29 none has merit, we uphold the classification. Significantly, although our colleague believes that the Commission acted arbitrarily and capriciously when it reclassified broadband, he agrees that the Commission has statutory authority to classify broadband as a telecommunications service. Concurring & Dissenting Op. at 10. A. Before addressing petitioners’ substantive challenges to the Commission’s reclassification of broadband service, we must consider two procedural arguments, both offered by US Telecom. First, US Telecom asserts that the Commission violated section 553 of the Administrative Procedure Act, which requires that an NPRM “include . . . either the terms or substance of the proposed rule or a description of the subjects and issues involved.” 5 U.S.C. § 553(b)(3). According to US Telecom, the Commission violated this requirement because the NPRM proposed relying on section 706, not Title II; never explained that the Commission would justify reclassification based on consumer perception; and failed to signal that it would rely on the telecommunications management exception. Under the APA, an NPRM must “provide sufficient factual detail and rationale for the rule to permit interested parties to comment meaningfully.” Honeywell International, Inc. v. EPA, 372 F.3d 441, 445 (D.C. Cir. 2004) (internal quotation marks omitted). The final rule, however, “need not be the one proposed in the NPRM.” Agape Church, Inc. v. FCC, 738 F.3d 397, 411 (D.C. Cir. 2013). Instead, it “need only be a ‘logical outgrowth’ of its notice.” Covad Communications Co. v. FCC, 450 F.3d 528, 548 (D.C. Cir. 2006). An NPRM satisfies the logical outgrowth test if it