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pdfOMB No. 3117‐0016/USITC No. 20‐1‐4189; Expiration Date: 6/30/2020
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U.S. PRODUCERS’ QUESTIONNAIRE
UTILITY SCALE WIND TOWERS FROM CANADA, INDONESIA, KOREA, AND
VIETNAM
This questionnaire must be received by the Commission by April 6, 2020
See last page for filing instructions.
The information called for in this questionnaire is for use by the United States International Trade Commission in
connection with its countervailing and antidumping duty investigations concerning utility scale wind towers (“wind
towers”) from Canada, Indonesia, Korea, and Vietnam (Inv. Nos. 701‐TA‐627‐629 and 731‐TA‐1458‐1461 (Final)). The
information requested in the questionnaire is requested under the authority of the Tariff Act of 1930, title VII. This
report is mandatory and failure to reply as directed can result in a subpoena or other order to compel the submission of
records or information in your firm’s possession (19 U.S.C. § 1333(a)).
Name of firm
Address
City
State
Zip Code
Website
Has your firm produced wind towers (as defined on next page) at any time since January 1, 2017?
NO
(Sign the certification below and promptly return only this page of the questionnaire to the Commission)
YES
(Complete all parts of the questionnaire, and return the entire questionnaire to the Commission)
Return questionnaire via the U.S. International Trade Commission Drop Box by clicking on the
following link: https://dropbox.usitc.gov/oinv/. (PIN: WIND)
CERTIFICATION
I certify that the information herein supplied in response to this questionnaire is complete and correct to the best of my
knowledge and belief and understand that the information submitted is subject to audit and verification by the Commission. By
means of this certification I also grant consent for the Commission, and its employees and contract personnel, to use the
information provided in this questionnaire and throughout this proceeding in any other import‐injury proceedings conducted by
the Commission on the same or similar merchandise.
I, the undersigned, acknowledge that information submitted in response to this request for information and throughout this
proceeding or other proceedings may be disclosed to and used: (i) by the Commission, its employees and Offices, and contract
personnel (a) for developing or maintaining the records of this or a related proceeding, or (b) in internal investigations, audits,
reviews, and evaluations relating to the programs, personnel, and operations of the Commission including under 5 U.S.C.
Appendix 3; or (ii) by U.S. government employees and contract personnel, solely for cybersecurity purposes. I understand that all
contract personnel will sign appropriate nondisclosure agreements.
Name of Authorized Official Title of Authorized Official
Date
Signature
Phone
Email address
Business Proprietary
U.S. Producers’ Questionnaire ‐ Wind Towers (Final)
Page 2
PART I.—GENERAL INFORMATION
Background.—This proceeding was instituted in response to a petition filed on July 9, 2019, by the Wind
Tower Trade Coalition (Arcosa Wind Towers, Inc. (Dallas, TX) and Broadwind Towers, Inc. (Manitowoc,
WI)). Countervailing and/or 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/title_7/2020/utility_scale_wind_towers_canada_indonesia_korea
/final.htm.
Wind towers covered by these investigations are certain wind towers, whether or not tapered, and
sections thereof. Certain wind towers are designed to support the nacelle and rotor blades in a wind
turbine with a minimum rated electrical power generation capacity in excess of 100 kilowatts and with a
minimum height of 50 meters measured from the base of the tower to the bottom of the nacelle (i.e.,
where the top of the tower and nacelle are joined) when fully assembled.
A wind tower section consists of, at a minimum, multiple steel plates rolled into cylindrical or conical
shapes and welded together (or otherwise attached) to form a steel shell, regardless of coating, end‐
finish, painting, treatment, or method of manufacture, and with or without flanges, doors, or internal or
external components (e.g., flooring/decking, ladders, lifts, electrical buss boxes, electrical cabling,
conduit, cable harness for nacelle generator, interior lighting, tool and storage lockers) attached to the
wind tower section. Several wind tower sections are normally required to form a completed wind tower.
Wind towers and sections thereof are included within the scope whether or not they are joined with
nonsubject merchandise, such as nacelles or rotor blades, and whether or not they have internal or
external components attached to the subject merchandise.
Specifically excluded from the scope are nacelles and rotor blades, regardless of whether they are
attached to the wind tower. Also excluded are any internal or external components which are not
attached to the wind towers or sections thereof, unless those components are shipped with the tower
sections.
