(dissenting).
I.
I respectfully dissent. While I agree that under some circumstances deference to a state agency’s interpretation of a federal regulation may be appropriate, deference is not appropriate in this case. Judicial deference to an agency’s interpretation of a regulation is inappropriate if the language of the regulation is unambiguous, as an agency is not permitted to contravene the plain meaning of the language used in the regulation. See St. Otto’s Home v. Minn. Dep’t of Human Servs., 437 N.W.2d 35, 40 (Minn.1989). While context may help us ascertain its plain meaning, see King v. St Vincent’s Hosp., 502 U.S. 215, 221, 112 S.Ct. 570, 116 L.Ed.2d 578 (1991), an examination of the actual language that comprises the text is always necessary to reach conclusions about meaning. In this case, the court concludes that 40 C.F.R. § 122.4(i) (2006) is ambiguous without any analysis of the regulation’s actual language and without explanation as to what in the language is unclear. Instead, the court lists various interpretations of 40 C.F.R. § 122.4(i) that have been offered in the course of other litigation. The fact that multiple interpretations have been suggested does not establish ambiguity, see Bank Midwest, Minnesota, Iowa, N.A. v. Lipetzky, 674 N.W.2d 176, 179 (Minn.2004), yet the court concludes that the regulation is ambiguous simply because of “differing interpretations that have been applied to this regulation.” Analyzing 40 C.F.R. § 122.4(i)’s actual language, I conclude that deference to the MPCA’s interpretation of 40 C.F.R. § 122.4(i) is not warranted because the regulation is not ambiguous.
II.
Under 40 C.F.R. § 122.4(i), the Minnesota Pollution Control Agency (MPCA) may not issue a National Pollutant Discharge Elimination System (NPDES) permit “[t]o a new source or a new discharger, if the discharge from its construction or operation will cause or contribute1 to the violation of water quality standards.” 40 C.F.R. § 122.4(i) (footnote added). The language of the regulation is clear. No permit may be issued to a new source or discharger if it will cause a violation of water quality standards, e.g., if the addition of phosphorus discharged from the source seeking the permit would elevate phosphorus levels in a body of water above the level that constitutes a violation. Nor may a permit be issued to a new source or discharger if it will contribute to a violation of water quality standards, e.g., if the new source would discharge phosphorus into a body of water previously determined to have phosphorus levels in excess of permissible levels. In determining whether a discharge will cause or contribute to a *527violation, the MPCA may take into consideration pollution from sources other than the source seeking a permit, but only so far as is necessary to determine whether a violation exists before or will exist after issuance of the permit.
It is undisputed that phosphorus levels in the Lake Pepin Watershed currently exceed water quality standards and, as determined by the MPCA, are in violation of those standards. Minn. Pollution Control Agency, MPCA 2002 303(d) List (Jan. 22, 2003), available at http://www. pea.state.mn.us/publieations/reports/tmdl-20021ist.pdf. The MPCA has also determined that the proposed Maple Lake/An-nandale facility will increase the cities’ discharge of phosphorus into that watershed from approximately 1,400 pounds of phosphorus annually to about 3,600 pounds annually. Thus, while the proposed facility will not cause a violation of the standards, it is clear that an increase of 2,200 pounds of phosphorus per year will “help bring about,” that is, contribute to, a water quality standards violation in the Lake Pepin Watershed. It is also clear that the violation will occur irrespective of any action taken by the City of Litchfield to reduce the amount of phosphorus it discharges into the watershed. By granting the NPDES permit to the cities of Maple Lake and Annandale, the MPCA ignores the unambiguous language of 40 C.F.R. § 122.4(i). Therefore, the MPCA’s issuance of the NPDES permit should be reversed.
III.
Even if the plain meaning of the regulation’s language is ignored and it is assumed that the regulation is ambiguous, I would still conclude that deference is inappropriate because none of the traditional rationales for deferring to an agency’s interpretation of a regulation are present in this case.
