Form 18-1-3884 US producers' questionnaire

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

US producers--Large power transformers

Large power transformers from Korea (Inv. no 731-TA-1189)

OMB: 3117-0016

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OMB No. 3117-0016/USITC No. 18-1-3884; Expiration Date: 6/30/2020
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U.S. PRODUCERS’ QUESTIONNAIRE
LARGE POWER TRANSFORMERS FROM KOREA
This questionnaire must be received by the Commission by May 21, 2018
See last page for filing instructions.
The information called for in this questionnaire is for use by the United States International Trade Commission in
connection with its review of the antidumping duty order concerning large power transformers from Korea (Inv. No.
731-TA-1189 (Review)). The information requested in the questionnaire is requested under the authority of the Tariff
Act of 1930, title VII. This report is mandatory and failure to reply as directed can result in a subpoena or other order to
compel the submission of records or information in your firm’s possession (19 U.S.C. § 1333(a)).

Name of firm
Address
City

State

Zip Code

Website
Has your firm produced large power transformers (as defined on the next page) at any time since January 1,
2012?

NO

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

YES

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

Return questionnaire via the Commission Drop Box by clicking on the following link:
https://dropbox.usitc.gov/oinv/ (PIN: TRANS)
CERTIFICATION
I certify that the information herein supplied in response to this questionnaire is complete and correct to the best of my
knowledge and belief and understand that the information submitted is subject to audit and verification by the Commission. By
means of this certification I also grant consent for the Commission, and its employees and contract personnel, to use the
information provided in this questionnaire and throughout this proceeding in any other import-injury proceedings or reviews
conducted by the Commission on the same or similar merchandise.
I, the undersigned, acknowledge that information submitted in response to this request for information and throughout this
proceeding or other proceedings may be disclosed to and used: (i) by the Commission, its employees and Offices, and contract
personnel (a) for developing or maintaining the records of this or a related proceeding, or (b) in internal investigations, audits,
reviews, and evaluations relating to the programs, personnel, and operations of the Commission including under 5 U.S.C.
Appendix 3; or (ii) by U.S. government employees and contract personnel, solely for cybersecurity purposes. I understand that all
contract personnel will sign appropriate nondisclosure agreements.
Name of Authorized Official

Title of Authorized Official

Date

Phone:
Signature

Email address

Business Proprietary
U.S. Producers’ Questionnaire - large power transformers

Page 2

PART I.—GENERAL INFORMATION
Background.--On August 31, 2012, the Department of Commerce (“Commerce") issued an antidumping
duty order on imports of large power transformers from Korea. On July 3, 2017, the Commission
instituted a review pursuant to section 751(c) of the Tariff Act of 1930 (19 U.S.C. § 1675(c)) (the Act) to
determine whether revocation of the order would be likely to lead to continuation or recurrence of
material injury to the domestic industry within a reasonably foreseeable time. If both the Commission
and Commerce make an affirmative determination, the order will remain in place. If either the
Commission or Commerce makes a negative determination, Commerce will revoke the order.
Questionnaires and other information pertinent to this proceeding are available at
https://www.usitc.gov/investigations/701731/2017/large_power_transformers_korea/first_review_full.htm.

Large power transformers covers large liquid dielectric power transformers (“LPTs”) having a top power
handling capacity greater than or equal to 60,000 kilovolt amperes (60 megavolt amperes), whether
assembled or unassembled, complete or incomplete.
Incomplete LPTs are subassemblies consisting of the active part and any other parts attached to,
imported with, or invoiced with the active parts of LPTs. The ‘‘active part’’ of the transformer consists of
one or more of the following when attached to or otherwise assembled with one another: The steel core
or shell, the windings, electrical insulation between the windings, or the mechanical frame for an LPT.
The product definition encompasses all such LPTs regardless of name designation, including but not
limited to step-up transformers, step-down transformers, autotransformers, interconnection
transformers, voltage regulator transformers, rectifier transformers, and power rectifier transformers.
The LPTs subject to this order are currently classifiable under subheadings 8504.23.0040, 8504.23.0080,
and 8504.90.9540 of the Harmonized Tariff Schedule of the United States (HTSUS). Although the HTSUS
subheadings are provided for convenience and customs purposes, the written description of the scope
of this order is dispositive.
Reporting of information.-- If information is not readily available from your records in exactly the form
requested, furnish carefully prepared estimates. If your firm is completing more than one questionnaire
in connection with this proceeding (i.e., a producer, importer, and/or purchaser questionnaire), you
need not respond to duplicated questions in the questionnaires.
Confidentiality.--The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.
Verification.--The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all of your files, worksheets, and
supporting documents used in the preparation of the questionnaire response. Please also retain a copy
of the final document that you submit.
Release of information.--The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in

Business Proprietary
U.S. Producers’ Questionnaire - Large power transformers (R1)

Page 3

connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import-injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals.
I-1.

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

Dollars

The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
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.
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 large power transformers,
including auxiliary facilities operated in conjunction with (whether or not physically separate
from) such facilities.
Establishments
Covered1

City, State

Zip (5 digit)

1
2
3
4
5
6
1

Additional discussion on establishments consolidated in this questionnaire:

Description

Business Proprietary
U.S. Producers’ Questionnaire - Large power transformers (R1)
I-3.

