 Welcome to the RFL once unlicensed podcast. I'm Caleb as always. We've got tosses over here. Say hi tosses Hi, hi tosses. Hi tosses and this week. We're joined by host Cameron crumb from regulatory solutions So we're gonna be talking about the BBC turn turn turn We're gonna be talking about regulatory things jazz mapping or we'll see where the conversation goes But before we hop into this conversation real quick tosses give the good people out there their call to action Yes, absolutely. Don't forget to like listen or subscribe to a channel right here on YouTube or anywhere You download your audio podcast like Apple Google or Spotify All right, all right, so let's go ahead and jump to it So Cameron my man We really appreciate you taking the time out of your busy day to talk to us today and Tell us about like I said the BDC and all this regulatory stuff, you know, it's a really hot topic You know when at first the stuff started coming out There was a lot of freaking out across the industry I think and you know now it seems like this is not an insurmountable goal We can get this done But you know, I think the more information and the more light that we can shed especially with those deadlines and stuff coming up And clear through the flood I think it's gonna help everybody out there get a better understanding as to what's going on So again, appreciate it take the time go ahead and run through just kind of a quick introduction of like who you are kind of how you've gotten into this space and You know, what's what has led you up to this day? Wow, well, okay Uh, that's that's quite a bit but um, so, you know, I have a background in wireless engineering Kind of started in my career in the cellular world. Uh, I did a bunch of network design around the Are actually around the world. I was in about three different countries over the course of about seven years Doing cellular network design 12 different cities and then I got into the obviously the Wisp space Built a Wisp brand it for about eight years sold that to jab and the process of running that You know, I wrote the wismann software Which was a billing, you know billing and kind of all-encompassing platform like they are these days and sold that to sonar in 2017 and You know did a couple things between that time But one of the things I got into, you know when running wismann we we did a lot of Mapping in fact, that's how that's how the whole thing started was We wanted to map and monitor our network and just have an application that we could just bring up and see our network status On a map on the screen anytime we wanted and that's really kind of how it started That's where the name came from wismann was kind of wish monitor and So, um, so so I had this background in gis. I'd also written an rf propagation program for the cellular industry back in the late 90s early 2000s and That program was based in A platform called map info which which used to be a big competitor to esri They were kind of they were kind of the two big competing platforms in the telecom space at the time and And the base of that platform is written in map info and I had kind of become this map info Expert I was in these local user groups and teaching You know people how to use it and that kind of stuff and they had a little interface called map basic that you could You know kind of write your own custom gis applications into and so I Built propagation on top of that and sold it. You know had some moderate success So I had this background and in both rf and gis So that was kind of a natural fit into writing, you know wismann for myself And so that kind of led us into you know, once we got Uh started getting customers and things the FCC of course came out with the 477 requirements back in the late, you know Whatever you call them the odds, I guess and so we started the odds Yeah, so uh, so we started writing, uh, you know people started asking us if we could help with that And of course it was it was a pretty easy thing back then to plug that into wismann and then You know people said well, I don't even know how to file could you file for so we for an extra little fee We would actually file there for seven sevens every year. So once I sold wismann We um, yeah, we started getting requests from our former customers They said well, we don't know how to do this. Still, can you help us and so I said, yeah, sure I can I can help you out So I had you know, I had a handful of people that I was doing it for and then over the years People have been referring other people to me on facebook. So now twice a year I have this big group of people who come to me and ask me to do this stuff So I track it and keep a pretty good eye on what's going on and of course this bdc stuff that came about You know now we have to get really granular Down to the address level with their fabric and all that stuff. So So that's where we are and that's what kind of led me to this point um, so, you know that the new company I have is You know, just was kind of born out of this need. There was just really nobody doing the full service I mean, there's there's other there's other people doing parts of it You know some some the propagation stuff or overlays and being able to get some address list But nobody's really putting it all together. And so that's kind of where Uh, you know where we came up with this this company. So and you know as a side note I also still work, you know, pretty much full time for visp as their cto. So it's still it's still a You know, these are but this is kind of a side project, but it's but it obviously it's very important and You know, we brought in brian webster as well because he has a big background in mapping and then of course my former partner from From wisp on robert olive is is helping me out on the business side of things. And so We just you know, we just needed some some other expertise because we're going to be really busy as it is so But but anyway, this this new requirement is I know it's really kind of confounding people and And there's I see all the discussion going on and it's it's, you know, almost hourly There's some new post about it you know people either complaining or figuring out, you know, what they're going to do or how they're going to do it and um, you know, we're we're just trying to trying to provide another resource to help so But but yeah, it's it's uh, it's going to be I think A difficult thing in our industry It seems to me that the bdc was kind of put in place to almost to squash the little guys And because it is expensive, you know to get the work done and to get the filing right And it's expensive really expensive if you get it wrong and you know, so So that's that's kind of where we are with it and You know, we have, you know, we we can get the pe certifications and that kind of stuff You know, it's it's really difficult to find a pe And I know that that's been a big point of contention With the the rules that they have they had this pe requirement Even though initially I think they said that you could have an engineering officer I think they kind of clarified that in some of the report and orders where they they basically said well Yeah, it still has to be a pe And now they have this, you know, they've relaxed that for the next three filings, but Um, it's a difficult thing to find. I've been in this industry a long time I had a former partner in my propagation business That was a pe in and he was registered in several states Um, and he was one of the few people I knew in the wireless industry Of all the, you know, the hundreds of engineers I ran across in the cellular days and and all that stuff Nobody had a pe. I mean, I knew two guys that had a pe and one of them was my partner and so It just is not something that, uh, double e's who do rf or wireless design really, uh, really do because There's no test for it. So the, you know, when you When to get a pe you have to take, you know, what they call the e it test and then work for a few years And then you can go back and take the pe exam And the e it kind of encompasses all aspects of engineering, right? So there's there's components for like mechanical civil Um, electrical, you know, whatever in the in the e it test And so a lot most people take it like fresh out of school because that's when all that stuff is fresh for them And and then, you know, you