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pdfOMB No. 3117‐0016/USITC No. 16‐1‐3484; Expiration Date: 6/30/2017
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U.S. PRODUCERS’ QUESTIONNAIRE
FERROVANADIUM FROM KOREA
This questionnaire must be received by the Commission by April 11, 2016
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 duty investigation concerning ferrovanadium from Korea (Inv. No. 731‐TA‐1315
(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)).
Name of firm
Address
City
State
Zip Code
Website
Has your firm a) produced ferrovanadium (as defined on next page) for its own account; b) toll processed
ferrovanadium for another firm (i.e., been a “toller”); or c) contracted another firm to toll‐produce
ferrovanadium for your firm (i.e., been a “tollee”) at any time since January 1, 2013?
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 U.S. International Trade Commission Drop Box by clicking on the
following link: https://dropbox.usitc.gov/oinv/. (PIN: FeV)
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, 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:
Fax:
Email address
Business Proprietary
U.S. Producers’ Questionnaire ‐ Ferrovanadium
Page 2
PART I.—GENERAL INFORMATION
Background. This proceeding was instituted in response to a petition filed on March 28, 2016, by the
Vanadium Producers and Reclaimers Association and its members: AMG Vanadium, LLC, Cambridge,
Ohio; Bear Metallurgical Company, Butler, Pennsylvania; Gulf Chemical & Metallurgical Corporation,
Freeport, Texas; and Evraz Stratcor, Inc., Hot Springs, Arkansas. Antidumping duties may be assessed on
the subject imports as a result of this proceeding 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/701731/2016/ferrovanadium_korea/preliminary.htm.
Ferrovanadium covered by these investigations is all ferrovanadium regardless of grade (i.e. percentage
of contained vanadium), chemistry, form, shape, or size. Ferrovanadium is an alloy of iron and vanadium
that is used chiefly as an additive in the manufacture of steel. The merchandise is commercially and
scientifically identified as ferrovanadium. It specifically excludes vanadium additives other than
ferrovanadium, such as nitrided vanadium, vanadium aluminum master alloys, vanadium chemicals,
vanadium oxides, vanadium waste and scrap, and vanadium‐bearing raw materials such as spent
hydrotreating and hydrorefining catalyst, slag, boiler residues and fly ash.
Ferrovanadium is classified under Harmonized Tariff Schedule of the United States (‘‘HTSUS’’)
subheading 7202.92.00. Goods provided for in HTSUS subheading 2850.00.20 (certain compounds of
vanadium) or subheadings 8112.92.70 and 8112.99.20 (unwrought vanadium or vanadium powders,
waste or scrap) are specifically excluded. Although the HTSUS item number is provided for convenience
and Customs purposes, the written description of the scope of this investigation remains dispositive.
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.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Ferrovanadium
Page 3
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 ferrovanadium 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 732(c)(4) of
the Act (19 U.S.C. § 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.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Ferrovanadium
I‐1a.
Page 4
OMB statistics.‐‐Please report below the actual number of hours required and the cost to your
firm of completing this questionnaire.
I‐1b.
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.
TAA information release.‐‐In the event that the U.S. International Trade Commission (USITC)
makes an affirmative final determination in this proceeding, do you consent to the USITC's
release of your contact information (company name, address, contact person, telephone
number, email address) appearing on the front page of this questionnaire to the Departments of
Commerce, Labor, and Agriculture, as applicable, so that your firm and its workers can be made
eligible for benefits under the Trade Adjustment Assistance program?
No
Yes
I‐2.
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 ferrovanadium, including
auxiliary facilities operated in conjunction with (whether or not physically separate from) such
facilities.
Establishments
City, State
Zip (5 digit)
Description
covered1
1
1
2
3
4
5
6
Additional discussion on establishments consolidated in this questionnaire: .
Business Proprietary
U.S. Producers’ Questionnaire ‐ Ferrovanadium
I‐3.
Petition support.‐‐Does your firm support or oppose the petitions?
Country
Korea
I‐4.
I‐5.
I‐6.
Page 5
Support
Oppose
Take no position
Ownership.‐‐Is your firm owned, in whole or in part, by any other firm?
No
Yes‐‐List the following information.
Firm name
Address
Extent of
ownership
(percent)
Related importers/exporters.‐‐Does your firm have any related firms, either domestic or
foreign, that are engaged in importing ferrovanadium from Korea into the United States or that
are engaged in exporting ferrovanadium from Korea to the United States?