Page 4

Position regarding continuation of order.--Does your firm support or oppose continuation of
the following antidumping duty order currently in place for large power transformers?
Country

Support

Oppose

Take no position

Korea
I-4.

Ownership.--Is your firm owned, in whole or in part, by any other firm?
No

Firm name

I-5.

Yes--List the following information.

Address

Extent of
ownership
(percent)

Related importers/exporters.--Does your firm have any related firms, either domestic or
foreign, that are engaged in importing large power transformers into the United States or that
are engaged in exporting large power transformers to the United States?
No
Firm name

Yes--List the following information.
Country

Affiliation

Business Proprietary
U.S. Producers’ Questionnaire - Large power transformers (R1)
I-6.

Related producers.--Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of large power transformers?
No

Yes--List the following information.

Firm name

I-7.

Page 5

Country

Affiliation

Business plan.--In Part II of this questionnaire we request a copy of your company’s business
plan. Does your company or any related firm have a business plan or any internal documents
that describe, discuss, or analyze expected market conditions for large power transformers?

No

Yes

If yes, please provide the requested documents. If you are not providing the
requested documents, please explain why not.

Business Proprietary
U.S. Producers’ Questionnaire - Large power transformers (R1)

Page 6

PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Nathanael Comly (202-2053174, [email protected]) or Christopher Robinson (202-205-2542;
[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

II-2a.

Changes in operations.--Please indicate whether your firm has experienced any of the following
changes in relation to the production of large power transformers since January 1, 2012.

Check as many as appropriate.
Plant openings
Plant closings
Relocations
Expansions
Acquisitions
Consolidations
Prolonged shutdowns or
production curtailments
Revised labor agreements
Corporate restructuring
Other (e.g., technology)

If checked, please describe; leave blank if not
applicable.

Business Proprietary
U.S. Producers’ Questionnaire - Large power transformers (R1)
II-2b.

Anticipated changes in operations.--Does your firm anticipate any changes in in the character of
its operations or organization relating to the production of large power transformers in the
future?

No

II-3a.

Page 7

Yes

If yes, supply details as to the time, nature, and significance of
such changes and provide underlying assumptions, along with
relevant portions of business plans or other supporting
documentations that address this issue. Include in your
response a specific projection of your firm’s capacity to
produce large power transformers (in MVA top rated) for 2018
and 2019.

Production using same machinery.--Please report your firm’s production of products made on
the same equipment and machinery used to produce large power transformers, 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 MVA top rated)
Calendar year
Item

2015

2016

January-March
2017

2017

2018

Overall production capacity
Production of:
Large power transformers (60 to
299 MVA)
Large power transformers (over
300 MVA)
Total large power transformers1
Other products
Total
1
2

0

0

0

0

0

0

0

0

0

0

2

Please see reconciliation below.
Please identify these products:

.

Business Proprietary
U.S. Producers’ Questionnaire - Large power transformers (R1)
II-3a.

Page 8

Production using same machinery –Continued

RECONCILIATION OF LARGE POWER TRANSFORMERS PRODUCTION.--Please ensure that the quantities
reported above for large power transformers (i.e., those of 60 to 299 MVA plus those over 300 MVA) in
each time period equal the quantity reported for large power transformers in II-4 (i.e., line C) in each
time period. If the calculated fields below return values other than zero (i.e., “0”), the data reported
must be revised prior to submission to the Commission.
Calendar year
Item

2015

Total large power transformers –
question II-4 line C = zero ("0"), if
not revise.

2016

0

January-March
2017

0

2017

0

2018

0

0

II-3b.

Operating parameters.--The production capacity reported in II-3a is based on operating
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.

II-3e.

Efficiency gains.--Have there been changes to the technology used in the production of large power
transformers that have resulted in efficiency gains in your firm's large power transfersformers since
January 1, 2012?
No

Yes

If yes, please describe these efficiency gains.

hours

Business Proprietary
U.S. Producers’ Questionnaire - Large power transformers (R1)
II-3f.

Page 9

Product shifting.--Is your firm able to switch production (capacity) between large power
transformers and other products (i.e., products other than large power transformers) 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-3g.

Product shifting factors.--Please describe the factors that affect your firm’s ability to shift
production capacity between between large power transformers and other products (i.e., products
other than large power transformers) (e.g., time, cost, relative price change, qualification or lack
thereof, etc.), and the degree to which these factors enhance or constrain such shifts.

II-3h.

Product shifting by MVA rating.--Is your firm able to switch production (capacity) between large
power transformers with a rating of 60 to 299 MVA and large power transformers with a rating of
300 MVA or more using the same equipment and/or labor?
No

II-3i.

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

.

Product shifting factors by MVA rating.--Please describe the factors that affect your firm’s ability to
shift production capacity between between large power transformers with a rating of 60 to 300
MVA and large power transformers with a rating of 300 MVA or more (e.g., time, cost, relative price
change, qualification or lack thereof, etc.), and the degree to which these factors enhance or
constrain such shifts.

Business Proprietary
U.S. Producers’ Questionnaire - Large power transformers (R1)
II-4.

