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pdfOMB No. 3117‐0016/USITC No. 18‐1‐3952; Expiration Date: 6/30/2020
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U.S. PRODUCERS’ QUESTIONNAIRE
UTILITY SCALE WIND TOWERS FROM CHINA AND VIETNAM
This questionnaire must be received by the Commission by October 31, 2018
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 review of the countervailing and antidumping duty orders concerning utility scale wind towers
(“wind towers”) from China and Vietnam (Inv. Nos. 701‐TA‐486 and 731‐TA‐1195‐1196 (Review)). 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)).
Name of firm
Address
City
State
Zip Code
Website
Has your firm produced wind towers (as defined on the next page) at any time since January 1, 2012?
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: WIND)
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 or reviews
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
proceeding or other proceedings 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
U.S. Producers’ Questionnaire – Wind towers (R1)
Page 2
PART I.—GENERAL INFORMATION
Background.‐‐On February 15, 2013, the Department of Commerce (“Commerce”) issued countervailing
and antidumping duty orders on imports of wind towers from China and Vietnam. On January 2, 2018,
the Commission instituted a review pursuant to section 751(c) of the Tariff Act of 1930 (19 U.S.C. §
1675(c)) (the Act) to determine whether revocation of the orders would be likely to lead to continuation
or recurrence of material injury to the domestic industry within a reasonably foreseeable time. If both
the Commission and Commerce make an affirmative determination, the orders will remain in place. If
either the Commission or Commerce makes a negative determination, Commerce will revoke the orders.
Questionnaires and other information pertinent to this proceeding are available at
https://www.usitc.gov/investigations/701731/2018/utility_scale_wind_towers_china_and_vietnam/full
_review.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.
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). Prior to 2011, subject
merchandise was classified in the HTSUS under statistical reporting number 7308.20.0000 and may
continue to be to some degree. 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 are classified under HTSUS 7308.20.0020 when imported as a tower or tower section(s) alone.
Wind towers may also be classified under HTSUS 8502.31.0000 when imported as part of a wind turbine (i.e.,
accompanying nacelles and/or rotor blades).
2
Business Proprietary
U.S. Producers’ Questionnaire – Wind towers (R1)
Page 3
Reporting of information.‐‐If information is not readily available from your records in exactly the form
requested, furnish carefully prepared estimates. If your firm is completing more than one questionnaire
in connection with this proceeding (i.e., a producer, importer, and/or purchaser questionnaire), you
need not respond to duplicated questions in the questionnaires.
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 of your 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.
D‐GRIDS tool.‐‐The Commission has a tool that firms can use to move data from their own MS Excel
compilation files into self‐contained data tables within this MS Word questionnaire, thereby reducing
the amount of cell‐by‐cell data entry that would be required to complete this form. This tool is a macro‐
enabled MS Excel file available for download from the Commission's generic questionnaires webpage
(https://www.usitc.gov/trade_remedy/question.htm) called the "D‐GRIDs tool." Use of this tool to help
your firm complete this questionnaire is optional. Firms opting to use the D‐GRIDs tool to populate their
data into this questionnaire will need the D‐GRIDs specification sheet PDF file specific to this proceeding
(available on the case page which is linked under the "Background" above) which includes the necessary
references relating to this questionnaire, as well as the macro‐enable MS Excel D‐GRIDs tool itself from
the generic questionnaires page. More detailed instructions on how to use the D‐GRIDs tool are
available within the D‐GRIDs tool itself.
Business Proprietary
U.S. Producers’ Questionnaire – Wind towers (R1)
Page 4
I‐1.
OMB statistics.‐‐Please report below the actual number of hours required and the cost to your
firm of completing this questionnaire.
I‐2.
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
50 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.
Establishments covered.‐‐Provide the city, state, zip code, and brief description of each
establishment covered by this questionnaire. If your firm is publicly traded, please specify the
stock exchange and trading symbol in the footnote to the table. Firms operating more than one
establishment should combine the data for all establishments into a single report.
“Establishment”‐‐Each facility of a firm involved in the production of wind towers, including
auxiliary facilities operated in conjunction with (whether or not physically separate from) such
facilities.
Establishments
Covered1
City, State
Zip (5 digit)
Description
1
2
3
4
5
6
1
Additional discussion on establishments consolidated in this questionnaire:
I‐3.
Position regarding continuation of the orders.‐‐Does your firm support or oppose continuation
of the following antidumping and countervailing duty orders currently in place for wind towers?
Country
Support
Oppose
Take no position
China AD
Vietnam AD
China CVD
Business Proprietary
U.S. Producers’ Questionnaire – Wind towers (R1)
I‐4.
Ownership.‐‐Is your firm owned, in whole or in part, by any other firm?
No
Yes‐‐List the following information.
Firm name
Page 5
Extent of
ownership
(percent)
Address
I‐5.
Related importers/exporters.‐‐Does your firm have any related firms, either domestic or
foreign, that are engaged in importing wind towers into the United States or that are engaged in
exporting wind towers to the United States?
No
Yes‐‐List the following information.
Firm name
Country
Affiliation
Business Proprietary
U.S. Producers’ Questionnaire – Wind towers (R1)
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I‐6.
Related producers.‐‐Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of wind towers?