No
Yes‐‐List the following information.
Firm name
Address
Affiliation
Related producers.‐‐Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of ferrovanadium?
No
Yes‐‐List the following information.
Firm name
Address
Affiliation
Business Proprietary
U.S. Producers’ Questionnaire ‐ Ferrovanadium
Page 6
PART II.‐‐TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Keysha Martinez (202‐205‐
2136, [email protected]). 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 ferrovanadium since January 1, 2013.
(check as many as appropriate)
(If checked, please describe; 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 ‐ Ferrovanadium
Page 7
II‐3a. Production using same machinery.‐‐ Please report your firm’s production of products made on
the same equipment and machinery used to produce ferrovanadium, and the combined
production capacity on this shared equipment and machinery in the periods indicated.
“Overall 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).
“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.
Quantity (in 1,000 pounds)
Calendar years
Item
2013
2014
2015
Overall production capacity
Production of:
Ferrovanadium1
0
0
0
2
Other products
Total
1
Report the quantity of production for ferrovanadium in this question based on total weight (not in
contained vanadium). The data reported here should correspond to the total production of
ferrovanadium reported in questions II‐7 and II‐12 but on a total weight basis.
2
Please identify these products: .
II‐3b. Operating parameters.‐‐The production capacity reported in II‐3a is based on operating hours
per week, weeks per year.
II‐3c. Capacity calculation.‐‐Please describe the methodology used to calculate overall production
capacity reported in II‐3a, and explain any changes in reported capacity.
II‐3d. Production constraints.‐‐Please describe the constraint(s) that set the limit(s) on your firm’s
production capacity.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Ferrovanadium
Page 8
II‐3e. Product shifting.—
(i)
Is your firm able to switch production (capacity) between ferrovanadium and other products
using the same equipment and/or labor?
No
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.
II‐4.
Tolling.‐‐Since January 1, 2013, has your firm been involved in a toll agreement regarding the
production of ferrovanadium (i.e., in which vanadium pentoxide or other upstream raw
materials were provided to a toller that then produces ferrovanadium on behalf of a tollee)?
“Toll agreement”‐‐Agreement between two firms whereby the first firm (“TOLLEE”) furnishes
the raw materials and the second firm (“TOLLER”) 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‐‐For all such agreements entered into by your firm, please indicate whether your firm
was the Toller (the producer of ferrovanadium) or tollee (the firm that furnished the
inputs to the Toller).
Our firm
Toller
Special instruction
Provide data on your firm's toll
production and shipments in
question II‐12
Tollee1
Please name the toller(s):
Provide data on shipments into
the market of merchandise that
was toll produced in question II‐13
1
Identify the raw material input that your firm provided the toller(s):
Other firm(s)
Please name the tollee(s):
Business Proprietary
U.S. Producers’ Questionnaire ‐ Ferrovanadium
II‐5.
Page 9
Foreign trade zones.‐‐
(a)
Firm's FTZ operations.‐‐Does your firm produce ferrovanadium in and/or admit
ferrovanadium 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‐‐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 ferrovanadium into a foreign trade zone (FTZ) for use in distribution of
ferrovanadium and/or the production of downstream articles?
No/Don’t know
Yes‐‐Identify the firms and the FTZs.
II‐6.
Importer.‐‐Since January 1, 2013, has your firm imported ferrovanadium?
“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‐‐COMPLETE AND RETURN A U.S. IMPORTERS’ QUESTIONNAIRE
Business Proprietary
U.S. Producers’ Questionnaire ‐ Ferrovanadium
II‐7.
Page 10
Production, shipment and inventory data.‐‐Report your firm’s production capacity, production,
shipments, and inventories related to the production of ferrovanadium in its U.S.
establishment(s) during the specified periods. Do not report data here for merchandise that
was involved in a toll agreement.
“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.
“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.
Such transactions are valued at fair market value.
“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.
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 ‐ Ferrovanadium
Page 11
II‐7. Production, shipment and inventory data.—(Do not report data here for merchandise
that was involved in a toll agreement).
Quantity (in 1,000 pounds contained vanadium) and value (in $1,000)
Calendar years
Item
2013
2014
1
Average production capacity (quantity) (A)
2015
Beginning‐of‐period inventories (quantity)
(B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:
Quantity (F)
2
Value (G)
Transfers to related firms:
Quantity (H)
2
Value (I)
3
Export shipments:
Quantity (J)
Value (K)
End‐of‐period inventories4 (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 .