work for a few years and then you take the the pe exam and you're kind of your specialized field And they have different sections Uh that you can do so like the double e pe there's there's a couple different tests you can take depending on what you're doing And the one they recommend if you're a an rf guy is the control systems and power systems test, which You know I just don't you know, it's Okay, I mean I get I get that there's you know, some wave theory and stuff in power systems and and some things like that But but there's nothing really specific to doing wireless Uh kind of wireless network design. And so one of the reasons I never did it was for that Uh, there just wasn't wasn't a call for it. We weren't stamping anything. You know, we didn't have to certify anything in that world And so uh, so there just aren't that many guys around that that know how to do this. So Um, I talked to a few I knew one here in the Dallas area that I've known for a lot of years and he's You know, he's he's getting up there, too I think he's in his you know mid to late 70s now and Um, I just don't know anybody else that that does it and then You know, we put out kind of some feelers because we wanted to have you know A couple guys on the on the hook to you know, just in case we got a huge volume of work It does take time to review the data and these guys aren't going to stamp it without their review because you know, they're putting their license at risk and um So other guys that I talked to Didn't know anything about wireless and I was like, well, I'm not sure how you're going to review it and stamp it You know, if you don't know what we're doing here It's difficult to you know to do so So that's where we are, but we do have some resources available for that It's been a struggle to get them but we do have that and um, hopefully that People need it. We can provide that service Okay, well stepping back and we'll loop back around in the pe parks I think there's a a lot of different debate and stuff going on around there But to step it back a second like the bdc Let's talk a little bit here about like what is the bdc? And what are the main differences between this new bdc filing and the 477 filings that people are doing or supposed to be doing And um, you know, let's talk a little bit about the differences between those and why This is kind of a much more of an honoris or at least sure in depth process Yes, so okay So the the 477 consisted of a couple of different parts, right? You had your subscription file, which was You know, basically the you know, it was a classification of speed tiers and technology codes, right a grouping of those and then Within a given tract, right? So you had to report how many subscribers You had in a track that had a certain technology code and a certain speed tier. This is census tract, right? That's correct. That's correct when I talk about tracks or blocks These are census tracks and blocks, right? Which is kind of a large sort of grouping Try to break this down and yeah, this is also not my exact wheelhouse to the nitty-gritty details So for sure. I'm like, well if I don't fully track and I'm sure there's plenty of others don't So if I get a little Interative on some of these questions, I'll no problem. No problem. Yeah, it's it's such old hat to me I figure everybody knows this but I guess, you know, that's that's a bad assumption on my part So yeah, so the census tracks are kind of the biggest You know boundary area they have for the census, right? So so it goes tracks, uh, and then they break that down into what they call block groups And then of course individual blocks, which is kind of the smallest Entity within, you know, how they how they define a geographical region for this census And so so the tracks are pretty big, right? So they just are trying to get kind of an idea I think of how many subscribers and what speeds can be available for those kind of larger areas And then they have what they call the deployment file, which which uses blocks, right? So you have to report In the blocks again, uh by speed tier and your your maximum advertised consumer, right a grade a bandwidth in that block, right? So, uh, I think for the most part, you know, most people don't get down to You know, oh, yeah, I this tower It's got, you know, a lot of obstructions and I can really only provide, you know 10 meg service over here where I provide 100 meg service on this part of my network Uh, honestly, I've never seen anybody get that kind of granular on their On their census block They kind of just take their maximum speed that they advertised out on the web and they say, oh, yeah, I can provide that everywhere And you know, I'm going to throw that out there. So for every block that I that I cover I'm going to say that I can provide that speed. And so there's no There's no granularity there. There's no real, you know, okay Well, I really can't provide that in a lot of places I can, you know, maybe get half of that or a quarter of that or something just based on my network topology um So so anyway, it's it's uh, still not very granular because if you can cover one person in a block Then you know, then you can say you cover the whole block and the block is You're you're about that. Yeah It really depends. Um on on where it is in the country. I mean a block could be You know 10 square miles in some places and it could be, you know, it could be a quarter I mean, it could be a couple of acres in another place, right? I mean, it just really depends on population density and stuff like that. So So, um, you know, again, you could cover a block that actually has one home in it, right? And that's it. That's the only thing in that block. So But you get to an urban area and now, you know, one block may have You know, 2000 people in it. So it just really depends on You know on on where it is in the country So it's really not a great way to determine where service is available, right? Because, you know, I think for the most part most of the especially wireless ISPs are operating in You know suburban to rural markets and So, you know, those blocks tend to get pretty big, but there's not a lot of homes in them So, you know, it's kind of this double-edged short, you know So yeah, I can cover this block because I serve this as one guy in the bottom corner of it But, you know, all these other people out there can get service, you know, they're blocked by trees or whatever But I still say I service the whole block and the whole reason that like the 477 came about is basically the FCC saying, hey We didn't have some idea of what our actual coverage is, right? I mean, because to some extent it's very much An educated guesstimate and I guess you kind of consider this a shotgun approach as to saying, you know This percentage of this county or the city or the state or the country as a whole has coverage, right? Yeah, and and, you know, it was kind of the smallest geographical entity available, right? And unless you want to get down to address levels, right? So, you know address level stuff is difficult because You know, I mean just just try to find an address in like northern New Mexico or Wyoming on google earth or google maps or something I mean, you're you're not finding it. I mean, it just their coverage is pretty poor in some parts of the country Um, and and sometimes it just puts you in the middle of whatever the closest town is, you know If you try to look something up. So so trying to do that was was um, it just wasn't possible So the FCC went out and contracted with this company cost quest to to build this fabric and I mean, if they if they have what they say they have which is addresses for the entire country That's pretty impressive I mean, I I honestly don't know where the data came from because China, you know, there's there's not Yeah, there's not even a national e911 database. I mean, they're trying to build one Um, and you can go look at that map, but there's some states that don't participate Uh, and there's some counties within states that don't participate There's some counties within some states that don't even have the information available themselves And so or it's it's not online, right? You have to like physically go down And and look up parcels and things like that Uh in order to get that information and so that that's what I'm saying to