dissenting in part:
Over 250 people, many of whom had worked in the same factory for several decades, had their monthly pension payments cut by seventy-five percent — from $6.00 to $1.50 per month for each year of service— when their employer shut down the plant at which they were employed. They brought, a claim under the Employee Retirement Income Security Act (ERISA), a statute that was passed in order to avoid precisely the kind of tragedy recounted here. Although there is no question that the Pension Benefit Guaranty Corporation (PBGC) was statutorily authorized to extend coverage to the appellants, it rejected their claims. The majority upholds the PBGC’s decision as a reasonable exercise of its discretion under the statute. Because I believe that the PBGC did not, as it was required to do, construe the statute in light of its resounding remedial purpose, I dissent from the majority’s decision upholding the district court’s grant of summary judgment to the PBGC. I would remand to the district court to require the PBGC to give a persuasive explanation as to why its stingy construction of the statute comports with Congress’ explicitly generous purpose in making ERISA’s federal guarantees retroactively apply to plans terminated within the two months before the Act was passed.
As the Supreme Court has recognized, “[o]ne of Congress’ central purposes in enacting this complex legislation was to prevent the ‘great personal tragedy’ suffered by employees whose vested benefits are not paid when pension plans are terminated.” Nachman Corp. v. PBGC, 446 U.S. 359, 374-375, 100 S.Ct. 1723, 1732-1733, 64 L.Ed.2d 354 (1980) (footnote omitted).1 The most telling expression of ERISA’s broad remedial purpose was the extraordinary provision before us, retroactively guaranteeing the pension benefits of employees whose pension plans terminated as early as July 1, 1974, over two months before ERISA was enacted. “In order to provide prompt and effective protection for the employees concerned,”2 Congress decided “to afford the [PBGC] emergency authority to institute insurance protection on a ‘crash’ basis,”3 well before it could put into effect ERISA’s provisions for employer liability, reporting and other measures aimed at protecting the PBGC's financial integrity. As Senator Williams, chairman of the conference committee, explained to his colleagues, “[t]his was done in recognition of the fact that depressed economic conditions in certain regions created the possibility that a number of plans were in critical straits and were terminating or were likely to do so imminently.”4 The addition of such “window period” coverage demonstrates an inclination to come down on the side of generosity toward workers whose expectation of adequate retirement income has been devastated, casting a long and threatening shadow over their later years.
The statute provides that the PBGC shall pay benefits for certain plans that termi*849nated after June 30, 1974, and before September 2, 1974, the date of enactment, and that the PBGC shall determine whether a plan has terminated within the two month period “on the basis of the date on which benefits ceased to accrue or on any other reasonable basis consistent with the purposes of this subsection.” 29 U.S.C. § 1461(b). One member of the conference committee, which drafted the “window period” provision, explained that it would extend coverage to a plan much like that of these appellants. Representative Thompson thus recommended the bill to his colleagues in part as follows:
In my own district, the Roebling plant of the Colorado Fuel and Iron Co. was closed June 30 thereby thrusting almost 1,400 men and women into the ranks of the unemployed. Many of these employees had 30 to 35 years of service in the plant .... Although the plant ceased operation June 30, the pension plan for those employees continues in existence. The conference substitute covers all pension plant [sic] terminations of single employer plans occurring after July 1, 1974. Inasmuch as the Roebling pension plan was not terminated prior to July 1,1974, within the meaning of the term as used in the conference report, the plant and its employees are covered [by section 1461(b) ].5
Congress thus appears to have contemplated coverage under section 1461(b) of a plan for a plant in which no employees worked during the window period.