No
Yes‐‐List the following information.
Firm name
I‐7.
Country
Affiliation
Business plan.‐‐In Parts II and IV of this questionnaire we request a copy of your company’s
business plan. Does your company or any related firm have a business plan or any internal
documents that describe, discuss, or analyze expected market conditions for wind towers?
No
Yes
If yes, please provide the requested documents. If you are not providing the
requested documents, please explain why not.
Business Proprietary
U.S. Producers’ Questionnaire – Wind towers (R1)
Page 7
PART II.‐‐TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from 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
II‐2a. Changes in operations.‐‐Please indicate whether your firm has experienced any of the following
changes in relation to the production of wind towers since January 1, 2012.
Check as many as appropriate.
If checked, please describe, including the month and
year of the event; leave blank if not applicable.
Plant openings
Plant closings
Relocations
Expansions
Acquisitions
Consolidations
Prolonged shutdowns or
production curtailments
Revised labor agreements
Other (e.g., technology)
Business Proprietary
U.S. Producers’ Questionnaire – Wind towers (R1)
Page 8
II‐2b Anticipated changes in operations.—Does your firm anticipate any changes in in the character
of its operations or organization relating to the production of wind towers in the future?
No
Yes
If 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 documentations that
address this issue. Include in your response a specific projection of your
firm’s capacity to produce wind towers (in units) for 2018 and 2019.
II‐3a. Production using same machinery.—Does your firm produce other products on the same
equipment and machinery used to produce wind towers?
No
Yes
If yes‐‐ Please describe the other products:
II‐3d. Production constraints.‐‐Please describe the constraint(s) that set the limit(s) on your firm’s
production capacity.
II‐3e. Product shifting.—
(i)
Is your firm able to switch production capacity between wind towers and other products
using the same equipment and/or labor?
No
Yes
If yes—(i.e., have produced other products or are able to produce other
products) Please identify other actual or potential products:
(ii)
Please describe the factors that affect your firm’s ability to shift production capacity
between products (e.g., time, cost, relative price change, etc.), and the degree to which
these factors enhance or constrain such shifts.
Business Proprietary
U.S. Producers’ Questionnaire – Wind towers (R1)
Page 9
II‐4. Production, shipment, and inventory data.‐‐Report your firm’s production capacity, production,
shipments, and inventories related to the production of wind towers in its U.S. establishment(s)
during the specified periods.
“Average production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. 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).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
“U.S. commercial shipments” –Shipments made within the United States as a result of an arm’s
length commercial transaction in the ordinary course of business. Report net values (i.e., gross
sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods) in U.S. dollars, f.o.b. your point of shipment.
“Internal consumption” – Product consumed internally by your firm. Such transactions are
valued at fair market value.
“Transfers to related firms” –Shipments made to related domestic firms. Such transactions
are valued at fair market value.
“Related firm” –A firm that your firm solely or jointly owns, manages, or otherwise controls.
“Export shipments” –Shipments to destinations outside the United States, including shipments
to related firms.
“Inventories”— Finished goods inventory, not raw materials or work‐in‐progress.
“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).
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the trade data, as Commission staff may contact your firm regarding
questions on the trade data. The Commission may also request that your company submit copies
of the supporting documents/records (such as production and sales schedules, inventory records,
etc.) used to compile these data.
Business Proprietary
U.S. Producers’ Questionnaire – Wind towers (R1)
Page 10
II‐4. Production, shipment, and inventory data.‐‐Continued
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).
Quantity (in units) and value (in $1,000)
Calendar year
Item
2012
2013
2014
2015
January‐June
2016
2017
2017
2018
Average production
capacity1 (quantity) (A)
Beginning‐of‐period
inventories (quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
quantity (D)
value (E)
2
Internal consumption:
quantity (F)
value (G)
Transfers to related
firms:2
quantity (H)
value (I)
3
Export shipments:
quantity (J)
value (K)
End‐of‐period inventories
(quantity) (L)
1
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 (use additional pages as necessary). .
2
Internal consumption and transfers to related firms must be valued at fair market value. Does your firm
use a different basis for valuing these transactions, please specify that basis (e.g., cost, cost plus, etc.):
(however, provide the data above at fair market value).
3
Identify your firm’s principal export markets: .
Business Proprietary
U.S. Producers’ Questionnaire – Wind towers (R1)
Page 11
II‐4. Production, shipment, and inventory data.‐‐Continued
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.‐‐Generally, the data reported for the
end‐of‐period inventories (i.e., line L) 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, F, H, and J). Please ensure that any
differences are not due to data entry errors in completing this form, but rather reflect your firm’s actual
records; and, also provide explanations for any differences (e.g., theft, loss, damage, record systems
issues, etc.) if they exist.
Calendar year
Item
B + C – D – F – H – J – L
= should equal zero
("0") or provide an
explanation.1
2012
2013
0
2014
0
2015
0
0
January‐June
2016
0
2017
0
2017
2018
0
0
1
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are
nonetheless accurate: .
II‐5. Channels of distribution.‐‐ Report your firm’s U.S. shipments (i.e., inclusive of commercial U.S.
shipments, internal consumption, and transfers to related firms) by channel of distribution.
