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The benchmark for the Recycled Boxboard industry is based on data
recent data which includes early action projects.   ARB has said
repeatedly that it would not penalize facilities for conducting
early action projects and inspired facilities to begin reducing
GHGs.  Unfortunately, the recycled boxboard group is being
penalized for conducting early action projects, as the results of
these early action projects are being included in the benchmark. 
Furthermore, the data used for this benchmark are very limited and
not statistically significant.  As most of the recycled boxboard
mills in the country reside outside California, the ARB’s approach
makes it impossible to tell whether the California Recycled
Boxboard group is operating better or worse than its national
peers.  This again creates a competitive disadvantage when
California mills compete against its national peers.   We ask that
ARB reconsider the data it is using for this group and look into a
national data set for the recycled boxboard group.  We request that
more recent data be omitted to provide reward for early action
projects.  We request that data prior to 2008 be included in order
to develop a fair benchmark and improve the statistical
significance of this benchmark.