2
Internal consumption and transfers to related firms must be valued at fair market value. In the event that your firm
uses a different basis for valuing these transactions, please specify that basis (e.g., cost, cost plus, etc.) and provide value
data using that basis for each of the periods noted above: .
3
Identify your firm’s principal export markets: .
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 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.
Calendar years
Reconciliation
B + C – D – F – H – J – L = should equal
zero ("0") or provide an explanation.1
1
2013
2014
0
2015
0
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless accurate: .
0
Business Proprietary
U.S. Producers’ Questionnaire ‐ Ferrovanadium
II‐8.
Page 12
Channels of distribution.‐‐Report your firm’s commercial U.S. shipments by channel of
distribution. Do not report data here for merchandise that was involved in a toll agreement.
Quantity (in 1,000 pounds contained vanadium) and value (in $1,000)
Calendar years
Item
2013
Channels of distribution:
Commercial U.S. shipments:
To distributors (quantity) (M)
To end users (quantity) (N)
2014
2015
Calendar years
Reconciliation
M + N – D = zero ("0"), if not revise.
2013
2014
0
2015
0
0
Business Proprietary
U.S. Producers’ Questionnaire ‐ Ferrovanadium
II‐9.
Page 13
Employment data.‐‐Report your firm’s employment‐related data related to the production of
ferrovanadium and provide any explanation for any trends in these data. Do not report data
here for merchandise that was involved in a toll agreement.
“Production 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.
“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 years
Item
2013
2014
2015
Average number of PRWs (number)
Hours worked by PRWs
(1,000 hours)
Wages paid to PRWs ($1,000)
Explanation of trends:
II‐10. Related firms.‐‐If your firm reported transfers to related firms in question II‐7, 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.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Ferrovanadium
Page 14
II‐11. Purchases.‐‐Other than direct imports, has your firm otherwise purchased ferrovanadium since
January 1, 2013?
“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.
“Direct import” –A transaction to buy from a foreign producer where your firm is the importer
of record or consignee.
No
Yes‐‐Report such purchases below and explain the reasons for your firms'
purchases:
(Quantity in 1,000 pounds contained vanadium)
Calendar years
Item
2013
2014
2015
1
Purchases from U.S. importers
of ferrovanadium from—
Korea
All other sources
Purchases from domestic
producers2
2
Purchases from other sources
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:
.
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U.S. Producers’ Questionnaire ‐ Ferrovanadium
Page 15
II‐12. Trade data on operations by TOLLER.—If your firm performed tolling operations on behalf of
another firm (produced for the tollee), report your firm’s production capacity, production,
shipments to or on behalf of tollee(s), and employment related to the production of
ferrovanadium in your firm’s U.S. establishment(s) during the specified periods. (See definition
of toller/tollee in II‐4).
Quantity (in 1,000 pounds contained vanadium) and value (in $1,000)
Calendar year
Item
2013
2014
2015
1
Average production capacity
(quantity)
Production (quantity)
U.S. shipments of tolled material
(shipped to or on behalf of
tollee(s)):
Quantity
Tolling charge (value)
Export shipments of tolled
material (exported to or on
behalf of tollee(s)):2
Quantity
Tolling charge (value)
Employment data:
Average number of PRWs
(number)
Hours worked by PRWs (1,000
hours)
Wages paid to PRWs (value)
1
The production capacity (see definitions in instruction booklet) 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
Identify your principal export markets:
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U.S. Producers’ Questionnaire ‐ Ferrovanadium
Page 16
II‐13. Trade data on operation by TOLLEE.—Report your firm’s shipments, inventories, and channels
of distribution related to the ferrovanadium produced (tolled from raw material inputs you
supplied) on your behalf in the United States during the specified periods. (See definitions of
toller/tollee in II‐4.)
Quantity (in 1,000 pounds contained vanadium) and value (in $1,000)
Calendar year
Item
2013
2014
2015
Beginning‐of‐period inventories
(quantity)
Ferrovanadium available for sale
(quantity)1
U.S. shipments:
Commercial shipments:
quantity
value
2
Internal consumption:
quantity
value
2
Transfers to related firms:
quantity
value
3
Export shipments:
quantity
value
End‐of‐period inventories
(quantity)
Channels of distribution:
U.S. commercial shipments to
distributors (quantity)
U.S. commercial shipments to
end users (quantity)
1
Ferrovanadium returned to tollee by toller.