Quantity (in units)
Calendar year
Item
2012
Channels of distribution:
U.S. shipments—
to distributors (M)
to end users (N)
2013
2014
2015
January‐June
2016
2017
2017
2018
RECONCILIATION OF CHANNELS.‐‐Please ensure that the quantities reported for channels of distribution
(i.e., lines M and N) in each time period equal the quantity reported for U.S. shipments (i.e., lines D, F,
and H) in each time period. If the calculated fields below return values other than zero (i.e., “0”), the
data reported must be revised prior to submission to the Commission.
Calendar year
Reconciliation item
M + N – D – F – H =
zero ("0"), if not revise.
2012
0
2013
0
2014
0
2015
0
January‐June
2016
0
2017
0
2017
0
2018
0
Business Proprietary
U.S. Producers’ Questionnaire – Wind towers (R1)
Page 12
II‐6. Employment data.‐‐Report your firm’s employment‐related data related to the production of
wind towers and provide an explanation for any trends in these data.
“Production and Related Workers” (PRWs) includes working supervisors and all nonsupervisory
workers (including group leaders and trainees) engaged in fabricating, processing, assembling,
inspecting, receiving, storage, handling, packing, warehousing, shipping, trucking, hauling,
maintenance, repair, janitorial and guard services, product development, auxiliary production
for plant’s own use (e.g., power plant), recordkeeping, and other services closely associated with
the above production operations.
Average number employed may be computed by adding the number of employees, both full
time and part time, for the 12 pay periods ending closest to the 15th of the month and divide
that total by 12. For the January to June periods, calculate similarly and divide by 6.
If your firm had the same number of PRWs in all calendar years and had not experienced
any changes in PRWs in the most recent interim period, you would have the same
number of PRWs for the interim periods, regardless of whether the interim periods are
Jan‐Mar (Q1), Jan‐June (Q1+Q2), or Jan‐Sept (Q1+Q2+Q3).”
“Hours worked” includes time paid for sick leave, holidays, and vacation time. Include overtime
hours actually worked; do not convert overtime pay to its equivalent in straight time hours.
“Wages paid” –Total wages paid before deductions of any kind (e.g., withholding taxes, old‐age
and unemployment insurance, group insurance, union dues, bonds, etc.). Include wages paid
directly by your firm for overtime, holidays, vacations, and sick leave.
Calendar year
January‐June
Item
Employment data:
Average number of
PRWs (number) (O)
2012
2013
2014
2015
2016
2017
2017
2018
Hours worked by PRWs
(1,000 hours) (P)
Wages paid to PRWs
($1,000) (Q)
Explanation of trends:
Business Proprietary
U.S. Producers’ Questionnaire – Wind towers (R1)
Page 13
II‐7. Transfers to related firms.‐‐If your firm reported transfers to related firms in question II‐4,
please indicate the nature of the relationship between your firm and the related firms (e.g., joint
venture, wholly owned subsidiary), whether the transfers were priced at market value or by a
non‐market formula, whether your firm retained marketing rights to all transfers, and whether
the related firms also processed inputs from sources other than your firm.
II‐8.
Order book production.—Report your firm’s expected production based on its “order books”
for the specified periods.
Quantity (in units)
Jul‐Sept
Oct‐Dec
Jan‐Mar
Apr‐Jun
Jul‐Sept
Sept‐Dec
Item
2018
2018
2019
2019
2019
2019
Expected
production
Business Proprietary
U.S. Producers’ Questionnaire – Wind towers (R1)
Page 14
II‐9. Purchases.‐‐ Has your firm purchased wind towers produced in the United States or in other
countries since January 1, 2012? (Do not include imports for which your firm was the importer
of record. These should be reported in an importer questionnaire).
“Purchase” – A transaction to buy product from a U.S. corporate entity such as another U.S.
producer, a U.S. distributor, or a U.S. firm that has directly imported the product.
“Import” –A transaction to buy from a foreign supplier where your firm is the importer of
record.
No
Yes
If yes—(1) COMPLETE AND RETURN A U.S. PURCHASERS’
QUESTIONNAIRE; and
(2) Report such purchases in the table below and explain the reasons for
your firm’s purchases:
Note: If your firm served as the importer of record for any purchases from foreign suppliers,
either for your own account or as a service for another entity, those purchases are to be
considered "imports" not "purchases" and should not be included in the table below
Quantity (in units)
Calendar years
Item
January‐June
2012
2013
2014
2015
2016
2017
2017
2018
Vietnam
All other sources
Purchases from
domestic
producers2
Purchases from
other sources2
Purchases from U.S.
importers1 of wind
towers from—
China
1
Please list the name of the importer(s) from which your firm purchased this product. If your firm’s
import suppliers differ by source, please identify the source for each listed supplier: .
2
Please list the name of the producer(s) or U.S. distributor(s) from which your firm purchased this
product and the reason for purchasing instead of producing these items: .
Business Proprietary
U.S. Producers’ Questionnaire – Wind towers (R1)
Page 15
II‐10. Toll production.‐‐Since January 1, 2012, has your firm been involved in a toll agreement
regarding the production of wind towers?
“Toll agreement”‐‐Agreement between two firms whereby the first firm furnishes the raw
materials and the second firm uses the raw materials to produce a product that it then returns
to the first firm with a charge for processing costs, overhead, etc.