Further, excluded from the scope of the antidumping duty investigations are any products covered by
the existing antidumping duty order on utility scale wind towers from the Socialist Republic of Vietnam.
See Utility Scale Wind Towers from the Socialist Republic of Vietnam: Amended Final Determination of
Sales at Less Than Fair Value and Antidumping Duty Order, 78 FR 11150 (February 15, 2013).
Wind towers are currently imported under statistical reporting numbers 7308.20.00201 or
8502.31.00002 of the Harmonized Tariff Schedule of the United States (HTSUS). Wind towers of iron or
steel are classified under HTSUS 7308.20.0020 when imported separately as a tower or tower section(s).
Wind towers may be classified under HTSUS 8502.31.0000 when imported as combination goods with a
wind turbine (i.e., accompanying nacelles and/or rotor blades). The HTSUS provisions are for
convenience and customs purposes; the written description of the scope is dispositive.
1
Wind towers of iron or steel are classified under HTSUS 7308.20.0020 when imported separately as a tower or
tower section(s).
2
Wind towers may also be classified under HTSUS 8502.31.0000 when imported as combination of goods with a
wind turbine (i.e., accompanying nacelles and/or rotor blades).
Business Proprietary
U.S. Producers’ Questionnaire ‐ Wind Towers (Final)
Page 3
Unit.—A unit, unless otherwise stated, is a complete wind tower (whether or not comprised of multiple
sections) or wind tower equivalent (e.g., one section of a wind tower comprised of four sections would
be equal to ¼ or 0.25 wind towers).
Reporting of information.—If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
and/or purchaser questionnaire), you need not respond to duplicated questions.
Confidentiality.—The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.
Verification.—The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting
documents used in the preparation of the questionnaire response. Please also retain a copy of the final
document that you submit.
Release of information.—The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import‐injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals.
D‐GRIDS tool.‐‐The Commission has a tool that firms can use to move data from their own MS Excel
compilation files into self‐contained data tables within this MS Word questionnaire, thereby reducing
the amount of cell‐by‐cell data entry that would be required to complete this form. This tool is a macro‐
enabled MS Excel file available for download from the Commission's generic questionnaires webpage
(https://www.usitc.gov/trade_remedy/question.htm) called the "D‐GRIDs tool." Use of this tool to help
your firm complete this questionnaire is optional. Firms opting to use the D‐GRIDs tool to populate their
data into this questionnaire will need the D‐GRIDs specification sheet PDF file specific to this proceeding
(available on the case page which is linked under the "Background" above) which includes the necessary
references relating to this questionnaire, as well as the macro‐enable MS Excel D‐GRIDs tool itself from
the generic questionnaires page. More detailed instructions on how to use the D‐GRIDs tool are
available within the D‐GRIDs tool itself.
I‐1a. OMB statistics.‐‐Please report below the actual number of hours required and the cost to your
firm of completing this questionnaire.
Hours
Dollars
Business Proprietary
U.S. Producers’ Questionnaire ‐ Wind Towers (Final)
Page 4
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‐1b.
TAA information release.‐‐In the event that the U.S. International Trade Commission (USITC)
makes an affirmative final determination in this proceeding, do you consent to the USITC's
release of your contact information (company name, address, contact person, contact person’s
title, telephone number, email address) appearing on the front page of this questionnaire to the
Departments of Commerce, Labor, and Agriculture, as applicable, so that your firm and its
workers can be made eligible for benefits under the Trade Adjustment Assistance program?
No
Yes
I‐2a.
Establishments covered.‐‐Provide the city, state, zip code, and brief description of each
establishment covered by this questionnaire. Firms operating more than one establishment
should combine the data for all establishments into a single report.
“Establishment”‐‐Each facility of a firm involved in the production of wind towers, including
auxiliary facilities operated in conjunction with (whether or not physically separate from) such
facilities.
Establishments
City, State
Zip (5 digit)
Description
covered1
1
I‐2b.
I‐2c.
1
2
3
4
5
6
Additional discussion on establishments consolidated in this questionnaire: .
Stock symbol information.‐‐ If your firm or parent firm is publicly traded, please specify the
stock exchange and trading symbol: .
External counsel.‐‐ If your firm or parent firm is represented by external counsel in relation to
this proceeding, please specify the name of the law firm and the lead attorney(s).
