91 507–08 (D.C. Cir. 2003), under which “the agency must examine the relevant data and articulate a satisfactory explanation for its action including a rational connection between the facts found and the choice made,” State Farm, 463 U.S. at 43 (internal quotation marks omitted). We have applied this standard to section 10 forbearance decisions and have “consistently deferred to [such decisions], except in cases where the Commission deviated without explanation from its past decisions or did not discuss section 10’s criteria at all.” Verizon v. FCC, 770 F.3d 961, 969 (D.C. Cir. 2014) (internal citations omitted). In the Order, the Commission identified two bases for forbearing from sections 251 and 252. First, it considered evidence from commenters who argued that “last-mile unbundling requirements . . . led to depressed investment in the European broadband marketplace.” 2015 Open Internet Order, 30 FCC Rcd. at 5796 ¶ 417. Those commenters identified several studies suggesting that mandatory unbundling had reduced investment in broadband infrastructure in Europe relative to the United States. See Letter from Maggie McCready, Verizon, to Marlene H. Dortch, FCC, GN Dkt. Nos. 14-28 & 10-127 (Jan. 26, 2015); Letter from Kathryn Zachem, Comcast, to Marlene H. Dortch, FCC, GN Dkt. Nos. 14-28 & 10-127, at 5–7 (Dec. 24, 2014) (identifying Martin H. Thelle & Bruno Basalisco, Copenhagen Economics, How Europe Can Catch Up With the US: A Contrast of Two Contrary Broadband Models (2013)); Letter from Christopher S. Yoo to Marlene H. Dortch, FCC, GN Dkt. Nos. 14-28, 10-127, 09-191 (June 10, 2014). The Commission reasoned that its decision to forbear from section 251’s unbundling requirement, in combination with regulation under other provisions of Title II, would avoid similar problems and encourage further deployment because the scheme “establishes the regulatory predictability needed by