me I don't know how long cost quest has been working on this or how long they've been under contract to get this data But it's pretty impressive. Uh, if they if they have what they say they have So, you know, it's it's come from amazon ring cameras cell phones and and tick tick top apps, you know, right? I don't think there's enough for those out there. Honestly Yeah, there are there are still some areas that are underserved by absolutely anything. So yeah, it's yeah It'd be pretty interesting to see How good it really is. Yeah, because you know, you get into like parts of like I said like new mexico I am some of these really rural states where there's just almost no population and There'll be a road with a bunch of mailboxes at the end of it and that's the address I mean, yeah, you know, they don't have a geolocated address on the house because not even the postman goes there, you know So That those places it'll be interesting to see I know there's there's one particular company that I deal with a lot every year When this comes around in in vis that that has a pretty sizable footprint in northern new mexico And we always have issues with their addressing because it just You know, it just is hard to find you cannot find these physical addresses, you know, and so Uh, I I'll be I'll be curious to see how it turns out for them And and other people like them They're they're not going to take an address input as well turn where that old church burned down five years ago And where apple used to live, right? So yeah, yeah, you'd be surprised So the FCC and the government man were like, all right, so we're gonna put all this money in the broadband You know this whole push or in tia, you know in the the build back whatever So on and so forth So they decided that they need the the 477 was an adequate to fully gauge what servos levels were so they came up with this bdc And the I think the big, you know, the biggest honorous part of that is Is basically explaining that granular to the service address level, but then also like the technology and how you have to do it So so much more granularity. So if you kind of speak to that a bit, that would be really helpful Yeah, so so that obviously they want you to report, you know, the address IDs that you can cover, right? So they're going to give you the fabric file. So when you you go to cost quest site FCC slash cost quest whatever it is they so You go to their site you register you apply for their license and then and then they take your old 477 data that you filed previously So hopefully you filed And and they basically determine what what counties, right? You cover based on that, right? So if you're in a county, they they just kind of give you the whole county's worth of addressing And they put it all together in a file zip it up and then they give you send you a link to go get it And so now now you got to figure out what to do with it, right? So but the hard part on that I mean, there's there's two methods, right to report the first method is through a coverage polygon Uh, I think this is the worst one because you're basically giving them a coverage polygon and saying, okay You go determine where I can provide service But when you do that you also have to provide I mean, it's literally volumes of information about the coverage model I mean, they want stuff like the author of the coverage model, right? I mean, there's there's crazy requirements for when you upload a polygon for the model All of your radio parameters I mean, there's there's stuff down to like subcarrier power levels on the radios, right? And so so yeah, I mean, I mean the if you start reading through the document I mean, we can't really go into all of it here. But but I mean it is it is a crazy amount of data and honestly There's very few vendors. I think in this industry that will want either willing to provide the data or can provide the data Right, that's we can vouch for that. Yeah. And so so, you know, just just knowing what I know about Yeah, some some of the manufacturers and whatever, um, you know That I may or may not have worked for in the past, uh, have Have have um It's very difficult to get information. I mean I mean even internally within these organizations much less, um, you know, get somebody to send you Those kind of specs on a radio, right or we're on an antenna You know or or anything, right? So So that that presents a big problem, you know It's it's easy enough to generate a coverage polygon But you know, if that's all you're going to submit and you got to have all this other data I think you're really in a bad spot because I just don't think it's available And so the other method it is probably the one I think most people are going to use which, you know And I would encourage people to use it just because you do not have to provide all that technical data And that is just providing which a list of addresses that you can cover And so, you know, whatever method you use to do that, um, whether you kind of put put your own overlay on a map, which maybe Maybe gets you back to the polygon stuff again They may come back and say well, if you determined your address is using Your own coverage map and doing kind of like a spatial intersect in a gis platform or a spatial enabled database or something You know, they may still come back and say, okay. Well, use the polygon now I still want all this technical data, right? So there's other methodologies you can use. Uh, some people are just saying, you know I'm just going to submit the addresses I already have because I know I can service them and and that is the least amount of You know headache I I guess that's a strategy it's it's probably not a great strategy because You know, the idea of this whole thing is determine where the government's going to give money out, right? I mean, that's all the ultimate goal is to you know, they're not looking to see. Oh, well Yes, there's broadband here. We're going to encourage growth and development. No They're going to encourage stuff by giving out money and So, you know, if you don't care about somebody getting money to come over build you Okay, do the minimum and you know, just do the filing The other issue with that is that you've got to be able to prove That you can service those areas because this whole thing is going to be crowdsourced So, you know the the challenge is crowdsourced, right? So any Joe blow from the general public can come in and say Oh, look, they say they service this address and I know they don't, you know They they come out here and they said they can't service the address or whatever the case may be It could it could just be some disgruntled guy You know going in and to create headaches for you, right? I mean so anybody can come in and say no, they don't service these addresses And now you have to come back and prove that you do And so it it that's one of the really onerous parts I mean, I mean the volume of data required to do the filing is it's really bad But then put on top of it the fact that anybody can come in and challenge your addresses Now you've really got, you know problem I mean, this could be a full-time job, right for somebody just defending this filing because if you filing correctly And and even if it's uh, I think even if it's just by mistake Right you can still get fined So So if you say well to the best of my knowledge, I was able to service that it turns out I wasn't Well, you should have done a better job, right? And and I don't know how strict they're going to get I hope they're not that bad, you know in the past on the 477 It's pretty rare that they they did any enforcement action unless somebody was just blatantly or willfully You know not filing and just kind of gave them the middle finger Um, you know, it was pretty rare that that um, they You know proceeded with some kind of enforcement action, but Um, it seems like just the way they've been talking and the writing and the documents and stuff like that It seems like they're going to get pretty serious about this and the fines are pretty steep Do you have any idea 15 grand per incident? Wow. Yeah Yeah, that's per incident So that's that's how they're going to pay for all the money that they're giving out It's just going to find everybody to create the money to pay for it later, right? And that's typical government 101, right? Yeah Well, this