27 understandings. Although the Order provides for the possibility of waiver, it cautions, “An applicant seeking waiver relief under this rule faces a high bar. We anticipate granting such relief only in exceptional cases.” Order ¶ 132. Second, in a case discussing the terms “unjust” and “unreasonable” as used in § 201(b) and in its fraternal twin § 202(a), we said that those words “open[] a rather large area for the free play of agency discretion.” Orloff v. FCC, 352 F.3d 415, 420 (D.C. Cir. 2003); see also Global Crossing Telecomms., Inc. v. Metrophones Telecomms., Inc., 550 U.S. 45 (2007) (recognizing the Commission’s broad authority to define “unreasonable practice[s]” under § 201(b)). But “large” is not infinite. Third, in the order under review in Orloff the Commission focused on § 202 but mentioned § 201. We summarized it as holding that “if a practice is just and reasonable under § 202, it must also be just and reasonable under § 201.” Orloff, 352 F.3d at 418 (citing Orloff v. Vodafone AirTouch Licenses LLC d/b/a Verizon Wireless, 17 F.C.C. Rcd. 8987, 8999 (2002) (“Defendants . . . offer[] the same defenses to the section 201(b) claim as they do to the section 202(a) claim. We reject Orloff’s section 201(b) claim. As noted, section 201(b) declares unlawful only ‘unjust or unreasonable’ common-carrier practices. For the reasons discussed [regarding section 202(a)], we find Defendants’ concessions practices to be reasonable.”)). Fourth, the Commission (at least for the moment) allows ISPs to provide consumers differing levels of service at differing prices. As it says in its brief, “The Order does not regulate rates—for example, broadband providers can (and some do) reasonably charge consumers more for faster service or more data.” Commission Br. 133. The statement is true (for now) vis-à-vis rates to consumers. But the ban on paid