17-4-3783 Foreign producers' questionnaire

Information collections for import injury investigations (producers, importers, purchasers, and foreign producer questionnaires and institution notices for 5-year reviews)

Foreign producers--LCA (F)

100- to 150-seat large civil aircraft from Canada (701-TA-578 and 731-TA-1368)

OMB: 3117-0016

⚠️ Notice: This form may be outdated. More recent filings and information on OMB 3117-0016 can be found here:

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OMB No. 3117-0016/USITC No. 17-4-3783; Expiration Date: 6/30/2020
(No response is required if currently valid OMB control number is not displayed)

FOREIGN PRODUCERS’/EXPORTERS’ QUESTIONNAIRE
100- TO 150-SEAT LARGE CIVIL AIRCRAFT FROM CANADA
This questionnaire must be received by the Commission by November 16, 2017
See last page for filing instructions.
The information called for in this questionnaire is for use by the United States International Trade Commission in
connection with its countervailing duty and antidumping investigations concerning 100- to 150-seat large civil aircraft
(“100- to 150-seat LCA”) from Canada (Inv. Nos. 701-TA-578 and 731-TA-1368 (Final)). The information requested in
the questionnaire is requested under the authority of the Tariff Act of 1930, title VII.

Name of firm
Address
Website
Has your firm produced or exported and/or does your firm plan to produce or export 100- to 150-seat large civil
aircraft (as defined on next page) from any country at any time since January 1, 2014?

(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)

Data reported in this questionnaire relate to (Check one):
CANADA

OTHER:

Return questionnaire via the Commission Drop Box by clicking on the following link:
https://dropbox.usitc.gov/oinv/. (PIN: LCA1)
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
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

Phone:
Signature

Fax:

Email address

Business Proprietary
Foreign Producers’ Questionnaire – 100- to 150-seat LCA (Final)

Page 2

PART I.--GENERAL INFORMATION
Background.--This proceeding was instituted in response to a petition filed on April 27, 2017, by The
Boeing Company, Chicago, Illinois. Countervailing and antidumping duties may be assessed on the
subject imports as a result of these proceedings if the Commission makes an affirmative determination
of injury, threat, or material retardation, and if the U.S. Department of Commerce (“Commerce”) makes
an affirmative determination of subsidization and/or dumping. Questionnaires and other information
pertinent to this proceeding are available at
https://www.usitc.gov/investigations/701731/2017/100_150_seat_large_civil_aircraft_canada/final.ht
m.
100- to 150-seat LCA covered by these investigations are aircraft that have a standard 100- to 150-seat
two-class seating capacity and a minimum 2,900 nautical mile range, as these terms are defined below.
Standard 100- to 150-seat two-class seating capacity refers to the capacity to seat 100 to 150
passengers on commercial airlines routes, when the aircraft contain 8 passenger seats
configured for a 36-inch pitch, and the remaining passenger seats are configured for a 32-inch
pitch (regardless of actual seating configuration). For example, aircraft with a “standard 100- to
150-seat two-class seating capacity” can be configured with fewer than 100 seats (e.g., a CS100
with an all business class configuration). “Pitch” refers to the distance between a point on one
seat and the same point on the seat in front of it.
Having a “minimum 2,900 nautical mile range” means:
(i) Able to transport between 100 and 150 passengers and their luggage on routes
equal to or longer than 2,900 nautical miles; or
(ii) Covered by a U.S. Federal Aviation Administration (“FAA”) type certificate or
supplemental type certificate that also covers other aircraft with a minimum 2,900
nautical mile range.
The scope includes all aircraft covered by the description above, regardless of whether they enter the
United States fully or partially assembled, and regardless of whether, at the time of entry into the
United States, they are approved for use by the FAA.
100- to 150-seat LCA are currently imported under statistical reporting number 8802.40.0040 of the
Harmonized Tariff Schedule of the United States (HTSUS). The HTSUS provisions are for convenience and
customs purposes; the written description of the scope is dispositive.
Examples of 100- to 150-seat LCA meeting the definition of 100- to 150-seat LCA include but are not
limited to, 737-700, 737 MAX 7, CS100, CS300, A319ceo, and A319neo.
Regional civil aircraft includes aircraft either (a) with seat counts less than 100 intended for civil uses or
(b) aircraft with seat counts between 100 and 150 that do not otherwise conform to in-scope 100- to
150-seat LCA as defined on page 2 (e.g., Embraer 190, Bombardier CRJ 700, CRJ 900, and CRJ 1000).
Other single aisle LCA includes large civil aircraft with a single aisle that do not meet the definition of
100- to 150-seat LCA as defined on page 2 or regional civil aircraft as defined above (e.g., Boeing 737800/737 MAX 8, 737-900/737 MAX 9, 737 MAX 10, and Airbus A321).

