Download:
pdf |
pdfOMB No. 3117‐0016/USITC No. 19‐3‐4087; Expiration Date: 6/30/2020
(No response is required if currently valid OMB control number is not displayed)
LOST SALES AND LOST REVENUE SURVEY
UTILITY SCALE WIND TOWERS FROM CANADA, INDONESIA, KOREA, AND
VIETNAM
This survey must be received by the Commission by July 23, 2019
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 countervailing and antidumping duty investigations concerning utility scale wind towers (“wind
towers”) from Canada, Indonesia, Korea, and Vietnam (Inv. Nos. 701‐TA‐627‐629 and 731‐TA‐1458‐1461 (Preliminary)).
The information requested in the questionnaire is requested under the authority of the Tariff Act of 1930, title VII. This
report is mandatory and failure to reply as directed can result in a subpoena or other order to compel the submission of
records or information in your firm’s possession (19 U.S.C. § 1333(a)). Further information on this survey can be obtained
from John Benedetto (202‐205‐3270, John.Benedetto@usitc.gov).
Name of firm
Address
City
State
Zip Code
Website
Has your firm purchased or imported for own use or sale wind towers (as defined on next page) at any time
since January 1, 2016?
NO
(Sign the certification below and promptly return only this page of the survey to the Commission)
YES
(Complete all parts of the survey, and return the entire survey to the Commission)
Return questionnaire via the U.S. International Trade Commission Drop Box by clicking on the
following link: https://dropbox.usitc.gov/oinv/. (PIN: WIND)
CERTIFICATION
I certify that the information herein supplied in this survey 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 submitting this certification I
also grant consent for the Commission, and its employees and contract personnel, to use the information provided in this survey
and throughout this proceeding in any other import‐injury proceedings conducted by the Commission on the same or similar
merchandise.
I, the undersigned, acknowledge that information submitted in response to this request for information and throughout this
investigation or other proceeding may be disclosed to and used: (i) by the Commission, its employees and Offices, and contract
personnel (a) for developing or maintaining the records of this or a related proceeding, or (b) in internal investigations, audits,
reviews, and evaluations relating to the programs, personnel, and operations of the Commission including under 5 U.S.C. Appendix
3; or (ii) by U.S. government employees and contract personnel, solely for cybersecurity purposes. I understand that all contract
personnel will sign appropriate nondisclosure agreements.
Name of Authorized Official Title of Authorized Official
Date
Signature
Phone
Email address
Business Proprietary
Lost Sales and Lost Revenue Survey‐ Wind Towers
Page 2
GENERAL INFORMATION
Background.— This proceeding was instituted in response to a petition filed on July 9, 2019, by the
Wind Tower Trade Coalition (Arcosa Wind Towers, Inc. (Dallas, TX) and Broadwind Towers, Inc.
(Manitowoc, WI)). Countervailing and 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 (“Commerce”) makes an affirmative
determination of subsidization and/or dumping. Questionnaires and other information pertinent to this
proceeding are available at https://www.usitc.gov/investigations/701731/2019/
utility_scale_wind_towers_canada_indonesia_korea/preliminary.htm.
Wind towers covered by these investigations are certain wind towers, whether or not tapered, and
sections thereof. Certain wind towers are designed to support the nacelle and rotor blades in a wind
turbine with a minimum rated electrical power generation capacity in excess of 100 kilowatts and with a
minimum height of 50 meters measured from the base of the tower to the bottom of the nacelle (i.e.,
where the top of the tower and nacelle are joined) when fully assembled.
A wind tower section consists of, at a minimum, multiple steel plates rolled into cylindrical or conical
shapes and welded together (or otherwise attached) to form a steel shell, regardless of coating, end‐
finish, painting, treatment, or method of manufacture, and with or without flanges, doors, or internal or
external components (e.g., flooring/decking, ladders, lifts, electrical buss boxes, electrical cabling,
conduit, cable harness for nacelle generator, interior lighting, tool and storage lockers) attached to the
wind tower section. Several wind tower sections are normally required to form a completed wind tower.