Page 10

Production, shipment, and inventory data.--Report your firm’s production capacity, production,
shipments, and inventories related to the production of large power transformers in its U.S.
establishment(s) during the specified periods.
“Average production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
“U.S. commercial shipments” –Shipments made within the United States as a result of an arm’s
length commercial transaction in the ordinary course of business. Report net values (i.e., gross
sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods) in U.S. dollars, f.o.b. your point of shipment.
“Internal consumption” – Product consumed internally by your firm. Such transactions are
valued at fair market value.
“Transfers to related firms” –Shipments made to related domestic firms. Such transactions

are valued at fair market value.

“Related firm” –A firm that your firm solely or jointly owns, manages, or otherwise controls.
“Export shipments” –Shipments to destinations outside the United States, including shipments
to related firms.
“Inventories”— Finished goods inventory, not raw materials or work-in-progress.
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 - Large power transformers (R1)
II-4.

Page 11

Production, shipment, and inventory data. --Continued
Quantity (in MVA top rated); Value (in 1,000 dollars)
Calendar year
Item

Average production capacity
(quantity) (A)

2015

2016

January-March
2017

2017

2018

1

Beginning-of-period inventories
(quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
quantity (D)
value (E)
Internal consumption:2
quantity (F)
value (G)
Transfers to related firms:2
quantity (H)
value (I)
Export shipments:3
quantity (J)
value (K)
End-of-period inventories
(quantity) (L)
1

The production capacity reported is based on operating
hours per week,
weeks per year. Please describe the
methodology used to calculate production capacity, and explain any changes in reported capacity (use additional pages as necessary).
.
2
Internal consumption and transfers to related firms must be valued at fair market value. Does your firm use a different basis for
valuing these transactions, please specify that basis (e.g., cost, cost plus, etc.):
(however, provide the data above at fair market
value).
3
Identify your firm’s principal export markets:
.

Business Proprietary
U.S. Producers’ Questionnaire - Large power transformers (R1)
II-4.

Page 12

Production, shipment, and inventory data.--Continued

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

2015

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

2016

0

January-March
2017

0

2017

0

2018

0

0

1

Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are
nonetheless accurate:
.
II-5.

Channels of distribution.--Report your firm’s commercial U.S. shipments by channel of
distribution.
Quantity (in MVA top rated)
Calendar year
Item

2015

2016

January-March
2017

2017

2018

Channels of distribution:
Commercial U.S. shipments to—
Distributors (M)
Utilities (N)
Other end users (O)
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution
(i.e., lines M and N) in each time period equal the quantity reported for commercial U.S. commercial
shipments (i.e., line D) in each time period. If the calculated fields below return values other than zero
(i.e., “0”), the data reported must be revised prior to submission to the Commission.
Calendar year
Reconciliation
M + N + O – D = zero ("0"), if
not revise.

2015

2016
0

January-March
2017

0

2017
0

2018
0

0

Business Proprietary
U.S. Producers’ Questionnaire - Large power transformers (R1)
II-6.

Page 13

Historical U.S. shipments.--Report your firm’s U.S. shipments related to the production of large
power transformers in its U.S. establishment(s) during the specified periods.
Quantity (in MVA top rated); Value (in 1,000 dollars)
Calendar year
Item

2012

2013

2014

U.S. shipments:
Quantity
Value
II-7.

U.S. shipments by MVA rating.--Report your firm’s U.S. shipments related to the U.S. shipments
(i.e., inclusive of commercial U.S. shipments, internal consumption, and transfers to related
firms) of large power transformers during the specified periods.
Calendar year
Item

2015

2016

2017

U.S. shipments:
60 MVA to 299 MVA
Quantity (MVA top rated) (P)
Quantity (Units) (Q)
Value ($1,000) (R)
300 MVA or more
Quantity (MVA top rated) (S)
Quantity (Units) (T)
Value ($1,000) (U)
RECONCILIATION OF US SHIPMENTS.--Please ensure that the quantities and value reported for US
shipments in this question (i.e., lines P and S and lines R and U) in each time period equal the quantities
and value reported for U.S. shipments (i.e., lines D through I) in each time period in question II-4. If the
calculated fields below return values other than zero (i.e., “0”), the data reported must be revised prior
to submission to the Commission.
Calendar year
Reconciliation

2015

2016

2017

Quantity: P + S – D – F – H = zero
("0"), if not revise.

0

0

0

Value: R + U – E – G – I = zero
("0"), if not revise.

0

0

0

Business Proprietary
U.S. Producers’ Questionnaire - Large power transformers (R1)
II-8a.

Page 14

Ability and actual production by MVA (top rated) range.--Report whether your firm has the
capability to product the following categories of large power transformers based on MVA (toprated) in the United States and whether your firm actually produced large power transformers in
that range.

Item

Able to produce
(check if yes)

Actually produced
(2012-2017)
(check if yes)

60 to 99 MVA
100 to 199 MVA
200 to 299 MVA
300 to 399 MVA
400 to 499 MVA
500 to 599 MVA
600 to 699 MVA
700 or greater MVA
II-8b.

Technical limitations impacting firm's ability to produce above the 300 MVA (top-rated)
thresholds.-Are there technical limitations to your firm's ability to produce large power
transfers with a MVA (top-rated) of more than 300?
No

II-8c.