Internal consumption and transfers to related firms should be valued at fair market value. In the event that you use
different basis for valuing these transactions, please specify that basis (e.g., cost plus, etc.) and provide value data using
that basis for each of the periods noted above:
3
Identify your principal export markets:
.
2
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U.S. Producers’ Questionnaire ‐ Ferrovanadium
Page 17
II‐14. Total production of ferrovanadium.—Indicate the quantity of total production of
ferrovanadium in your firm’s U.S. establishment(s) in 2015, including ferrovanadium your firm toll‐
produced for another firm, accounted for by grade 40‐60% ferrovanadium (i.e., ferrovanadium
containing between 40 and 60 percent vanadium) and by grade 75‐85% ferrovanadium (i.e.,
ferrovanadium containing between 75 and 85 percent vanadium):
Quantity (in 1,000 pounds contained vanadium)
Item
Calendar year 2015
Grade 40‐60 percent ferrovanadium (M)
Grade 75‐85 percent ferrovanadium (N)
Other grade of ferrovanadium1 (O)
Total (P)
0
1
Specify the grade(s) here:
RECONCILIATION OF 2015 PRODUCTION.‐‐ Please ensure that the quantities reported for total
production of ferrovanadium in 2015 in this question match the 2015 production in questions II‐7 and II‐
12. 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.
Reconciliation
Calendar year 2015
M + N + O ‐ P = zero ("0"), if not revise.
II‐15. 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.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Ferrovanadium
Page 18
PART III.‐‐FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Charles Yost (202‐205‐3432,
[email protected]).
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
Fax
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 ferrovanadium:
2. Does your firm prepare profit/loss statements for ferrovanadium:
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 ferrovanadium, 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
with variances applied, job order cost, etc.).
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.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Ferrovanadium
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III‐5.
Other products.‐‐Please list the products your firm produced in the facilities in which your firm
produced ferrovanadium, and provide the share of net sales accounted for by these products in
your firm’s most recent fiscal year.
Products
III‐6.
Share of sales
Ferrovanadium
%
%
%
%
%
Does your firm purchase inputs (raw materials, labor, energy, or any services) used in the
production of ferrovanadium from any related suppliers (e.g., inclusive of transactions between
related firms, divisions and/or other components within the same company)? NOTE: THIS IS
OUTSIDE OF ANY TOLLING AGREEMENT.
Yes‐‐Continue to question III‐7.
III‐7.
No‐‐Continue to question III‐9a.
Inputs from related suppliers.‐‐Please identify the inputs used in the production of
ferrovanadium that your firm purchases from related suppliers and that are reflected in table 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 your 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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U.S. Producers’ Questionnaire ‐ Ferrovanadium
III‐8.
Page 20
Inputs purchased from related suppliers.‐‐Please confirm that the inputs purchased from
related suppliers, as identified in III‐7, were reported in III‐9a (financial results on
ferrovanadium) in a manner consistent with your firm’s accounting books and records.
Yes
No‐‐In the space below, please report the valuation basis of inputs purchased from related
suppliers as reported in table III‐9a.
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U.S. Producers’ Questionnaire ‐ Ferrovanadium
Page 21
III‐9a. Operations on ferrovanadium.‐‐Report the revenue and related cost information requested
below on the ferrovanadium 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 ON A
CALENDAR YEAR BASIS in chronological order from left to right.
NOTE.—THE DATA REPORTED IN III‐9a should correspond to the data your firm reported in question II‐7
Quantity (in 1,000 pounds contained vanadium) and value (in $1,000)
Calendar years-Item
2013
2014
2015
Net sales quantities:2
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
Total net sales quantities
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2
Net sales values:
Commercial sales
Internal consumption
Transfers to related firms
Total net sales values
3
Cost of goods sold (COGS):
Raw materials
Direct labor
Other factory costs
Total COGS
Gross profit or (loss)
Selling, general, and administrative
(SG&A) expenses:
Selling expenses
General and administrative expenses
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
All other expense items
All other income items
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.
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.
2
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 ‐ Ferrovanadium
Page 22
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.
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 table 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 table
III‐9a; i.e., if an aggregate nonrecurring item has been allocated to table III‐9a, only the allocated
value amount included in table 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 table III‐9a.
