Section 706 of the Telecommunications Act of 1996 requires that the FCC annually review broadband availability in the country. Further, that section of law then requires the FCC to take immediate action if they find that broadband is not being deployed fast enough. This is the law that in the past prompted the FCC to set a definition of broadband – first set at 4/1 Mbps a decade ago then updated to 25/3 Mbps in 2015. The FCC felt it couldn’t measure broadband deployment without a benchmark.

In this year’s annual proceeding the FCC has suggested a change in the definition of broadband. They are suggesting there should be a minimum benchmark of 10/1 Mbps used to define cellular broadband. That doesn’t sound like a bad idea since almost everybody uses cellular broadband at times and it would be good to know that the cellular companies have a speed target to shoot for.

But I am alarmed at how the FCC wants to use the new proposed cellular broadband standard. They are suggesting that cellular service that meets the 10/1 Mbps standard can be considered as a substitute for a landline broadband connection that meets the 25/3 Mbps test. This would represent a huge policy shift at the FCC because use of the cellular standard would allow them to claim that most Americans can get broadband. And that would eliminate them having to take any action to make broadband better in the country.

We can’t be particularly surprised by this shift in policy because now-Chairman Ajit Pai vociferously objected when the FCC increased the definition of broadband in January 2015 to 25/3 Mbps. He argued at the time that the speed definition of broadband should not be increased and that both satellite and cellular broadband ought to be considered as substitutes for landline broadband.

But as almost anybody with a broadband connection can tell you, speed is not the only parameter that matters with a broadband connection. Speed matters for folks in a busy broadband home like mine when different family members are trying to make simultaneous broadband connections. But even homes with lower broadband needs care about more than speed. The limiting factor with cellular data is the stingy amount of total downloads allowed in a month. The new ‘unlimited’ cellular plans are capped at 20 to 25 gigabytes per month. And satellite data not only has stingy data caps but also suffers from latency issues that means that a satellite customer can’t take part in any real-time activity on the web such as VoIP, distance learning or live streaming video.

There are several possible motives for this policy shift. First, this could just be an attempt by the FCC to take off the pressure of having to promote faster broadband everywhere. If their annual Section 706 examination concludes that most people in the country have broadband then they don’t have to push expensive federal programs to expand broadband coverage. But there is also the potential motive that this has been prompted by the cellular companies that want even more federal money to expand their rural cellular networks. AT&T has already been given billions in the CAF II proceeding to largely improve rural cellular towers.

Regardless of the motivation this would be a terrible policy shift. It would directly harm two huge groups of people – rural America and the many urban pockets without good broadband. This ruling would immediately mean that all urban areas would be considered to have broadband today along with a lot of rural America.

I don’t think this FCC has any concept of what it’s like living in rural America. There are already millions of households that already use cellular or satellite broadband. I’ve heard countless stories from households with schoolkids who spend upwards of $500 per month for cellular broadband – and even at that price these homes closely monitor and curtail broadband usage.

There are also huge swaths of rural America that barely have cellular voice service let alone 10/1 Mbps cellular broadband. I was recently in north-central Washington state and drove for over an hour with zero AT&T cell coverage. But even where there is cellular voice service the quality of broadband diminishes with distance from a cell tower. People living close by a tower might get okay cellular data speeds, but those even just a few miles away get greatly diminished broadband.

I know that Chairman Pai has two kids at home in Arlington Virginia. There he surely has fast broadband available from Comcast, and if he’s lucky he also has a second fast alternative from Verizon FiOS. Before the Chairman decides that cellular broadband ought to be a substitute for a landline connection I would challenge him to cut off his home broadband connection and use only cellular service for a few months. That would give him a taste of what it’s like living in rural America.