Law firm:
Lead attorney(s):
Business Proprietary
U.S. Producers’ Questionnaire ‐ Wind Towers (Final)
I‐3.
Petitioner status.‐‐Is your firm a petitioner in this proceeding or a member firm of the
petitioning entity?
No
Yes
I‐4.
I‐6.
Support
Oppose
Take no position
Canada‐ AD
Canada‐ CVD
Indonesia‐ AD
Indonesia‐ CVD
Korea‐ AD
Vietnam‐ AD
Vietnam‐ CVD
Ownership.‐‐Is your firm owned, in whole or in part, by any other firm?
No
Yes‐‐List the following information, relating to the ultimate parent/owner.
Firm name
Country
Extent of
ownership
(percent)
Related importers/exporters.‐‐Does your firm have any related firms, either domestic or
foreign, that are engaged in importing wind towers from Canada, Indonesia, Korea, and Vietnam
into the United States or that are engaged in exporting wind towers from Canada, Indonesia,
Korea, and Vietnam to the United States?
No
Yes‐‐List the following information.
Petition support.‐‐Does your firm support or oppose the petition?
Country
I‐5.
Page 5
Firm name
Country
Affiliation
Business Proprietary
U.S. Producers’ Questionnaire ‐ Wind Towers (Final)
I‐7.
Page 6
Related producers.‐‐Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of wind towers?
No
Yes‐‐List the following information.
Firm name
Country
Affiliation
Business Proprietary
U.S. Producers’ Questionnaire ‐ Wind Towers (Final)
Page 7
PART II.‐‐TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Ahdia Bavari (202‐205‐3191,
[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‐2. Changes in operations.‐‐Please indicate whether your firm has experienced any of the following
changes in relation to the production of wind towers since January 1, 2017.
(check as many as appropriate)
(If checked, please describe; leave blank if not applicable)
plant openings
plant closings
relocations
expansions
acquisitions
consolidations
prolonged shutdowns or
production curtailments
revised labor agreements
other (e.g., technology)
Business Proprietary
U.S. Producers’ Questionnaire ‐ Wind Towers (Final)
Page 8
II‐3a. Production using same machinery.—Please report your firm’s production of products using the
same equipment, machinery, or employees as used to produce wind towers, and the combined
production capacity on this shared equipment, machinery, or employees 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).
Note‐ If your firm does not produce any out‐of‐scope merchandise on the same machinery and
equipment as scope merchandise then the "overall production capacity" numbers reported in
this question should be exactly equal to the "average production capacity" numbers reported in
question II‐7. If, however, your firm does produce out‐of‐scope merchandise using the same
machinery and equipment as scope merchandise, then the "average production capacity"
reported in question II‐7 should exclude the portion of "overall production capacity" that was
used to produce this out‐of‐scope merchandise.
“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 units)
Calendar years
Item
2017
1
Overall production capacity
Production of:
Wind towers2
3
Other products
Total production using same
machinery or workers
2018
2019
0
0
0
0
0
0
1
Data reported for capacity (first line) should be greater than data reported for total production (last
line).
2
Data entered for production of wind towers will populate here once reported in question II‐7.
3
Please identify these products: .
Business Proprietary
U.S. Producers’ Questionnaire ‐ Wind Towers (Final)
Page 9
II‐3b. Production using same machinery by weight.—Please report your firm’s production of
products, by weight, using the same equipment, machinery, or employees as used to produce
wind towers, and the combined production capacity on this shared equipment, machinery, or
employees in the periods indicated.
Quantity (in short tons)
Calendar years
Item
2017
1
2018
2019
Overall production capacity
Production of:
Wind towers
0
0
0
2
Other products
Total production using same
machinery or workers
1
Data reported for capacity (first line) should be greater than data reported for total production (last
line).
2
Please identify these products: .
II‐3c.
Operating parameters.—The production capacity reported in II‐3a and II‐3b is based on the
following operating paramaters:
Hours per week
Weeks per year
II‐3d. Capacity calculation.—Please describe the methodology used to calculate overall production
capacity reported in II‐3a and II‐3b, and explain any changes in reported capacity.
II‐3e. Production constraints.—Please describe the constraint(s) that set the limit(s) on your firm’s
production capacity.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Wind Towers (Final)
II‐4.
