15-4-3342 U.S Foreign Producers'/Exporters' Questionnaire

OMB No. 3117-0016/USITC No. 15-4-3342; Expiration Date: 6/30/2017
(No response is required if currently valid OMB control number is not displayed)

FOREIGN PRODUCERS’/EXPORTERS’ QUESTIONNAIRE

SILICOMANGANESE FROM AUSTRALIA
This questionnaire must be received by the Commission by March 4, 2015
See last page for filing instructions.
The information called for in this questionnaire is for use by the United States International Trade Commission in
connection with its antidumping investigation concerning silicomanganese from Australia (inv. No. 731-TA-1269
(Preliminary)). The information requested in the questionnaire is requested under the authority of the Tariff Act
of 1930, title VII.

Name of firm
Address
Website
Has your firm produced or exported silicomanganese (as defined on next page) at any time since January 1,
2012?
Data reported in this questionnaire relate to:

Australia
NO

(Sign the certification below and promptly return only this page of the questionnaire to the Commission)

YES

(Complete all parts of the questionnaire, and return the entire questionnaire to the Commission)

Return questionnaire via the Commission Drop Box by clicking on the following link:
https://dropbox.usitc.gov/oinv/. (PIN: SIMN)
CERTIFICATION
I certify that the information herein supplied in response to this questionnaire is complete and correct to the best of my
knowledge and belief and understand that the information submitted is subject to audit and verification by the Commission.
By means of this certification I also grant consent for the Commission, and its employees and contract personnel, to use the
information provided in this questionnaire and throughout this proceeding in any other import-injury proceedings conducted by
the Commission on the same or similar merchandise.
I acknowledge that information submitted in this questionnaire response and throughout this proceeding may be used by the
Commission, its employees, and contract personnel who are acting in the capacity of Commission employees, for developing or
maintaining the records of this proceeding or related proceedings for which this information is submitted, or in internal audits and
proceedings relating to the programs and operations of the Commission pursuant to 5 U.S.C. Appendix 3. I understand that all
contract personnel will sign non-disclosure agreements.
Name of Authorized Official

Title of Authorized Official

Date

Phone:
Signature

Fax:

Email address

Business Proprietary
Foreign Producers’ Questionnaire – Silicomanganese

Page 2

PART I.—GENERAL INFORMATION
Background. This proceeding was instituted in response to a petition filed on February 19, 2015, by
Felman Production LLC, Letart, West Virginia. Antidumping duties may be assessed on the subject
imports as a result of these proceedings if the Commission makes an affirmative determination of injury,
threat, or material retardation, and if the U.S. Department of Commerce makes an affirmative
determination of dumping. Questionnaires and other information pertinent to this proceeding are
available at
http://www.usitc.gov/investigations/701731/2015/silicomanganese_australia/preliminary.htm
Silicomanganese. The products covered by this investigation are all forms, sizes and compositions of
silicomanganese except low-carbon silicomanganese, including silicomanganese briquettes, fines, and
slag. Silicomanganese is a ferroalloy composed principally of manganese, silicon, and iron, and normally
contains much smaller proportions of minor elements, such as carbon, phosphorus, and sulfur.
Silicomanganese is sometimes referred to as ferrosilicon manganese. Silicomanganese is used primarily
in steel production as a source of both silicon and manganese, and sometimes as an alloying agent in the
production of iron castings. Silicomanganese generally contains by weight not less than 4 percent iron,
more than 30 percent manganese, more than 8 percent silicon and not more than 0.2 percent
phosphorus. Silicomanganese is sold primarily in sized, lump form, with sizes generally varying from 8" x
4" to 2" x down,1 though all sizes of silicomanganese material are covered by the petition.
Silicomanganese is classifiable under subheading 7202.30.0000 of the Harmonized Tariff Schedule of the
United States ("HTSUS").
Low-carbon silicomanganese is excluded from the scope of this petition. Low-carbon silicomanganese
contains lower levels of carbon than standard silicomanganese and higher amounts of silicon. It is
sometimes referred to as ferromanganese-silicon. Low-carbon silicomanganese is used in the
manufacture of stainless steel and special carbon steel grades, such as motor lamination grade steel,
which requires a very low carbon content. The low-carbon silicomanganese excluded from this petition
is a ferroalloy with the following chemical specifications by weight: minimum 55 percent manganese,
minimum 27 percent silicon, maximum 0.10 percent phosphorus, maximum 0.10 percent carbon, and
maximum 0.05 percent sulfur. Low-carbon silicomanganese is classifiable under HTSUS subheading
7202.30.0000.
Reporting of information.-- If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
purchaser and/or foreign producer questionnaire), you need not respond to duplicated questions.
Confidentiality.--The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. '1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.