Business Proprietary
Foreign Producers’ Questionnaire – 100- to 150-seat LCA (Final)

Page 3

All other LCA includes large civil aircraft not included in the definition of 100- to 150-seat LCA as defined
on page 2 or as “other single aisle LCA” as defined above (i.e., LCA with more than one aisle).
Reporting of information.--If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer,
importer/purchaser, and/or foreign producer questionnaire), you need not respond to duplicated
questions.
Do not submit data by manufacturing facility if they are in the same country. If your firm has
multiple manufacturing establishments within one country, you are required to combine data
for those establishments within one foreign producer questionnaire response.
Do not submit data on multiple countries combined. The establishments reported here should
all be located in the country of the firm’s address reported on the certification page. In general,
multinational companies with production in multiple subject countries should submit separate
foreign producer questionnaire responses for each subject country. However, for the purpose of
this questionnaire, Airbus should combined its data for all nonsubject EU establishments into a
single response.
Confidentiality.--The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.
Verification.--The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting
documents used in the preparation of the questionnaire response. Please also retain a copy of the final
document that you submit.
Release of information.--The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import-injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals.
Valid number error messages.--If you are completing this form in a country that uses periods (“.”) to
delineate multiples of 1000 (e.g., one million would appear as $1.000.000 rather than $1,000,000), you
may be unable to enter in numbers greater than 999 in numeric form fields. The solution to this data
entry issue is to temporarily change your operating system’s number formatting to be consistent with
the U.S. number formatting system while you complete this form. Detailed instructions on how to
resolve this issue is provided at the end of this questionnaire and is available upon request from Carolyn
Carlson (202-205-3002, [email protected]).

Business Proprietary
Foreign Producers’ Questionnaire – 100- to 150-seat LCA (Final)
I-1.

Page 4

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

Dollars

The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
40 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.
I-2.

Establishments covered.--Provide the name and address of establishment(s) covered by this
questionnaire. If your firm is publicly traded, please specify the stock exchange and trading
symbol.
“Establishment” – Each facility of a firm involved in the production or export of 100- to 150-seat
LCA, including auxiliary facilities operated in conjunction with (whether or not physically
separate from) such facilities. Firms operating more than one establishment in a country should
combine the data for all establishments into a single report.

I-3.

Related producers.--Does your firm or any related firm produce, have the capability to produce,
or have any plans to produce 100- to 150-seat LCA in the United States or other countries?
No

I-4.

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

Related U.S. importers.--Does your firm or any related firm import or have any plans to import
100- to 150-seat LCA into the United States?
No

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

Business Proprietary
Foreign Producers’ Questionnaire – 100- to 150-seat LCA (Final)

Page 5

PART II.--TRADE AND RELATED INFORMATION
Further information on this Part of the questionnaire can be obtained from Carolyn Carlson (202-2053002, [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 100- to 150-seat LCA since January 1, 2014.
(check as many as appropriate)
plant openings
plant closings
relocations
expansions
acquisitions
consolidations
prolonged shutdowns or
production curtailments
revised labor agreements
other (e.g., technology)

(If checked, please describe; leave blank if not applicable)

Business Proprietary
Foreign Producers’ Questionnaire – 100- to 150-seat LCA (Final)
II-3a.

Page 6

Production of in-scope and out-of-scope merchandise.--Please report your firm’s total aircraft
production. Include all aircraft production regardless of whether it is in the same facility as
production of in-scope 100- to 150-seat LCA.
“Production” – All production in your establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
Quantity (in number of units)
Calendar years
Item

Production of:
100- to 150- seat LCA1

2014

2015

January to September
2016

2016

2017

Out-of-scope products.-Regional civil aircraft2
Other single aisle LCA3
All other LCA4
Non-civilian aircraft
Other products5
Total
1

Data entered for production of 100- to 150-seat LCA will populate here once reported in question II-9.
Please identify the regional civil aircraft your firm produces:
.
3
Please identify the other single aisle LCA your firm produces:
.
4
Please identify the all other LCA your firm produces:
.
5
Please identify the other products your firm produces:
.
2

Business Proprietary
Foreign Producers’ Questionnaire – 100- to 150-seat LCA (Final)
II-3b.