Calendar years‐‐
2013
2014
2015
Nonrecurring item: In this column please provide a brief
Nonrecurring item: In these columns please report the amount of the relevant
description of each nonrecurring item and indicate the
nonrecurring item reported in table III‐9a.
specific line item in table III‐9a where the nonrecurring item is
classified.
Value ($1,000)
1. , classified as
2. , classified as
3. , classified as
4. , classified as
5. , classified as
6. , classified as
7. , classified as
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U.S. Producers’ Questionnaire ‐ Ferrovanadium
Page 23
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 table 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 table III‐
9a.
III‐12. Operations on ferrovanadium by TOLLER.‐‐Report the revenue and related cost information
requested below on your operations toll‐producing ferrovanadium in your U.S.
establishment(s).1 Provide data ON A CALENDAR‐YEAR BASIS in chronological order from left to
right.
NOTE: Data reported in III‐12 should correspond to the data your firm reported in question II‐12.
Quantity (in 1,000 pounds contained vanadium) and value (in $1,000)
Item
Calendar years
2013
2014
2015
2
Tolling operations:
Net quantity tolled
Net tolling revenue
Net packaging revenue
Total revenue from
tolling operations
0
0
0
Cost of tolling services:
Raw materials not
supplied by tollee
Direct labor
Other factory costs
Total cost of tolling
services
0
0
0
0
0
0
Gross profit or (loss)
Selling, general, and
administrative (SG&A)
expenses:
0
0
0
Operating income (loss)
3
0
0
0
Other expenses/(income)
0
0
0
Net income (loss)
1
Include only data on tolling operations performed in the United States.
2
The quantities and values should approximate the corresponding shipment quantities and values reported
in question II-12 of this questionnaire.
3
Include the interest expense, other expense, and (other income) on this line. Insert interest expense and
other expense as positive numbers, and insert other income as a negative number.
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 ‐ Ferrovanadium
Page 24
III‐13. Operations on ferrovanadium by TOLLEE.‐‐Report the revenue and related cost information
requested below on your firm’s sales of ferrovanadium toll‐produced by an unrelated toller in
the United States from raw materials your firm supplied.1 Provide data ON A CALENDAR‐YEAR
BASIS in chronological order from left to right.
NOTE: Data reported in III‐13 should correspond to the data your firm reported in question II‐13.
Quantity (in 1,000 pounds contained vanadium) and value (in $1,000)
Calendar years
Item
2013
2014
2
Net sales quantities:
Commercial sales
Internal consumption
Transfers to related firms
Total net sales quantities
0
0
2
Net sales values:
Commercial sales
Internal consumption
Transfers to related firms
Total net sales values
0
0
3
Cost of goods sold (COGS):
Raw materials supplied to
toller
Other costs
Toll conversion fee
Total COGS
0
0
0
0
Gross profit or (loss)
Selling, general, and
administrative (SG&A)
expenses:
2015
0
0
0
0
0
0
0
Operating income (loss)
4
Other expenses/(income)
0
0
0
Net income (loss)
1
Include only sales (whether domestic or export) and costs related to subject product toll-produced in the
United States.
2
Less discounts, rebates, 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 should include costs associated with commercial sales (including exports), internal consumption,
and transfers to related firms. Inputs from related firms should reflect the valuation basis in your firm’s books
and records in accordance with question III-7.
4
Include the net of interest expense, other expense, and (other income) on this line. Insert interest
expense and other expense as positive numbers, and insert other income as a negative number.
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 ‐ Ferrovanadium
Page 25
III‐14. Asset values.‐‐Report the total assets (i.e., both current and long‐term assets) associated with
the production, warehousing, and sale of ferrovanadium. If your firm does not maintain some or
all of the specific asset information necessary to calculate total assets for ferrovanadium 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 table III‐9a.
Provide data ON A CALENDAR YEAR BASIS.
Note: Total assets should include current assets such as cash, inventory, accounts receivable
and the like, and non‐current asssets should reflect property, plant, and equipment after any
deduction of accumulated depreciation and allowances, and other non‐current assets.
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)
Calendar years‐‐
Item
1
Total assets (net)
1
Producer
2013
2014
2015
2
Toller
3
Tollee
1
Producer’s total assets corresponding to the operational data reported in question III‐9a. Describe substantial
changes
2
Toller’s total assets corresponding to the operational data reported in question III‐12. Describe substantial
changes
3
Tollee’s total assets corresponding to the operational data reported in question III‐13. Describe substantial
changes
Business Proprietary
U.S. Producers’ Questionnaire ‐ Ferrovanadium
III‐15.
