I can understanding the FCC wanting someone to hang for submitting puffed up
coverage info. They think this is going to guarantee accuracy of the results
and prevent any challenges. If there are challenges then it will pit PE
against PE. Not so sure this is going to accomplish what they want. I don’t
overstate my reach or capability. I am fiber. The reach is finite and
inarguable. The gear I use has finite and inarguable capacity. However with
fiber I guess I can I can give you a Tbps theoretically. I don’t think this is
a problem for fixed providers. We either cover an area or we do not. With
wireless, everyone can fudge the map. I would guess that is what the FCC is
trying to stop.
From: Mark Radabaugh
Sent: Friday, July 22, 2022 9:32 AM
To: AnimalFarm Microwave Users Group
Subject: Re: [AFMUG] BDC
I could get my PE but I have zero interest in relearning all of the EIT
(renamed something else now) that is part of the book exam. But to your point
- nothing in my EE had any specific relevance to what we do on a day to day
basis. Fiber was a curiosity at the time, and phased array antennas were
cutting edge.
I still think the FCC / etc. is getting a little too hung up on the PE
requirement - I’m not convinced they actually required a state certified
Professional Engineer (Capital P) in the first place. Ohio specifically
says:
(A) Except for an individual who, as part of the internal classification
system of the individual's employer, uses the title "engineer" by itself or in
conjunction with another term described in division (B) of this section and who
does not represent the individual's self to the public or otherwise advertise
the individual's self as an engineer, no individual shall, in connection with
the individual's name, assume, use, or advertise:
(1) The title "engineer" by itself unless the individual is an engineer;
(2) The title "engineer" in conjunction with another term that modifies the
title "engineer" in a manner that conveys the impression that the individual is
a graduate of an accredited engineering curriculum unless the individual is a
graduate of an accredited engineering curriculum.
(B) Terms used in conjunction with the title "engineer" under division (A)(2)
of this section that imply a person is a graduate of an accredited engineering
curriculum include the following: "aerospace," "agricultural," "civil,"
"chemical," "computer," "electrical," "industrial," "mechanics," "mechanical,"
"metallurgical," "mining," "naval architectural and marine," "nuclear," and any
other term commonly used by an institution of higher learning to apply to
graduates of an accredited engineering curriculum.
The FCC said (in the waiver) "we agree that, under the Commission’s rules,
where a mobile or fixed service provider submits a certification of the
accuracy of its broadband submissions from a “corporate engineering officer,”
the corporate engineering officer does not need to be a certified PE. We
believe that the rule would be satisfied, for example, where the corporate
officer possesses at least a Bachelor of Science (B.S.) in engineering degree
and has both “direct knowledge” of, and responsibility for, the carrier’s
network design and construction.
To my reading I can specifically state that I am an engineer with a BSEE acting
in my capacity with the company, and not violate Ohio law in doing so.
Mark
On Jul 22, 2022, at 10:35 AM, Cameron Crum <cc...@murcevilo.com> wrote:
Yeah, it's a stupid requirement s most EE PEs don't know jack about wireless
and probably less about fiber. I happen to know a couple guys who bothered to
get their PE, but I know I never did simply because there wasn't even a test
for what I do. They want you to take the power systems and control systems exam
if you are an RF guy. IT really is dumb and I think they are just trying to
weed out the smaller guys who will be forced into a financial hardship.
On Thu, Jul 21, 2022 at 4:53 PM Chuck McCown via AF <af@af.afmug.com> wrote:
The waiver should be made permanent. The quality of the data will not
suffer.
From: Cameron Crum
Sent: Thursday, July 21, 2022 3:47 PM
To: AnimalFarm Microwave Users Group
Subject: Re: [AFMUG] BDC
Understood. We can work with very small providers. We aren't trying to put
anyone out of business. We do have some fixed costs like the PE unless you want
to self certify. I believe you qualify, or will at least for the waiver on the
next 3 filings.