is your new hobby. Ta says all those places where your your team mobile service doesn't work You just document them just like send them in I'm gonna I'm gonna go after T mobile so hard Yeah, so the mobile stuff is a little bit different, you know, but but yeah, it's still uh, it's still difficult to Um, you know to file. I don't know what those guys honestly. They they got engineers on staff It can probably handle this stuff, but um, but yeah It the you know, just the fact that you got to collect so much data So and getting back to that, you know, if you do the address is you do have to explain your methodology, right? Like how I determined I could cover this address, right? I don't understand. Sorry. I mean not to cut you off I've been absorbing all of this and I didn't realize it was that detailed, right? But I don't see how Any company no matter how big you are can possibly quantify all of that I mean, there's there's so much. This is wireless. We're talking about right. So there there's so many variables Um that are involved in in getting accurate data and it's only as good as you know You know your outputs only as good as what you put into it That's correct and that stuff is often, you know flawed as well. So I just don't see how anybody Can potentially keep up with this and yeah, it's just nuts Yeah, I would I would encourage people, you know, so it took them a while but we we submitted our Our methodology to the FCC to the the bdc group over there now and just said hey if if we Say we can determine, you know coverage at a certain place using this methodology Will that be acceptable and they came back and said, you know, yes, you know But watch out for this and this which, you know, we already knew but but You know, so so I would encourage anybody to You know to put that, you know into the help desk or whatever and just say, you know, can can I use this methodology? You know, is this going to get kicked back or am I going to get fined if I try to do it this way And just see what they say. I mean, you know, I I worry about people doing just kind of like I said And like you mentioned tosses even the propagation stuff that we have in this industry It's it's okay for, you know, putting maps online and and you know doing some, you know, go or no go type things for You know, if you're going to be doing a site survey or try to cut down on your site surveys I mean, it's adequate for that, but it's probably not adequate for this, right? I mean just the models are using the resolution of stuff and that's the other thing is they They want this data to be super accurate But they're only requiring Uh three arc second data in the models And so No, that's not. I mean, that's you know, that's like 100 meter data. That's their that's their minimum resolution, right? And that's terrible For propagation modeling. I mean, uh, you know, so It just it's kind of baffling because they're saying on one hand. Oh, yeah, it's got to be it's got to be super accurate You better be right. And on the other hand, they're they're only making you use data that's You know, that you know 100 beaters. That's a long way from where you're You know from where that point may be or whatever and and you know been that big I mean you could you could have coverage in one little part of that and it would still color that You know that that pixel on the map, right as long as you're within an acre of You know, yeah, yeah, that's what I'm saying. I mean, that's crazy. That's a crazy requirement or non requirement, I guess on that side, you know, so So I think it makes it really difficult because now they're saying, well, you said you said you could cover this Well, I just use 100 meter data in my propagation tool But oh, sorry, you know, it wasn't right. So, you know, even though you you thought you were doing it, right? You didn't so bam, you owe us 15 grand, right? so So it's uh, it's the conundrum For sure And uh, it's difficult to get in information out of them. You know, they're pretty slow to respond. I think it took I think it took me Something like 10 days to get a response about our methodology Yeah, I'm sure you asked a lot earlier like because when is the deadline of the deadline is what september 1st? That's correct. Yeah. So those last two weeks of august. Basically, I'm sure there's some absolutely hammers there Yeah, and that's you know, I would encourage people to Start start on this, you know, yesterday. I mean It's just I can't I can't stress enough like how difficult a process this is for Even people who know what they're doing with it and if you don't know what you're doing with it Waiting till the last minute is really not the right idea It's you know, if it's something you haven't ever dealt with before and you're trying to go out on your own, you know Get started now So what happens what happens if you don't file? It's 15,000. I mean if they if they know about you, right? I mean if you file the 477 Um, they know about you, right because they sent out emails to everybody Sorry a few months back saying okay, the fabric's ready, you know, get some sample data now And so you're familiar with it, right and you could go and get some sample files for your area Which of course they didn't change Uh all the IDs in for the live data So so the sample stuff was you know, I mean it really was sample stuff. It's worthless if you can't file with it. So um, but yeah, so Yeah, if you if you don't file, I'm sure they're gonna come after you So, I mean one approach maybe not necessarily a great idea is you just don't file and say I'm only going to take $1,500 l and not worry about all the other ones That's one way to look at it. I don't know. There may be a go to jail clause in there somewhere. So Yeah Yeah, you know, they talk about forfeitures and I think I think when they say that the forfeitures that that's the money Right $15,000. I I don't know, you know, ultimately what the um You know what the penalty is like if you get fined and don't pay. I mean, I'm pretty sure there's you know There's probably some kind of prosecution that can happen I don't know. I mean because this is kind of codified into law now It used to just be a regulation by the FCC, right the 477 But now that I think this is part of a law, you know, that was passed Um that they have to collect this data and so They can probably prosecute you now under that federal statute if you don't pay the fines Um, I don't know why you know, somebody would just want to pay 15 grand But uh, you know, it's a lot cheaper just to do it um, but but anyway, it's I guess it is up to the kind of the end You know the whisk at the end I know we've had several small guys come to us and just say man I don't know how I'm going to get this done and I don't really have the cash, you know to pay for it and stuff and um, you know, my opinion on the whole thing is that I think I've stated this before It's it's kind of really it's kind of really meant to favor the big carriers the big players and kind of push the small guys out Because the the regulatory burden and the financial burden that's going to be placed on them to get this done Well, and you know when if you're uh, you know an operator where you're primarily unlicensed everything Right at least unlicensed in mile We're not really, you know available to get into this bead fundings and stuff like that Like you it's offering, you know protection to say your area, you know If you've got a big gga build on cbrs, then yes, you're like, all right, this area is covered Here's the speeds, you know, this is a served area, right? And it would make a lot of sense to protect yourself from that case. But you know a five gig wisp out there You know in six and everything that comes down the road, you know, they're basically all the they're doing all this work And submitting all this information so they can not protect themselves from anything because they're still You know, it's an un-served area not eligible, right exactly. So yeah, that's uh The very sort of painful thing, you know, you would hope there would be some sort of clauses that allow for small business and definition levels and stuff like that because you know, this big government money is not really Chased and affected that heavily by, you know, some operator that's got, you know, 500, you know 500 subs or 1,000 subs or something like