In 2015, New Source Performance Standards were promulgated for new coal-fired plants at 80 Fed. Reg. 64510. These established partial CCS as the Best System of Emissions Reduction. In 2018, EPA proposed (at 83 Fed. Reg. 65424) that “the most efficient demonstrated steam cycle in combination with the best operating practices” would qualify as the Best System of Emissions Reduction for coal, effectively repealing the 2015 partial CCS standard. That proposed rule has not been finalized as of January 2020. The LPDD report proposes that NSPS standards can be enhanced beyond the 2015 level.