Page 10
Product shifting.—
(a)
Is your firm able to switch production (capacity) between wind towers and other products
using the same equipment and/or labor?
No
Yes
If yes—(i.e., have produced other products or are able to produce other products)
Please identify other actual or potential products.
(b)
Please describe the factors that affect your firm’s ability to shift production capacity
between products (e.g., time, cost, relative price change, etc.), and the degree to which
these factors enhance or constrain such shifts.
II‐5.
Tolling.‐‐Since January 1, 2017, has your firm been involved in a toll agreement regarding the
production of wind towers?
“Toll agreement”‐‐Agreement between two firms whereby the first firm furnishes the raw
materials and the second firm uses the raw materials to produce a product that it then returns
to the first firm with a charge for processing costs, overhead, etc.
No
Yes
If yes‐‐Please describe the toll arrangement(s) and name the firm(s) involved.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Wind Towers (Final)
II‐6.
Page 11
Foreign trade zones.‐‐
(a)
Firm's FTZ operations.‐‐Does your firm produce wind towers in and/or admit wind
towers into a foreign trade zone (FTZ)?
“Foreign trade zone” is a designated location in the United States where firms utilize
special procedures that allow delayed or reduced customs duty payments on foreign
merchandise. A foreign trade zone must be designated as such pursuant to the rules
and procedures set forth in the Foreign‐Trade Zones Act.
No
Yes
If yes‐‐Describe the nature of your firms operations in FTZs and identify the
specific FTZ site(s).
(b)
Other firms' FTZ operations.‐‐To your knowledge, do any firms in the United States
import wind towers into a foreign trade zone (FTZ) for use in distribution of wind towers
and/or the production of downstream articles?
No
Yes
If yes‐‐Identify the firms and the FTZs.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Wind Towers (Final)
II‐7.
Page 12
Production, shipment, and inventory data.‐‐Report your firm’s production capacity, production,
shipments, and inventories related to the production of wind towers in its U.S. establishment(s)
during the specified periods.
“Average production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
“Commercial U.S. 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 firms. Such transactions are valued at
fair market value.
“Related firm” –A firm that your firm solely or jointly owned, managed, or otherwise controlled;
a firm that solely or jointly owned, managed, or otherwise controlled your firm; and/or a firm
that was solely or jointly owned, managed, or otherwise controlled by a firm that also solely or
jointly owned, managed, or otherwise controlled your firm.
“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 ‐ Wind Towers (Final)
II‐7.
Page 13
Production, shipment, and inventory data.‐‐Continued
Quantity (in units) and value (in $1,000)
Calendar years
Item
Average production capacity by
establishment1 (quantity)
Establishment 1
2017
2018
2019
Establishment 2
Establishment 3
Establishment 4
Establishment 5
Establishment 6
All other establishments
0
0
0
Beginning‐of‐period inventories
(quantity) (B)
Average production by
establishment3 (quantity)
Establishment 1
Establishment 2
Establishment 3
Establishment 4
Establishment 5
Establishment 6
All other establishments
0
0
0
Average production capacity
across all establishments2
(quantity) (A)
Production across all
establishments4 (quantity) (C)
Table continued on next page. Footnotes next page.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Wind Towers (Final)
II‐7.
Page 14
Production, shipment, and inventory data.— Continued
Quantity (in units) and value (in $1,000)
Calendar years
Item
2017
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:
Quantity (F)
2019
5
2
Value (G)
Transfers to related firms:
Quantity (H)
5
2
Value (I)
Export shipments:
Quantity (J)
2018
6
Value (K)
End‐of‐period inventories (quantity) (L)
1
Report your firm’s average production capacity of wind towers in each of your U.S. establishment(s) during the specified
periods. Note the establishments listed above should correspond with the establishments listed in question I‐2.
2
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 .
3
Report your firm’s production of wind towers in each of your U.S. establishment(s) during the specified periods. Note the
establishments listed above should correspond with the establishments listed in question I‐2.
4
Please confirm whether the information above is reported in wind tower equivalents, rather than complete towers.
Please identify the number of sections per complete tower for each period: .
5
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a different basis
for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.): .
However, the data provided above in this table should be based on fair market value.
6
Identify your firm’s principal export markets: .
