46 competition the touchstone for refusal to apply Title II.” Concurring & Dissenting Op. at 12. All of those cases, however, predate the 1996 Telecommunications Act, which established the statutory test that Brand X considered and that we apply here. US Telecom raises a distinct arbitrary and capricious argument. It contends that the Commission needed to satisfy a heightened standard for justifying its reclassification. As US Telecom points out, the Supreme Court has held that “the APA requires an agency to provide more substantial justification when ‘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.’” Perez v. Mortgage Bankers Ass’n, 135 S. Ct. 1199, 1209 (2015) (quoting Fox Television, 556 U.S. at 515). “[I]t is not that further justification is demanded by the mere fact of policy change[,] but that a reasoned explanation is needed for disregarding facts and circumstances that underlay or were engendered by the prior policy.” Fox Television, 556 U.S. at 515–16. Put another way, “[i]t would be arbitrary and capricious to ignore such matters.” Id. at 515. US Telecom believes that the Commission failed to satisfy the heightened standard because it departed from factual findings it made regarding consumer perception in its 2002 Cable Broadband Order without pointing to any changes in how consumers actually view broadband. According to US Telecom, even in 2002, when the Commission classified broadband as an information service, consumers used broadband primarily as a means to access third-party content and broadband providers marketed their services based on speed. As we have explained, however, although in 2002 the Commission found that consumers perceived an integrated