that You know, that's not the the numbers they're kind of gunning for from a coverage perspective at least Yeah, it seems to me that way the the logical way of thinking about this, but this is the government we're talking about so Yeah, it's uh, it's gonna be tough for the small guys and I feel for those guys You know, we were there at one point and and we certainly didn't have the all these regulatory things when we started, you know back in 2003 um, it was kind of, you know, what what is it? What was uh, what was it math that had the Wireless cowboys or was that rory? I guess maybe you know, somebody had the wireless cowboys blog for a while You know talking about all this stuff back in the day, you know, just how to make it work And I mean, you know, I mean shoot I designed my own antennas because you know when I started There nobody was making antennas for this industry, you know, and uh Yeah, so my partner who actually was an antenna designer He actually designed antennas for a good portion of the cellular industry He was a contract engineer and he designed antennas for people like decibel products and Catherine scala, you know, antenna products You know, so al and telecom all the big players back in the day He pretty much was their design engineer and so we actually sat in my garage with the what's called a slot line and a And a spectrum analyzer and waveform generator and a function generator and And uh drew things out on a Smith chart, you know to design antennas, you know So so, uh, yeah, so it was it was a lot of fun But but they worked really well, you know, we used them for years They were slotted waveguide and I did some horns. I think tosses has seen those before And um, yeah, so it was it was a lot of fun But but yeah, I mean, you know back in the day There just wasn't anything going and and here we are these, you know, these wireless operators You know providing services to people that nobody else would And you know, now they're just kind of like, oh, hey, you know, that was all great But you know, we're gonna we're just gonna squash you on the bottom of our shoe and Hopefully you come off as we walk along, you know, so It's kind of sad that, you know, the the federal government doesn't really recognize You know the efforts of of the the entrepreneurs out here, you know, doing this work and You know making it making it very difficult to uh to proceed So but uh, you know, hopefully we can provide some assistance for some people and and If they need it and and hopefully people Don't get the fines if they decide to Kind of go it alone and and make some mistakes, you know And I'm hoping they're a little forgiving on this first round, but They they may be looking to make some examples to I think like anything though, I mean, you know, the government tends to go after people who can pay, right? You can't get blood from a rock either, right? So so I I seriously doubt, uh, You know, they're going to be going after the the really small guy that can't afford to pay And I think it's the the medium-sized Upper ones that, you know have Some cash to burn and yeah, we'll probably be and that's if you know, we're we're saying here that, you know They're going to start targeting some people and make some examples. They're going to have to obviously they they already started doing it with calf and art off, right? We've heard about these I mean pennies on the dollar. I mean with these like $3,000 fines or something like that I mean, it hasn't been like, you know millions and millions of dollars, but uh Yeah, I mean it's gonna happen. It's it's it's it's that simple. I also think for some of the smaller guys Um, I mean, obviously they they don't want to get fined So if anything they have to do the minimal like you said just guarantee The ones that they know the the ones that they they the addresses they actually serve So yes, it won't protect you from a build out But at the same time, you know, even though it's free money, right? You there's still limited resources and people to do these things So as you know, I would imagine as a company that received all this money It's going to be like am I actually going to go and fight the fight Try and Overbuild this guy who's already there when I have money to go just and keep keep the government happy by building out the areas That truly are underserved. So I think it's going to be a while uh before You know these little guys or whatever, you know kind of get overbuilt So I think that yeah the best defense if you don't have the monies to at least file What you know, you can't so you don't get fined. You're done pretty simple process And if somebody's going to come and overbuild you with license that they're going to do it no matter what, right? So yeah, no, I I tend to agree with that and you know the fact that these guys are you know, having to be put in that situation where you know, they've got to just You know kind of describe what they already service You know that may be also a risky strategy as well You know, I was thinking about that a little bit and and if you do that and because you have to describe Again, if you use the address methodology, you know or submission You have to describe how you determined, right? And if you just put it like a little paragraph Well, I know because I already service these well, they may say well, that's not that's not within the spirit of You know the the filing I mean we want to know where you can service to you know the other places you can service And so, you know, I'm I'm a little bit worried that if you do that they may come back and say well, you didn't you didn't follow What we asked, you know, this is not where you do service. This is where you can service And you know I don't know. I mean, I don't know how strict they're going to get and I hope they don't On that you're going to stuff just because again that now that puts another burden on on these guys, you know Who thought they might get away with you know kind of Small effort and then all of a sudden they're coming back and saying no go back and do it right, you know Just uh, just increment the street address by one number, right? Yeah, I can serve 907 main street. I can also serve 908 So, you know, yeah, how far does that go out? Yeah, this is not legal advice anyone listening. Uh Well, we all know that that doesn't actually work, right? I mean True true in situations where this house is covered. This house is not the guy right next door is that no freaking way that's happening, right? So Yeah, um, yeah, unfortunately, I I wish it was that easy because you could just kind of cascade that along but But yeah, and the enforcement side of it again with the actual address data being just so janky to like it's hard to To do a full level enforcement So, you know, if as long as yeah, it seems to me as long as you're submitting what you can Following the letter of the law, but also more or less a spirit at least in the beginning, you know, it's like It's worth doing and like not getting yourself tied up in the full-blown panic, right? Because I mean it is going to be an iterative sort of stumble through process So, you know, don't think that if you can't totally, you know, do all this that it's the end of the world So yeah, and I think it's filing filing something is better than nothing like you said I mean, I'm sure the initial red flags will be do we have a 477 for this person? Yes, and do we have the new filings? No, that's a red flag It's almost like the irs and paying your taxes as long as you Pay something every year they see revenue coming in They look they look for the guy that all of a sudden stopped paying for a period of time like red flag What happened, you know, and so yeah Yeah, I I think that's probably the case too. That's going to be a big part of it I do know, you know in in the it seems like the last three years They've been stepping up more and more on the 477 enforcement to Not necessarily finding people, but I know It used to be you submitted the stuff and you never heard anything, right? And now they're coming back with I mean tiny little details within, you know in the filings So if you have a speed In your subscription file That's higher than the speeds in the deployment file like your max what you claim is your maximum They come back and say why you know, how are you delivering the speed