Investor Presentaiton

39 (a)(1)," asserting that these provisions describe “distinct steps" with different actors. JA.106. But while only EPA identifies a "best system,” Section 111(a)(1) defines "standards of performance"-and under Sections 111(b) and (d), EPA and the States set those. This interplay makes Sections 111(a)(1), (b), and (d) quintessential examples of "interlocking language and structure." Guam, 141 S. Ct. at 1613. More generally, courts routinely interpret definitions along with their statute's operative provisions, see Cyan, 138 S. Ct. at 1071, especially when "mechanical" constructions of a definition would create "incongruities" in how the statute operates, Lawson v. Suwannee Fruit & S.S. Co., 336 U.S. 198, 200-01 (1949). UARG rejected an earlier attempt to expand EPA's powers through a CAA definitional provision based on how the definition operates in practice. See 573 U.S. at 316. The same principle counsels the same result here. Starting with "source," Section 111 makes plain that standards of performance are individual targets, which in turn makes it hard to interpret "best system" (an essential input to those standards) apart from anything a particular source could achieve. Consistent with EPA's national mandate, Section 111(b) directs the agency to list categories of "sources" and issue performance standards for the "new sources" within each category. 42 U.S.C. § 7411(b)(1). In contrast, Section 111(d) starts and ends with "source" in the singular: States establish standards "for any existing source," and may consider factors specific to “the existing source” when applying them. Id. § 7411(d)(1). If the majority is right, though, then Section 111(d) becomes just another way to regulate groups or categories of sources. Congress' choice of singular and plural carries weight. Niz-Chavez, 141 S. Ct. at 1482. The

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