52 “simply derivative of” the service offered to end users. Id. at 5748–49 ¶ 339. As a result, the Commission concluded that it could regulate interconnection arrangements under Title II as a component of broadband service. Id. at 5686 ¶ 195. It refrained, however, from applying the General Conduct Rule or any of the bright-line rules to interconnection arrangements because, given that it “lack[ed] [a] background in practices addressing Internet traffic exchange,” it would be “premature to adopt prescriptive rules to address any problems that have arisen or may arise.” Id. at 5692–93 ¶ 202. Rather, it explained that interconnection disputes would be evaluated on a case-by-case basis under sections 201, 202, and 208 of the Communications Act. See id. at 5686–87 ¶ 195. US Telecom presents two challenges to the Commission’s decision to regulate interconnection arrangements under Title II, one procedural and one substantive. We reject both. Echoing its arguments with respect to reclassification, US Telecom first claims that the NPRM provided inadequate notice that the Commission would regulate interconnection arrangements under Title II. As we noted above, an NPRM satisfies APA notice obligations when it “expressly ask[s] for comments on a particular issue or otherwise ma[kes] clear that the agency [is] contemplating a particular change.” CSX Transportation, Inc., 584 F.3d at 1081. The NPRM did just that. It expressly asked whether the Commission should apply its new rules—rules which it had signaled might depend upon Title II reclassification, NPRM, 29 FCC Rcd. at 5612 ¶ 148—to interconnection arrangements. The NPRM explained that the 2010 Open Internet Order had applied only “to a broadband provider’s use of its own network . . . but [had] not appl[ied] . . . to the exchange of traffic between networks.” NPRM, 29 FCC Rcd. at 5582 ¶ 59. Although the