when you don't claim that you can right? And then you have to explain to them. Well, it's the one-off situation And I've got a point-to-point link to this guy or I've got this or it got that And sometimes they say okay, we'll take that one out there or take those out if you're doing that We don't want them, you know, we want to see what you provide to everybody And sometimes they accept it and just say okay fine, you know, so I think it really depends on the whoever you get That's kind of you know, I've seen some guys get real picky about it Some of the guys that are sending out these emails and some people just say okay fine You know, we'll accept your explanation But but that's been coming down a lot harder in the last especially the last two years I've noticed there's been a lot of kickbacks on small little things like that, right? And and a lot of this comes from you know, the billing systems that that produce these files and and You know, this includes visp. I mean, there's no there's no Setting in these programs to say okay, here's the speed I'm selling versus the speed they're provisioning, right? And so when they create these subscription files, they use the provision speeds because that's really the only data they have It's not they don't have like a blank in there, you know in the in the form that says Oh, I'm selling 50 meg, right? And that's what I need to file in the fcc 477 They're you know, they just have the speeds that get provision which might be You know 50.5 because they want to over provision a little bit so when people constantly run the speed test They're seeing 50, right? So, uh, you know just to eliminate that overhead they might you know that gets lost in the speed test and stuff so So you get a lot of these files that come in subscription files and things like that from the billing systems that have these decimals Well, they don't want decimals anymore, right? If it's under if it's over 2 meg, they don't want to desk. They don't see any decimals And so if you have a decimal they kick it back, right? So So even though the the billing systems do a pretty good job on the subscription files Um, they're not they're not perfect And so those even have to be gone through now and you know, it used to be that you could file with three decimal points They didn't care now. Nope. No decimals. So, um, they kick it back and so So, yeah, it it's gotten more complex and and uh, definitely they're enforcing it more Um, you know, they're coming back with little tiny picky things and I think that's just they're kind of that was kind of the ramp up to Yeah, this new bdc stuff. So I anticipate they're going to get pretty picky and You know, I don't know that they have the staff to get super picky But uh, I think they're going to get a little bit and um, they're going to start kind of going through it So, uh, that's just been my experience on you know on the fcc side and um, you know, of course the deployment stuff almost all the billing systems do a terrible job with deployment because um, yeah, they don't have they don't have any kind of coverage built in to the programs, you know, so You're finding out other other than just blocks that you currently have service in which is kind of drastically underestimating You know your your area You know, if you file that okay, I mean that's you can certainly do that but um, I encourage people to take advantage of the fact that the 477 doesn't require necessarily You know good propagation. There's no model requirement or anything like that to get your coverage and where you can provide service. So I always I always told people yeah Be optimistic in your reporting on that because it does help keep government money away But uh, my strategy on bdc has changed a little bit. I'd say if anything be conservative You know with the bdc stuff because uh, you've got you've got the burden of proof now. So So and that's that it's a whole another thing kind of going back to the the pe side of things So pe professional engineer, uh anyone that's not really familiar with it, which is a legal Thing like it's a licensing done at the state level if I understand it correctly That's right. Um Yeah, when I graduated I looked at doing it very briefly and was like nope. I'm good. So this is One I don't I don't need my name out there in that many places but two like, you know, I was double e Right. So, you know for me, it just didn't make sense with where my career was headed, but So in that that conversation is basically, you know, the The government requiring some sort of official Or official sign-off on what this data and who is submitting it, right? So And as I understand it is basically a pe signs off on it or there is some level of uh, Executive sign-off is available based on having a certain level of experience, you know, 10 years 7 years So if you can kind of speak to that like The back and forth part of that conversation because I know it's something that y'all been involved with too And you know understanding what that means. Yeah, so they so they gave a waiver You do have to kind of apply for the waiver. It's just kind of like a one line thing that you say I'm applying for the waiver on the pe requirement And here is are my qualifications, right? So it has to be either a doubly With direct knowledge, right of your network design So This is not like a contract hire kind of thing. This is okay. I'm a doubly and I work for this company I helped design the network, right? And and you have to have at least seven years of experience in in wireless network design and so Or whatever network, right? I mean, this is you know, obviously The audience here is probably mostly wireless guys, but but you know, this goes this goes the same for, you know, fiber cable DSL, you know, satellite, whatever, right? This is all this all had they all have the same requirements and it's a little bit easier Those guys because obviously they know that their addresses and things like that because they pass them, right? They either pass them with a pole or they pass them underground and they can get service so that's really easy to do those but The wireless is much more complex unfortunately, but yeah, so so it has to be a guy that has doubly that has seven years of experience or another person with what they say has specialized training in this network design and has at least 10 years of experience and again, it's a direct knowledge thing as well. So You know, so if you've been in business 10 years and you designed your own network And hopefully you've taken some classes or something along the way where you can say I received some specialized training I mean, I'm not sure on the job training of you know, trial and error is is acceptable I mean, I I've listened to many webinars many webinars. I'm very well trained I'm very well versed in inside wireless Yeah videos it would probably be good to You know at least have some class that you've taken that you can say oh, yeah, I received some specialized training I mean, I don't I mean, that's their wording So who knows how strict they're going to be about specialized training or whatever that is but but that that's the wording and so So they've said it's like three the first three cycles. How long is the cycle? Is that a year? Is that a quarter? Yes, so for the next year and a half basically you have to figure this out So so next June or the you know filing due next September, you know of 2023 will be the last waiver period Now, who knows they may extend it. They may wipe out the requirement all together You know, who knows what they're going to do between now and then but you've got three at least for now You know unless unless they come back after this thing's over after the first filing and say Geez, we got a ton of idiots to file these things. So, you know, we're we're going to put the PE requirement back in So I don't know. I mean, who knows what they what they're going to do, right? They kind of change stuff on a whim So there's a lot of old retired PE's out there that are looking for side gigs. There's a bunch of wisps out there They're gonna want to hire you hire you on and do something with that I tried to get my former partner now. He's he's almost 90 So I try to get him to to come in and and you know, I said how long has your certification been You know gone and surprisingly, it's only