4 I I agree with the majority that the Commission’s reclassification of broadband internet as a telecommunications service may not run afoul of any statutory dictate in the Telecommunications Act. But in changing its interpretation, the Commission failed to meet the modest requirements of Fox Television. Fox states that an agency switching policy must as always “show that there are good reasons for the new policy.” 556 U.S. at 515. But in special circumstances more is required. An “agency need not always provide a more detailed justification than what would suffice for a new policy created on a blank slate. [But s]ometimes it must—when, for example, its new policy rests upon factual findings that contradict those which underlay its prior policy; or when its prior policy has engendered serious reliance interests that must be taken into account.” Id. Here the Commission justifies its decision on two bases: changed facts and a new policy judgment. To the extent it rests on new facts, Fox requires us to examine whether there is really anything new. Fox also, of course, requires us to consider reliance interests, regardless of what the Commission has said about them. Thus novel facts and reliance interests are plainly at issue. The Commission also argues that its policy change would be reasonable even if the facts had not changed. Order ¶ 360 n.993 (“[W]e clarify that, even assuming, arguendo, that the facts regarding how [broadband] is offered had not changed, in now applying the Act’s definitions to these facts, we find that the provision of [broadband] is best understood as a telecommunications service, as discussed [elsewhere] . . . and disavow our prior interpretations to the extent they held otherwise.”). In sum then, at a minimum, we must inquire whether the Commission