dissenting, with whom Judges McKEE, AMBRO, and BECKER join.
An applicant for asylum seeks to avoid removal to a country where he insists he will be the victim of persecution. In recognition of the serious consequences of an erroneous denial of asylum, Congress, in the INA, has given asylum seekers the right to present evidence to an immigra*267tion judge (“U”), 8 U.S.C. § 1229a (2002),1 the right to an administrative appeal of an adverse decision to the Board of Immigration Appeals (“BIA”), 8 U.S.C. § 1229a(c)(4),2 and the right to judicial review by a Court of Appeals of a final agency order denying asylum and directing removal. 8 U.S.C. § 1252 (2002).3
The Attorney General’s streamlining regulations direct a single BIA member to make the final decision on whether a denial of asylum is the “correct” decision, 8 C.F.R. § 1003.1(a)(7)® (2002), and then instructs the Court of Appeals to review the IJ’s explanation for his or her disposition4 — an explanation that the BIA member expressly declines to adopt. 8 C.F.R. § 1003.1(a)(7)(iii).5 By thus severing the final decision-maker from the agency’s explanation for its denial, the Attorney General effectively says to asylum seekers, “You have a right to appeal to a Court of Appeals, but asylum may be denied and you may be removed for reasons that are not subject to its review.” Today, our court sanctions this perversion of judicial review. Chevron does not require us to defer to such a perversion, and I would decline to do so.
I.
The scheme of administrative and judicial review established in the INA for asylum cases is a familiar one. Comparable schemes have been before the Supreme Court on numerous occasions, and its decisions in those cases have articulated fundamental principles of administrative law that govern review under such schemes. See, e.g., SEC v. Chenery Corp., 332 U.S. 194, 196-97, 67 S.Ct. 1575, 91 L.Ed. 1995 (1947); Chevron U.S.A. Inc. v. Natural Res. Def. Council, 467 U.S. 837, 842-44, 104 S.Ct. 2778, 81 L.Ed.2d 694 (1984); INS v. Ventura, 537 U.S. 12, 17, 123 S.Ct. 353, 154 L.Ed.2d 272 (2002). Nothing in the INA or its legislative history suggests that Congress intended that review in asylum cases would depart from these well-established principles, and the statute must be applied in light of them. I conclude that the Attorney General’s streamlining regulations are inconsistent with the INA scheme as so applied.
In a number of ways, the Attorney General’s reading of the statute is more straightforward than that of the Court. *268The Court begrudgingly “assume[s] [that the Act] contemplates that an alien will have the opportunity for an administrative appeal.” Maj. Op. at 237-38. It does so because Congress has expressly mandated that an IJ, upon the entry of an order denying asylum and granting removal, “shall inform the alien of the right to appeal that decision.” 8 U.S.C. § 1229a(c)(4). The Attorney General has no doubts about the matter, and his streamlining regulations provide for such an appeal. Those regulations continue to recognize that, in accordance with the requirements of the statute, there can be no final agency order until the BIA has acted or the asylum seeker has foregone his right to appeal to the BIA. 8 U.S.C. § 1101(a)(47)(B) (2002).6 Thus, in any case where an appeal is taken, the final decision of the agency subject to judicial review is that of the BIA. Moreover, the Attorney General understands that, while the statute substantially constrains judicial review of administrative findings of fact,7 it contemplates de novo review by the BIA. Even when streamlining occurs, the single BIA member, before approving “the result reached in the decision under review,” must determine that it “was correct.” 8 C.F.R. § 1003.1(a)(7)(ii). As we succinctly explained in Abdulai v. Ashcroft, 239 F.3d 542, 548-49 (3d Cir.2001):
Congress has granted [the federal courts] power to review only “final order[s] of removal.” Because an alien facing removal may appeal to the BIA as of right, and because the BIA has the power to conduct a de novo review of IJ decisions, there is no “final order” until the BIA acts. Accordingly, we now expressly hold that the “final order” we review is that of the BIA.
See also Kayembe v. Ashcroft, 334 F.3d 231, 234 (3d Cir.2003) (“Our power of review ... extends only to the decision of the BIA.... Therefore, only if the BIA expressly adopts or defers to a finding of the IJ, will we review the decision of the IJ.”); Awolesi v. Ashcroft, 341 F.3d 227, 231 (3d Cir.2003) (“We review the decision of the BIA, not that of the IJ.”).