Yes

If yes, please explain.

Economic considerations impacting firm's willingness to produce above the 300 MVA (toprated) thresholds.-Are there economic considerations that impact your firm's willingness to
produce large power transformers above the MVA (top-rated) of more than 300?
No

Yes

If yes, please explain.

Business Proprietary
U.S. Producers’ Questionnaire - Large power transformers (R1)
II-9a.

Page 15

Ability and actual production by kV range.--Report whether your firm has the capability to
product the following categories of large power transformers based on high line voltage (kV) in
the United States and whether your firm actually produced large power transformers in that
range.

Item

Able to produce
(check if yes)

Actually produced
(2012-2017)
(check if yes)

Less than 345 kV
345 to 499 kV
500 to 764 kV
765 kV or greater
II-9b.

Technical limitations impacting firm's ability to produce above 764 kV.-Are there technical
limitations to your firm's ability to produce large power transfers with a high line voltage (kV) of
more than 764kV?
No

II-9c.

Yes

If yes, please explain.

Economic considerations impacting firm's willingness to produce above 764 kV.-Are there
economic considerations that impact your firm's willingness to produce large power
transformers with a high line voltage (kV) of more than 764kV?
No

Yes

If yes, please explain.

Business Proprietary
U.S. Producers’ Questionnaire - Large power transformers (R1)
II-10.

Page 16

Employment data.--Report your firm’s employment-related data related to the production of
large power transformers and provide an explanation for any trends in these data.
“Production and Related Workers” (PRWs) includes working supervisors and all nonsupervisory
workers (including group leaders and trainees) engaged in fabricating, processing, assembling,
inspecting, receiving, storage, handling, packing, warehousing, shipping, trucking, hauling,
maintenance, repair, janitorial and guard services, product development, auxiliary production
for plant’s own use (e.g., power plant), recordkeeping, and other services closely associated with
the above production operations.
Average number employed may be computed by adding the number of employees, both full
time and part time, for the 12 pay periods ending closest to the 15th of the month and divide
that total by 12. For the January to March periods, calculate similarly and divide by 3
“Hours worked” includes time paid for sick leave, holidays, and vacation time. Include overtime
hours actually worked; do not convert overtime pay to its equivalent in straight time hours.
“Wages paid” –Total wages paid before deductions of any kind (e.g., withholding taxes, old-age
and unemployment insurance, group insurance, union dues, bonds, etc.). Include wages paid
directly by your firm for overtime, holidays, vacations, and sick leave.
Calendar year
Item

2015

2016

January-March
2017

2017

2018

Average number of PRWs (number)
Hours worked by PRWs (1,000 hours)
Wages paid to PRWs ($1,000)
Explanation of trends:

II-11.

Transfers to related firms.--If your firm reported transfers to related firms in question II-4,
please indicate the nature of the relationship between your firm and the related firms (e.g., joint
venture, wholly owned subsidiary), whether the transfers were priced at market value or by a
non-market formula, whether your firm retained marketing rights to all transfers, and whether
the related firms also processed inputs from sources other than your firm.

Business Proprietary
U.S. Producers’ Questionnaire - Large power transformers (R1)
II-12.

Page 17

Purchases.--Other than imports by your firm, has your firm otherwise purchased large power
transformers (either domestic or imported) since January 1, 2012?
No

Yes-- Please indicate the reasons for your firm’s purchases (if your firms’
reasons differ by source, please elaborate) and report the quantity and
value of such purchases below for the specified periods.

“Purchase” – A transaction to buy product from a U.S. corporate entity such as another U.S.
producer, a U.S. distributor, or a U.S. firm that has directly imported the product.
“Import” –A transaction to buy from a foreign supplier where your firm is the importer of
record.
Reason for purchases:

Quantity (in MVA top rated)
Calendar year
Item

2015

2016

January-March
2017

2017

2018

Purchases from U.S. importers of
large power transformers from—
Korea1
All other sources2
Purchases from domestic
producers3
Purchases from other sources3
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 top sources of your firms purchases:
.
3
Please list the name of the producer(s) or U.S. distributor(s) from which your firm purchased this product:
.

II-13.

Toll production.--Since January 1, 2012, has your firm been involved in a toll agreement
regarding the production of large power transformers?
“Toll agreement”--Agreement between two firms whereby the first firm furnishes the raw
materials and the second firm uses the raw materials to produce a product that it then returns
to the first firm with a charge for processing costs, overhead, etc.

No

Yes

If yes-- Please describe the toll arrangement(s) and name the firm(s)
involved.

Business Proprietary
U.S. Producers’ Questionnaire - Large power transformers (R1)
II-14.

Page 18

Foreign trade zones.-Firm's FTZ operations.--Does your firm produce large power transformers in and/or
admit large power transformers into a foreign trade zone (FTZ)?

(a)

“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

Other firms' FTZ operations.--To your knowledge, do any firms in the United States
import large power transformers into a foreign trade zone (FTZ) for use in distribution of
large power transformers and/or the production of downstream articles?

(b)

No

II-15.

Yes

If yes-- Describe the nature of your firms operations in FTZs and identify
the specific FTZ site(s).

Yes

If yes--Identify the firms and the FTZs.

