers in the CO/WY/NE/KS area would be great, on or off list.
>>>
>>> I sure hope we're the only org with this problem still, and all the rest
>>> of you are good to go.
>>>
>>> Thanks,
>>> dave
>>>
>>> --
>>>
>>> Dave Logan
>>> Kentec Communications, Inc.
>>> 970-522-8107
>>>
>>>
>>
>> --
>> - Andrew "lathama" Latham -
>>
>

-- 
- Andrew "lathama" Latham -

Re: FCC BDC engineer?

[Josh Luthman]

Andrew,

Where does it say that it is or is not required?  This is a request for
clarification filed by the CCA.

On Tue, Jul 5, 2022 at 1:59 PM Andrew Latham  wrote:

> I read https://docs.fcc.gov/public/attachments/DA-22-543A1.pdf and a PE
> is not required.
>
> On Tue, Jul 5, 2022 at 9:47 AM KCI Dave Logan via NANOG 
> wrote:
>
>> Hi all.  We operate a small regional ISP in Colorado, but no size is too
>> small to ignore the FCC, as you all know.
>>
>> We're really struggling to find the required engineer for the filing, and
>> we're small enough that we don't have an officer with engineering
>> credentials.
>>
>> Any pointers in the CO/WY/NE/KS area would be great, on or off list.
>>
>> I sure hope we're the only org with this problem still, and all the rest
>> of you are good to go.
>>
>> Thanks,
>> dave
>>
>> --
>>
>> Dave Logan
>> Kentec Communications, Inc.
>> 970-522-8107
>>
>>
>
> --
> - Andrew "lathama" Latham -
>

Re: FCC BDC engineer?

[Bryan Fields]

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.
-- 
Bryan Fields

727-409-1194 - Voice
http://bryanfields.net

Re: FCC BDC engineer?

[Jared Mauch]

Yeah the big thing I’ve seen is that companies have historically over claimed 
on their 477 reports in weird and interesting ways.  I understand why and how 
it happens, for example, if we do a HH meet for service at location X in census 
tract 2020-01 and I have a 2 mile loop to location Y in census tract 2020-02, 
what is the service address? When there’s a new service, how does it get 
re-geocoded?  Did you get all the exceptions handled properly?  

The new BDC rules are also a bit odd compared to the 477 ones, which if at an 
address I sold 2 services, I might have 2 locations but BDC says it’s 1 even if 
duplex.

Things just get a bit sticky around this is all when it comes to this.  I 
appreciate better accuracy as Comcast still claims to offer service at my home 
which isn’t true.  So do a few other providers as well which is inaccurate.

I already filed my 477 for 1H22, now to get this BDC done.

- jared

> On Jul 5, 2022, at 1:58 PM, Andrew Latham  wrote:
> 
> I read https://docs.fcc.gov/public/attachments/DA-22-543A1.pdf and a PE is 
> not required.
> 
> On Tue, Jul 5, 2022 at 9:47 AM KCI Dave Logan via NANOG  
> wrote:
> Hi all.  We operate a small regional ISP in Colorado, but no size is too 
> small to ignore the FCC, as you all know.
> 
> We're really struggling to find the required engineer for the filing, and 
> we're small enough that we don't have an officer with engineering credentials.
> 
> Any pointers in the CO/WY/NE/KS area would be great, on or off list.
> 
> I sure hope we're the only org with this problem still, and all the rest of 
> you are good to go.
> 
> Thanks,
> dave
> 
> -- 
> 
> Dave Logan
> Kentec Communications, Inc.
> 970-522-8107
> 
> 
> 
> -- 
> - Andrew "lathama" Latham -

Re: FCC BDC engineer?

[Andrew Latham]

I read https://docs.fcc.gov/public/attachments/DA-22-543A1.pdf and a PE is
not required.

On Tue, Jul 5, 2022 at 9:47 AM KCI Dave Logan via NANOG 
wrote:

> Hi all.  We operate a small regional ISP in Colorado, but no size is too
> small to ignore the FCC, as you all know.
>
> We're really struggling to find the required engineer for the filing, and
> we're small enough that we don't have an officer with engineering
> credentials.
>
> Any pointers in the CO/WY/NE/KS area would be great, on or off list.
>
> I sure hope we're the only org with this problem still, and all the rest
> of you are good to go.
>
> Thanks,
> dave
>
> --
>
> Dave Logan
> Kentec Communications, Inc.
> 970-522-8107
>
>

-- 
- Andrew "lathama" Latham -

Re: FCC BDC engineer?