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.—Generally, the data reported for the end‐of‐
period inventories (i.e., line L) should be equal to the beginning‐of‐period inventories (i.e., line B), plus production
(i.e., line C), less total shipments (i.e., lines D, F, H, and J). Please ensure that any differences are not due to data
entry errors in completing this form, but rather 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 years
Reconciliation
B + C – D – F – H – J – L = should equal zero
("0") or provide an explanation.1
2017
2018
0
2019
0
1 Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless accurate:
0
.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Wind Towers (Final)
II‐8.
Page 15
Order book production.—Report your firm’s expected production based on its “order books”
for the specified periods.
Quantity (in units)
Item
Jan‐Mar 2020
Expected
production
II‐9.
Apr‐Jun 2020
Jul‐Sept 2020
Oct‐Dec 2020
U.S. shipments by height.— Report your firm’s U.S. shipments of wind towers during 2017‐19 in
each specified size range, as measured from the base of the tower to the hub (“hub height”).
Quantity (in units) and value ($1,000)
Size range
2017
2018
2019
Below 80 meters
Quantity (O)
Value (P)
80 ‐ 89.9 meters
Quantity (Q)
Value (R)
90 ‐ 99.9 meters
Quantity (S)
Value (T)
100 ‐ 109.9 meters
Quantity (U)
Value (V)
110 ‐ 119.9 meters
Quantity (W)
Value (X)
120 meters or more
Quantity (Y)
Value (Z)
RECONCILIATION OF SHIPMENTS. .—Please ensure that the quantities and values reported for shipments by
size (i.e., lines O, Q, S, U, W, Y and P, R, T, V, X, Z, respectively,) equal the quantity and value reported for U.S.
shipments (i.e., lines D, F, H and E, G, I, respectively). 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
2017
2018
2019
Quantity: O + Q + S + U + W + Y
– D – F – H = zero ("0"), if not
revise.
0
0
0
Value: P + R + T + V + X + Z – E –
G – I = zero ("0"), if not revise.
0
0
0
Business Proprietary
U.S. Producers’ Questionnaire ‐ Wind Towers (Final)
Page 16
II‐10. U.S. shipments of wind towers without internal components.— Please report the share of your
firm’s U.S. shipments of wind towers reported in II‐9 that were shipped without any mechanical
and/or electrical fittings such as platforms, ladders, lighting, lifts (elevators), electrical‐cable
harnesses, storage lockers, and/or other accessories (“internals”): %.
II‐11. U.S. shipments of wind tower sections.— Report your firm’s U.S. shipments of wind tower
sections during the specified periods.
Quantity (in units) and value (in $1,000)
Calendar years
Item
2017
2018
2019
U.S. shipments
of sections1 2 .—
Quantity (AA)
Value (AB)
1
Reminder, reported units are to be based on full wind tower equivalents as described in the definitions
on page 2.
2
Please describe the sections shipped, how the customer created or built a full tower (i.e., what other
source of supply), and where and how these data are reported in question II‐7:
.
II‐12. Sections sold for repowering.— Please report the share of wind tower sections reported in the
previous question that were used for the purpose of repowering: %.
II‐13. Offshore wind towers.‐‐Did your firm supply any domestically manufactured wind towers from
your U.S. establishments to your customers for any offshore applications in 2017‐19?
No
Yes
If yes—Please report the information for these towers in the table below.
Quantity (in units) and value (in $1,000)
Calendar years
Item
2017
2018
2019
U.S. shipments of wind
towers for offshore
applications1 2 .—
Quantity (AC)
Value (AD)
1
Please provide the geographic locations of the offshore wind towers: .
Business Proprietary
U.S. Producers’ Questionnaire ‐ Wind Towers (Final)
Page 17
II‐14. Employment data.‐‐Report your firm’s employment‐related data related to the production of
wind towers and provide an explanation for any trends in these data.
“Production and Related Workers” (PRWs) includes working supervisors and all nonsupervisory
workers (including group leaders and trainees) engaged in fabricating, processing, assembling,
inspecting, receiving, storage, handling, packing, warehousing, shipping, trucking, hauling,
maintenance, repair, janitorial and guard services, product development, auxiliary production
for plant’s own use (e.g., power plant), recordkeeping, and other services closely associated with
the above production operations.
Average number employed may be computed by adding the number of employees, both full
time and part time, for the 12 pay periods ending closest to the 15th of the month and divide
that total by 12.
