30 “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. v. Surface Transportation Board, 584 F.3d 1076, 1081 (D.C. Cir. 2009). The Commission’s NPRM satisfied this standard. Although the NPRM did say that the Commission was considering relying on section 706, it also “expressly asked for comments” on whether the Commission should reclassify broadband: “[w]e seek comment on whether the Commission should rely on its authority under Title II of the Communications Act, including . . . whether we should revisit the Commission’s classification of broadband Internet access service as an information service . . . .” NPRM, 29 FCC Rcd. at 5612 ¶ 148 (footnote omitted). US Telecom’s second complaint—that the NPRM failed to provide a meaningful opportunity to comment on the Commission’s reliance on consumer perception—is equally without merit. In Brand X, the Supreme Court explained that classification under the Communications Act turns on “what the consumer perceives to be the . . . finished product.” 545 U.S. at 990. Given this, and given that the NPRM expressly stated that the Commission was considering reclassifying broadband as a telecommunications service, interested parties could “comment meaningfully” on the possibility that the Commission would follow Brand X and look to consumer perception. Brand X also provides the answer to US Telecom’s complaint about the telecommunications management exception. In Brand X, the Court made clear that to reclassify broadband as a telecommunications service, the Commission would need to conclude that the telecommunications component of broadband was “functionally separate” from the