Page 7

Fixed assets used in 100- to 150-seat LCA production.--Please report the total value of your
firm’s fixed tangible assets, i.e., assets with a useful life greater than one year, used in the
production of 100- to 150- seat LCA by whether those assets are solely dedicated to 100- to 150seat LCA and cannot be economically repurposed versus other fixed assets that either are or can
economically be repurposed for the production of other aircraft.

Item
Fixed assets that are:
100 percent dedicated to the
production of 100- to 150- seat
LCA and cannot economically be
repurposed for other aircraft1
Other fixed assets used to
product 100- to 150- seat LCA
(i.e., assets that are or can
economically be used in the
production of other aircraft).2
Total fixed assets

Value (1,000 dollars)
Calendar years
2014
2015

January to September
2016
2017

2016

Please describe and explain why these assets cannot economically be repurposed to produce other aircraft:
.
2
Please describe:
.

II-3c.

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

II-3d.

Product shifting.-(i).

Is your firm able to switch production (capacity) between 100- to 150-seat LCA and other
products using the same equipment and/or labor?
No

(ii).

Yes--(i.e., have produced other products or are able to produce other
products). Please identify other actual or potential products:
.

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
Foreign Producers’ Questionnaire – 100- to 150-seat LCA (Final)

Page 8

II-4.

Share of sales.--What percentage of your firm’s total sales in its most recent fiscal year was
represented by sales of 100- to 150-seat LCA?
percent.

II-5.

Firm's estimated share of production.--Please estimate the percentage of total production of 100to 150-seat LCA in the country specified on the certification page accounted for by your firm’s
production in 2016:
percent.

II-6.

Firm's estimated share of country's exports.--Please estimate the percentage of total exports to
the United States of 100- to 150-seat LCA from the country specified on the certification page
accounted for by your firm’s exports in 2016:
percent.

II-7.

Inventories in the United States.--Has your firm, since January 1, 2014, maintained any
inventories of 100- to 150-seat LCA in the United States (not including inventories held by firms
identified in question I-3)?
“Inventories” – Finished goods inventory, not raw materials or work in progress.
No

Yes--Report the quantity of such end-of-period inventories below.
Quantity (in number of units)
Calendar year

Item

2014

2015

January to September
2016

2016

2017

Inventory
II-8.

Third country trade actions.--Is the 100- to 150-seat LCA exported by your firm subject to
antidumping/countervailing duty/safeguard findings, remedies, or proceedings in third
countries?
No

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

Business Proprietary
Foreign Producers’ Questionnaire – 100- to 150-seat LCA (Final)
II-9.

Page 9

Trade data.--Report your firm’s production capacity, production, shipments, and inventories
related to the production of 100- to 150-seat LCA in your 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 for all
products manufactured in that establishment using the same manufacturing equipment.
Assume normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” – All production in your establishment(s), including production consumed
internally within your firm.
“Shipments” – Shipments of products produced in your establishment(s). Quantities
reported should be net of returns. All shipment data (home market shipment and export
shipments) should be based on the date of delivery.
“Home market commercial shipments” – Shipments, other than internal consumption and
transfers to related firms, made to customers domiciled and operating their fleet in your firm's
home market regardless of where the physical delivery took place.
“Home market internal consumption/transfers to related firms” – Shipments made to related
customers domiciled and operating their fleet in your firm's home market as well as your firm's
internal consumption of completed aircraft.
“Export shipments” – Shipments customers domiciled and operating their fleet in markets other
than your firm's home market, including shipments to related firms and regardless of where the
physical delivery took place.
“Inventories” – Finished goods inventory (i.e., completed airplanes) ready for sale and/or
delivery, 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
Foreign Producers’ Questionnaire – 100- to 150-seat LCA (Final)
II-9a.

Page 10

Trade data.--Continued.
Quantity (in number of units)
Actual experience
Calendar year
Item

2014

2015

January to September
2016

2016

2017

Average production capacity (A)
Beginning-of-period inventories
(B)
Production (C)
Home market shipments:
Internal consumption/
transfers (D)
Commercial shipments (E)
Exports to the United States (F)
Exports to all other markets2 (G)
Total exports (H)
(should equal F+G)

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

End-of-period inventories (J)
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
Identify principal other export markets.
.