Imports.--Since January 1, 2012, has your firm imported large power transformers?
“Importer” – The person or firm primarily liable for the payment of any duties on the
merchandise, or an authorized agent acting on his behalf.
No

Yes
If yes-- COMPLETE AND RETURN A U.S. IMPORTERS’ QUESTIONNAIRE

II-16.

Imports by an affiliated firm.--Since January 1, 2012, has a firm affiliated with your firm
imported large power transformers?
No

Yes
If yes—HAVE YOUR AFFLIATED FIRM COMPLETE AND RETURN A U.S.
IMPORTERS’ QUESTIONNAIRE

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II-17.

Effect of order.--Describe the significance of the existing antidumping duty order covering
imports of large power transformers from Korea in terms of its effect on your firm’s production
capacity, production, U.S. shipments, inventories, purchases, employment, revenues, costs,
profits, cash flow, capital expenditures, research and development expenditures, and asset
values. You may wish to compare your firm’s operations before and after the imposition of the
order.

II-18.

Likely impact of revocation.--Would your firm anticipate any changes in in the character of its
operations or organization, including its production capacity, production, U.S. shipments,
inventories, purchases, employment, revenues, costs, profits, cash flow, capital expenditures,
research and development expenditures, or asset values relating to the production of large
power transformers in the future if the antidumping duty orders on large power transformers
from Korea were to be revoked?

No

II-19.

Yes

If yes, supply details as to the time, nature, and significance of
such changes and provide underlying assumptions, along with
relevant portions of business plans or other supporting
documentations that address this issue. Include in your
response a specific projection of your firm’s capacity to
produce large power transformers (in MVA top rated) for 2018
and 2019.

Other explanations:--If your firm would like to explain further 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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PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to David Boyland (202-708-4725,
[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

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 large power transformers:

2.
3.

4.
5.

Does your firm prepare profit/loss statements for large power transformers:
Yes
No
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,
10Qs,
Monthly,
quarterly,
semi-annually,
annually
Accounting basis:
GAAP,
cash,
tax, or
other comprehensive basis of
accounting (specify)
Report how your firm recognizes revenue from the sales of large power transformers in
the specified periods.
Fiscal year
Item

2015

2016

2017

Share of revenue recognized:
At point of sale or date of delivery
Based on milestones specified in purchase order1
Other2
Total (should sum to 100.0 percent in each column)
1

0.0

0.0

Please describe the most common milestones used for revenue recognition when based on milestone
specified in the purchase order.
2
Please describe the other revenue recognition method(s) used.
.

0.0

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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
large power transformers, as well as specific statements and worksheets) used to compile these data.

III-3.

Cost accounting system.--Briefly describe your firm’s cost accounting system (e.g., standard
cost, job order cost, etc.).

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. Please include sufficient detail as to what
items in each category are being allocated; e.g., for COGS: direct materials, labor, variable
overhead, fixed overhead, etc.

III-5a. Product listing.--Please list the products your firm produces in the facilities in which it produces
large power transformers, and provide the share of net sales accounted for by these products in
your firm’s most recent fiscal year.
Products

Share of sales

Large power transformers

%
%
%
%
%

III-5b. Anticipated changes in product listing.--Do you anticipate that the share of your firm’s net sales
accounted for by these products will change in the next fiscal year?
No
Yes--In the space below, please describe the anticipated changes.

Business Proprietary
U.S. Producers’ Questionnaire - Large power transformers (R1)
III-6.

Does your firm purchase inputs (raw materials, labor, energy, or any services) used in the
production of large power transformers from any related suppliers (e.g., inclusive of
transactions between related firms, divisions and/or other components within the same
company)?
Yes--Continue to question III-7.

III-7.

Page 22

No--Continue to question III-9a.

Inputs from related suppliers.--Please identify the inputs used in the production of large power
transformers that your firm purchases from related suppliers and that are reflected in question
III-9a. For “Share of total COGS” please report this information by relevant input on the basis of
your most recently completed fiscal year. For “Input valuation” please describe the basis, as
recorded in the company’s own accounting system, of the purchase cost from the related
supplier; e.g., the related supplier’s actual cost, cost plus, negotiated transfer price to
approximate fair market value.
Input

Related supplier

Share of total COGS

Input valuation as recorded in the firm’s accounting books and records

III-8.

Inputs from related suppliers at cost.--Please confirm that the inputs purchased from related
suppliers, as identified in III-7, were reported in question III-9a (financial results on large power
transformers) in a manner consistent with the 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 question III-9a.

