Since these are denials that have been elevated to the CCLRB, I'm not sure there is a way to compare these stats to those of other states. Most states don't have a similar process or review board. Our overall denial rate is FAR less than this--it is below 1%. The CCLRB denials represent a small minority of applications. You are absolutely correct, I failed to look at the total denial rate instead of just the Board reviews. Below 1% is very reasonable in the grand scheme of things. Thanks!