On September 20, 2013, the US Environmental and Protection Agency (EPA) proposed a revised rule for "Standards of Performance for Greenhouse Gas Emissions from New Stationary Sources: Electric Utility Generating Units". These performance standards set limits on the amount of carbon dioxide (CO2) that can be emitted per megawatt-hour (MWh) of electricity generation from new coal-fired and natural gas-fired power plants built in the US. These limits were based on determinations of "best system of emission reduction (BSER) adequately demonstrated". Central in this determination was evaluating whether Carbon Dioxide Capture and Storage (CCS) qualified as BSER. The proposed rule states that CCS qualifies as BSER for coal-fired generation but not for natural gas-fired generation. In this paper, we assess the EPA's analysis that resulted in this determination. We are not trying to judge what the absolute criteria are for CCS as the BSER but only the relative differences as related to coal- vs natural gas-fired technologies. We conclude that there are not enough differences between "base load" coal-fired and natural gas-fired power plants to justify the EPA's determination that CCS is the BSER for coal-fired power plants but not for natural gas-fired power plants.