First Name | Bill |
---|---|
Last Name | Buchan |
Email Address | buchan@mktpotential.com |
Affiliation | |
Subject | Recycled Boxboard Benchmark |
Comment | 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. |
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Date and Time Comment Was Submitted | 2011-08-05 13:27:37 |
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