The Attorney General also recognizes, as he must, that an asylum seeker is entitled under the statute to judicial review of the agency’s final decision, and the streamlining regulations so provide. They go on, however, to deprive the Court of Appeals of any basis for reviewing the agency’s final decision, to deprive the Court of the benefit of the agency’s expertise, and to deprive the asylum seeker of de novo review of the IJ’s fact finding. These aspects of the streamlining regulations are at odds with the statute as applied in light of at least two well-established principles of administrative law.
II.
First and foremost, judicial review necessarily requires something to review and, if the agency provides only its result without an explanation of the underlying fact finding and analysis, a court is unable to provide judicial review. See SEC v. Chenery Corp., 332 U.S. 194, 196-97, 67 S.Ct. 1575, 91 L.Ed. 1995 (1947) (“If the admin*269istrative action is to be tested by the basis upon which it purports to rest, that basis must be set forth with such clarity as to be understandable.”);8 Dunlop v. Bachowski, 421 U.S. 560, 572, 95 S.Ct. 1851, 44 L.Ed.2d 377 (1975); Guentchev v. INS, 77 F.3d 1036, 1038 (7th Cir.1996) (statement of reasons is the “norm of administrative law”). As we also explained in Abdulai in the specific context of the INA:
[Njothing in the INA specifically requires the Board to explain its decisions. But the availability of judicial review (which is specifically provided in the INA) necessarily contemplates something for us to review.... Because the BIA’s failure of explanation makes it impossible for us to review its rationale, we grant the petition for review, vacate the Board’s order, and remand the matter. ...
Abdulai, 239 F.3d at 555. While we did not cite to Chenery for this proposition in Abdulai, our holdings with respect to judicial review of administrative decisions clearly embrace Chenery's reasoning. See, e.g., N.L.R.B. v. Permanent Label Corp., 657 F.2d 512, 532 (3d Cir.1981) (“Requiring the Board to articulate its reasons for imposing a bargaining order does not represent an unwarranted judicial interference with administrative procedure. Indeed that requirement, as we have pointed out, stems from the Supreme Court’s instructions in [N.L.R.B. v. Gissel Packing Co., 395 U.S. 575, 89 S.Ct. 1918, 23 L.Ed.2d 547 (1969)], and from fundamental rules of administrative law.” (citing Chenery, 332 U.S. at 196-97, 67 S.Ct. 1575)).9
Whenever the streamlining regulations are invoked, they deprive a reviewing court, by their express terms, of any basis for knowing either the findings of fact or the rationale upon which the BIA’s denial of asylum rests and they thus make judicial review impossible. 8 C.F.R. § 1003.1(a)(7)(iii) requires that the BIA’s order expressly state “the Board affirms, without opinion, the result of the decision below.” This means that the BIA accepts only “the result” of the IJ’s deliberations. Indeed, the regulations, in addition to foreclosing the BIA from giving “further explanation or reasoning,” go on to state that the effect of the BIA’s order is to “approve ... the result reached in the decision below” and to disavow any implication that the approval extends any further. The BIA’s order thus does not only fail to adopt the findings and reasoning of the IJ, it expressly disavows endorsing those findings and that analysis. See 8 C.F.R. *270§ 1003.1(a)(7)(iii) (requiring that the order to state that it “does not necessarily imply approval of all of the reasoning of [the IJ’s decision]”). The net and necessary result is that the reviewing court has no findings or reasoning of the final decision-maker to review. This result has already been addressed in Chenery, 332 U.S. at 196-97, 67 S.Ct. 1575, and Abdulai, 239 F.3d at 555, and it is rendered no less defective by virtue of being authorized by the Attorney General’s streamlining regulations.
In short, judicial review, by definition, necessarily involves an explanation for the agency’s final decision. Congress has spoken directly to the issue of whether asylum seekers will have a right to judicial review. Accordingly, the situation before us is simply not one in which Chevron deference is due. See Chevron, 467 U.S. at 842-843, 104 S.Ct. 2778 (“First, always, is the question whether Congress has directly spoken to the precise question at issue. If the intent of Congress is clear, that is the end of the matter; for the court, as well as the agency, must give effect to the unambiguously expressed intent of Congress.”). The Attorney General may not deprive asylum seekers of that right by calling something judicial review even though relief may be denied for undisclosed reasons not subject to judicial review.