[Brough Turner]

Brian Webster (of wirelessmapping.com) has partnered with Carmeron Crum to
address BDC reporting here:  https://www.regulatorysolutions.us/index.html
And if you are a member of WISPA, there's been discussions and some good
webinars there.

Thanks,
Brough

Brough Turner
netBlazr Inc. – Free your Broadband!
Mobile:  617-285-0433   Skype:  brough
netBlazr Inc.  | Twitter
 | LinkedIn
 | Facebook





On Tue, Jul 5, 2022 at 11:54 AM Tom Mitchell 
wrote:

> Reach out to the folks at IP Architechs (https://iparchitechs.com/),
> Readitech (https://engr.readitech.com/) or any of the good PE firms and
> they can help.
>
> -- Tom
>
>
> On Tue, Jul 5, 2022 at 8:44 AM KCI Dave Logan via NANOG 
> wrote:
>
>> Hi all.  We operate a small regional ISP in Colorado, but no size is too
>> small to ignore the FCC, as you all know.
>>
>> We're really struggling to find the required engineer for the filing, and
>> we're small enough that we don't have an officer with engineering
>> credentials.
>>
>> Any pointers in the CO/WY/NE/KS area would be great, on or off list.
>>
>> I sure hope we're the only org with this problem still, and all the rest
>> of you are good to go.
>>
>> Thanks,
>> dave
>>
>> --
>>
>> Dave Logan
>> Kentec Communications, Inc.
>> 970-522-8107
>>
>>

Re: FCC BDC engineer?

[Tom Mitchell]

Reach out to the folks at IP Architechs (https://iparchitechs.com/),
Readitech (https://engr.readitech.com/) or any of the good PE firms and
they can help.

-- Tom


On Tue, Jul 5, 2022 at 8:44 AM KCI Dave Logan via NANOG 
wrote:

> Hi all.  We operate a small regional ISP in Colorado, but no size is too
> small to ignore the FCC, as you all know.
>
> We're really struggling to find the required engineer for the filing, and
> we're small enough that we don't have an officer with engineering
> credentials.
>
> Any pointers in the CO/WY/NE/KS area would be great, on or off list.
>
> I sure hope we're the only org with this problem still, and all the rest
> of you are good to go.
>
> Thanks,
> dave
>
> --
>
> Dave Logan
> Kentec Communications, Inc.
> 970-522-8107
>
>

Re: FCC BDC engineer?

[Josh Luthman]

There still is no clarification on the requirement of an official PE stamp.

My personal feeling is that if it's not decided by now, the week after
filing opens, it would be an unreasonable burden for filers.  I believe
it's more "professional engineer" like a CPNI for CBRS.

On Tue, Jul 5, 2022 at 11:44 AM KCI Dave Logan via NANOG 
wrote:

> Hi all.  We operate a small regional ISP in Colorado, but no size is too
> small to ignore the FCC, as you all know.
>
> We're really struggling to find the required engineer for the filing, and
> we're small enough that we don't have an officer with engineering
> credentials.
>
> Any pointers in the CO/WY/NE/KS area would be great, on or off list.
>
> I sure hope we're the only org with this problem still, and all the rest
> of you are good to go.
>
> Thanks,
> dave
>
> --
>
> Dave Logan
> Kentec Communications, Inc.
> 970-522-8107
>
>

FCC BDC engineer?

[KCI Dave Logan via NANOG]

Hi all.  We operate a small regional ISP in Colorado, but no size is too small 
to ignore the FCC, as you all know.

We're really struggling to find the required engineer for the filing, and we're 
small enough that we don't have an officer with engineering credentials.

Any pointers in the CO/WY/NE/KS area would be great, on or off list.

I sure hope we're the only org with this problem still, and all the rest of you 
are good to go.

Thanks,
dave

--

Dave Logan
Kentec Communications, Inc.
970-522-8107

ITNOG6

[Brian Turnbow via NANOG]

Hello Everyone,

The 15th and 16th of September we will be holding ITNOG6 in Bologna Italy.
EPF is being held in Rome from the 12th to the 14th and Bologna is a short 
speed train ride away, so if you are attending why not come and nog Italian 
style?
We have published the event details and call for papers on our website and we 
welcome presentations in English as well as Italian.
https://www.itnog.it/itnog6/

Hope to see a lot of you there and If you would like to present something 
please send it in to our PC.

Sorry for any duplicates

Brian