Even if one were to discount the significance of such remarks, however, the interpretation of ERISA “must be guided by the familiar canon of statutory construction that remedial legislation must be construed broadly to effectuate its purposes.” Tcher-epnin v. Knight, 389 U.S. 332, 336, 88 S.Ct. 548, 553, 19 L.Ed.2d 564 (1967). Accord Peyton v. Rowe, 391 U.S. 54, 65, 88 S.Ct. 1549, 1555, 20 L.Ed.2d 426 (1968); International Union, UAW v. Marshall, 584 F.2d 390, 396 (D.C.Cir.1978); National Automatic Laundry & Cleaning Council v. Schultz, 443 F.2d 689, 706 (D.C.Cir.1971). This court has gone even further and articulated “as a reasonable corollary” of this basic doctrine the principle “that when a petitioner under a government benefits program puts forward an interpretation of a legislative provision that is arguably consonant with the statutory language, he is at least entitled to a reasoned statement why the administrator will not adopt that interpretation.” UAW v. Marshall, 584 F.2d at 396.
In the UAW case we were required to determine whether the Secretary of Labor had properly construed a provision in the Trade Act of 1974, a primary purpose of which was to expand eligibility for “worker adjustment assistance” for employees displaced by increased competition from imports in their industry. Eligibility under the 1974 Act turned in part on whether increased competition from imports contributed importantly to the separation of a significant number of workers “in a firm or an appropriate subdivision thereof.” In the absence of any specific legislative history behind this clause, the Secretary had determined that the largest “appropriate subdivision” for the purposes of this provision was the individual plant. The UAW had argued for larger subunits, such as all the plants involved in production of a particular car model which would have expanded eligibility. It contended that the use of “an” before “appropriate subdivision” supported its interpretation that several subdivisions were possible and that “an appropriate subdivision” need not be the most appropriate subdivision. Finding the UAW’s interpretation plausible, this court remanded to the Secretary for an explanation of the circumstances that he believed mandated the choice of the plant as the appropriate subdivision in light of this duty “to choose a subdivision that best effectuates the purposes of the Trade Act.”
The UAW case is an application of the familiar principle that an agency’s interpretation of statutory language, which we or*850dinarily will uphold as long as it is reasonable, must be consistent with the purpose of the legislation. Where the language at issue is part of a novel and comprehensive remedial scheme like ERISA, the UAW case teaches that this principle has a sharper edge to it: If a putative beneficiary advances a plausible interpretation of the statute, the agency must at least give a rational explanation why its own more restrictive interpretation is nevertheless reasonable in light of the purpose of the legislation.6 I do not believe we have been given any satisfactory explanation by PBGC here as to why it rejected the appellants’ interpretation.
The PBGC, now backed by the majority, asserts that a countervailing legislative purpose — that of ensuring the financial integrity of the insurance fund and of keeping premiums low — justifies its niggardly construction of eligibility under section 1461. I find such a generalized economic justification wholly inadequate. First, every piece of remedial legislation that involves the disbursement of money has a secondary “purpose” of not disbursing too much money and thus endangering the program. In the UAW case itself, there was surely a legislative purpose to conserve funds for those whose jobs were most clearly affected by imports. But until the agency could demonstrate that this secondary purpose was actually undermined by the petitioner’s construction of the statute, it was governed instead by the overriding remedial purpose of affording coverage in cases that reasonably came within the statutory eligibility definition.
In this case, the PBGC has not attempted to demonstrate that the financial integrity of its insurance fund would be threatened or the employers’ premiums affected by a decision to cover the appellants’ pension benefits. Because of the unusual finite nature of “window period” claims, the PBGC concedes that a decision in favor of the appellants here would probably not affect a single other case. There are no floodgates; the window has already been closed for several years, precluding any substantial drain on ERISA’s funds.
The PBGC also concedes it has the statutory authority to extend coverage to these claimants under section 1461(b), since it is undisputed that benefits ceased to “accrue” during the window period. However, enveloping itself in the comfortable cloak of agency discretion, the PBGC has decided not to apply the simple and objective test of when benefits no longer accrue but rather to determine the eligibility of all “window period” claimants solely under the second statutory criterion, “any other reasonable basis consistent with the purposes of this subsection.” According to the PBGC, the statute’s use of the disjunctive “or” grants it the discretion to read out of the statute the “accrual of benefits” test and to apply the “any reasonable basis” test in every case. The majority agrees.