1

The size “2” x down includes lumps that are 2” in length and 2” or less in width.

Business Proprietary
Foreign Producers’ Questionnaire – Silicomanganese

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Verification.--The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting
documents used in the preparation of the questionnaire response. Please also retain a copy of the final
document that you submit.
Release of information.--The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. '1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR '207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import-injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals.
I-1.

OMB statistics.--Please report below the actual number of hours required and the cost to your
firm of completing this questionnaire.
Hours

Dollars

The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
20 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.

Business Proprietary
Foreign Producers’ Questionnaire – Silicomanganese
I-2.

Page 4

Establishments covered.--Provide the name and address of establishment(s) covered by this
questionnaire. If your firm is publicly traded, please specify the stock exchange and trading
symbol.
“Establishment”-- Each facility of a firm in Australia involved in the production or export of
silicomanganese, including auxiliary facilities operated in conjunction with (whether or not
physically separate from) such facilities. Firms operating more than one establishment in
Australia should combine the data for all establishments into a single report.

I-3.

Related U.S. producers.--Does your firm or any related firm produce, have the capability to
produce, or have any plans to produce silicomanganese in the United States or other countries?
No

Yes--Please name the firm(s) and country(ies) below and, if U.S. producer(s),
ensure that they complete the Commission’s producer questionnaire.

Business Proprietary
Foreign Producers’ Questionnaire – Silicomanganese
I-4.

Related U.S. importers.--Does your firm or any related firm import or have any plans to import
silicomanganese into the United States?
No

I-5.

2

3

4

5

Yes--Please name the firm(s) below and ensure that they complete the
Commission’s importer questionnaire.

U.S. importers.--Please provide the names, street addresses (not P.O. boxes), contacts,
telephone numbers, and e-mail addresses of the FIVE largest U.S. importers of your firm’s
silicomanganese in 2014.

Importer’s name

1

Page 5

Contact
person

Email

Telephone

Street address (not
P.O. box), city, state,
and zip code

Street Address
,
City State Zip Code
Street Address
,
City State Zip Code
Street Address
,
City State Zip Code
Street Address
,
City State Zip Code
Street Address
,
City State Zip Code

Share of
your
firm’s
2014 U.S.
exports
(%)

Business Proprietary
Foreign Producers’ Questionnaire – Silicomanganese

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PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Michael Szustakowski (202205-3169, mgs@usitc.gov) or Keysha Martinez (202-205-2136, Keysha.Martinez@usitc.gov). Supply all
data requested on a calendar-year basis.
II-1.

Contact information.-- Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in part II.
Name
Title
Email
Telephone
Fax

II-2.

Changes in operations.--Please indicate whether your firm has experienced any of the following
changes in relation to the production of silicomanganese since January 1, 2012.
(check as many as appropriate)
plant openings
plant closings
relocations
expansions
acquisitions
consolidations
prolonged shutdowns or
production curtailments
revised labor agreements
other (e.g., technology)

(please describe)

Business Proprietary
Foreign Producers’ Questionnaire – Silicomanganese

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Anticipated changes in operations.--Does your firm anticipate any changes in the character of
its operations or organization (as noted above) relating to the production of silicomanganese in
the future?

II-3.

No

Yes–Supply details as to the time, nature, and significance of such changes
and provide underlying assumptions, along with relevant portions of
business plans or other supporting documentation that address this
issue. Include in the response a specific projection of your firm’s
capacity to produce silicomanganese (in short tons) for 2015 and
2016.

Product shifting.--Please provide answers to each of the following questions relating to your
firm’s ability to shift production between silicomanganese and other products.

II-4.

(a)

In relation to furnaces not dedicated 100 percent to the production of silicomanganese,
please provide the following information on the other products produced in those
furnaces (if more than four products, list the largest).