Business Proprietary
Foreign Producers’ Questionnaire – 100- to 150-seat LCA (Final)
II-9a.

Page 11

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

2014

2015

January to September
2016

2016

2017

B + C – D – E – F –G – J = should
equal zero ("0") or provide an
explanation.1
0
0
0
0
1
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are
nonetheless accurate.

Business Proprietary
Foreign Producers’ Questionnaire – 100- to 150-seat LCA (Final)
II-9b.

Page 12

Channels of distribution.--Please report your firm’s exports to the United States by type of
customer.
Quantity (in number of units)
Calendar year
Item

2014

2015

January to September
2016

2016

2017

Channels of distribution:
Exports to the United States:
To airlines (quantity) (K)
To leasing or financing
companies (quantity) (L)
To other customers
(quantity) (M)
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of
distribution (i.e., lines K, L, and M) in each time period equal the quantity reported for exports to
the United States (i.e., line F) 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.
Actual experience
Calendar year
Item

2014

2015

January to September
2016

2016

2017

K + L + M – F = should equal zero
("0") or provide an explanation.1
0
0
0
0
1
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are
nonetheless accurate.

II-10.

Anticipated changes in operations.--Does your firm anticipate any changes in the character of
its operations or organization relating to the production of 100- to 150-seat LCA in the future?
No

Yes--Supply details as to the time, nature, and significance of such changes
and provide underlying assumptions, along with relevant portions of
business plans or other supporting documentation that address this
issue.

Business Proprietary
Foreign Producers’ Questionnaire – 100- to 150-seat LCA (Final)

Page 13

II-11a. Projections.--In light of your firm's expectations discussed in question II-10, report your firm’s
anticipated production capacity, production, shipments, and inventories related to the
production of 100- to 150-seat LCA in your establishment(s) during the specified periods.
Quantity (in number of units)
Projections
Calendar years
Item

2017

2018

2019

2020

2021

2022

Average production capacity (A)
Beginning-of-period inventories (B)
Production (C)
Home market shipments:1
Internal consumption/ transfers
(D)
Commercial shipments (E)
Exports to the United States2 (F)
Exports to all other markets3 4 (G)
Total exports (H)
(should equal F+G)

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

End-of-period inventories (J)
1

Please describe the assumptions for your firm's projections for home market shipments (i.e., sales to customers in
your country, or in the case of Airbus customers in the EU) over the 2017-22 period.
.
2
Please describe the assumptions for your firm's projections of exports to the United States (i.e., sales to U.S.
customers) over the 2017-22 period.
.
3
Please describe the assumptions for your firm's projections of exports to markets other than the United States (i.e.,
sales to non-U.S. and customers outside of your home country, or in the case of Airbus outside of the EU) over the
2017-22 period.
.
4
Identify principal other export markets.
.

Business Proprietary
Foreign Producers’ Questionnaire – 100- to 150-seat LCA (Final)

Page 14

II-11a. Projections data.--Continued.
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported
for the end-of-period inventories (i.e., line J) should be equal to the beginning-of-period
inventories (i.e., line B), plus production (i.e., line C), less total shipments (i.e., lines D, E, F, and
G). Please ensure that any differences are not due to data entry errors in completing this form,
but rather actually reflect your firm’s records; and also provide any likely explanations for any
differences (e.g., theft, loss, damage, record systems issues, etc.) if they exist.
Calendar year
Item

2017

2018

2019

2020

2021

2022

B + C – D – E – F –G – J = should
equal zero ("0") or provide an
explanation.1
0
0
0
0
0
1
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are
nonetheless accurate.

Business Proprietary
Foreign Producers’ Questionnaire – 100- to 150-seat LCA (Final)

Page 15

II-11b. Channels of distribution.--Please report your firm’s anticipated exports to the United States by
type of customer.
Quantity (in number of units)
Calendar year
Item

2017

2018

2019

2020

2021

2022

2017

2018

2019

2020

2021

2022

K + L + M – F = should equal zero
("0") or provide an explanation.1
0
0
0
0
0
1
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are
nonetheless accurate.

