*LOTS* of bad submissions from LOTS of companies, big and small, over the years. It all needs to stop. I'm not sure this is the right way, but it's the way we're apparently going down.
----- Mike Hammett Intelligent Computing Solutions Midwest Internet Exchange The Brothers WISP ----- Original Message ----- From: "Chuck McCown via AF" <af@af.afmug.com> To: "AnimalFarm Microwave Users Group" <af@af.afmug.com> Cc: "Chuck McCown" <ch...@go-mtc.com> Sent: Friday, July 22, 2022 10:48:40 AM Subject: Re: [AFMUG] BDC 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 <blockquote> 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: <blockquote> 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: <blockquote> 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: <blockquote> Not a new version but a whole new other report in addition to 477 I think. Sent from my iPhone <blockquote> On Jul 21, 2022, at 2:39 PM, Jason McKemie < j.mcke...@veloxinetbroadband.com > wrote: </blockquote> <blockquote> 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: <blockquote> “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: <blockquote> 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: <blockquote> 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: <blockquote> 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: <blockquote> 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. -- AF mailing list AF@af.afmug.com http://af.afmug.com/mailman/listinfo/af_af.afmug.com </blockquote> -- AF mailing list AF@af.afmug.com http://af.afmug.com/mailman/listinfo/af_af.afmug.com </blockquote> -- AF mailing list AF@af.afmug.com http://af.afmug.com/mailman/listinfo/af_af.afmug.com -- AF mailing list AF@af.afmug.com http://af.afmug.com/mailman/listinfo/af_af.afmug.com </blockquote> </blockquote> -- AF mailing list AF@af.afmug.com http://af.afmug.com/mailman/listinfo/af_af.afmug.com </blockquote> -- AF mailing list AF@af.afmug.com http://af.afmug.com/mailman/listinfo/af_af.afmug.com </blockquote> -- AF mailing list AF@af.afmug.com http://af.afmug.com/mailman/listinfo/af_af.afmug.com </blockquote> -- AF mailing list AF@af.afmug.com http://af.afmug.com/mailman/listinfo/af_af.afmug.com -- AF mailing list AF@af.afmug.com http://af.afmug.com/mailman/listinfo/af_af.afmug.com </blockquote> -- AF mailing list AF@af.afmug.com http://af.afmug.com/mailman/listinfo/af_af.afmug.com -- AF mailing list AF@af.afmug.com http://af.afmug.com/mailman/listinfo/af_af.afmug.com </blockquote> -- AF mailing list AF@af.afmug.com http://af.afmug.com/mailman/listinfo/af_af.afmug.com </blockquote> -- AF mailing list AF@af.afmug.com http://af.afmug.com/mailman/listinfo/af_af.afmug.com -- AF mailing list AF@af.afmug.com http://af.afmug.com/mailman/listinfo/af_af.afmug.com
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