FCC BDC engineer?

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.


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.

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.

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.

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

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

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.


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

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

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.

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


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

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.

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.