Product(s)

Costs and timeframes involved in switching
production to/from SiMn

Est. share of furnace
fleet’s production time
dedicated to product1
(share)

1. Ferromanganese

2. Ferrosilicon

3.

4.

1

Provide an estimated share that represents how much of the annual average total production
hours of all of your firm’s furnaces relates to the production of the listed product in a given year. For
example, report 25 percent of ferromanganese if in a year 500 hours are dedicated to ferromanganese
and 1500 hours are dedicated to silicomanganese.

Business Proprietary
Foreign Producers’ Questionnaire – Silicomanganese

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Additional discussion:

(b)

In relation to those furnaces dedicated 100 percent to the production of
silicomanganese since January 1, 2012, could these furnaces be converted to the
production of products other than silicomanganese?
No

(c)

Yes.--And at what cost/time constraint?

Does your firm own or operate furnaces not reported in question II-4(a) at all (i.e., not
involved in silicomanganese production during the period) that could be converted to
the production of silicomanganese?
No

Yes.--And at what cost/time constraint?

Business Proprietary
Foreign Producers’ Questionnaire – Silicomanganese
II-5a.

Page 9

Overall capacity and production.-- Please report your firm’s production of products made on
the same equipment and machinery used to produce silicomanganese, and the combined
production capacity on this shared equipment and machinery.
“Average production capacity” or “capacity” –The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods for all
products manufactured in that establishment using the same manufacturing equipment.
Assume normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
(Quantity in short tons)
Calendar years
Item

2012

2013

2014

Overall production capacity
Production of:
Silicomanganese1

0

0

0

0

0

0

Ferromanganese
Ferrosilicon
Other product 3 (from
question II-4a)
Other product 4 (from
question II-4a)
Other products2
Total
1
2

Data on production of silicomanganese will be populated from data reported in question II-11.
Please identify these products:

“Production” --All production in your establishment(s) in Australia, including production
consumed internally within your firm.
II-5b.

Operating parameters.--The production capacity (see definitions in instruction booklet) reported in
II-5a is based on operating
hours per week,
weeks per year.

II-5c.

Capacity calculation.--Please describe the methodology used to calculate overall production
capacity reported in II-5a, and explain any changes in reported capacity.

Business Proprietary
Foreign Producers’ Questionnaire – Silicomanganese

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II-5d.

Production constraints.--Please describe the constraint(s) that set the limit(s) on your firm’s
production capacity.

II-6.

Share of sales.--What percentage of your firm’s total sales in its most recent fiscal year was
represented by sales of silicomanganese?
percent

II-7.

Firm's estimated share of production in Australia.--Please estimate the percentage of total
production of silicomanganese in the country specified on the certification page accounted for by
your firm’s production in 2014.
percent

II-8.

Firm's estimated share of country's exports.--Please estimate the percentage of total exports to
the United States of silicomanganese from the country specified on the certification page
accounted for by your firm’s exports in 2014.
percent

II-9.

Inventories in the United States.--Has your firm, since 2012, maintained any inventories of
silicomanganese in the United States (not including inventories held by firms identified in
questionI-3)?
“Inventories”--Finished goods inventory, not raw materials or work in progress.
No

Yes--Report the quantity of such end-of-period inventories below.
Quantity (in short tons)
Calendar year
Item

2012

2013

2014

Inventory
II-10.

Third country trade actions.--Is the silicomanganese exported by your firm subject to
antidumping/countervailing duty/safeguard findings, remedies, or proceedings?
No

Yes--List the products(s), countries affected, and the date of such
findings/remedies/proceedings.

Business Proprietary
Foreign Producers’ Questionnaire – Silicomanganese
II-11.

