Why the BTOP/BIP NOFA definition of broadband is inadequate

On Wednesday NTIA and RUS released their long-awaited, eagerly anticipated Notice of Funds Availability (NOFA) for the BTOP and BIP programs, respectively, which aim to spur the deployment of broadband through making available billions in grants and loans.

While there's lots to be discussed about what's contained herein, I want to start with the part of this that's already drawing the most ridicule: how they define broadband...