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III-9a. Operations on large power transformers.--Report the revenue and related cost information
requested below on the large power transformers operations of your firm’s U.S.
establishment(s).1 Do not report resales of products. Note that internal consumption and
transfers to related firms must be valued at fair market value. Input purchases from related
suppliers should be consistent with and based on information in the firm’s accounting books and
records. Provide data for your firm’s three most recently completed fiscal years, and for the
specified interim periods.
Quantity (in MVA top rated); Value (in 1,000 dollars)
Fiscal year
Item

2015

January-March

2016

2017

2017

2018

2

Net sales quantities:
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

Total COGS

0

0

0

0

0

Gross profit or (loss)

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 (reported in III-9c)
Direct labor
Other factory costs

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 volume amounts reported should correspond to revenue and cost recognition
reflected in this table; i.e., volume reported in this table, depending on revenue recognition approach, may or may not correspond to the 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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III-9b. Historical operations on large power transformers.--Report the revenue and related
performance information requested below on the large power transformers operations of your
firm’s U.S. establishment(s).1
Quantity (in MVA top rated); Value (in 1,000 dollars)
Fiscal years ended--

Item

2012

2013

2014

Net sales quantity
Net sales value
Operating income or (loss)

III-9c. Inputs reported as raw material.--Report the cost of input materials corresponding to the
operations reported in question III-9a.
Value (in $1,000)
Fiscal years ended-Item

2015

2016

January-March
2017

2017

2018

Grain oriented silicon electrical steel
(GOES)
Steel plate
Dielectric mineral oil
Controls and accessories
Windings
All other raw material inputs
Total raw material costs (III-9a)

0

0

0

0

If you reported a figure for “Controls and accessories,” please explain below how you define the
term “accessories” in the normal course of business.

0

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III-9d. Financial data reconciliation.--The calculable line items from question III-9a (i.e., total net sales
quantities and values, total COGS, gross profit (or loss), total SG&A, and net income (or loss))
have been calculated from the data submitted in the other line items. Do the calculated fields
return the correct data according to your firm's financial records ignoring non-material
differences that may arise due to rounding?
Yes

No--If the calculated fields do not show the correct data, please double check the
feeder data for data entry errors and revise.
Also, check signs accorded to the post operating income line items; the two
expense line items should report positive numbers (i.e., expenses are
positive and incomes or reversals are negative--instances of the latter
should be rare in those lines) while the income line item also in most
instances should have its value be a positive number (i.e., income is positive,
expenses or reversals are negative).
If after reviewing and potentially revising the feeder data your firm has
provided, the differences between your records and the calculated fields
persist please identify and discuss the differences in the space below.

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III-10. Nonrecurring items (charges and gains) included in large power transformer financial results.-For each annual and interim period for which financial results are reported in question III-9a,
please specify all material (significant) nonrecurring items (charges and gains) in the schedule
below, the specific question III-9a line item where the nonrecurring items are included, a brief
description of the relevant nonrecurring items, and the associated values (in $1,000), as
reflected in question III-9a; i.e., if an aggregate nonrecurring item has been allocated to question
III-9a, only the allocated value amount included in question III-9a should be reported in the
schedule below. Note: The Commission’s objective here is to gather information only on
material (significant) nonrecurring items which impacted the reported financial results of the
subject product in question III-9a.
Calendar years

2015
Item

2016

2017

Value ($1,000)

Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7

Nonrecurring item: In this table please provide a brief description of each nonrecurring item reported above and
indicate the specific line item in table III-9a where the nonrecurring item is classified.
Description of the
nonrecurring item

Income statement classification of the nonrecurring item

Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7

III-11. Classification of identified nonrecurring items (charges and gains) in the accounting books and
records of the company.--If nonrecurring items were reported in question III-10 above, please
identify where your company recorded these items in your accounting books and records in the
normal course of business; i.e., just as responses to question III-10 identify where these items
are reported in question III-9a.

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III-12. Asset values.--Report the total assets (i.e., both current and long-term assets) associated with
the production, warehousing, and sale of large power transformers. If your firm does not
maintain some or all of the specific asset information necessary to calculate total assets for large
power transformers in the normal course of business, please estimate this information based
upon a method (such as production, sales, or costs) that is consistent with relevant cost
allocations in question III-9a. Provide data as of the end of your firm’s three most recently
completed fiscal years.
Note: Total assets should reflect net assets after any accumulated depreciation and allowances
deducted.
Total assets should be allocated to the subject products if these assets are also related to other
products. Please provide a brief explanation if there are any substantial changes in total asset
value during the period; e.g., due to asset write-offs, revaluation, and major purchases.
Value (in $1,000)
Fiscal years ended-Item
Total assets (net)
1

2015

2016

2017

1

If applicable, describe reason(s) for notable changes in total reported assets during period

If you reported total assets on the basis of an allocation method, please describe the allocation in
detail below.

III-13. Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development expenses for large power transformers. Provide
data for your firm’s three most recently completed fiscal years, and for the specified interim
periods.
Value (in $1,000)
Fiscal years ended-Item

Capital expenditures

2015

2016

January-March
2017

2017

1

Research and development
expenses2
1
2

Please describe the nature, focus, and significance of your firm’s capital expenditures on the subject product.
Please describe the nature, focus, and significance of your firm’s R&D expenses related to subject product.

2018

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III-14. Data consistency and reconciliation.--Please indicate whether your firm’s financial data for
questions III-9a, 12, and 13 are based on a calendar year or your firm’s fiscal year:
Calendar year

Fiscal year

Specify fiscal year

Please note the quantities and values reported in question III-9a should, to the extent applicable
(see question III-9a (note 2), reconcile with the data reported in question II-4 (including export
shipments) as long as they are reported on the same calendar year basis.
RECONCILIATION OF TRADE VS FINANCIAL DATA.--Please ensure, to the extent applicable (see question
III-9a (note 2)), that the quantities and values reported for total shipments in part II equal the quantities
and values reported for total net sales in part III of this questionnaire in each time period unless the
financial data from part III are reported on a fiscal year basis, in which case only the interim periods must
reconcile. If the calculated fields below return values other than zero (i.e., “0”) and both are being
reported on a calendar basis, please explain the discrepancy below.
Fiscal years ended-Item

2015

2016

January-March
2017

2017

2018

Quantity: Trade data from question
II-4 (lines D, F, H, and J) less financial
total net sales quantity data from
question III-9a, = zero ("0").