“Hours worked” includes time paid for sick leave, holidays, and vacation time. Include overtime
hours actually worked; do not convert overtime pay to its equivalent in straight time hours.
“Wages paid” –Total wages paid before deductions of any kind (e.g., withholding taxes, old‐age
and unemployment insurance, group insurance, union dues, bonds, etc.). Include wages paid
directly by your firm for overtime, holidays, vacations, and sick leave.
Calendar years
Item
2017
2018
2019
Average number of PRWs (number)
Hours worked by PRWs (1,000 hours)
Wages paid to PRWs ($1,000)
II‐15. Employment data.— Continued
Explanation of trends:
II‐16. Related firms.‐‐If your firm reported transfers to related firms in question II‐7, please identify
the firm(s) and 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.
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U.S. Producers’ Questionnaire ‐ Wind Towers (Final)
Page 18
II‐17. Purchases.‐‐Has your firm purchased wind towers produced in the United States or in other
countries since January 1, 2017? (Do not include imports for which your firm was the importer
of record. These should be reported in an importer questionnaire).
“Purchase” – A transaction to buy product from a U.S. corporate entity such as another U.S.
producer, a U.S. distributor, or a U.S. firm that has directly imported the product.
“Import” –A transaction to buy from a foreign supplier where your firm is the importer of
record.
No
Yes
If yes‐‐Report such purchases in the table below and explain the reasons
for your firms' purchases.
Note: If your firm served as the importer of record for any purchases from foreign suppliers,
either for your own account or as a service for another entity, those purchases are to be
considered "imports" not "purchases" and should not be included in the table below
(Quantity in units)
Calendar years
Item
Purchases from U.S.
importers1 of wind towers
from—
Canada
2017
2018
2019
Indonesia
Korea
Vietnam
All other sources
Purchases from domestic
producers2
Purchases from other
sources2
1
Please list the name of the importer(s) from which your firm purchased this product. If your
firm’s import suppliers differ by source, please identify the source for each listed supplier:
.
2
Please list the name of the producer(s) or U.S. distributor(s) from which your firm
purchased this product: .
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U.S. Producers’ Questionnaire ‐ Wind Towers (Final)
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II‐18. Imports.‐‐Since January 1, 2017, has your firm imported wind towers?
No
Yes
If yes‐‐COMPLETE AND RETURN A U.S. IMPORTERS’ QUESTIONNAIRE
II‐19. Internal consumption/transfers to related firms — In 2019, did your firm internally consume
and/or transfer to a related firm any portion of its wind towers production, as reported in lines F
and H of question II‐7?
No‐ Do not complete question II‐20.
Yes‐ Complete question II‐20.
II‐20. Captive production use. — Please report the share of your firm’s 2019 internal consumption
and/or transfers to related firms for the uses identified below. These data should reconcile with
the 2018 quantities reported in question II‐7 (lines F and H).
Transfers to related firms
Internal consumption
2019
2019
(units)
(units)
Products
Sold as is (Re‐entry into
merchant market)
N/A
Assembled into wind turbines
Assembled into other
products1
1
Please describe these products: .
RECONCILIATION OF CAPTIVE PRODUCTION USE.— The sum of the data reported above should
be equal to the data reported in lines F and H of question II‐7 of 2019.
Calendar year
Reconciliation
2019
Internal consumption (line F in II‐
7) reconciliation.
0
Transfers to related parties (line
H in II‐7) reconciliation.
0
These data should reconcile with the 2018 quantities reported in question II‐7 (lines F and H). If not,
please revise.
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U.S. Producers’ Questionnaire ‐ Wind Towers (Final)
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II‐21. Other explanations.‐‐If your firm would like to further explain a response to a question in Part II
for which a narrative box was not provided, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.
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U.S. Producers’ Questionnaire ‐ Wind Towers (Final)
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PART III.‐‐FINANCIAL INFORMATION
Address questions on this part of the questionnaire to David Boyland at (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 wind towers:
2. Does your firm prepare profit/loss statements for wind towers:
Yes
No
3. How often did your firm (or parent company) prepare financial statements
(including annual reports, 10Ks)? Please check relevant items below.