No
Yes
If yes‐‐ Please describe the toll arrangement(s) and name the firm(s)
involved.
II‐11. Foreign trade zones.‐‐
(a)
Firm's FTZ operations.‐‐Does your firm produce wind towers in and/or admit wind
towers into a foreign trade zone (FTZ)?
“Foreign trade zone” is a designated location in the United States where firms utilize
special procedures that allow delayed or reduced customs duty payments on foreign
merchandise. A foreign trade zone must be designed as such pursuant to the rules and
procedures set forth in the Foreign‐Trade Zones Act.
No
Yes
If yes‐‐ Describe the nature of your firms operations in FTZs and identify
the specific FTZ site(s).
(b)
Other firms' FTZ operations.‐‐To your knowledge, do any firms in the United States
import wind towers into a foreign trade zone (FTZ) for use in distribution of wind towers
and/or the production of downstream articles?
No
Yes
If yes‐‐Identify the firms and the FTZs.
II‐12. Direct imports.‐‐Since January 1, 2012, has your firm imported wind towers?
“Importer” – The person or firm primarily liable for the payment of any duties on the
merchandise, or an authorized agent acting on his behalf. The importer may be the consignee,
or the importer of record.
No
Yes
If yes‐‐ COMPLETE AND RETURN A U.S. IMPORTERS’ QUESTIONNAIRE. (See
link on page 2)
Business Proprietary
U.S. Producers’ Questionnaire – Wind towers (R1)
Page 16
For questions II‐13 and II‐14, if your response differs for particular orders, please indicate and explain
the particular effect of imposition and/or revocation of specific orders.
II‐13. Effect of order.‐‐Describe the significance of the existing countervailing and antidumping duty
orders covering imports of wind towers from China and Vietnam in terms of its effect on your
firm’s production capacity, production, U.S. shipments, inventories, purchases, employment,
revenues, costs, profits, cash flow, capital expenditures, research and development
expenditures, and asset values. You may wish to compare your firm’s operations before and
after the imposition of the order.
II‐14. Likely impact of revocation.‐‐Would your firm anticipate any changes in in the character of its
operations or organization, including its production capacity, production, U.S. shipments,
inventories, purchases, employment, revenues, costs, profits, cash flow, capital expenditures,
research and development expenditures, or asset values relating to the production of wind
towers in the future if the countervailing and antidumping duty orders on wind towers from
China and Vietnam were to be revoked?
No
Yes
If 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
documentations that address this issue. Include in your
response a specific projection of your firm’s capacity to
produce wind towers (in units) for 2019 and 2020.
II‐15. Other explanations:‐‐If your firm would like to explain further a response to a question in Part II
for which a narrative box was not provided, 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.
Business Proprietary
U.S. Producers’ Questionnaire – Wind towers (R1)
Page 17
PART III.‐‐FINANCIAL INFORMATION
Address questions on this part of the questionnaire to David Boyland (202‐708‐4725,
david.boyland@usitc.gov).
III‐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 III.
Name
Title
Email
Telephone
III‐2. Accounting system.‐‐Briefly describe your firm’s financial accounting system.
A.
When does your firm’s fiscal year end (month and day)?
If your firm’s fiscal year changed during the data‐collection period, explain below:
B.1. Describe the lowest level of operations (e.g., plant, division, company‐wide) for which
financial statements are prepared that include wind towers:
2. Does your firm prepare profit/loss statements for wind towers:
Yes
No
3. How often did your firm (or parent company) prepare financial statements (including
annual reports, 10Ks)? Please check relevant items below.
Audited, unaudited, annual reports, 10Ks, 10 Qs,
Monthly, quarterly, semi‐annually, annually
4. Accounting basis: GAAP, cash, tax, or other comprehensive basis of
accounting (specify)
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the financial data, as Commission staff may contact your firm
regarding questions on the financial data. The Commission may also request that your company
submit copies of the supporting documents/records (financial statements, including internal
profit‐and‐loss statements for the division or product group that includes wind towers, as well as
specific statements and worksheets) used to compile these data.
III‐3.
Cost accounting system.‐‐Briefly describe your firm’s cost accounting system (e.g., standard
cost, job order cost, etc.).
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U.S. Producers’ Questionnaire – Wind towers (R1)
Page 18
III‐4. Allocation basis.‐‐Briefly describe your firm’s allocation basis, if any, for COGS, SG&A, and
interest expense and other income and expenses.
III‐5.
Product listing.‐‐Please list the products your firm produces in the facilities in which it produces
wind towers, and provide the share of net sales accounted for by these products in your firm’s
most recent fiscal year.
Products
Share of sales
Wind towers
%
%
%
%
%
III‐6.
Does your firm purchase inputs (raw materials, labor, energy, or any services) used in the
production of wind towers from any related suppliers (e.g., inclusive of transactions between
related firms, divisions and/or other components within the same company)?
Yes‐‐Continue to question III‐7.
III‐7.
No‐‐Skip to question III‐9a.