Business Proprietary
Foreign Producers’ Questionnaire – 100- to 150-seat LCA (Final)

Page 16

II-12a. Orders.--Please provide the following information on your firm's orders for 100- to 150-seat
large civil aircraft from U.S. customers that either (a) have been delivered since January 1, 2014
or (b) for which delivery is pending. Please provide these data in a spreadsheet structured as
follows:
“Ancillary items” – includes goods, services, and other items of value in addition to the aircraft
itself that are provided, or to be provided, to a customer as part of an aircraft sales agreement.
Ancillary items include, but are not limited to, entry-into-service support, training support for
pilots, cabin crew, maintenance, and spare parts.
A
B
C
D
E
F
G
H

Column

I
J
K
L
M
N
O
P
Q
R
S
T
U
V

Data field description
Order date
Order type (e.g., new firm order, option exercise, conversion from other aircraft)
Purchaser (i.e., firm's name)
Purchaser type (e.g., airline, leasing company, other customer)
Operator (i.e., firm's name)
Model order
Units ordered (in number of units)
Options / purchase rights obtained
Per aircraft total price (inclusive of engine prices and prices of ancillary items),
net of all discounts in USD as of the order date
Engine price included in the per aircraft price, net of all discounts (the per
aircraft price not the per engine price)
Ancillary items price included in the per aircraft price
Ancillary items description (a short description of the ancillary items include in
the order)
Deliveries made prior to January 1, 2014 (in number of units)
Deliveries made in 2014 (in number of units)
Deliveries made in 2015 (in number of units)
Deliveries made in 2016 (in number of units)
Deliveries made and scheduled to be made in 2017 (in number of units)
Deliveries scheduled to be made in 2018 (in number of units)
Deliveries scheduled to be made in 2019 (in number of units)
Deliveries scheduled to be made in 2020 (in number of units)
Deliveries scheduled to be made in 2021 (in number of units)
Deliveries scheduled to be made in 2022 (in number of units)

II-12b. Backlog.--Report your firm’s backlog of 100- to 150-seat LCA for each of the following periods:
Date
December 31, 2014
December 31, 2015
December 31, 2016
September 30, 2016
September 30, 2017

Quantity (in number of units)
U.S. customers

Non-U.S. customers

Business Proprietary
Foreign Producers’ Questionnaire – 100- to 150-seat LCA (Final)

Page 17

II-12c. Duration between orders and deliveries.--For deliveries of 100- to 150-seat large civil aircraft
made by your firm to all customers in 2016, what is the average duration between order date
and delivery completion date?

II-12d. Delivery schedule management.--Please describe your firm’s approach to managing the
relationship between the intake of new orders and the scheduling of deliveries for 100- to 150seat large civil aircraft. What ratio of new orders to deliveries in a given period does your firm
consider healthy and sustainable? To what extent does your firm take orders for delivery in a
given period beyond the number of orders that matches the available delivery slots in that
period?

II-12e. Delivery schedule flexibility.--Does your firm have policies, methods, or practices to make 100to 150-seat LCA delivery slots available to customers in a manner intended to increase the
chances of obtaining new orders, including potentially large orders and/or orders from large
customers? Such policies, methods, or practices may include, but are not limited to, keeping
near-term delivery slots available in anticipation of possible new orders, increasing capacity, and
negotiating delivery schedule modifications with existing customers to make near-term delivery
slots available.
No

Yes

If yes--Please describe these policies, methods, or practices.

II-12f. Changes in capacity.--Describe the circumstances that would provide a business case for
increasing your capacity to produce single-aisle LCA. In particular, specify the cost associated
with adding a particular amount of capacity, the time it would take to add such capacity,
supplier commitment and constraints that would be considered, and the number of aircraft
orders that would be required to justify such investment.

Business Proprietary
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II-12g. Actual order cancellation/deferment discussions.--For any of your firm’s unfilled 100- to 150seat LCA orders as of September 30, 2017, has your firm discussed the possible cancellation
and/or deferment of orders with customer(s)?

Yes

If yes--Please identify the customer(s) and describe the nature of the
discussions.

II-12h. Potential at risk orders.--Regardless of any actual discussions with customers about order
cancellation or deferment detailed above, does your firm consider any unfilled 100- to 150-seat
LCA orders to be at risk of cancellation and/or deferral?