Cameron
On Thu, Jul 21, 2022 at 4:36 PM Chuck McCown via AF <af@af.afmug.com> wrote:
Yes, but your solution is equivalent to my annual net profit as I am such
a new and small company. I am complaining to the FCC penury.
From: Cameron Crum
Sent: Thursday, July 21, 2022 3:23 PM
To: AnimalFarm Microwave Users Group
Subject: Re: [AFMUG] BDC
We have a solution for filing with PE certification at
www.regulatorysolutions.us if you need assistance.
Cameron
On Thu, Jul 21, 2022 at 4:17 PM Chuck McCown via AF <af@af.afmug.com>
wrote:
Not a new version but a whole new other report in addition to 477 I
think.
Sent from my iPhone
On Jul 21, 2022, at 2:39 PM, Jason McKemie
<j.mcke...@veloxinetbroadband.com> wrote:
I haven't been reading up on this, is this the new form 477
replacement with increased requirements?
On Thu, Jul 21, 2022 at 2:51 PM Chuck McCown via AF <af@af.afmug.com>
wrote:
“Internet access”. If I am strictly a layer 2 pipe providing
transport - only then I am not a provider of internet. If someone
coincidentally connects it to layer 3 things... well then that is outside of my
control.
From: Josh Luthman
Sent: Thursday, July 21, 2022 1:41 PM
To: Chuck McCown
Cc: AnimalFarm Microwave Users Group
Subject: Re: [AFMUG] BDC
>Facilities-based providers of fixed and mobile broadband internet
access who have one or more end user connections in service on June 30, 2022
On Thu, Jul 21, 2022 at 3:35 PM Chuck McCown <ch...@go-mtc.com>
wrote:
But what types of business does it apply to? I am sure that I
can find a loophole. Like I deliver virtual ice cream via ethernet so it
should not apply to me.
From: Josh Luthman
Sent: Thursday, July 21, 2022 12:47 PM
To: AnimalFarm Microwave Users Group
Cc: Chuck McCown
Subject: Re: [AFMUG] BDC
Ethernet/GPON doesn't matter. It's copper versus optical
delivery. :)
On Thu, Jul 21, 2022 at 11:21 AM Chuck McCown via AF
<af@af.afmug.com> wrote:
I wonder if I can get away with being an ethernet service
provider with free access to the internet thrown in...
From: Josh Luthman
Sent: Thursday, July 21, 2022 8:33 AM
To: AnimalFarm Microwave Users Group
Subject: Re: [AFMUG] BDC
WISPA is absolutely fighting this. We absolutely did not want
this. There's way more opposition than WISPA has resources, but we still did
get some wins.
On Wed, Jul 20, 2022 at 11:12 PM Steve Jones
<thatoneguyst...@gmail.com> wrote:
I'm sure wispa is out there looking out for us
That is sarcasm
Wispa isnt what itwas when it lived in this neighborhood
I feel we all need to watch brokeback mountain to prepare
what's coming
On Wed, Jul 20, 2022, 6:16 PM Chuck McCown via AF
<af@af.afmug.com> wrote:
Perhaps. I am sure there will be things filed about this.
From: Brian Webster
Sent: Wednesday, July 20, 2022 4:46 PM
To: 'AnimalFarm Microwave Users Group'
Cc: 'Chuck McCown'
Subject: RE: [AFMUG] BDC
Keep in mind that is a temp fix and only good for the next
18 months. Then the full PE cert is required.
Thank you,
Brian Webster
www.wirelessmapping.com
From: AF [mailto:af-boun...@af.afmug.com] On Behalf Of
Chuck McCown via AF
Sent: Wednesday, July 20, 2022 5:10 PM
To: af@af.afmug.com
Cc: Chuck McCown
Subject: [AFMUG] BDC
Starting to look into what I have to do.
Just read the certification requirements. This is the
language of the alternate, non PE, non degreed engineer certifier:
(ii) specialized training relevant to broadband network
engineering and design, deployment, and/or performance, and at least ten years
of relevant experience in broadband network engineering, design, and/or
performance.
I am guessing everyone on this list fits this set of
qualifications.
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