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I understand and appreciate CARB needing to establish a greenhouse
gas benchmark for each type of industry to determine allowances. 
However, when the type of industry is a population of one (such as
our case) then that is not a benchmark.  Statistically, a pool of
twenty should be used to develop such a starting point.  Since
there is not twenty similar industries in the State of California,
then the data source should be enlarged to incorporate such a pool.
 This will be accomplished soon with the manatory reporting on a
national levels.  Once this data is collected, then it should be
used to develop a benchmark.  Using a population of one to develop
a standard is onerous and is very burdensome to the facility that
must find means to reduce it's carbon footprint even though it may
be the best in the nation or close down because the cost of credits
outweigh the expected margin of the facility's profit.