Yes

If yes--Please identify the customer(s) and, for each customer order,
provide the number of at risk scheduled deliveries per year. Also, please
provide a detailed description of why these orders are at risk for
cancellations, reduction in quantity, and/or deferment.

II-12i. Price escalation, pre-delivery payments, and/or meet-or-release provisions for unfilled U.S.
100- to 150-seat LCA orders.--For your firm’s unfilled 100- to 150-seat LCA orders scheduled for
delivery to U.S. customers after September 30, 2017, do these orders contain price escalation
formulae, pre-delivery payment schedules, and/or meet-or-release provisions?

Yes

If yes--Please provide the details of these escalation price escalation
formulae, pre-delivery payment schedules, and/or meet-or-release
provisions?

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II-12j. Ancillary items provided in connection with unfilled U.S. 100- to 150-seat LCA orders.--For
your firm’s 100- to 150-seat large civil aircraft orders that are reported in the data provided for
question II-12a, please identify and describe the ancillary items (i.e., goods, services, and other
items of value in addition to the aircraft itself) that your firm is providing, or has committed to
provide, to the customer as part of the aircraft agreement giving rise to the unfilled orders. The
value of these items should be reported as indicated above in question II-12a.

II-12k. Selection and pricing of 100- to 150-seat LCA engines for unfilled U.S. orders.--For your firm’s
100- to 150-seat large civil aircraft orders that are reported in the data provided for question II12a, please report relevant information with respect to the selection and pricing of engines that
will be incorporated into the aircraft. In your answer, please discuss: (i) the name of the engine
supplier(s), (ii) engine supplier participation, if any, in customer negotiations with respect to
engine prices, future support for engine-related maintenance, spare parts, training, and other
goods and services; and (iii) how engine prices, costs, revenues, discounts, rebates, and other
engine-related items are recorded and recognized by your firm and the relevant engine supplier.

II-13.

Sales efforts.--Please report on recent, current and likely future aircraft sales efforts concerning
U.S. customers (including sales campaigns and other attempts to sell aircraft to specific
customers), covering the period from 2014 through 2022. Please provide details regarding the
nature and timing of each sales effort. Do not include sales efforts that have already led to firm
100- to 150-seal LCA orders reported above.

II-14.

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.

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Foreign Producers’ Questionnaire – 100- to 150-seat LCA (Final)

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PART III.--PRICING AND MARKET FACTORS
Further information on this Part of the questionnaire can be obtained from John Benedetto (202-2053270, [email protected]).
III-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

III-2.

Method of sales.--Please provide a general description of your firm’s method(s) of sales (e.g.,
individual purchase, contract, bids, etc.) for 100- to 150-seat LCA.

III-3a. Bid or purchase solicitation process description.--Please describe the bidding or purchase
solicitation process for contracts to sell 100- to 150-seat LCA. Please describe all factors you
considered in determining your initial bid price (e.g., costs, capacity, domestic competition,
foreign competition).

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III-3b. Trends in bid or sales prices.--Explain any trends in your bid or sales prices since January 1,
2014, and factors influencing those trends. In your response, please discuss whether, and the
extent to which, your firm changed or otherwise modified its 100- to 150-seat LCA pricing
strategies, policies, or practices at any time since January 1, 2014.

III-3c.

Impact of bids or purchase price offers.--How does the nature and outcome of bids or purchase
price offers (from your firm and competing firms) to a particular purchaser of 100- to 150-seat
LCA influence your subsequent bids or price offers to other purchasers? For example, if you
were not awarded a sale by a particular purchaser, would you alter your bid or offer price or
terms in making a subsequent quote to another purchaser?

IV-3d. Impact of sales performance.--How does recent market sales performance of a given 100- to
150-seat LCA model affect the likelihood that a purchaser will order, or prefer to order, that
model when placing orders in the future?

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Foreign Producers’ Questionnaire – 100- to 150-seat LCA (Final)

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III-3e. Bid type.--Are bids open or closed?
Open

Closed

If bids are closed, is the identity of your competitor(s) common knowledge?
Yes

III-3f.

N/A

Bid purchaser discussions.--In the negotiating process, does the purchaser discuss with you the
bids of competing firms (whether or not they disclose the identity of the competition) in order
to get you to lower your bid price?
No

Yes

If yes, describe these discussions

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Foreign Producers’ Questionnaire – 100- to 150-seat LCA (Final)
III-4.