Wind towers and sections thereof are included within the scope whether or not they are joined with
nonsubject merchandise, such as nacelles or rotor blades, and whether or not they have internal or
external components attached to the subject merchandise.
Specifically excluded from the scope are nacelles and rotor blades, regardless of whether they are
attached to the wind tower. Also excluded are any internal or external components which are not
attached to the wind towers or sections thereof, unless those components are shipped with the tower
sections.
Wind towers are currently imported under statistical reporting numbers 7308.20.00201 or
8502.31.00002 of the Harmonized Tariff Schedule of the United States (HTSUS). The HTSUS provisions
are for convenience and customs purposes; the written description of the scope is dispositive.
Unit.—A unit, unless otherwise stated, is a complete wind tower (whether or not comprised of multiple
sections) or wind tower equivalent (e.g., one section of a wind tower comprised of four sections would
be equal to ¼ or 0.25 wind towers).
1
Wind towers of iron or steel are classified under HTSUS 7308.20.0020 when imported separately as a tower or
tower section(s).
2
Wind towers may also be classified under HTSUS 8502.31.0000 when imported as combination of goods with a
wind turbine (i.e., accompanying nacelles and/or rotor blades).
Business Proprietary
Lost Sales and Lost Revenue Survey‐ Wind Towers
Page 3
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,
and/or purchaser 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.
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. In addition, if your firm is a U.S. producer, the information you
provide on your production and imports of wind towers and your responses to the questions in Part I of
the producer questionnaire will be provided to the U.S. Department of Commerce, upon its request, for
use in connection with (and only in connection with) its requirement pursuant to section
702(c)(4)/732(c)(4) of the Act (19 U.S.C. § 1671a(c)(4)/1673a(c)(4)) to make a determination concerning
the extent of industry support for the petition requesting this proceeding. Any information provided to
Commerce will be transmitted under the confidentiality and release guidelines set forth above. Your
response to these questions constitutes your consent that such information be provided to Commerce
under the conditions described above.
Contact information.‐‐Please identify the responsible individual and the manner by which Commission
staff may contact that individual regarding the confidential information submitted in this survey. This
may or may not be the person whose signature is at the bottom of page 1.
Name
Title
Email
Telephone
Business Proprietary
Lost Sales and Lost Revenue Survey‐ Wind Towers
Page 4
Firms operating more than one establishment should combine the data for all establishments into a
single response.
PURCHASE INFORMATION
1.
Purchases and imports.— Report separately your firm’s domestic purchases and imports of
wind towers.
“Purchase” – Purchase from a U.S. entity such as a U.S. producer, a U.S. importer, or other U.S.
firm.
“Import” – Purchase directly from a foreign supplier and your firm is the importer of record.
2016
2017
2018
Jan‐Mar 2019
Item
Purchases of wind towers produced
in—
United States
Quantity (in units)
Canada
Indonesia
Korea
Vietnam
1
All other countries
Sources unknown2
0
0
0
0
Indonesia
Korea
0
0
0
0
Total purchases
Imports of wind towers from—
Canada
Vietnam
1
All other countries
3
Total imports
1
Please identify these countries:
Please indicate the firm(s) from which you purchased this merchandise:
3
If your firm imported wind towers at any time since January 1, 2016, please also complete and return a
U.S. importers' questionnaire in this proceeding. Please ensure the import quantities above match the data
in your U.S. importers’ questionnaire.
2
Business Proprietary
Lost Sales and Lost Revenue Survey‐ Wind Towers
Page 5
2. Changes in purchasing patterns.—Please indicate how the shares of your firm’s purchases of wind
towers from different sources have changed since January 1, 2016.
Source of
purchases
Did not
purchase Decreased Increased
Constant Fluctuated
Explanation for trend
United States
Canada
Indonesia
Korea
Vietnam
All other
countries
Sources
unknown
3. Major purchasing factors.‐‐Please list, in order of their importance, the main factors your firm
considers in deciding from whom to purchase wind towers.
1.
2.
3.