Inputs from related suppliers.‐‐Please identify the inputs used in the production of wind towers
that your firm purchases from related suppliers and that are reflected in question III‐9a. For
“Share of total COGS” please report this information by relevant input on the basis of your most
recently completed fiscal year. For “Input valuation” please describe the basis, as recorded in
the company’s own accounting system, of the purchase cost from the related supplier; e.g., the
related supplier’s actual cost, cost plus, negotiated transfer price to approximate fair market
value.
Input
Related supplier
Share of total COGS
Input valuation as recorded in the firm’s accounting books and records:
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Page 19
III‐8. Inputs from related suppliers at cost.‐‐Please confirm that the inputs purchased from related
suppliers, as identified in III‐7, were reported in III‐9a (financial results on wind towers) in a
manner consistent with the firm’s accounting books and records.
Yes
No
If no‐‐In the space below, please report the valuation basis of inputs
purchased from related suppliers as reported in question III‐9a.:
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Page 20
III‐9a. Operations on wind towers.‐‐Report the revenue and related cost information requested below
on the wind towers operations of your firm’s U.S. establishment(s).1 Do not report resales of
products. Note that internal consumption and transfers to related firms must be valued at fair
market value. Input purchases from related suppliers should be consistent with and based on
information in the firm’s accounting books and records. Provide data for your firm’s six most
recently completed fiscal years, and for the specified interim periods. If your firm was involved
in tolling operations (either as the toller or as the tollee), please contact David Boyland at (202)
708‐4725 before completing this section of the questionnaire.
Quantity (in units) and value (in $1,000)
Fiscal years ended‐‐
Item
2012
2013
Net sales quantities:2
2014
2015
2016
2017
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms
(“Transfers”)
0
0
0
0
0
0
Internal consumption
Transfers to related firms
0
0
0
0
0
0
Raw materials
Direct labor
Other factory costs
Total net sales quantities
Net sales values:2
Commercial sales
Total net sales values
Cost of goods sold (COGS):3
Total COGS
0
0
0
0
0
0
Gross profit or (loss)
0
0
0
0
0
0
Selling, general, and administrative
(SG&A) expenses:
Selling expenses
General and administrative
expenses
0
0
0
0
0
0
0
0
0
0
0
0
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
All other expense items
All other income items
0
0
0
0
0
0
Net income or (loss) before income
taxes
Depreciation/amortization
included above
1 Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
2
Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding shipment quantities
and values reported in Part II of this questionnaire.
3 COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
Note ‐‐ The table above contains calculations that will appear when you have entered data in the MS
Word form fields.
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U.S. Producers’ Questionnaire – Wind towers (R1)
III‐9a. Operations on wind towers.‐‐Continued
Page 21
Quantity (in units) and value (in $1,000)
Item
Net sales quantities:3
January‐June 2017
January‐June 2018
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
0
0
Internal consumption
Transfers to related firms
0
0
Raw materials
Direct labor
Other factory costs
Total COGS
0
0
Gross profit or (loss)
Total net sales quantities
Net sales values:3
Commercial sales
Total net sales values
Cost of goods sold (COGS):4
0
0
Selling, general, and administrative (SG&A)
expenses:
Selling expenses
General and administrative expenses
0
0
0
0
All other expense items
All other income items
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
Net income or (loss) before income taxes
Depreciation/amortization included above
0
0
1 Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
2
Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding shipment quantities
and values reported in Part II of this questionnaire.
3 COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
Note ‐‐ The table above contains calculations that will appear when you have entered data in the MS
Word form fields.
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III‐9b. Financial data reconciliation.‐‐The calculable line items from question III‐9a (i.e., total net sales
quantities and values, total COGS, gross profit (or loss), total SG&A, and net income (or loss))
have been calculated from the data submitted in the other line items. Do the calculated fields
return the correct data according to your firm's financial records ignoring non‐material
differences that may arise due to rounding?
Yes No‐‐If the calculated fields do not show the correct data, please double check the
feeder data for data entry errors and revise.
Also, check signs accorded to the post operating income line items; the two
expense line items should report positive numbers (i.e., expenses are
positive and incomes or reversals are negative‐‐instances of the latter
should be rare in those lines) while the income line item also in most
instances should have its value be a positive number (i.e., income is positive,
expenses or reversals are negative).
If after reviewing and potentially revising the feeder data your firm has
provided, the differences between your records and the calculated fields
persist please identify and discuss the differences in the space below.
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Page 23
III‐10. Nonrecurring items (charges and gains) included in the subject product financial results.‐‐For
each annual and interim period for which financial results are reported in question III‐9a, please
specify all material (significant) nonrecurring items (charges and gains) in the schedule below,
the specific question III‐9a line item where the nonrecurring items are included, a brief
description of the relevant nonrecurring items, and the associated values (in $1,000), as
reflected in question III‐9a; i.e., if an aggregate nonrecurring item has been allocated to question
III‐9a, only the allocated value amount included in question III‐9a should be reported in the
schedule below. Note: The Commission’s objective here is to gather information only on
material (significant) nonrecurring items which impacted the reported financial results of the
subject product in question III‐9a.
Item
Fiscal years
2012
2013
2014
January‐June
2015
2016
2017
2017
2018
Value ($1,000)
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7
Nonrecurring item: In this table please provide a brief description of each nonrecurring item reported above and
indicate the specific line item in table III‐9a where the nonrecurring item is classified.