Under our case law, one rationale for giving deference to an agency’s reasonable interpretation of an ambiguous regulation is rooted in the separation of powers doctrine. Reserve Mining Co. v. Herbst, 256 N.W.2d 808, 824 (Minn.1977). More specifically, deference is warranted to prevent the judiciary from exercising excessive or potentially unconstitutional discretion over policy matters. Id. at 825. Such matters are properly the domain of the legislative and executive branches, which have both greater fact-finding abilities and greater political accountability than the judiciary. See id. However, when judicial review of an agency’s interpretation of a regulation does not involve second-guessing policy decisions, the separation of powers doctrine is not a reason to defer to an agency’s interpretation. To the contrary, the separation of powers doctrine compels the judiciary to ensure that other governmental bodies execute laws faithfully.
Another rationale for deferring to an agency’s interpretation of a regulation arises when, unlike the judiciary, the agency has “the expertise necessary to decide technical matters.” In re Excess Surplus Status of Blue Cross & Blue Shield of Minn., 624 N.W.2d 264, 278 (Minn.2001). Accordingly, if the regulation refers to an open-ended technical or scientific matter— for example, a requirement that the agency determine whether certain effluents cause or contribute to a public health hazard, see Minn. Ctr. for Envtl. Advocacy v. Minn. Pollution Control Agency, 644 N.W.2d 457, 464 (Minn.2002) (interpreting “significant environmental effects”) — then it would be appropriate to defer to the agency’s interpretation, provided that interpretation is reasonable. However, when interpretation of the regulation does not implicate any special scientific or tech*528nical expertise, there is no reason to defer. In fact, when the regulation requires only a straightforward reading, it is the judiciary that possesses the special expertise.
Deference may also be appropriate “when the administrative practice at stake involves a contemporaneous construction of a statute [or regulation] by the [people] charged with the responsibility of setting its machinery in motion, of making the parts work efficiently and smoothly while they are yet untried and new.” Udall v. Tollman, 380 U.S. 1, 16, 85 S.Ct. 792, 13 L.Ed.2d 616 (1965) (internal quotation marks omitted); see also Resident v. Noot, 305 N.W.2d 311, 312 (Minn.1981) (noting deference is appropriate “when the agency interpretation is one of long standing”); In re Estate of Abbott, 213 Minn. 289, 296, 6 N.W.2d 466, 469 (1942) (“That great weight should be given departmental construction of taxation statutes is dependent upon such construction’s having been long continued and uniform * * *.” (Citations omitted.)). In such a case, deference may be justified because longstanding and consistent interpretations may have encouraged reliance by the public and because the failure of a delegating authority to correct the interpretation implies either that the interpretation is correct or that the authority has willingly acquiesced to the agency’s interpretation. See Udall, 380 U.S. at 17-18, 85 S.Ct. 792; In re Estate of Abbott, 213 Minn. at 296, 6 N.W.2d at 470. However, in cases in which the agency interpretation is recent, any reliance interest is diminished, and changed or new interpretations may be the product of political opportunism rather than good-faith efforts at interpretation.
As noted previously, no rationale for deference is present in this case. The MPCA is tasked with determining whether “construction or operation” of a new facility “will cause or contribute to the violation of water quality standards.” 40 C.F.R. § 122.4(i). Water quality standards have been set and are not in dispute. See 33 U.S.C. § 1313 (2000). Therefore, on its face, that determination is simply a matter of measuring a known quantity — pollutants discharged — against an established standard — the water quality standards. Thus, a court’s review of that determination does not require judicial second-guessing of either legislative or executive policy decisions. The only question presented is whether the policy decision made is being properly carried out. Nor does this case involve a scientific evaluation of technical or scientific matters beyond the comprehension of judges; it requires only a basic understanding of the English language and elementary number usage. Further, 40 C.F.R. § 122.4(i) was promulgated in the mid-1980s, so the regulation cannot be considered “untried and new.” Moreover, an interpretation first offered by the MPCA in 2004 — or by the EPA in litigation in 1999 — cannot be considered “contemporaneous.”