Please list any other factors that are very important in your purchase decisions:
Business Proprietary
Lost Sales and Lost Revenue Survey‐ Wind Towers
Page 6
4. Purchasing subject imports rather than domestic products.—
(a)
Since January 2016, did your firm import and/or purchase imports of wind towers from
Canada, Indonesia, Korea, and/or Vietnam instead of purchasing U.S.‐produced wind
towers? Respond for each subject country.
No
Yes
(If “No” for all countries, skip to next
Source
(also respond to parts (b) and (c))
question)
Canada
Indonesia
Korea
Vietnam
(b)
If you responded “Yes” to part (a), was the imported product priced lower than the
domestic product?
Source
Yes
No
Canada
Indonesia
Korea
Vietnam
(c)
If you responded “Yes” to part (a), was price a primary reason for importing and/or
purchasing subject imports rather than domestic product?
Source
Yes
If Yes, estimate the quantity
of imports purchased and/or
imported instead of domestic
product since January 2016
(in units)
Canada
Indonesia
Korea
Vietnam
No
If No, please indicate the
reason your firm imported
and/or purchased imports
instead of domestic product
Business Proprietary
Lost Sales and Lost Revenue Survey‐ Wind Towers
Page 7
5.
U.S. producers and import competition.—
(a)
Since January 1, 2016, in connection with a sale or offer to sell wind towers to your firm,
did U.S. producers reduce their prices of domestically produced wind towers in order to
compete with lower‐priced imports of wind towers from the subject
countries? Respond for each subject country.
Yes (also respond to
No (If “No” for all countries,
Source
question part (b))
skip to next question)
Don’t know
(b)
Canada
Indonesia
Korea
Vietnam
If your firm responded “yes” to any of the above countries, please provide an estimate
of the reduction in U.S. producers’ prices, and any additional explanations, such as
timing (e.g., months/years), frequency of price reductions, or other market/competitive
factors.
Source
Estimated
reduction in U.S.
prices
(percent)
Canada
%
Indonesia
%
Korea
%
Vietnam
%
Additional explanation, including such information as
timing (e.g., months/years), frequency of price
reductions, or other market/competitive factors
6. Other explanations‐‐Please provide any additional comments in this box.
Business Proprietary
Lost Sales and Lost Revenue Survey‐ Wind Towers
Page 8
OMB INFORMATION
8. OMB statistics.‐‐Please report the actual number of hours required and the cost to your firm of
completing this survey.
Hours
Dollars
The questions in this survey 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 survey is estimated to average 4 hours per response,
including the time for reviewing instructions, gathering data, and completing and reviewing the
survey.
We welcome comments regarding the accuracy of this burden estimate, suggestions for reducing the
burden, and any suggestions for improving this survey. Please attach such comments to your response
or send to the Office of Investigations, USITC, 500 E St. SW, Washington, DC 20436.
HOW TO FILE YOUR SURVEY RESPONSE
Please do not attempt to modify the format or permissions of the survey document.
Please submit the completed survey using one of the methods noted below. If your firm
is unable to complete the MS Word survey 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 survey 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: WIND
• E‐mail.—E‐mail the MS Word survey to John.Benedetto@usitc.gov; include a scanned copy of the
signed certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic documents
that are electronically transmitted to the Commission to protect your sensitive information from
unauthorized disclosure. The USITC secure drop‐box system and the Electronic Document Information
System (EDIS) use Federal Information Processing Standards (FIPS) 140‐2 cryptographic algorithms to
encrypt data in transit. Submitting your nonpublic documents by a means that does not use these
encryption algorithms (such as by email) may subject your firm’s nonpublic information to unauthorized
disclosure during transmission. If you choose a non‐encrypted method of electronic transmission, the
Commission warns you that the risk of such possible unauthorized disclosure is assumed by you and not
by the Commission.
If your firm did not purchase this product, please fill out page 1, print, sign, and submit a scanned copy
to the Commission.
File Type | application/pdf |
File Title | Microsoft Word - Wind Towers II (P) - LSLR questionnaire - DRAFT |
Author | ahdia.bavari |
File Modified | 2019-07-10 |
File Created | 2019-07-10 |