21 broadband. The positive effect is expected from the way in which, in the Commission’s eyes, the new rules encourage demand for and supply of content, which it believes will indirectly spur demand for and investment in broadband access. The direct effect, of which the Commission doesn’t really speak, seems unequivocally negative, as petitioner United States Telecom Association (“USTA”) argues. USTA Pet’rs’ Br. 4 (“Individually and collectively, these rules will undermine future investment by large and small broadband providers, to the detriment of consumers.”); see also id. 54. Besides imposing the usual costs of regulatory compliance, the Order increases uncertainty in policy, which both reason and the most recent rigorous econometric evidence suggest reduce investment. Scott R. Baker, Nicholas Bloom & Steven J. Davis, Measuring Economic Policy Uncertainty, 131 QUARTERLY JOURNAL OF ECONOMICS (forthcoming 2016). (Though the paper is focused on economy-wide policy uncertainty and effects, it is hard to see why the linkage shown would not apply in an industry-specific setting.) In fact, the Order itself acknowledges that vague rules threaten to “stymie” innovation, Order ¶ 138, but then proceeds to adopt vague rules. Here, a major source of uncertainty is the Internet Conduct Standard, which forbids broadband providers to “unreasonably interfere with or unreasonably disadvantage” consumer access to internet content. 47 C.F.R. § 8.11. All of these terms—“unreasonably,” “interfere,” and “disadvantage”—are vague ones that increase uncertainty for regulated parties. Indeed, the FCC itself is uncertain what the policy means, as indicated by the FCC Chairman’s admission that even he “do[esn’t] really know” what conduct is proscribed. February 26, 2015 Press Conference, available at http://goo.gl/oiPX2M (165:30-166:54). The Commission