Page 26
Capital expenditures and research and development expenses.‐‐Report your firm’s capital
expenditures and research and development expenses for ferrovanadium. Provide data ON A
CALENDAR YEAR in chronological order from left to right.
Value (in $1,000)
Calendar years‐‐
Item
2013
2014
2015
Capital expenditures
Producer1
Toller2
3
Tollee
Research and development expenses
1
Producer
2
Toller
3
Tollee
1
Producers’ capital expenditures and R&D expenses corresponding to the operational data reported in question III9a.
2
Toller’s capital expenditures and R&D expenses corresponding to the tolling operational data reported in question
III-12.
3
Tollee’s capital expenditures and R&D expenses corresponding to the tollee’s operational data reported in
question III-13.
Please indicate the nature, focus, and significance of your firm’s capital expenditures on the subject product.
________________________________________________________________
Please indicate the nature, focus, and significance of your firm’s R&D expenses on the subject product.
________________________________________________________________
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U.S. Producers’ Questionnaire ‐ Ferrovanadium
Page 27
III‐16. 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 on 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‐7 (including export shipments) as long as they are reported on the same
calendar year basis.
Do these data in question III‐9a reconcile with data in question II‐7?
Yes
No
If no, please explain.
III‐17. Effects of imports on investment.‐‐Since January 1, 2013, has your firm experienced any actual
negative effects on its return on investment or the scale of capital investments as a result of
imports of ferrovanadium from Korea?
No
Yes‐‐My firm has experienced actual negative effects as follows:
(check as many as appropriate)
(please describe)
Cancellation, postponement,
or rejection of expansion
projects
Denial or rejection of
investment proposal
Reduction in the size of
capital investments
Return on specific
investments negatively
impacted
Other
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U.S. Producers’ Questionnaire ‐ Ferrovanadium
Page 28
III‐18. Effects of imports on growth and development.‐‐Since January 1, 2013, has your firm
experienced any actual negative effects on its growth, ability to raise capital, or existing
development and production efforts (including efforts to develop a derivative or more advanced
version of the product) as a result of imports of ferrovanadium from Korea?
No
Yes‐‐My firm has experienced actual negative effects as follows:
(check as many as appropriate)
(please describe)
Rejection of bank loans
Lowering of credit rating
Problem related to the issue
of stocks or bonds
Ability to service debt
Other
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U.S. Producers’ Questionnaire ‐ Ferrovanadium
Page 29
III‐19. Anticipated effects of imports.‐‐Does your firm anticipate any negative effects due to imports of
ferrovanadium from Korea?
No
Yes
If yes, my firm anticipates negative effects as follows:
III‐20. Other explanations.‐‐If your firm would like to further explain a response to a question in Part III
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.
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U.S. Producers’ Questionnaire ‐ Ferrovanadium
Page 30
PART IV.‐‐ PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Michele Breaux (202‐205‐
2781, [email protected]).
IV‐1. Contact information.‐‐Please identify the individual that Commission staff may contact
regarding the confidential information submitted in part IV.
Name
Title
Email
Telephone
Fax
PRICE DATA
IV‐2. This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. customers since January 1, 2013 of the following products produced by your
firm.
Product 1.‐‐ Ferrovanadium containing 40‐60 percent vanadium, 2" by down
Product 2.‐‐ Ferrovanadium containing 75‐85 percent vanadium, 2" by down
Please note that values should be f.o.b., U.S. point of shipment and should not include U.S.‐inland
transportation costs. Values should reflect the final net amount paid to your firm (i.e., should be net
of all deductions for discounts or rebates).
During January 2013‐December 2015, did your firm produce and sell to unrelated U.S.
customers any of the above listed products (or any products that were competitive with these
products)?
Yes.‐‐Please complete the following pricing data table(s) as appropriate.
No.‐‐Skip to question IV‐3.
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U.S. Producers’ Questionnaire ‐ Ferrovanadium
IV‐2.
Page 31
Price data.‐‐Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
Report data in actual pounds contained vanadium and actual dollars (not 1,000s).
(Quantity in pounds contained vanadium, value in dollars)
Product 1
Quantity
Value
Quantity
Product 2
Period of shipment
Value
2013:
January‐March
April‐June
July‐September
October‐December
2014:
January‐March
April‐June
July‐September
October‐December
2015:
January‐March
April‐June
July‐September
October‐December
1
Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods), f.o.b. your firm’s U.S. point of shipment.
