Industry Groups Say FCC Should End BDC Professional Engineer Requirement

Several groups urged the FCC to eliminate the PE certification requirement. The lack of certified PEs continues to exist, said the Wireless ISP Association, noting that several parties have "come forward in this docket with specific, credible, individualized evidence as to the inability to procure assistance from a PE." WISPA opposed submission of additional information about terrestrial fixed wireless services beyond what was proposed in the FNPRM.

It "remains true that many qualified engineers have expertise in network planning, radio frequency, and other skills that are more relevant to accurate mapping than a PE certification," said USTelecom. The group added there's "no evidence that filings certified by PEs versus qualified engineers are more accurate." The waivers already granted for this requirement "did not negatively impact the BDC submissions by mobile and fixed providers," USTelecom said.

"There is no evidentiary support that more comprehensive changes would increase the accuracy of maps," said CTIA. Removing the PE certification requirement would "provide certainty to providers, avoid imposing unnecessary costs, and eliminate the need to continue using piecemeal waivers to address this persistent concern" about a lack of PEs, CTIA said. The group also said there's "no reasonable basis" to impose additional reporting requirements on fixed wireless providers.

Some commenters disagreed. Removing the requirement would "substantially undermine" efforts to ensure reliable mapping, said Vantage Point Solutions. "Requiring the formal certification of a PE promotes a standard of quality that the commission alleges it prioritizes."

RWA said, "The waiver process better serves the public than an overly broad elimination of the PE requirement that would apply to all broadband providers, regardless of their ability to justify a waiver." The group also backed requiring that satellite providers submit additional documents with their BDC submissions. The new data "can provide much needed clarity on the benefits and limitations of satellite networks," RWA said.

Amazon warned that disclosure of capacity information "could harm competition" because the information "may give competitors insight into the technological capabilities of satellite operators' satellites on a per unit basis." Access to this information "would enable competitors to rely on this information in developing competing products and business strategies," Amazon said.

NTCA suggested that "more must be done to prevent persistent coverage overstatements by all providers from being permanently ensconced" within the national broadband map. The adoption of "better technical standards for all of the various network platforms that are used to deliver broadband services is the most efficient and effective method" to prevent overstatements of coverage.

ACA Connects opposed a CTIA-proposal on the fixed broadband location restoration process. "While allowing providers to restore locations without submitting additional data could conserve provider resources during the location restoration process, it could require more resources from challenging parties and commission staff to both submit and review challenges to the newly-restored locations," the group said: "Because CTIA’s de minimis proposal would tend to shift burdens from the most resource-rich providers onto commission staff and challengers without justification, it should not be adopted."