The Broadband DATA Act sets forth specific requirements for BDC (Broadband Data Collection) filings, outlining the necessary certifications and qualifications. Compliance with certification criteria is crucial to ensuring the accuracy and reliability of data submissions.
Below are the requirements for certification of BDC:
Corporate Officer Certification:
A fundamental requirement for BDC filings is the inclusion of a certification signed by a corporate officer of the provider. This certification entails a thorough examination of the submission's information. The corporate officer must affirm, to the best of their actual knowledge, information, and belief, that all statements of fact within the submission are true and correct.
Qualified Engineer Certification:
In addition to the corporate officer certification, each BDC filing must feature a certification of accuracy by a qualified engineer employed by the provider. The engineer must possess direct knowledge of or responsibility for the generation of the provider's BDC filing. Like the corporate officer certification, the engineer must validate that all statements of fact in the submission are true, accurate, and aligned with the provider's ordinary course of network design and engineering.
The qualified engineer certifying the BDC filing must meet one of the following qualifications:
- Be a certified Professional Engineer (P.E);
- Be a Corporate engineering officer with a Bachelor of Science in Engineering (BSE) with direct knowledge of, and responsibility for, the carrier’s network design and construction to certify that the BDC submission is in accordance with the service provider’s ordinary course of network design and engineering; or
- Due to the 2022 Limited Waiver and its 2023 Extension, an "otherwise qualified engineer" is defined as:
- An engineer who has either obtained a bachelor's or advanced degree in fields related to electrical engineering, electronic technology, or a comparable technical discipline, along with a minimum of seven years of applicable experience in broadband network design and/or performance;
- Alternatively, it could also refer to an engineer who has received specialized training in areas relevant to broadband network engineering and design, deployment, and/or performance, coupled with at least ten years of relevant experience in broadband network engineering, design, and/or performance.
Maintaining Additional Network Information:
Providers opting for certification by an "otherwise qualified engineer" must keep additional network information for the applicable BDC filing date. This data may be requested by the Commission for validation purposes, emphasizing the importance of data integrity and transparency. The data requirements differ based on the service offered. You can find the specific guidelines for the data to be retained in the Data Specifications for Provider Infrastructure Data outlined in the Challenge, Verification, and Audit Processes available here:
By engaging certified corporate officers and qualified engineers, providers contribute to the validity of the data reported, ultimately supporting the consistency and quality of broadband network design and performance assessments.
It is important to note that all BDC submissions, even those endorsed by an "otherwise qualified engineer," must still include a certification from a corporate officer.
More Information:
For more detailed information and specific requirements, providers are encouraged to refer to the detailed specifications outlined in the Broadband DATA Act and related documentation provided by the FCC.
We partner with licensed engineering firms experienced in RF such as Rfwel Engineering who are qualified under either criteria. Please contact us if you have legal questions regarding BDC certifications.