​On September 11, 2023, NRECA filed reply comments with the Federal Communications Commission supporting the extension of a waiver of the requirement that Broadband Data Collection (BDC) submissions be certified by a state-licensed professional engineer (PE). Requiring a PE certification creates a significant hardship for smaller ISPs. In addition, NRECA recommended that the waiver only be extended for ISPs with less than 100,000 subscribers. Further, the Commission should continue to implement other measures to improve the accuracy of BDC data. NRECA suggests that the Commission should focus on periodic audits, along with increased scrutiny of ISPs with high rates of inaccuracy. Increased monitoring by the Commission, followed by prompt and direct enforcement against bad actors, will be far more effective in ensuring BDC accuracy than relying on assurances associated with a certified PE stamp.