0

0

0

0

0

Value: Trade data from question II-4
(lines E, G, I, and K) less financial total
net sales value data from question III9a, = zero ("0").

0

0

0

0

0

Do these data in question III-9a reconcile with data in question II-4?
Yes

No

If no, please explain.

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 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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PART IV.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Cindy Cohen (202-205-3230,
[email protected]).
IV-1.

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

IV-2.

How often do transactions or sales require your firm to go through a qualification process or
enter a blanket agreement, as a condition to bid on a particular project?
Item

Always

Frequently

Sometimes

Rarely/Never

Qualification process required
Blanket agreement required
IV-3a. Bid Opportunities.--How often is there more than one chance to bid on a particular sales
agreement?
Always

Frequently

Sometimes

Rarely/Never

IV-3b. Bid Competition.--How often does the purchaser discuss with you the bids of competing firms
(whether or not you disclose who the competition is) in order to get a lower bid price?
Always

Frequently

Sometimes

Rarely/Never

Business Proprietary
U.S. Producers’ Questionnaire - Large power transformers (R1)
IV-4.

Page 30

Services Included in Bid.--Do the bids that you make for LPTs typically include other services
such as installation, maintenance, warranties, etc.?
No

Yes

If yes, describe.

IV-5.

Discount policy.--Please describe your firm’s discount policies.

IV-6.

Pricing terms.-(a)

What are your firm’s typical sales terms for its U.S.-produced large power transformers?
Net 30
days

(b)

Net 60
days

2/10 net
30 days

Other

Other (specify)

On what basis are your firm’s prices of domestic large power transformers usually
quoted (check one)?
Delivered

F.o.b.

If f.o.b., specify point

Business Proprietary
U.S. Producers’ Questionnaire - Large power transformers (R1)
IV-7.

Page 31

Multiple shipment contracts.-(a)

Please report the approximate share of the value of your firm’s sales of its U.S.produced large power transformers in 2017 by type of contract.
Share of value of
2017 sales

Type of sale
Single shipment contract

%

Blanket/alliance agreement (bidding)

%

Blanket/alliance agreement (private)

%

Multiple shipment individual contract (bidding)

%

Multiple shipment individual contract (private)

%

Total (should sum to 100.0%)

0.0

%

(b)

What is the average number of large power transformers in a multiple-shipment
contract?
units

(c)

Absent a change in the specifications or terms of the original agreement (e.g., a change
in warranty, purchaser’s request for installation, etc.), can prices be renegotiated during
the contract period?
No

(d)

Yes

If yes, how often are prices renegotiated?
Always

Frequently

Sometimes

Rarely/Never

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IV-8.

Lead times.--What is the average lead time between a customer’s order and the date of delivery
for your firm’s sales of its U.S.-produced large power transformers?
days

IV-9.

Shipping information.-(a)

What is the approximate percentage of the cost of U.S.-produced large power
transformers that is accounted for by U.S. inland transportation costs?
%

(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 large power transformers
that are delivered the following distances from your firm’s production facility.
Distance from production facility

Share

Within 100 miles

%

101 to 1,000 miles

%

Over 1,000 miles

%

Total (should sum to 100.0%)

0.0

%

IV-10. Geographical shipments.--In which U.S. geographic market area(s) has your firm sold its U.S.produced large power transformers since January 1, 2012 (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.
IV-11. End uses.--Have there been any changes in the end uses of large power transformers since
January 1, 2012? Do you anticipate any future changes?
Changes in end
uses
Changes since
January 1, 2012
Anticipated
changes

No

Yes

Explain

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IV-12. Availability of supply.--Has the availability of large power transformers in the U.S. market
changed since January 1, 2012? Do you anticipate any future changes?
Availability in the U.S.
market

Please explain, noting the countries and reasons for the
No Yes changes.

Changes since January 1, 2012:
U.S.-produced product
Imports from Korea
Imports from all other
countries
Anticipated changes:
U.S.-produced product
Imports from Korea
Imports from all other
countries
IV-13. Demand trends.-- Indicate how demand within the United States and outside of the United
States (if known) for large power transformers has changed since January 1, 2012, and how you
anticipate demand will change in the future. Explain any trends and describe the principal
factors that have affected, and that you anticipate will affect, these changes in demand.

Market

Overall
increase

No
change

Fluctuate
with no
Overall
decrease clear trend

Demand since January 1, 2012
Within the United States
Outside the United States
Anticipated future demand
Within the United States
Outside the United States

Explanation and factors (including
any major changes in demand
during any particular year since
2012)

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IV-14. Product changes.--Have there been any significant changes in the product range, product mix,
or marketing of large power transformers since January 1, 2012? Do you anticipate any future
changes?
Changes in
product range,
product mix, or
marketing

No

Yes

Explain

Changes since
January 1, 2012
Anticipated
changes
IV-15.