been a couple years. I mean he kept it for a long time But you know, also to be a PE going back to what you said, Caleb It is a state licensed deal. So it's kind of like being a lawyer, right? You got to take the bar in your state and then get licensed by your state to practice law So it's kind of the same thing It's professional engineers licensed and so you take your PE the PE exam in that state to be able to practice You know engine professional engineering, I guess in that state, right? Now, you know, most states just like with lawyers like if you apply if you say, oh, you know, I'm working here temporarily You know, I'd like to You know be able to certify documents or drawings or whatever it is with your PE stamp A lot of states will just say, okay You know fine just fill out this form and pay your 25 bucks or whatever it is and yeah, we'll we'll allow you to stamp stuff in our state You know, but um, so You know, it's kind of the same thing But it is it is a difficult thing to get and uh, it's a difficult thing to keep There's an ongoing education requirement, right? So you have to do Continuing education every year so many hours of continuing education or it's just like any license Yeah, no an accountant. You have to do the same thing the lawyer. You have to do the same thing. So yeah Yeah, so so I mean, you know, these guys are experienced and they know their stuff I mean, it's not it's not an easy thing. I mean, I looked at the exam I like to go take it because I think they in a lot of states they have a waiver Uh, if you didn't take the EIT, you know, if you have so many years of experience You can still go take the PE exam, right But but man, I mean it it's intense. I mean the math stuff I haven't done that kind of math since college, you know, I mean, you know solving differential equations and things I mean, you know, I go back and review it But I'd probably have to study for a year before I go take the thing You know, it's it's like the tfa exam or something You know, everybody fails the second one or something like that and you go study for a year and come back and take it again, right? so Yeah, I don't I don't have that kind of mental bandwidth left anymore, so Yeah, it's just a little busy Right now You know, and it's it's a whole different beast, you know for for a structural PE to sign off on a tower design, right? Like the the load stresses and the wind loads like these are all you know, not simple But they're very well-defined, you know, how a PE signs off on the tower or a bridge Or, you know a power system, you know for some machine or whatever it may be You know for for a PE to sign off on this wireless system that might have 20 vendors worth of equipment in it, you know between the wireless the network side The mechanical side and everything else, you know, and this is kind of Nebulous thing, right? Especially when they're not following, you know, lte standards and stuff like even the The the full on standards-based stuff is hard enough. But now, you know with the the mix of equipment and everything else it's You know, it would be a tough proposition without someone who's not, you know, I'm a PE But you know, I do this on the side or, you know specifically focus on this particular niche Well, you know, it gets even harder For them because it's one thing if you You know and and like I said, I came from the cellular world where everything was documented down to the, you know decimal points, right and so You know, you knew exactly what was on every tower where what the antennas you were using how much coax was up there You know, what the sweep test looked like on that line I mean, I mean it was all very very well engineered and I think, you know We start people people are signing up with us and stuff right now and and You know, we have to get AP information. There's just no way around it We got to know what they're using transmit powers and tenets And it's really surprising how many guys don't know, you know, this stuff about their network and If if there's one benefit out of this whole thing, it's going to be Uh, that it gets people to engage in better, you know, network practices The whole global noise floor is about the drop 20db I mean, I I mean there's there's people who don't know what direction their antennas face and I'm not trying to you know, I'm not trying to disparage people. I mean they're doing, you know good work trying to get internet to people but, you know guys that that don't have a background in in engineering or or You know, any kind of even like manufacturing or anything like that that that are just trying to fill a need I'm not going to understand that it's it's a testament Really good testament to our most of the manufacturers out there that people can just throw this stuff up and it works as well as it does, you know I mean that that's pretty good because You know without having any engineering behind it You're just you popping something in the air and attaching some cables that you've never tested before Uh, you know, you're not you're not doing sweep tests to make sure that you're within Tolerance You're right. Yeah. Yeah, I mean or you made yourself, you know, yeah I think that up there with omnis. Yeah, right So and and you know, I mean omni almost be preferable to some of the stuff because you know At least at least you don't know I have to know the direction But you know, some of the some of the stuff you guys are coming in going. Well, I don't know I mean, I don't know how many I guess they know Somewhat how many antennas they have on a site, but they don't know what direction they face You know, they don't know if they have down tilt. They don't know what transmit the powers are on the radios Um, you know, it's not documented anywhere and that's that's to me. That's quite surprising You know, because I would I would never do that but Um, but I think it's going to force people into much better You know network practices, you know to figure out what's where You know, and I don't know how you get away with it for so long if you've got a large network You know, you're just going to kill yourself with interference if you don't know where you're facing with what frequencies and power outputs, you know So that may that may be some of the issues with Guys that are having trouble with speeds and things, you know, it's but um, but certainly It's got to be gathered and and It you know, if you don't have it, it's probably going to take you some time to go get it And uh, so start now Yeah, I mean think about all these these whiffs that I've you know grown and you know, they they got it figured out They're really cranking and they start buying these other smaller, you know competitors and stuff and a lot of times these bios They're you know, they're they're good to have the network documented like at all, right? So, you know now you've got to go back and force all those maintenance things to be like, hey We have to report this accurate. We have our new stuff But you know, we bought out jim bobs network a year and a half ago that kind of works. Okay And now they've got to basically fully Review and document everything with that. So it's going to be going to be honoris Well, I can tell you it makes, you know, just on the network documentation side It makes things really easy if you ever do want to sell So I'll tell you a little story about when we sold to jab, right? um they wanted to come in And spend a week like going to every tower site and looking over our stuff and everything Well, one of the things that we built into wispond and this was really pretty much for ourselves You know, we in fact when I built first started building wispond We never intended on selling it It was just a tool for internal use and then people started asking if they could buy it And we didn't even have billing in it at that point It was just a literally just you know, kind of a network management subscriber management tool So that we could, you know, see where everybody was and keep track of everything, you know It was basically our network documentation And so we would take pictures of everything and storm with you know, the data we had I mean every parameter of every single site, you know Every antenna every radio, you know, what we used when it was changed, you know when it was added, you know, whatever In in the system and