Law360, New York (May 23, 2014, 12:23 PM EDT) -- Drawing almost a million comments, the public comment period for the U.S. Environmental Protection Agency's proposed "Standards of Performance for Greenhouse Gas Emissions from New Stationary Sources: Electric Utility Generating Units" closed on May 9, 2014.[1] The proposed rule has come under heavy fire for its selection of carbon capture and sequestration ("CCS") as the best system of emission reduction ("BSER") to control carbon dioxide emissions at new coal-fired facilities.[2] With the high cost of CCS forestalling construction of any new coal plants, opponents of the rule overwhelmingly take issue with the selection of CCS from a legal and technical perspective. Commenters also strongly admonish the EPA's de facto ban on coal as a serious threat to grid reliability and electricity prices....