Page 23

Bid or purchase solicitation exclusions.--Since January 1, 2014 have there been instances when
your firm has been excluded from bidding or participating in a purchase solicitation (e.g., your
firm submitted a bid or purchase price that the purchaser did not consider, or the purchaser did
not ask your firm to bid) on particular U.S. sales of 100- to 150-seat LCA?
No

Yes

If yes, please state the year of the sale, the purchaser, and the reason that your firm was
excluded (if known, e.g., price, technology, etc.), for the 5 most recent such instances since
January 1, 2014.
Year of sale

Purchaser

Reason your firm was excluded

III-5a. Lifecycle costs.--Based on your firm’s negotiations involving the sales of 100- to 150-seat LCA,
please identify the factors that U.S. purchasers reference in determining 100- to 150-seat LCA
lifecycle costs.

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Foreign Producers’ Questionnaire – 100- to 150-seat LCA (Final)

Page 24

III-5b. Lifecycle costs.--Please list the top 5 factors contributing to lifecycle costs (in net present value
(“NPV”) calculations) of 100- to 150-seat LCA.
Factor

NPV

Explanation

III-6a. Launch sales.—In general, are you familiar with launch sales of LCA?
Yes

N/A

If yes, what type/level of discount from the average list price do launch customers typically
receive?
Products

Average discount
(percent)

Explanation and factors

Derivative LCA models
Clean sheet LCA models
How do launch prices affect your firm’s purchase price expectations for similar LCA?
Products
Derivative LCA models
Clean sheet LCA models

Explanation and factors

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Foreign Producers’ Questionnaire – 100- to 150-seat LCA (Final)

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III-6b. Marquee customer sales.—In general, are you familiar with marquee customer sales of LCA?
Yes

N/A

If yes, what type/level of discount from the average list price do marquee customers typically
receive?
Products

Average discount
(percent)

Explanation and factors

Derivative LCA models
Clean sheet LCA models
How do marquee customer prices affect your firm’s purchase price expectations for similar LCA?
Products

Explanation and factors

Derivative LCA models
Clean sheet LCA models
III-7.

Demand trends.--Indicate how demand within the United States and outside of the United
States (if known) for 100- to 150-seat LCA has changed since January 1, 2014. Explain any trends
and describe the principal factors that have affected these changes in demand.

Market
Within the United States
Outside the United States

Overall
increase

Fluctuate
No
Overall
with no
change decrease clear trend

Explanation and factors

Business Proprietary
Foreign Producers’ Questionnaire – 100- to 150-seat LCA (Final)
III-8.

Product changes.--Have there been any significant changes in the production or marketing of
100- to 150-seat LCA since January 1, 2014?
No

III-9.

Page 26

Yes

If yes, please describe and quantify if possible.

Conditions of competition.-(a) Is the 100- to 150-seat LCA market subject to business cycles (other than general
economy-wide conditions) and/or other conditions of competition distinctive to 100- to
150-seat LCA? If yes, describe.
Check all that apply.

Please describe.

Skip to question III-10.

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
100- to 150-seat LCA since January 1, 2014?
No

Yes

If yes, describe.

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Foreign Producers’ Questionnaire – 100- to 150-seat LCA (Final)

Page 27

III-10. Supply constraints.--Has your firm refused, declined, or been unable to supply 100- to 150-seat
LCA since January 1, 2014 (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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Foreign Producers’ Questionnaire – 100- to 150-seat LCA (Final)

Page 28

III-11a. Delivery deferral.—Since January 1, 2007, did your firm defer delivery of 100- to 150-seat LCA?
If Yes, provide how often has your firm deferred delivery of 100- to 150-seat LCA, the length of
the deferral, and the reasons for those deferrals on a customer-by-customer basis?