I disagree. The PBGC’s (and now the majority’s) interpretation of the statute renders meaningless the first and more objective “accrual of benefits” test. This, of course, violates “[t]he cardinal principle of statutory construction [which is] to save and not to destroy .. . [and] to give effect, if possible, to every clause and word of a statute.” United States v. Menasche, 348 U.S. 528, 538-39, 75 S.Ct. 513, 519-20, 99 L.Ed. 615 (1955). To avoid this result, appellants read the statute as granting the PBGC the discretion under the second test to expand coverage to some who would not qualify under the “accrual of benefits” test, but not the discretion to deny coverage *851where it would be authorized under the first test. Such an interpretation would give effect to every clause in the statute and would be far more consistent with the remedial purpose of ERISA and section 1461(b).7 This construction would also avoid the counterintuitive result reached by the PBGC in this case, where it concluded that a plan had terminated before benefits under the plan had “ceased to accrue.”
The PBGC achieves this result by deciding that section 1461(b) coverage does not extend to plans that, according to a balancing of all the factors under the “other reasonable basis” test, have “effectively” or “substantially” terminated before the “window period.” The PBGC thus appears to have read into section 1461(b) an additional stumbling block for claimants that would be unwarranted even if one accepted the PBGC’s argument that it has absolute discretion to choose the “any other reasonable basis” test for deciding when a plan “terminated.” Counsel for the PBGC at oral argument had difficulty saying that this plan had actually terminated before July 1,1974, but could say only that the process of plan termination had gone far enough to justify its conclusion that the plan had terminated.
In support thereof the majority and the PBGC emphasize the marginal nature of the accrual of benefits within the “window period.” Of course, anytime a statute sets out a clear bright line and objective criteria for placing cases on one side or another, it is almost inevitable that some cases will fall very close to the line. But it is an important virtue of clear and objective criteria that they provide a ready way to resolve those close cases. The PBGC would abandon the clear line suggested by Congress for a balancing of all the relevant factors, a method of decisionmaking that maximizes its own discretion. It would further expand its discretion by permitting exclusion of plans that have substantially terminated (but not yet actually terminated). I do not believe that the “plain language” of section 1461(b) vests so much discretion in the PBGC.
In my view, the PBGC has squeezed every last drop of agency discretion it could extract — and some it rightly couldn’t — from a few words of a statutory scheme intended to remedy the disastrous consequences of pension plan collapse, and thus drowned the only hope these 250 individuals had of restoring a measure of retirement security. I cannot approve this result as a reasonable one based on a reasonable construction of section 1461(b) of ERISA. I therefore respectfully dissent.
. The legislative history, reprinted in Sub-comm. on Labor, Senate Comm, on Labor and Public Welfare, 94th Cong., 2d Sess., Legislative History of the Employee Retirement Income Security Act of 1974 (1976) [hereinafter cited as “Legislative History”], is replete with tragic stories like that before us. See, e.g., 3 Legislative History at 4665 (statement of Rep. Thompson); id. at 4694 (remarks of Rep. Brademas); id. at 4712-13 (remarks of Rep. Ford); id. at 4716-17 (remarks of Rep. Daniels); id. at 4749-50 (remarks of Sen. Javits); id. at 4792-94 (remarks of Sen. Bentsen).
. Id. at 4678 (statement of Rep. Ullman introducing and explaining conference committee report and changes).
. Id. at 4766 (remarks of Sen. Williams, conference committee chairman, explaining committee bill).
. Id.
. Id. at 4665.
. This does not mean, of course, that the agen- . cy must accept the interpretation that will result in eligibility for the largest number of persons. In the UAW case after remand, for example, we upheld the Secretary’s decision to use the individual plant as the largest appropriate subdivision after he demonstrated that any larger subdivision would result in a windfall to large numbers of workers whose jobs had not been significantly affected by competition from imports. International Union, UAW v. Marshall, 627 F.2d 559 (D.C.Cir.1980). The UAW case means simply that the reasonableness of an agency’s statutory interpretation, and of its rejection of another more generous and fully plausible interpretation, must be evaluated in light of the statute’s broad remedial purpose.
. Such an interpretation would also be consistent with Representative Thompson’s expectation that the Roebling plan would be covered by section 1461(b). See supra p. 849.