In comparison, if we were reviewing water quality standards set by the MPCA, deference would be warranted because that decision requires the evaluation of the effects of discharged substances on wildlife and public safety, which implicates special technical and scientific competence. See Minn. Ctr. for Envtl. Advocacy, 644 N.W.2d at 465. It would also be warranted because selecting such standards requires policy judgments involving the analysis of costs and benefits of the different options and consideration of competing interests. For example, if it were concerned with population growth, the MPCA could have presumably indexed water quality standards to population. Thus, if we were being asked to review the actual standards selected by the MPCA, considerations related to the separation of powers doctrine would make deference entirely appropri*529ate. Similarly, if we were being asked to review the MPCA’s methods for measuring contaminants existing in a body of water or in effluent from a discharger, the agency’s decisions would also merit deference, as those decisions would clearly require application of the agency’s special scientific and technical knowledge. However, once water quality standards have been established and the appropriate measurements have been taken, neither expertise nor separation of powers should permit the MPCA latitude to redefine “cause or contribute” in order to ignore those standards.
In determining that we should defer to the MPCA’s interpretation of 40 C.F.R. § 122.4(i), the court conflates the deference that might properly be accorded the MPCA in setting water quality standards with a reason to defer to the agency’s interpretation of all other aspects of the regulatory scheme. In doing so, the court blurs the line between setting the standards and determining whether an action will cause or contribute to the violation of those standards, and on that basis claims that the issue before the court is both a matter of policy and a matter implicating special expertise. It is neither.
IV.
Even if it is assumed that the regulation is ambiguous and that some or all of the traditional reasons for deferring to the agency’s interpretation of the regulation are present, before deference is appropriate, the agency’s interpretation must be reasonable, as a court should not allow an agency to impose a meaning on a legal authority that its text will not bear. See St. Otto’s Home, 437 N.W.2d at 40. Here, the court determines that the MPCA’s interpretation of 40 C.F.R. § 122.4(i) is reasonable without ever connecting that interpretation to the language of the regulation. Instead, the court describes the complicated analysis chosen by the MPCA to address phosphorus discharge in the NPDES permitting system and announces that these matters are within the MPCA’s discretion.2 However, if the MPCA’s chosen interpretation is incompatible with the text of 40 C.F.R. § 122.4(f), the complexity of or the care taken in applying that interpretation is not helpful. Because the language of the regulation, as informed by any relevant agency expertise, is a necessary touchstone for determining the reasonableness of the interpretation, the court’s failure to discuss whether and how the MPCA’s interpretation is supported by the language of 40 C.F.R. § 122.4(f) undermines its reasonableness conclusion. When examined in light of the regulation’s language, the interpretation of 40 C.F.R. § 122.4(i) offered by the MPCA is not reasonable.
As an initial matter, the court is mistaken when it suggests that the U.S. Supreme Court’s decision in Arkansas v. Oklahoma, *530503 U.S. 91, 112 S.Ct. 1046, 117 L.Ed.2d 239 (1992), establishes the reasonableness of the MPCA’s interpretation. First, Arkansas v. Oklahoma does not stand for the proposition that it is unreasonable to interpret 40 C.F.R. § 122.4(i) as prohibiting issuance of all NPDES permits in connection with waters in violation of water quality standards. Arkansas v. Oklahoma involved interpretation of the Clean Water Act itself, 40 C.F.R. § 122.4(d), and Oklahoma state standards requiring “no degradation of water quality.” 503 U.S. at 95, 107, 112 S.Ct. 1046. It did not involve interpretation of 40 C.F.R. § 122.4(i) and the phrase “cause or contribute.” While the court in Arkansas v. Oklahoma did hold that nothing in the Clean Water Act established a categorical ban on “any discharge of effluent that would reach waters already in violation of existing water quality standards,” id. at 107, 112 S.Ct. 1046, the Court did not hold that the EPA was without authority to promulgate a regulation establishing a categorical ban on issuance of NPDES permits for bodies of water in violation of water quality standards. To the contrary, the court stated that the Act “vests in the EPA and the States broad authority to develop long-range, area-wide programs to alleviate and eliminate existing pollution.”3 Id. at 108, 112 S.Ct. 1046. The EPA used that broad authority in promulgating 40 C.F.R. § 122.4(i). Second, it does not follow from a fair reading of Arkansas v. Oklahoma that the pollution offset proposed for the Lake Pepin Watershed District, as advocated by the MPCA here, is reasonable.