Description of the
nonrecurring item
Income statement classification of the nonrecurring item
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7
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III‐11. Classification of identified nonrecurring items (charges and gains) in the accounting books and
records of the company.‐‐If non‐recurring items were reported in question III‐10 above, please
identify where your company recorded these items in your accounting books and records in the
normal course of business; i.e., just as responses to question III‐10 identify where these items
are reported in question III‐9a.
III‐12. Asset values.‐‐Report the total assets (i.e., both current and long‐term assets) associated with
the production, warehousing, and sale of wind towers. If your firm does not maintain some or
all of the specific asset information necessary to calculate total assets for wind towers in the
normal course of business, please estimate this information based upon a method (such as
production, sales, or costs) that is consistent with relevant cost allocations in question III‐9a.
Provide data as of the end of your firm’s six most recently completed fiscal years.
Note: Total assets should reflect net assets after any accumulated depreciation and allowances
deducted.
Total assets should be allocated to the subject products if these assets are also related to other
products. Please provide a brief explanation if there are any substantial changes in total asset
value during the period; e.g., due to asset write‐offs, revaluation, and major purchases.
Value (in $1,000)
Fiscal years ended‐‐
Item
1
Total assets (net)
1
Describe:
2012
2013
2014
2015
2016
2017
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Page 25
III‐13. Capital expenditures and research and development expenses.‐‐Report your firm’s capital
expenditures and research and development expenses for wind towers. Provide data for your
firm’s six most recently completed fiscal years, and for the specified interim periods.
Value (in $1,000)
Fiscal years ended‐‐
Item
2012
Capital expenditures
1
Research and
development
expenses2
2013
2014
January‐June
2015
2016
2017
2017
2018
1
Please describe the nature, focus, and significance of your firm’s capital expenditures on the subject product.
2
Please describe the nature, focus, and significance of your firm’s R&D expenses related to subject product.
III‐14. Data consistency and reconciliation.‐‐Please indicate whether your firm’s financial data for
questions III‐9a, 12, and 13 are based on a calendar year or your firm’s fiscal year:
Calendar year
Fiscal year Specify fiscal year
Please note the quantities and values reported in question III‐9a should reconcile with the data
reported in question II‐6 (including export shipments) as long as they are reported on the same
calendar year basis.
RECONCILIATION OF TRADE VS FINANCIAL DATA.‐‐ Please ensure that the quantities and values reported
for total shipments in part II equal the quantities and values reported for total net sales in part III of this
questionnaire in each time period unless the financial data from part III are reported on a fiscal year
basis, in which case only the interim periods must reconcile. If the calculated fields below return values
other than zero (i.e., “0”) and both are being reported on a calendar basis, please explain the discrepancy
below.
Partial year
periods
Full year data
Reconciliation
Quantity: Trade data from
question II‐4 (lines D, F, H, and
J) less financial total net sales
quantity data from question
III‐9a, = zero ("0").
Value: Trade data from
question II‐4 (lines E, G, I, and
K) less financial total net sales
value data from question III‐
9a, = zero ("0").
2012
2013
2014
2015
2016
2017
2017
2018
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
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U.S. Producers’ Questionnaire – Wind towers (R1)
Do these data in question III‐9a reconcile with data in question II‐4?
Yes
No
Page 26
If no, please explain.
III‐15. Other explanations.‐‐If your firm would like to further explain a response to a question in Part III
for which a narrative box was not provided, 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.
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Page 27
PART IV.‐‐PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Cindy Cohen (202‐205‐3230,
cindy.cohen@usitc.gov).
IV‐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 IV.
Name
Title
Email
Telephone
IV‐2. Price setting.‐‐ How does your firm determine the prices that it charges for sales of wind towers
(check all that apply)? If your firm issues price lists, please submit sample pages of a recent list.
Transaction
by
transaction
Contracts
IV‐3.
Set
price
lists
Other
If other, describe
Discount policy.‐‐ Please indicate and describe your firm’s discount policies (check all that
apply).
Quantity
discounts
IV‐4.
Annual
total
volume
discounts
No
discount
policy
Other
Describe
Pricing terms.‐‐On what basis are your firm’s prices of domestic wind towers usually quoted
(check one)?
Delivered
F.o.b.
If f.o.b., specify point
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IV‐5. Contract versus spot.‐‐ Approximately what share of your firm’s sales of its U.S.‐produced wind
towers in 2017 was on a (1) long‐term contract basis, (2) annual contract basis, (3) short‐term
contract basis, and (4) spot sales basis?
Type of sale
Long‐term
Short‐term
Annual
Total
contracts
contracts
Spot sales
contracts
(should
(multiple
(multiple
(for a single
(multiple
sum to
deliveries for
deliveries for
delivery)
deliveries for 12
100.0%)
less than 12
more than 12
months)
months)
months)
Share of 2017
%
%
%
% 0.0 %
sales
IV‐6. Contract provisions.— Please fill out the table regarding your firm’s typical sales contracts for
U.S.‐produced wind towers (or check “not applicable” if your firm does not sell on a long‐term,
short‐term and/or annual contract basis).
