Remember the Where’s Waldo books? To jog your memory, they’re the ones that challenge “readers” to find a lanky, bespectacled kid in a red striped shirt amongst a busy page of images.

Well, a similar search for broadband is on, but here’s the twist: Unlike the Where’s Waldo books, the FCC (News - Alert) keeps changing instructions about what to look for.

You see, the FCC recently was calling broadband anything 200kbps and above, which as we probably can all agree is ridiculously low. So the commission revised that upward to define broadband as starting at 4mbps downstream and 1mbps upstream. Good news, right? Well, maybe. But there are few problems with this new definition, as well as of the FCC’s timing in making this pronouncement.

First, the commission upped the broadband ante within its latest broadband deployment report, which it made public in July, that said “…between 14 and 24 million Americans still lack access to broadband, and the immediate prospects for deployment to them are bleak.” Whether or not this was the FCC’s true intention, heightening the broadband bar at this particular point in time looks as if it could be an effort to gin up the country’s digital divide.

As TMCnet’s Gary Kim (News - Alert) recently wrote, redefining broadband also creates some new questions and problems given international telecom bodies have for years defined 1.5mbps and above as broadband, 1.5mbps to 64kbps as wideband, and 64kbps and below as narrowband.

Indeed, with this new broadband definition, he notes, “we now have a set of data collection practices and definitions that instantly make all third-generation wireless broadband networks, and all small business T1 services, ‘not broadband,’ by definition.” And that could be a major business factor if wireless providers are, for example, not allowed to bid for universal service funds, which require a 4mbps threshold, he continues.

Kim goes on to say that by redefining broadband, the FCC is able to support its claim that "broadband is not being deployed to all Americans in a reasonable and timely fashion."

But, he concludes, it is a bit disingenuous to set a 4mbps standard, claim the country has a gap, and not qualify that statement at all times by saying the claim applies only to fixed terrestrial connections, not to mobile or satellite services.

To the commission’s credit, however, it is attempting to adapt to the ever-changing environment that is communications technology, and it seems to working diligently to fix some significant problems with past broadband accounting, as FCC Commissioner Michael J. Copps (News - Alert) notes in the following quote.

“At last—a section 706 Report where broadband is really broadband, where zip codes are not surrogates for subscribers, and where the documented failure to connect millions upon millions of Americans disproves previous FCC findings that broadband is being reasonably and timely deployed. I am pleased to support the Broadband Deployment Report that we issue today. 

“By relying on an inadequate and unrefined approach to data collection for the previous five reports, the commission seriously defaulted on its statutory responsibility. Going down the same old path here would have done a further injustice to this country’s reinvigorated commitment to broadband. In early data collection exercises, the commission used information from service providers that simply reported on which zip codes had at least one subscriber to broadband service at a speed of 200 kbps or higher. I still fail to see how anyone ever viewed this approach as indicative of anything useful. The false impression left by that approach was that everyone in a zip code was fully connected to high-speed broadband when all we really knew was that one person or business somewhere – perhaps on the very fringe of a zip code – subscribed to a minimum-speed service. That told us nothing about the extent to which broadband was available within a zip code or the quality of that service. …

“Good data is a prerequisite to good policy choices. The five preceding reports lacked such data and the results were … poor policy choices. This is even clearer now than it was at the time of those reports, given the depth of data we that has been mined as part of the lengthy, fact-driven process that resulted in the National Broadband Plan, including input collected from the newly-revised FCC Form 477 requiring providers to report broadband subscribership by Census Tract instead of zip code.”