It does not help that a summary affir-mance signifies under the regulations that the BIA views “any errors in the decisions of the Immigration Judge [as] harmless or non-material.” In any case where the BIA disagrees with the IJ in whole or in part, but has an alternative and independent basis for denial, the error of the IJ will be harmless or non-material, yet that alternative and independent basis will never be disclosed and, accordingly, will never be exposed to judicial review. It necessarily follows that an alien may be denied asylum and be put in serious jeopardy for a reason that is never exposed to judicial review.
Nor does it help that the regulations instruct the Court of Appeals to review the fact finding and analysis of the IJ. See Executive Office of Immigration Review: Board of Immigration Appeals Streamlining, 64 Fed. Reg. at 56,138 (Oct. 18, 1999) (“The decision rendered below will be the final agency decision for judicial review purposes.... [T]he Immigration Judge’s decision becomes the decision reviewed.”). In any case in which the BIA disagrees with the IJ in whole or in part, but has an alternative and independent basis for denying asylum, review of the IJ’s fact finding and analysis is a meaningless exercise. The Court’s suggestion that it makes no difference whether the explanation is provided by the final decision-maker or the IJ is reminiscent of Alice’s Wonderland. The difference is between the asylum seeker’s having judicial review of the reason for his removal and his having no such review.10
*271The Attorney General’s perversion of the judicial review mandated by Congress is strikingly illustrated by the record that was recently before us in Ezeagwuna v. Ashcroft, 301 F.3d 116 (3d Cir.2002), a case that was not, but could have been, affirmed without opinion under the streamlining regulations. There, as here, the IJ concluded that the alien was not credible and, accordingly, had not carried his burden of persuasion. Id. at 123. The IJ reached this conclusion because: (1) he found it implausible that the alien had been abused in the manner she claimed; and (2) the alien appeared to be giving testimony she had rehearsed. Id. at 123-24. On appeal, the BIA found that the record did not support the reasons given for the IJ’s credibility decision. Nevertheless, it also found that the alien lacked credibility and, accordingly, that the IJ had reached the correct result. The BIA reached its conclusion on the credibility issue for a reason different from those of the IJ: the alien had impeached her own credibility by submitting fraudulent documents in support of her asylum application. The BIA accordingly ordered removal. Id. at 124-25.
On appeal, we held that the evidence the BIA relied upon in concluding that the documents were fraudulent was unreliable and untrustworthy and that the BIA’s reliance upon it had violated the alien’s right to Due Process. Id. at 130.
Cases like Ezeagmma can, consistent with the streamlining regulations, be decided without an opinion. A single BIA member could well have determined in good faith that the errors of the IJ were harmless or immaterial because the BIA member reached the same conclusion. He could also have concluded in good faith that there was no genuine dispute regarding the applicable law and that the case did not involve the application of precedent to a novel fact situation. Had a single BIA member made these determinations and decided the case without opinion under the streamlining regulations, we, as the reviewing court, (1) would have been unaware of the basis for the agency’s final decision and, accordingly, would not have had the opportunity to vindicate the violation of the alien’s constitutional rights; and (2) would have been unaware that, in the expert eyes of the BIA exercising de novo review, the fact finding done by the IJ was unacceptable and, exercising restricted review, we might well have allowed that fact finding to stand. Fortunately for the asylum seeker in Eze-agvmna, her case was not streamlined and her rights were vindicated. Had the streamlining decision gone the other way, however, she might well have been sent home to persecution without any judicial review of the basis of the decision to deny asylum.
This case may well be one like Ezeagwu-na. The BIA member could well have viewed the grounds for the IJ’s credibility determination as impermissibly speculative and, accordingly, may well have relied on alternative, undisclosed grounds. If so, Dia will have been removed for reasons that were unexposed to judicial review.
III.
The streamlining regulations, and the Court’s sanctioning of them, have further *272consequences that conflict with the statutory scheme viewed in light of a second well-established principle of administrative law. A reviewing court must defer to, and must insist upon the benefit of, the application of the agency’s expertise in the context of the matter before it. “[A] reviewing court, in dealing with a determination or judgment which an administrative agency alone is authorized to make, must judge the propriety of such action solely by the grounds invoked by the agency. If those grounds are inadequate or improper [or unknown] the Court is powerless to affirm the administrative action by substituting what it considers to be a more adequate or proper basis.” Chenery, 332 U.S. at 196, 67 S.Ct. 1575. The absence of an explanation from the agency decision-maker not only precludes judicial review, it also deprives the Court of the benefit of the agency’s expertise and impairs the ability of the Court to confine itself to its intended role.