2
Pricing product definitions are provided on the first page of Part IV.
Note.‐‐If your firm’s product does not exactly meet the product specifications but is competitive with the specified product,
provide a description of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Pricing data methodology.—Please describe the method and the kinds of documents/records
that were used to compile your price data.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records used in
the preparation of the price data, as Commission staff may contact your firm regarding
questions on the price data. The Commission may also request that your company submit copies
of the supporting documents/records (such as sales journal, invoices, etc.) used to compile these
data.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Ferrovanadium
IV‐3.
Page 32
Price setting.‐‐ How does your firm determine the prices that it charges for sales of
ferrovanadium (check all that apply)? If your firm issues price lists, please submit sample pages
of a recent list.
Transaction
by
transaction
Contracts
IV‐4.
Set
price
lists
Other
If other, describe
Discount policy.‐‐ Please indicate and describe your firm’s discount policies (check all that
apply).
Quantity
discounts
Annual
total
volume
discounts
IV‐5.
Other
Describe
Pricing terms.‐‐
(a)
What are your firm’s typical sales terms for its U.S.‐produced ferrovanadium?
Net 30
days
No
discount
policy
(b)
Net 60
days
2/10 net
30 days
Other
Other (specify)
On what basis are your firm’s prices of domestic ferrovanadium usually quoted (check
one)?
Delivered
F.o.b.
If f.o.b., specify point
IV‐6. Contract versus spot.‐‐Approximately what share of your firm’s sales of its U.S.‐produced
ferrovanadium in 2015 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
Short‐term
Long‐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 2015
%
%
%
% 0.0 %
sales
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U.S. Producers’ Questionnaire ‐ Ferrovanadium
IV‐7.
Page 33
Contract provisions.‐‐Please fill out the table regarding your firm’s typical sales contracts for
U.S.‐produced ferrovanadium (or check “not applicable” if your firm does not sell on a long‐
term, short‐term and/or annual contract basis).
Typical sales
contract provisions
Item
Short‐term
contracts
(multiple deliveries
for less than 12
months)
Average contract
duration
No. of
days
Price renegotiation
(during contract
period)
Yes
No
Quantity
Price
Both
Meet or release
provision
Yes
No
Based on published
prices
Yes
No
Fixed quantity
and/or price
Not applicable
Annual contracts
Long‐term contracts
(multiple deliveries (multiple deliveries for
more than 12 months)
for 12 months)
365
IV‐8. Price Indices.—
(a)
Does your firm base sales prices on published prices from the following sources?
No—Skip to question IV‐9.
Yes‐‐Check all that apply to your firm.
Publication
(Check all that apply)
Ryan’s Notes
Platts Metal Week
U.S. import statistics
1
Source(s) other than those listed above
1
List the source(s):
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U.S. Producers’ Questionnaire ‐ Ferrovanadium
IV‐9.
Page 34
Lead times.‐‐What is your firm’s share of sales from inventory and produced to order and 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 ferrovanadium?
Share of 2015
Source
sales
Lead time (days)
From inventory
%
Produced to order
%
Total (should sum to 100.0%)
0.0 %
IV‐10. Shipping information.‐‐
(a)
What is the approximate percentage of the total delivered cost of U.S.‐produced
ferrovanadium that is accounted for by U.S. inland transportation costs? percent
(b)
Who generally arranges the transportation to your firm’s customers’ locations?
Your firm Purchaser (check one)
(c)
Indicate the approximate percentage of your firm’s sales of ferrovanadium that are
delivered the following distances from its 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 %
IV‐11. Geographical shipments.‐‐ In which U.S. geographic market area(s) has your firm sold its U.S.‐
produced ferrovanadium since January 1, 2013 (check all that apply)?
Geographic area
√ if applicable
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.
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U.S. Producers’ Questionnaire ‐ Ferrovanadium
Page 35
IV‐12. End uses.‐‐List the end uses of the ferrovanadium that your firm manufactures. For each end‐
use product, what percentage of the total cost is accounted for by ferrovanadium and other
inputs?
Share of total cost of end use product
accounted for by
Total
(should sum to
100.0% across)
ferrovanadium
Other inputs
End use product
%
%
0.0 %
%
%
0.0 %
%
%
0.0 %
IV‐13. Substitutes.‐‐ Can other products be substituted for ferrovanadium?