Audited, unaudited, annual reports, 10Ks, 10 Qs,
Monthly, quarterly, semi‐annually, annually
4. Accounting basis: U.S. GAAP, IFRS, cash, tax, or other
comprehensive basis of accounting (specify)
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the financial data, as Commission staff may contact your firm
regarding questions on the financial data. The Commission may also request that your company
submit copies of the supporting documents/records (financial statements, including internal
profit‐and‐loss statements for the division or product group that includes wind towers, as well as
specific statements and worksheets) used to compile these data.
III‐3.
Cost accounting system.‐‐Briefly describe your firm’s cost accounting system (e.g., standard
cost, job order cost, etc.).
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U.S. Producers’ Questionnaire ‐ Wind Towers (Final)
III‐4.
A.
Page 22
Allocation basis.‐‐Briefly describe your firm’s allocation basis, if any, for COGS, SG&A,
and interest expense and other income and expenses.
B.
Procurement process in general.‐‐Please describe the company's procurement process
for its primary raw materials and the manner/extent to which wind tower customers are
involved (directly or indirectly) with purchase decisions.
C.
Procurement process and cost controls.‐‐During the period examined and to the extent
applicable, please describe efforts to minimize fluctuations and/or otherwise control the
cost of primary raw materials.
D.
Sales/production levels and conversion costs.‐‐Please describe how changes in
production and sales volume of wind towers during the period examined impacted the
level of average wind tower conversion costs. As applicable, please also identify and
describe specific examples of anticipated/negotiated production and sales volume that
was not undertaken and its corresponding impact on conversion costs.
III‐5.
Product listing.‐‐Please list the products your firm produced in the facilities in which your firm
produced wind towers, and provide the share of net sales accounted for by these products in
your firm’s most recent fiscal year.
Products
Share of sales
Wind towers
%
%
%
%
%
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U.S. Producers’ Questionnaire ‐ Wind Towers (Final)
III‐6.
Page 23
Inputs from related suppliers.‐‐Does your firm purchase inputs (raw materials, labor, energy, or
any services) used in the production of wind towers from any related suppliers (e.g., inclusive of
transactions between related firms, divisions and/or other components within the same
company)?
Yes‐‐Continue to question III‐7
III‐7.
No‐‐Continue to question III‐9a.
Inputs from related suppliers detailed.‐‐Please identify the inputs used in the production of
wind towers that your firm purchases from related suppliers and that are reflected in question
III‐9a. For “Share of total COGS” please report this information by relevant input on the basis of
your most recently completed fiscal year. For “Input valuation” please describe the basis, as
recorded in your company’s own accounting system, of the purchase cost from the related
supplier; e.g., the related supplier’s actual cost, cost plus, negotiated transfer price to
approximate fair market value.
Input
Related supplier
Input valuation as recorded in the firm’s accounting books and records
Share of total COGS
III‐8.
Inputs purchased from related suppliers.‐‐Please confirm that the inputs purchased from
related suppliers, as identified in III‐7, were reported in III‐9a (financial results on wind towers)
in a manner consistent with your firm’s accounting books and records.
Yes
No
If no‐‐In the space below, please report the valuation basis of inputs purchased
from related suppliers as reported in question III‐9a.
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U.S. Producers’ Questionnaire ‐ Wind Towers (Final)
Page 24
III‐9a. Operations on wind towers.‐‐Report the revenue and related cost information requested below
on the wind towers operations of your firm’s U.S. establishment(s).1 Do not report resales of
products. Note that internal consumption and transfers to related firms must be valued at fair
market value. Input purchases from related suppliers should be consistent with and based on
information in the firm’s accounting books and records. Provide data for your firm’s three most
recently completed fiscal years that most closely correspond to calendar‐years 2017‐19. If your
firm was involved in tolling operations (either as the toller or as the tollee), please contact David
Boyland at (202) 708‐4725 before completing this section of the questionnaire.
Quantity (in units) and value (in $1,000)
Fiscal years ended‐‐
Item
Net sales quantities:2
Commercial sales (“CS”)
2017
2018
2019
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
0
0
0
Commercial sales
Internal consumption
Transfers to related firms
0
0
0
Steel plate (HSLA and/or alloy)
Flanges
Other raw materials
0
0
0
Direct labor
Other factory costs
Total COGS
0
0
0
Gross profit or (loss)
0
0
0
Total net sales quantities
Net sales values:2
Total net sales values
Cost of goods sold (COGS):3
Total raw material costs
Selling, general, and administrative (SG&A)
expenses:
Selling expenses
General and administrative expenses
0
0
0
0
0
0
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
All other expense items
All other income items
Net income or (loss) before income taxes
Depreciation/amortization included above
0
0
0
1 Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
2 Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding
shipment quantities and values reported in Part II of this questionnaire.