Moreover, there is nothing in the text of 40 C.F.R. § 122.4(i) that suggests that one discharger may be allowed to increase its allowable discharge simply because another discharger has taken steps to reduce its discharge. In addition, the MPCA’s interpretation appears to be in conflict with the goals of both the NPDES permitting scheme and the Clean Water Act, under which the NPDES permit system operates. I presume that elimination of pollutant discharge is a goal of the National Pollutant Discharge Elimination System, and the purpose of the Clean Water Act “is to restore and maintain the chemical, physical, and biological integrity of the Nation’s waters.” 33 U.S.C. § 1251(a) (2000) (emphasis added); see also 33 U.S.C. § 1251(b) (2000) (“It is the policy of the Congress to recognize, preserve, and protect the primary responsibilities and rights of States to prevent, reduce, and eliminate pollution, to plan the development and use (including restoration, preservation, and enhancement) of land and water resources, and to consult with the Administrator in the exercise of his authority under this chapter.” (Emphasis added.)). In contrast, the MPCA’s interpretation of 40 C.F.R. § 122.4(i), which permits discharge offsets, is not limited in either time or place. Under this interpretation, presumably the MPCA may consider offsets based on discharge reductions from the distant past and unknown future as well as from geographically distant locales, which would largely circumvent any mandate to improve water quality and re*531duce pollution. To hold that the MPCA’s interpretation is reasonable is to hold that reading the “cause or contribute” language out of 40 C.F.R. § 122.4(i) is also reasonable. It is also to hold that the MPCA has unfettered discretion to issue permits allowing polluters to cause or contribute to violations of water quality standards. But none of these holdings are reasonable. Thus, I conclude that the MPCA’s interpretation of 40 C.F.R. § 122.4(i) in this case is not reasonable.
V.
In summary, 40 C.F.R. § 122.4(i) is not ambiguous, there are no factors present in this case that would indicate that deference to the MPCA’s interpretation of the regulation is appropriate, and the MPCA’s interpretation of the regulation is not reasonable. Accordingly, I would affirm the court of appeals’ reversal of the MPCA’s decision to issue the NPDES permit.
. "To cause” means "[t]o bring about” or "[to produce] an effect, result, or consequence.” American Heritage Dictionary 305 (3rd ed.1996). "Contribute” means “[t]o give or supply in common with others” and “[t]o help bring about a result [or to] act as a factor.” Id. at 410.
. Significantly, the MPCA’s analysis for addressing phosphorus discharge in the NPDES permitting process for bodies of water in violation of water quality standards for phosphorus is not as complicated as the court implies. Further, the court misrepresents the MPCA’s policy by neglecting to mention that such bodies of water appear to be exempted from the normal NPDES permitting analysis. See Minn. Pollution Control Agency, MPCA Phosphorus (P) Strategy: NPDES Permits at 1 (March 2000), available at http://www.pca. state.mn.us/water/pubs/phos-npdes.pdf ("For water quality segments that are impaired or threatened for phosphorus or phosphorus-related conditions as listed on the 303(d) list [i.e., in violation of water quality standards], the MPCA shall use its authority to limit point-source discharges, including existing discharges, by including phosphorus limits where appropriate in NPDES permits as part of a TDML allocation of point and/or non-point discharges.”).
. I note that the MPCA's interpretation of 40 C.F.R. § 122.4(i) does nothing to “alleviate and eliminate existing pollution.” To the contrary, because there is no indication that the reduction in phosphorus discharge from the Litchfield facility is contingent on approval of the permit for the Annandale/Maple Lake facility, the MPCA’s interpretation will result in increased pollution. Moreover, while the Court in Arkansas v. Oklahoma expresses concern about "frustrating] the construction of new plants that would improve existing conditions,” see 503 U.S. at 108, 112 S.Ct. 1046, denial of a NPDES permit in this case will do nothing to prevent construction of facilities that, unlike the proposed Annandale/Maple Lake facility, will actually improve water quality.