Short‐term contracts Annual contracts Long‐term contracts
(multiple deliveries
(multiple
Typical sales
(multiple deliveries
Item
for more than 12
deliveries for 12
contract provisions
for less than 12
months)
months)
months)
Average contract
duration
No. of
days
Price renegotiation
(during contract
period)
Yes
No
Quantity
Price
Both
Yes
No
Fixed quantity
and/or price
Indexed to raw
material costs1
Not applicable
1
Please identify the indexes used:
365
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Page 29
IV‐7. Long‐term arrangements.—Please list any long‐term contracts or supply agreements that your
firm has with purchasers of wind towers. Briefly describe these agreements, including the name
of the purchaser, dates, any minimum purchase quantities, and any dedicated capacity.
IV‐8.
Minimum
purchase
quantities
(units)
Dates
covered
Brief description
Lead times.‐‐What is the typical lead time between a customer’s order and the date of delivery
for your firm’s sales of its U.S.‐produced wind towers?
Share of 2017
Lead time
Source
sales
(average number of days)
From inventory
%
Produced to order
%
0.0
%
Total (should sum to 100.0%)
IV‐9.
Dedicated
capacity
(units)
Purchaser
name
Shipping information.‐‐
(a)
(b)
(c)
What is the approximate percentage of the cost of U.S.‐produced wind towers that is
accounted for by U.S. inland transportation costs? %
Who generally arranges the transportation to your firm’s customers’ locations?
Your firm Purchaser (check one)
Indicate the approximate percentage of your firm’s sales of wind towers that are
delivered the following distances from your firm’s production facility.
Distance from production facility
Share
Within 100 miles
%
101 to 1,000 miles
%
Over 1,000 miles
%
Total (should sum to 100.0%)
0.0 %
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IV‐10. Geographical shipments.‐‐ In which U.S. geographic market area(s) has your firm sold its U.S.‐
produced wind towers since January 1, 2012 (check all that apply)? Also, please indicate the
share of your firms’ 2017 shipments that were shipped to each region.
Shipments
Share of
since
Geographic area
January 1, shipments
in 2017
2012
Northeast.–CT, ME, MA, NH, NJ, NY, PA, RI, and VT.
Midwest.–IL, IN, IA, KS, MI, MN, MO, NE, ND, OH, SD, and WI.
Southeast.–AL, DE, DC, FL, GA, KY, MD, MS, NC, SC, TN, VA, and WV.
Central Southwest.–AR, LA, OK, and TX.
Mountains.–AZ, CO, ID, MT, NV, NM, UT, and WY.
Pacific Coast.–CA, OR, and WA.
Other.–All other markets in the United States not previously listed,
including AK, HI, PR, and VI.
Total (should sum to 100.0%)
0.0
IV‐11. End uses.‐‐Have there been any changes in the end uses of wind towers since January 1, 2012?
Do you anticipate any future changes?
Changes in end
uses
No
Yes
Changes since
January 1, 2012
Anticipated
changes
Explain
IV‐12. Substitutes.‐‐ Have there been any changes in the number or types of products that can be
substituted for wind towers since January 1, 2012? Do you anticipate any future changes?
Changes in
substitutes
No Yes
Changes since
January 1, 2012
Anticipated
changes
Explain
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Page 31
IV‐13. Availability of supply.‐‐Has the availability of wind towers in the U.S. market changed since
January 1, 2012? Do you anticipate any future changes?
Availability in the U.S.
Please explain, noting the countries and reasons for the
market
No Yes changes.
Changes since January 1, 2012:
U.S.‐produced product
Imports from China and
Vietnam
Imports from all other
countries
U.S.‐produced product
Imports from China and
Vietnam
Imports from all other
countries
Anticipated changes:
IV‐14. Demand trends.‐‐ Indicate how demand within the United States and outside of the United
States (if known) for wind towers has changed since January 1, 2012, and how you anticipate
demand will change in the future. Explain any trends and describe the principal factors (for
example, federal or state government policies and natural gas prices) that have affected, and
that you anticipate will affect, these changes in demand.
Market
Fluctuate
Overall
No
Overall
with no
increase change decrease clear trend
Explanation and factors
Demand since January 1, 2012
Within the
United
States
Outside
the United
States
Anticipated future demand
Within the
United
States
Outside
the United
States
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Page 32
IV‐15. Product changes.‐‐ Have there been any significant changes in the product range, product mix,
or marketing of wind towers since January 1, 2012? Do you anticipate any future changes?
Changes in
product range,
product mix, or
marketing
No Yes
Changes since
January 1, 2012
Anticipated
changes
Explain
IV‐16. Conditions of competition.‐‐
(a) Is the wind tower market subject to business cycles (other than general economy‐wide
conditions) and/or other conditions of competition distinctive to wind towers?
Check all that apply.
Please describe.
No
Skip to question IV‐17.
Yes‐Business cycles (e.g.
seasonal business)
Yes‐Other distinctive
conditions of competition
(b) If yes, have there been any changes in the business cycles or conditions of competition for
wind towers since January 1, 2012?
No
Yes
If yes, describe.
IV‐17. Supply constraints.‐‐Has your firm refused, declined, or been unable to supply wind towers
since January 1, 2012 (examples include placing customers on allocation or “controlled order
entry,” declining to accept new customers or renew existing customers, delivering less than the
quantity promised, being unable to meet timely shipment commitments, inability to meet
certain specifications, etc.)?