Page 11

Trade data.--Report your firm’s production capacity, production, shipments, and inventories
related to the production of silicomanganese in your establishment(s) in Australia during the
specified periods.
Do not submit data by manufacturing facility if they are in the same country. If your firm has
multiple manufacturing establishments within one country, you are required to combine data
for those establishments within one foreign producer questionnaire response.
Do not submit data on multiple countries combined. The establishments reported here should
all be located in the country of the firm’s address reported on the certification page.
Multinational companies with production in multiple subject countries should submit separate
foreign producer questionnaire responses for each subject country.
“Shipments”--Shipments of products produced in your establishment(s) in Australia. Quantities
reported should be net of returns.
“Home market commercial shipments”--Shipments, other than internal consumption and
transfers to related firms, within Australia.
“Home market internal consumption/transfers to related firms”--Shipments made to
related firms in Australia, including product consumed internally by your firm.
“Export shipments”--Shipments to destinations outside Australia, including shipments
to related firms.
“Inventories”--Finished goods inventory, not raw materials or work-in-progress.

Business Proprietary
Foreign Producers’ Questionnaire – Silicomanganese
II-11.

Page 12

Trade data--Continued.

Quantity (in short tons)

Item

Actual experience

Projections1

Calendar year

Calendar year

2012

2013

2014

2015

2016

2

Average production capacity (A)
Beginning-of-period inventories
(B)
Production (C)
Home market shipments:
Internal consumption/
transfers (D)
Commercial shipments (E)
Exports to the United States (F)
Exports to all other markets3 (G)
Total exports (H)
(should equal F+G)

0

0

0

0

0

Total shipments (I)
(should equal D+E+F+G)

0

0

0

0

0

End-of-period inventories (J)
1

Please explain the basis for your firm’s projections.
The production capacity reported is based on operating
hours per week,
weeks per year. Please
describe the methodology used to calculate production capacity, and explain any changes in reported capacity.
2

3

Identify principal other export markets.

Business Proprietary
Foreign Producers’ Questionnaire – Silicomanganese
II-11.

Page 13

Trade data.—Continued.
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported
for the end-of-period inventories (i.e., line J) should be equal to the beginning-of-period
inventories (i.e., line B), plus production (i.e., line C), less total shipments (i.e., lines D, E, F, and
G). Please ensure that any differences are not due to data entry errors in completing this form,
but rather actually reflect your firm’s records; and also provide any likely explanations for any
differences (e.g., theft, loss, damage, record systems issues, etc.) if they exist.

Item
B + C – D – E – F –G – J =
should equal zero ("0") or
provide an explanation.1

2012

Actual experience

Projections

Calendar year

Calendar year

2013

0

2014

0

2015

0

2016

0

1

Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate.

II-12.

Other explanations:--If your firm would like to further explain a response to a question in Part II
that did not provide a narrative box, please note the question number and the explanation in
the space provided below. Please also use this space to highlight any issues your firm had in
providing the data in this section, including but not limited to technical issues with the MS Word
questionnaire.

0

Business Proprietary
Foreign Producers’ Questionnaire – Silicomanganese

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HOW TO FILE YOUR QUESTIONNAIRE RESPONSE
This questionnaire is available as a “fillable” form in MS Word format on the Commission’s
website at:
http://www.usitc.gov/investigations/701731/2015/silicomanganese_australia/preliminary.htm

Please do not attempt to modify the format or permissions of the questionnaire
document. Please submit the completed questionnaire using one of the methods
noted below. If your firm is unable to complete the MS Word questionnaire or
cannot use one of the electronic methods of submission, please contact the
Commission for further instructions.
• Upload via Secure Drop Box.—Upload the MS Word questionnaire along with a scanned copy
of the signed certification page (page 1) through the Commission’s secure upload facility:
Web address: https://dropbox.usitc.gov/oinv/ Pin: SIMN
• E-mail.—E-mail your questionnaire to mgs@usitc.gov; include a scanned copy of the signed
certification page (page 1). Please note that submitting your questionnaire by e-mail may subject your

firm’s business proprietary information to transmission over an unsecure environment and to possible
disclosure. If you choose this option, the Commission warns you that any risk involving possible disclosure
of such information is assumed by the submitter and not by the Commission.

If your firm did not produce or export this product, please fill out page 1, print, sign, and
submit a scanned copy to the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, you are required to serve
a copy of the completed questionnaire on parties to the proceeding that are subject to
administrative protective order (see 19 CFR §207.7). A list of such parties may be obtained from
the Commission’s Secretary (202-205-1803). A certificate of service must accompany the
completed questionnaire you submit (see 19 CFR §207.7). Service of the questionnaire must be
made in paper form.