No
Yes‐‐Please fill out the table.
End use in which this
substitute is used
Substitute
Have changes in the price of this substitute
affected the price for ferrovanadium?
No Yes
Explanation
1.
2.
3.
IV‐14. Demand trends.‐‐ Indicate how demand within the United States and outside of the United
States (if known) for ferrovanadium has changed since January 1, 2013. Explain any trends and
describe the principal factors that have affected these changes in demand.
Market
Overall
No
Overall
increase change decrease
Fluctuate
with no
clear trend
Explanation and factors
Within
the United
States
Outside
the United
States
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Page 36
IV‐15. Product changes.‐‐Have there been any significant changes in the product range, product mix,
or marketing of ferrovanadium since January 1, 2013?
No
Yes
If yes, please describe and quantify if possible.
IV‐16. Conditions of competition.‐‐
(a) Is the ferrovanadium market subject to business cycles (other than general economy‐wide
conditions) and/or other conditions of competition distinctive to ferrovanadium? If yes,
describe.
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
ferrovanadium since January 1, 2013?
No
Yes
If yes, describe.
IV‐17. Supply constraints.‐‐Has your firm refused, declined, or been unable to supply ferrovanadium
since January 1, 2013 (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, been unable to meet timely shipment commitments, etc.)?
No
Yes
If yes, please describe.
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U.S. Producers’ Questionnaire ‐ Ferrovanadium
Page 37
IV‐18. Raw materials.‐‐How have ferrovanadium raw materials prices changed since January 1, 2013?
Explain, noting how raw material price changes
have affected your firm’s selling prices for
ferrovanadium.
Fluctuate
with no
Overall
No
Overall
increase change decrease clear trend
IV‐19. Interchangeability.‐‐Is ferrovanadium 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
United
States
Korea
Austria
Canada
Korea
Austria
Canada
Czech
Republic
Czech Republic Other countries
For any country‐pair producing ferrovanadium 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 ‐ Ferrovanadium
Page 38
IV‐19. Factors other than price.‐‐Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between ferrovanadium
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
United
States
Korea
Austria
Canada
Korea
Austria
Canada
Czech
Republic
Czech Republic Other countries
For any country‐pair for which factors other than price always or frequently are a significant
factor in your firm’s sales of ferrovanadium, identify the country‐pair and report the
advantages or disadvantages imparted by such factors:
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U.S. Producers’ Questionnaire ‐ Ferrovanadium
Page 39
IV‐20. Customer identification.‐‐List the names and contact information for your firm’s 10 largest U.S.
customers for ferrovanadium since January 1, 2013. Indicate the share of the quantity of your
firm’s total shipments of ferrovanadium that each of these customers accounted for in 2015.
Customer’s name
Contact person
Email
Telephone
City
State
Share
of
2015
sales
(%)
1
2
3
4
5
6
7
8
9
10
Business Proprietary
U.S. Producers’ Questionnaire ‐ Ferrovanadium
Page 40
IV‐21. Competition from imports
(a)
Lost revenue.‐‐Since January 1, 2013: To avoid losing sales to competitors selling
ferrovanadium from Korea, did your firm:
No
Yes
(b)
Reduce prices
Roll back announced price increases
Lost sales.‐‐Since January 1, 2013: Did your firm lose sales of ferrovanadium to imports
of this product from Korea?
No
Yes
(c)
The submission of lost sales/lost revenue allegations is to be completed only by NON‐
PETITIONERS.
If your firm indicated “yes” to any of the above, your firm can provide the Commission
with additional information by downloading and completing the lost sales/lost revenues
worksheet at http://usitc.gov/trade_remedy/question.htm. Note that the Commission
may contact the firms named to verify the allegations reported.
Is your firm submitting the lost sales/lost revenues worksheet?
No—Please explain.
Yes—Please complete the worksheet and submit via the Commission dropbox.
https://dropbox.usitc.gov/oinv/. (PIN: FeV)
IV‐22. Other explanations.‐‐If your firm would like to further explain a response to a question in Part
IV that did not provide a narrative response 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.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Ferrovanadium
Page 41
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/701731/2016/ferrovanadium_korea/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: FeV
• E‐mail.—E‐mail the MS Word questionnaire to [email protected]; 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_FeV |
Author | keysha.martinez |
File Modified | 2016-03-30 |
File Created | 2016-03-30 |