Deferred time
Less than 6 months
6 to 12 months
1 to 2 years
More than 2 years

Number of 100- to 150-seat LCA
Customer(s) and reasons
Between January 1, 2007 and December 31, 2013
Manufacturing
production delay
Other delay
(number)
(number)
Explanation, by customer

Number of 100- to 150-seat LCA
Customer(s) and reasons
Since January 1, 2014
Manufacturing
production delay
Other delay
(number)
(number)
Explanation, by customer

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Foreign Producers’ Questionnaire – 100- to 150-seat LCA (Final)

Page 29

IV-11b. Conversion.--For all instance since January 1, 2014, identify when a U.S. customer converted an
order for 100- to 150-seat LCA to an order for other LCA, or vice versa.
Item
Customer
Model originally
ordered
Number of aircraft
originally ordered
Date of original order
Date conversion right
exercised
Model ordered after
conversion
Number of aircraft
converted

Example 1

Example 2

Example 3

Example 4

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Foreign Producers’ Questionnaire – 100- to 150-seat LCA (Final)

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III-12. Interchangeability.—Are 100- to 150-seat LCA 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

Canada – Bombardier
CS100 or CS300

EU Airbus A319

100- to 150-seat LCA
produced in other
countries

U.S. – Boeing 737700 or 737 MAX 7
Canada –
Bombardier CS100
or CS300
EU Airbus A319
For any country-pair producing 100- to 150-seat LCA that is sometimes or never
interchangeable, identify the country-pair and explain the factors that limit or preclude
interchangeable use:

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Foreign Producers’ Questionnaire – 100- to 150-seat LCA (Final)

Page 31

III-13. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, technical support, etc.) between 100- to 150-seat LCA 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

Canada – Bombardier
CS100 or CS300

EU Airbus A319

100- to 150-seat
LCA produced in
other countries

U.S. – Boeing 737700 or 737 MAX 7
Canada –
Bombardier CS100
or CS300
EU Airbus A319
For any country-pair for which factors other than price always or frequently are a significant
factor in your firm’s sales of 100- to 150-seat LCA, identify the country-pair and report the
advantages or disadvantages imparted by such factors:

Business Proprietary
Foreign Producers’ Questionnaire – 100- to 150-seat LCA (Final)

Page 32

III-14. U.S. customer identification.-(a) Please provide the names and contact information for your firm’s FIVE largest U.S. customers
for 100- to 150-seat LCA since January 1, 2007.
U.S. customer’s
name

Contact
person

Share of your firm’s 2007-17 sales to U.S.
customers (%)

1
2
3
4
5

III-15. Other explanations.--If your firm would like to further explain a response to a question in Part III
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
Foreign Producers’ Questionnaire – 100- to 150-seat LCA (Final)

Page 33

Correcting Valid number error messages.--If you are completing a Commission

questionnaire in a country that uses periods (“.”) to delineate multiples of 1000 (e.g., one million would
appear as $1.000.000 instead of as $1,000,000), you may be unable to enter in numbers greater than
999 in numeric form fields. This issues stem from your computer number formatting setting (e.g., not
the MS Word document itself, but the computer from which you are opening up the document). In the
United States commas (,) delineate multiples of 1000 and periods (.) delineate fractions less than one.
Many EU countries use the reverse where multiples of 1000 are delineated with periods (.) and
fractions less than one are delineated with commas (,). The US International Trade Commission’s
questionnaires are set-up in the United States with the U.S. number formatting. When this formatting
interacts with a computer set to EU number formatting, we believe this may cause this issue.
The solution to this data entry issue is to temporarily change your operating system’s number
formatting to be consistent with the U.S. number formatting system while you complete the
questionnaire.
To temporarily change your computer’s number settings to U.S. settings, please do the following (for
Microsoft Windows Operating system):
•
•
•
•
•

START
Control Panel
Region and Language (under Clock, Language, and Region category)
Format tab
Change the Format from your existing one (e.g., “Italian (Italy)”) to “English (United States)” (see
screen shots below)

When you do this the number “twelve million dollars and thirty five cents” would change from
$12.000.000,35 (Italy format) to $12,000,000.35 (U.S. format), and then there will be no conflict with
the USITC foreign producer questionnaire form. When you finish reporting the data then you can close
the questionnaire and switch back to Italy settings.

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Foreign Producers’ Questionnaire – 100- to 150-seat LCA (Final)

Page 34

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/701731/2017/100_150_seat_large_civil_aircraft_
canada/final.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: LCA1

• E-mail.--E-mail your 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 did not produce or export this product, please fill out page 1, print, sign, and submit a
scanned copy to the Commission.
Parties to this proceeding.--If your firm is a party to this proceeding, you are required to serve a copy of
the completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (202205-1803). 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	USITCQUESTIONNAIRE
Subject	Title 7 investigations
Author	Carlson, Carolyn
File Modified	2017-10-16
File Created	2017-10-16