In a recent asylum case, the Court of Appeals for the Ninth Circuit overturned an order of removal based on an argument for asylum that had been addressed by the IJ but not by the BIA. The argument turned on whether conditions in Guatemala had improved to the point that no realistic threat of persecution currently existed. The Supreme Court held that the Court of Appeals had violated “well-established principles of administrative law” by proceeding “without giving the BIA the opportunity to address the [disputed] matter in the light of its own expertise.” INS v. Ventura, 537 U.S. 12, 17, 123 S.Ct. 353, 154 L.Ed.2d 272 (2002). The Court explained why the Ninth Circuit Court of Appeals’s action “seriously disregarded the agency’s legally mandated role”:
Within broad limits the law entrusts the agency to make the basic asylum eligibility decision here in question. In such circumstances a “judicial judgment cannot be made to do service for an administrative judgment.” Nor can an “appellate court ... intrude upon the domain which Congress has exclusively entrusted to an administrative agency.” A court of appeals “is not generally empowered to conduct a de novo inquiry into the matter being reviewed and to reach its own conclusions based on such an inquiry.” Rather, “the proper course, except in rare circumstances, is to remand to the agency for additional investigation or explanation.”
INS v. Ventura, 537 U.S. at 16, 123 S.Ct. 353 (citations omitted).
Just as Congress did not intend the Ninth Circuit Court of Appeals to perform the BIA’s “legally mandated role,” neither did it intend for our Court to address in the first instance issues like whether Guinea is a “country where the military, as well as civilian militias, act independently of the federal government.” Maj. Op. at 252. While our Court has not usurped the role of the BIA as did the Ventura court, it has permitted the agency to absolve itself, by regulation, of the responsibility for fulfilling the BIA’s legally mandated role. Given the Congressional mandate, our Court should not allow this abdication of responsibility.
IV.
The Attorney General’s desire to streamline the appeals process is understandable. Moreover, I agree with the Court that he has been given by Congress the authority to simplify and expedite the process before the agency. I perceive no reason, for example, why he cannot have a single BIA member decide a category of appeals like the one identified in the streamlining regulation. Moreover, a single member can clearly decide appeals by adopting the opinion of the IJ or by adopt*273ing it with specified exceptions. What the Attorney General may not do consistent with the INA and well-established principles of administrative law is to deprive the reviewing court of the ability to provide the judicial review mandated by Congress. More specifically, he cannot foreclose the BIA from explaining its decision in some way.
Contrary to the Court’s suggestion, the Attorney General’s streamlining scheme is not at all analogous to the affirmance of District Court judgments by court of appeals without an opinion. The BIA’s order is materially different from a judgment order of a court of appeals that may be reviewed by higher judicial authority. While an opinion of a court of appeals may be helpful, it is not essential to the intended operation of the federal judicial system. A court of appeals possesses no special expertise that the Supreme Court lacks and both courts review a court’s judgment using the same standards of review. The INA, on the other hand, contemplates an administrative review by an entity which has special, relevant expertise and which will exercise de novo review of the IJ’s findings of fact as well as her conclusions of law. Both factors are very important in cases like the one before us, and the Congressional scheme cannot function as intended if the BIA does not tell us what facts it found and what reasoning it relied upon.
V.
I would grant the petition for review and remand to the BIA with instructions to provide an explanation of the grounds for its decision.
. 8 U.S.C. § 1229a(b)(4)(B) provides that: "In proceedings under this section, under regulations of the Attorney General-the alien shall have a reasonable opportunity to examine the evidence against the alien, to present evidence on the alien's own behalf, and to cross-examine witnesses presented by the Government....”
. 8 U.S.C. § 1229a(c)(4) states: "If the immigration judge decides that the alien is removable and orders the alien to be removed, the judge shall inform the alien of the right to appeal that decision and of the consequences for failure to depart under the order of removal, including civil and criminal penalties.”
