53 Commission “tentatively conclude[d] that [it] should maintain this approach, . . . [the NPRM sought] comment on whether [the Commission] should change [its] conclusion.” Id. US Telecom insists that the NPRM was nonetheless inadequate because it nowhere suggested that the Commission might justify regulating interconnection arrangements under Title II on the basis that they are a component of the offering of telecommunications to end users. Under the APA, an NPRM provides adequate notice as long as it reveals the “substance of the proposed rule or a description of the subjects and issues involved.” 5 U.S.C. § 553(b)(3). An NPRM does so if it “provide[s] sufficient factual detail and rationale for the rule to permit interested parties to comment meaningfully.” Honeywell International, Inc., 372 F.3d at 445 (internal quotation marks omitted). Again, the NPRM did just that. It asked whether the Commission should expand its reach beyond “a broadband provider’s use of its own network” in order to “ensure that a broadband provider would not be able to evade our open Internet rules by engaging in traffic exchange practices.” NPRM, 29 FCC Rcd. at 5582 ¶ 59. By focusing on the threat that broadband providers might block edge provider access to end users at an earlier point in the transmission pathway, the NPRM allowed interested parties to comment meaningfully on the possibility that the Commission would consider interconnection arrangements to be part of the offering of telecommunications to end users. Indeed, interested parties interpreted the NPRM as presenting just that possibility. To take one example, COMPTEL explained in its comments that “as feared by the Commission in its [NPRM], a [broadband] provider can simply evade the Commission’s 2010 rules by moving its demand for an access fee upstream to the entry point to the [broadband provider’s network].” Letter from Markham C. Erickson, Counsel to COMPTEL, to Marlene H. Dortch,