No
Yes
If yes, please describe.
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U.S. Producers’ Questionnaire – Wind towers (R1)
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IV‐18. Raw materials.‐‐
(a) Indicate how wind towers’ raw material prices have changed since January 1, 2012, and
how you expect they will change in the future.
Raw
materials
prices
Fluctuate
with no Explain (including if applicable, the
clear effect of section 232 and antidumping
Overall
No
Overall
increase change decrease trend duty tariffs on steel products).
Changes since
January 1,
2012
Anticipated
changes
(b) Have raw material price changes affected your firm’s selling prices for wind towers?
No
Yes
If yes, please describe.
IV‐19. Price comparisons.‐‐Please compare market prices of wind towers in U.S. and non‐U.S. markets,
if known. Provide specific information as to time periods and regions for any price comparisons.
IV‐20. Market studies.‐‐Please provide as a separate attachment to this request any studies, surveys,
etc. that you are aware of that quantify and/or otherwise discuss wind towers supply (including
production capacity and capacity utilization) and demand in (1) the United States, (2) each of
the other major producing/consuming countries, including China and Vietnam, and (3) the world
as a whole. Of particular interest is such data from 2012 to the present and forecasts for the
future.
IV‐21. Export constraints.‐‐Describe how easily your firm can shift its sales of wind towers between the
U.S. market and alternative country markets. In your discussion, please describe any contracts,
other sales arrangements, or other constraints that would prevent or retard your firm from
shifting wind towers between the U.S. and alternative country markets within a 12‐month
period.
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IV‐22. Barriers to trade.‐‐Are your firm’s exports of wind towers subject to any tariff or non‐tariff
barriers to trade in other countries?
No
Yes
If yes, please list the countries and describe any such barriers and any
significant changes in such barriers that have occurred since January 1,
2012, or that are expected to occur in the future.
IV‐23. Interchangeability.‐‐Is wind towers produced in the United States and in other countries
interchangeable (i.e., can they physically be used in the same applications)?
Please indicate A, F, S, N, or 0 in the table below:
A = the products from a specified country‐pair are always interchangeable
F = the products are frequently interchangeable
S = the products are sometimes interchangeable
N = the products are never interchangeable
0 = no familiarity with products from a specified country‐pair
Country‐pair
China
Vietnam
Other countries
United States
China
Vietnam
For any country‐pair producing wind towers that is sometimes or never interchangeable,
identify the country‐pair and explain the factors that limit or preclude interchangeable use:
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U.S. Producers’ Questionnaire – Wind towers (R1)
Page 35
IV‐24. Factors other than price.‐‐Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between wind towers produced
in the United States and in other countries a significant factor in your firm’s sales of the
products?
Please indicate A, F, S, N, or 0 in the table below:
A = such differences are always significant
F = such differences are frequently significant
S = such differences are sometimes significant
N = such differences are never significant
0 = no familiarity with products from a specified country‐pair
Country‐pair
China
Vietnam
Other countries
United States
China
Vietnam
For any country‐pair for which factors other than price always or frequently are a significant
factor in your firm’s sales of wind towers, identify the country‐pair and report the advantages
or disadvantages imparted by such factors:
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U.S. Producers’ Questionnaire – Wind towers (R1)
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IV‐25. Impact of the section 301 investigation.— This question concerns the section 301 investigation
and tariffs on wind towers that have been proposed and implemented by the United States in
response to Chinese trade practices.
(a) Did the announcement in March, 2018 and subsequent implementation of tariff remedies in
the section 301 investigation impact, or do you anticipate that it will impact, your firm's
wind tower business and/or the U.S. wind tower market as a whole?
Yes—Please fill out table below and
answer part (b)
No
Don’t know
Item
Response
1
Impact on your firm
1
Impact on overall U.S. market
1
Please identify the magnitude and timing of any effects, and compare your firm's
operations/overall market before and after the announcement of the section 301 measures.
(b) Assessment of specific impacts of the section 301 investigation.‐‐Please indicate the impact
of the announcement and subsequent implementation of remedies in the section 301
investigation and tariff actions regarding wind towers.
Item
Fluctuate
with no
No
clear
Increase change Decrease
trend
Explanation and factors
Overall demand for
wind towers in the
U.S. market
Prices for wind towers
in the U.S. market
IV‐26. Other explanations.‐‐ If your firm would like to further explain a response to a question in Part
IV for which a narrative response box was not provided, 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.
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U.S. Producers’ Questionnaire – Wind towers (R1)
Page 37
HOW TO FILE YOUR QUESTIONNAIRE RESPONSE
This questionnaire is available as a “fillable” form in MS Word format on the
Commission’s website at:
https://www.usitc.gov/investigations/701731/2018/utility_scale_wind_towers_china_a
nd_vietnam/full_review.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: WIND
• E‐mail.—E‐mail the MS Word questionnaire to Keysha.martinez@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 does not produce 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, it is 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.
| File Type | application/pdf |
| File Title | Microsoft Word - US Producer questionnaire |
| Author | keysha.martinez |
| File Modified | 2018-09-18 |
| File Created | 2018-09-18 |