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Opinion of the Court
Id., at 208. This justification, however, hardly meets ADEC's own standard of a "source-specific . . . economic impac[t] which demonstrate[s] [SCR] to be inappropriate as BACT." Id., at 177. In short, as the Ninth Circuit determined, EPA validly issued stop orders because ADEC's BACT designation simply did not qualify as reasonable in light of the statutory guides.
In its briefs to this Court, ADEC nonetheless justifies its selection of Low NOx as BACT for MG-17 on the ground that lower aggregate emissions would result from Cominco's "agree[ment] to install Low NOx on all its generators." Brief for Petitioner 42, and n. 12 (emphasis added); id., at 29; Reply Brief for Petitioner 19, n. 16. We need not dwell on ADEC's attempt to resurrect Cominco's emissions-offsetting suggestion, see supra, at 477, adopted in the initial May 1999 draft permit, but thereafter dropped. As ADEC acknowledges, the final PSD permit did not offset MG-17's emissions against those of the mine's six existing generators, installations that were not subject to BACT. Brief for Petitioner 42, n. 12; App. 149. ADEC recognized in September and December 1999 that a State may treat emissions from several pollutant sources as falling under one "bubble" 19 for
PSD permit purposes only if every pollutant source so aggregated is "part of the permit action." Id., at 111, 199. Off-setting new emissions against those from any of the mine's other generators, ADEC agreed, "[was] not a consideration of the BACT review provided for by the applicable law or guidelines," for those generators remained outside the permit's compass. Id., at 112, 199. ADEC plainly did not, and could not, base its December 10, 1999, permit and technical analysis on an emissions-offsetting rationale drawing in gen-19 Cf. Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc., 467 U. S. 837, 853-859 (1984) (upholding EPA regulations allowing States to treat all pollutant-emitting devices within the same stationary source in a nonattainment area as though encased in a single "bubble").
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