the ability of available technologies to ... meet a given discharge standard.” Id. EPA chose not to do so because the SAB “did not specify a timetable for that complex endeavor or suggest that is was possible to complete such an analysis in time to inform the impending VGP.” EPA Br. at 58-59. We do not find that answer compelling. There is no impediment to engaging in further study, and further study may advance the goals of the CWA. Thus, EPA could have well found that onshore treatment was “available.” Indeed, EPA’s failure to consider onshore treatment is inconsistent with the CWA’s mandate that TBELs be technology-forcing. Congress designed the CWA to force agencies and permittees to adopt technologies that achieve the greatest reductions in pollutants. See NRDC, 822 F.2d at 124 (<HOLDING>). As Judge Starr noted in NRDC, “the most
holding that cwa seeks not only to stimulate but to press development of new more efficient and effective technologies which is the essential purpose of this series of progressively more demanding technologybased standards holding that the standard for withholding of removal is more demanding than the standard for asylum holding that the more transformative the new work the more likely the use of the old work is a fair one holding that more than notice to a defendant is required holding the aedpa standard is demanding but not insatiable