I said, well, what do you guys want to know? I mean, I can I can give you access to this and we can generate reports on this They didn't even go look at one site When they came in and they saw that data was there available, you know They didn't go they say oh, we don't need to go if you got it all here and you got I mean we had pictures of you know our electrical boxes We had pictures of the cabling we had pictures of you know, the radios However, they were hooked to the antennas the front the back, you know What it looked like from the view on the tower, you know from the antenna, so So, I mean, I would encourage it and that's a lot of detail, but I know most of these systems can handle You know putting in that kind of data, you know Um, I would encourage people to start using You know, whether it's it's visper sonar power code or splinx or you know, any of the systems that are out there I'm pretty sure they all have ways that you can document your information And and add pictures and things like that. I would say go do that because it makes stuff like this A lot easier When it comes down to having to get that information, you know quickly You know, you know, and you never know, you know, you never know what the government's going to require of you Uh, you know for being in business these days, so It just it just makes sense plus like I said makes it a lot easier when you go to sell something It's a lot more impressive to a buyer to know that they're what they're getting into Then to uh, have to you know, kind of figure it out because I guarantee you if it's a mess They're going to come in and go yeah, we're going to drop the price, you know by half a million bucks or whatever 100 dollars a sub so So, yeah, it it's a good idea to get into that practice Yeah, I mean, you know data is king and it's never going to be like It's going to be less useful, right? And it seems that you know, it's painful as it be like the government's just going to continue sticking their Appendages Into this industry kind of more and more as they drive for this, you know, sort of utopian concept of universal coverage So it's you know document learn grow and you know, it's just it's going to be a part of it So but like you said, there's a ton of benefits that will behoove you in the grand scheme of things So don't think this is just for you know for the government. Oh, yeah This is there's there's you know, there's a little bit of a sweet side to that medicine at least Yeah, for sure. It uh, it can It can be advantageous in a number of ways So all right camera rule man, we could probably sit here and talk about this for a long time You know, there's just there's so many little interesting side paths and everything we could run down But you know, I think we've hit the main points, you know, again educating the folks out there differences 24 77 bdc The pe side the requirement side and what this really means for you in the real world and where it could be going So, you know to kind of wrap this up Do you any really closing remarks or you know anything you want to point particularly attention to you? Yeah I mean, you know, I've said it multiple times, but uh, this is Really important that that you get this in and and try to be as accurate as possible But the most important thing is right now just get it going I mean, don't wait on this because it is a lot of data that you have to collect. It's a lot of information Uh, the filing itself is a lot of data So yeah get get started, you know with with however you're going to get it done So that's that's my those are my words of advice right now Yep, don't don't sleep on this everybody. It's real and we've got to get it done so Uh for for the folks out there that are looking, uh, you know to get in contact with you camera You know, where can they find you? What's your contact your company? You know, we mentioned in the beginning regulatory solutions But you know a little bit about this the to put a find out on kind of the services that you offer Sure. Yeah, we can talk a little bit about that. So it's regulatory solutions dot us And uh, that's our website. Um, it's myself and brian webster and robert olive Brian's got a big background and you know, of course doing lots of network design and wireless mapping He runs another company called wireless mapping dot com Provides a lot of services for people doing you know design work regulatory work and things like that Just and one other thing I forgot to mention while we were talking earlier on the regulatory side a lot of financial institutions, right? I was talking to john scribner. Um, you know, and he's he's with a lending institution now and, um They require compliance, right? And so if you're borrowing money from people You've got to be in compliance and he was really excited about the fact that we could actually in fact We we worked to deal with him to put into our software Uh to allow third party allow communication with third party, you know people about your compliance, right? So they can go and put in like Address Yeah, so it allows us to share that information and not not detailed information just saying yes They filed and here's like the file summary or whatever, right? That's what we're sending out So he was very excited about that. Uh, so anyway back to what we do Right now we're focused mostly on fcc 477 and bdc filings We do the state stuff too. So like california You know cpuc or whatever out there has a requirement I think there's a couple other states that may be about to start requirements for state filings on this stuff too Uh, we'll be able to handle that we've had some requests about other things like, you know, 499s and um, you know And then certifications for like the art off stuff or the calf to certifications, you know people have to do Um, we can do that as well. We're not focused on it right now because there's such a time crunch Um, you know once we get past this filing date We can probably help people with that as well But right now we're kind of focused, you know all our time and effort on on getting the bdc stuff together And so uh, that's really what it is, you know, it's it is you know, kind of a kind of a side gig for us. Um, Just because we we all have other full-time jobs You know, like I said, i'm cto at visp right now as well and and um, but and we are doing just just fyi And I know there's only a couple of days. I'm looking at my date clock here Four days left five days left in the month. So, um, we are doing a an early bird special We might extend that another week or so But we're just trying to encourage people to get you know data to us if they're going to use us You know sign up get data to us now because it is a lot of data and Like our pe is only one guy right now. We have another guy that we're talking to so we may have two here, but um It you know, it takes a little while for him to do the the certification Right because he's going to go verify he's going to take a sampling Of addresses and run his own methodology on them and make sure that you know, it is what we say it is and so Um, it takes a little bit of time and and so he's only got so many hours in the day plus he does lots of other work So, um, you know, we we encourage people to get that stuff in and I would say Probably for any other vendors out there that are helping people with this You know, I'm guessing they want the data as soon as possible You know, I mean, I I know where we are with it and so It's you know, I'm sure everybody else is is kind of freaking out as well Like, you know, we got to get this stuff in because You man, you wait till the last week and we can't guarantee that we're going to get it done You know in time so all right. Well, that has been great information Cameron We really appreciate you taking the time to talk to us today Trying to educate folks out there the best we can yes one of the goals that we push on so It's been a great conversation Taso is anybody looking for us? Where can they find us? You can find us everywhere on social media You can find us on facebook on all the wisp type groups On instagram And you know, the best place is on our website rf elements dot com or on our forum rfe lab dot com All right. All right. Well next time until we talk to everybody out there, you'll be good out there Thanks. See you. All right. See you guys. Thanks