text: What makes this volta face all the moreunexpected is that BACT standards, which apply to individual facilities on a case-by-case basis, are generally more stringent than NSPS, which set minimum emission control standards forcategories of industrialsources. In regulatory parlance, NSPS providethefloor for BACT determinations. If the EPA would not useBACT to require fuel switching,then it would seem unreasonable even paranoid to suspect the EPA of planning to useNSPS for that purpose.