Conditions of competition.-(a) Is the large power transformers market subject to business cycles (other than general
economy-wide conditions) and/or other conditions of competition distinctive to large power
transformers?
Check all that apply.

Please describe.

No

Skip to question IV-16(a).

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
large power transformers since January 1, 2012?
No

Yes

If yes, describe.

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IV-16a. Impact of smart grid technology on firm.--Have developments relating to smart grid technology
had a discernible impact on your firm's production and sales of large power transformers since
January 1, 2012?
No

Yes

If yes, describe.

IV-16b. Impact of increase in renewable energy on firm.--Have developments relating to growth in
renewable energy sources had a discernible impact on your firm's production and sales of large
power transformers since January 1, 2012?
No

Yes

If yes, describe.

IV-17. Section 232 relief effects.-(a) Familiarity.--Are you familiar with the 232 national security investigation or the subsequent
imposition of tariffs on imported steel products?
Yes--Continue to question IV-17(b).

No--Continue to question IV-18.

(b) Raw materials impact.--Rate and describe the effect of the announcement of the 232
national security investigation in April 2017 or the subsequent imposition of tariffs on
imported steel products in March 2018 on the price of raw materials used to make large
power transformers.
Rating of the factor
No/minimal effect
Factor
Announcement of the 232
investigation in April 2017
Imposition of tariffs on
imported steel products in
March 2018

1

2

Substantial effect
3

4

5

Describe your rating and
the impact of the event
(including timing and
quantification as applicable)

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IV-17. Section 232 relief effects.--Continued
(c) Overall conditions impact.--Rate and describe the effect of the announcement of the 232
national security investigation in April 2017 or the subsequent imposition of tariffs on
imported steel products in March 2018 on other conditions of competition for large power
transformers.
Rating of the factor
No/minimal effect
Factor

1

2

Substantial effect
3

4

5

Describe your rating and
the impact of the event
(including timing and
quantification as applicable)

Announcement of the 232
investigation in April 2017
Imposition of tariffs on
imported steel products in
March 2018

IV-18. Supply constraints.--Has your firm refused, declined, or been unable to supply large power
transformers since January 1, 2012 (examples include placing customers on allocation or
“controlled order entry,” declining to accept new customers or renew existing customers,
delivering less than the quantity promised, being unable to meet timely shipment commitments,
etc.)?
No

Yes

If yes, please describe.

IV-19. Raw materials.--Indicate how large power transformers raw material prices have changed since
January 1, 2012, and how you expect they will change in the future.

Raw materials prices
Changes since January 1, 2012
Anticipated changes

Fluctuate
with no
clear
Overall
No
Overall
increase change decrease trend

Explain, noting how raw material
price changes have affected your
firm’s selling prices for large power
transformers.

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IV-20. Price comparisons.--Please compare market prices of large power transformers in U.S. and nonU.S. markets, if known. Provide specific information as to time periods and regions for any price
comparisons.

IV-21. Market studies.--Please provide as a separate attachment to this request any studies, surveys,
etc. that you are aware of that quantify and/or otherwise discuss large power transformers
supply (including production capacity and capacity utilization) and demand in (1) the United
States, (2) each of the other major producing/consuming countries, including Korea, and (3) the
world as a whole. Of particular interest is such data from 2012 to the present and forecasts for
the future.
IV-22. Export constraints.--Describe how easily your firm can shift its sales of large power transformers
between the U.S. market and alternative country markets. In your discussion, please describe
any contracts, other sales arrangements, or other constraints that would prevent or retard your
firm from shifting large power transformers between the U.S. and alternative country markets
within a 12-month period.

IV-23. Barriers to trade.--Are your firm’s exports of large power transformers subject to any tariff or
non-tariff barriers to trade in other countries?

No

Yes

If yes, please list the countries and describe any such barriers and any
significant changes in such barriers that have occurred since January 1,
2012, or that are expected to occur in the future.

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IV-24. Interchangeability.--Are large power transformers 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

Korea

Other countries

United States
Korea
For any country-pair producing large power transformers that is sometimes or never
interchangeable, identify the country-pair and explain the factors that limit or preclude
interchangeable use:

IV-25. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between large power
transformers 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

Korea

Other countries

United States
Korea
For any country-pair for which factors other than price always or frequently are a significant
factor in your firm’s sales of large power transformers, identify the country-pair and report the
advantages or disadvantages imparted by such factors:

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IV-26. 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.

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HOW TO FILE YOUR QUESTIONNAIRE RESPONSE
This questionnaire is available as a “fillable” form in MS Word format on the
Commission’s website at:
https://www.usitc.gov/investigations/701731/2017/large_power_transformers_korea/f
irst_review_full.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: TRANS

• E-mail.—E-mail the MS Word questionnaire to Nathanael Comly (202-205-3174,
[email protected]) or Christopher Robinson (202-205-2542;
[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 (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 Typeapplication/pdf
File TitleUSITCQUESTIONNAIRE
AuthorDuncan, Russell
File Modified2018-04-23
File Created2018-04-23

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