The Competitive Carriers Association (CCA) asked the FCC for a ruling to clarify that Broadband Data Collection (BDC) filings may be certified by a qualified professional engineer or an otherwise qualified engineer that is not a licensed professional engineer accredited by a state licensing board. The agency seeks public input on the request. Commission’s rules require an engineer to review and certify the accuracy of the broadband availability data submitted by mobile and fixed providers as part of the BDC.
In particular, the Commission requires each company to include certifications as to the accuracy of its data submissions by a certified professional engineer or corporate engineering officer. The engineer must certify ‘‘that he or she has examined the information contained in the submission and that, to the best of the engineer’s actual knowledge, information, and belief, all statements of fact contained in the submission are true and correct and in accordance with the service provider’s ordinary course of network design and engineering.’’
This certification is in addition to the corporate officer certification required by the Broadband DATA Act. For government and other third-party entities that submit verified broadband availability data, the engineering certification must also include a certification by a certified professional engineer that he or she is employed by the government or other third-party entity submitting the verified broadband availability data and has direct knowledge of, or responsibility for, the generation of the government or other entity’s Broadband Data Collection coverage maps.
In its submission of a Petition for a Declaratory Ruling, CCA asserts the ‘‘experience and expertise developed by RF engineers through their work provides comprehensive skills relevant to broadband deployment [and] provides skills comparable to, and perhaps more relevant than, general licensure through the PE . . . exam process.’’ CCA wants the agency to clarify that the requirement in 47 CFR 1.7004(d) that all providers must include as part of their BDC filing a certification of the accuracy of its submissions. Those filings should be provided by a certified professional engineer but may be completed by a qualified engineer who possesses the appropriate expertise but does not hold a professional engineer license.
Additionally, CCA asks the Commission to spell out that the term ‘‘corporate engineering officer’’ may be any employee who has ‘‘direct knowledge’’ and is ‘‘responsible for’’ the carrier’s network design and construction and who possesses a Bachelor of Science degree in Engineering. Alternatively, CCA requests a limited waiver of the requirement that BDC data be certified by a licensed professional engineer, and instead allow mobile providers to certify their data with an RF engineering professional with specified qualifications that are directly relevant to broadband availability assessment.
CCA recommends that if the Commission seeks to specify qualification standards or requirements for engineers to certify broadband availability, it should adopt standards that specifically relate to broadband availability assessment, such as academic and employment experience, RF and propagation modeling experience, and knowledge relevant to wireless carriers’ networks.
Comments are due to WC Docket No. 19–195 by June 8. The due date was triggered by Federal Register publication.
By Leslie Stimson, Inside Towers Washington Bureau Chief
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