. 8 U.S.C. § 1252(a)(1) states: “Judicial review of a final order of removal (other than an order of removal without a hearing pursuant to section 1225(b)(1) of this title) is governed only by chapter 158 of Title 28, except as provided in subsection (b) of this section and except that the court may not order the taking of additional evidence under section 2347(c) of Title 28.”
. See Executive Office of Immigration Review: Board of Immigration Appeals Streamlining, 64 Fed. Reg. at 56,138 (Oct 18, 1999) (“The decision rendered below will be the final agency decision for judicial review purposes .... [T]he Immigration Judge's decision becomes the decision reviewed.”).
. The order of a single BIA member "approves the result reached in the decision below; it does not necessarily imply approval of all of the reasoning of that decision....” 8 C.F.R. § 1003.1 (a)(7)(iii).
. 8 U.S.C. § 1101(a)(47)(B) states in part that: The ["order of deportation”] shall become final upon the earlier of (i) a determination by the Board of Immigration Appeals affirming such order; or (ii) the expiration of the period in which the alien is permitted to seek review of such order by the Board of Immigration Appeals.
. 8 U.S.C. § 1252(b)(4)(B) provides that, in the context of judicial review, "the administrative findings of fact are conclusive unless any reasonable adjudicator would be compelled to conclude to the contrary.”
. The Court in Chenery stated that:
It will not do for a court to be compelled to guess at the theory underlying the agency's action; nor can a court be expected to chisel that which must be precise from what the agency has left vague and indecisive. In other words, “we must know what a decision means before the duty becomes ours to say whether it is right or wrong.”
332 U.S. at 196-97, 67 S.Ct. 1575 (quoting U.S. v. Chicago M., St. P. & P.R. Co., 294 U.S. 499, 511, 55 S.Ct. 462, 79 L.Ed. 1023 (1935)). This, according to the Court, is a corollary to the rule that "a reviewing court, in dealing with a determination or judgment which an administrative agency alone is authorized to make, must judge the propriety of such action solely by the grounds invoked by the agency.” Id. at 196, 67 S.Ct. 1575.
. The proposition that judicial review requires an administrative agency to articulate the reasoning for its decisions also follows logically from our holding that the Attorney General’s stated reasons for granting or denying asylum must not be “arbitrary, irrational, or contrary to law.” Ezeagwuna v. Ashcroft, 301 F.3d 116, 126 (3d Cir.2002) (citing Andriasian v. INS, 180 F.3d 1033, 1040 (9th Cir.1999)). It is difficult, if not impossible, for a reviewing court to apply this standard to an agency’s action if the agency has not explained why it acted as it did. See 1 Richard J. Pierce, Jr., Administrative Law Treatise § 8.5, at 546 (4th ed.2002).
. The Court's opinion simply ignores the fact that the streamlining regulations permit an asylum seeker to be removed for reasons unexposed to judicial review. It does so with the ipse dixit: "The BIA clearly 'invokes' the IJ's opinion as the grounds on which the agency’s decision rests; we thus judge the propriety’ of the IJ's action in order to 'test' the agency's action.” Maj. Op. at 241. The Court fails to explain, however, how a BIA order that does not "imply approval of all of the reasoning of” the IJ’s opinion can "clearly ‘invoke[]' the IJ opinion as the ground on which, the agency's decision rests.” Every court of appeals that has engaged in judicial review of an IJ's decision has done so because the IJ's reasoning was expressly adopted by the BIA. See Chen v. INS, 87 F.3d 5, 7 (1st Cir.1996) (citing cases from the Second, Fourth, Fifth, Seventh, Eighth, Tenth, and Eleventh Circuits, in each of which, the BIA expressly adopted the reasoning of the IJ as its own). Significantly, we held in Abdulai that the IJ's opinion had not become that of the BIA’s. 239 F.3d at 549 n. 2. We came to this conclusion because "the BIA never expressly 'adopted' any portion of the IJ's opin*271ion or announced that it was deferring to any of the IJ’s findings.” Id.
Citing Albathani v. INS, 318 F.3d 365, 377 (1st Cir.2003), our Court’s opinion also asserts, without explanation, that “Chenery does not require that [the agency's] statement [of reasons] come from the BIA rather than the IJ.” Maj. Op. at 241. Chenery makes no sense, however, unless it is read to require that the reasons given be the reasons of the agency’s final decision-maker. Otherwise, as I have stressed, agency action may be taken for reasons never exposed to the Congressionally mandated judicial review.