The Draft Rule essentially requires all new fossil fuel-fired power plants to meet the carbon dioxide (CO2) emissions profile of a combined cycle natural gas plant. While most new natural gas plants will not be required to include any new technologies, no new coal plants can be constructed without carbon capture and sequestration (CCS )capabilities. Litigation is expected over the Draft Rule due to the novel nature of the Draft Rule in regulating CO2 and EPA's departure in several instances in the Draft Rule from its usual method of setting new source performance standards (NSPS) on a source category by source category basis.