3 COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
Note ‐‐The table above contains calculations that will appear when you have entered data in the MS
Word form fields.
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U.S. Producers’ Questionnaire ‐ Wind Towers (Final)
Page 25
III‐9b. Financial data reconciliation.‐‐The calculable line items from question III‐9a (i.e., total net sales
quantities and values, total COGS, gross profit (or loss), total SG&A, and net income (or loss))
have been calculated from the data submitted in the other line items. Do the calculated fields
return the correct data according to your firm's financial records ignoring non‐material
differences that may arise due to rounding?
Yes
No
If 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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U.S. Producers’ Questionnaire ‐ Wind Towers (Final)
Page 26
III‐10. Nonrecurring items (charges and gains) included in wind tower financial results.‐‐For each
annual 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.
Fiscal years ended‐‐
Item
2017
2018
2019
Value ($1,000)
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7
Nonrecurring item: In this table please provide a brief description of each nonrecurring item reported above and
indicate the specific line item in table III‐9a where the nonrecurring item is classified.
Description of the
nonrecurring item
Income statement classification of the nonrecurring item
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7
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U.S. Producers’ Questionnaire ‐ Wind Towers (Final)
Page 27
III‐11. Classification of identified nonrecurring items (charges and gains) in the accounting books and
records of the company.‐‐If non‐recurring items were reported in question III‐10 above, please
identify where your company recorded these items in your accounting books and records in the
normal course of business; i.e., just as responses to question III‐10 identify where these items
are reported in question III‐9a.
III‐12. Asset values.‐‐Report the total assets (i.e., both current and long‐term assets) associated with
the production, warehousing, and sale of wind towers. If your firm does not maintain some or
all of the specific asset information necessary to calculate total assets for wind towers in the
normal course of business, please estimate this information based upon a method (such as
production, sales, or costs) that is consistent with relevant cost allocations in question III‐9a.
Provide data as of the end of your firm’s three most recently completed fiscal years that most
closely correspond to calendar‐years 2017‐19.
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
2017
1
Total assets (net)
1
III‐13.
2018
2019
Describe .
Capital expenditures and research and development expenses.‐‐Report your firm’s capital
expenditures and research and development expenses for wind towers. Provide data for your
firm’s three most recently completed fiscal years that most closely correspond to calendar‐
years 2017‐19.
Value (in $1,000)
Fiscal years ended‐‐
Item
2017
1
Capital expenditures
2
Research and development expenses
1
2018
2019
Please describe the nature, focus, and significance of your firm’s capital expenditures on the subject product.
.
2
Please describe the nature, focus, and significance of your firm’s R&D expenses related to subject product.
.
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U.S. Producers’ Questionnaire ‐ Wind Towers (Final)
Page 28
III‐14. Data consistency and reconciliation.‐‐Please indicate whether your firm’s financial data for
questions III‐9a, III‐12, and III‐13 are based on a calendar year or on your firm’s fiscal year:
Calendar year
Fiscal year
Specify fiscal year
Please note the quantities and values reported in question III‐9a should reconcile with the data
reported in question II‐7 (including export shipments) as long as they are reported on the same
calendar year basis.
RECONCILIATION OF TRADE VS FINANCIAL DATA.‐‐Please ensure that the quantities and values reported
for total shipments in part II equal the quantities and values reported for total net sales in part III of this
questionnaire in each time period unless the financial data from part III are reported on a fiscal year
basis. 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‐‐
Reconciliation
2017
2018
2019
Quantity: Trade data from question II‐7
(lines D, F, H, and J) less financial total
net sales quantity data from question III‐
9a, = zero ("0").
0
0
0
Value: Trade data from question II‐7
(lines E, G, I, and K) less financial total
net sales value data from question III‐9a,
= zero ("0").
0
0
0
Do these data in question III‐9a reconcile with data in question II‐7?
Yes
No
If no, please explain.
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U.S. Producers’ Questionnaire ‐ Wind Towers (Final)
Page 29
If your responses to any of the items in questions III‐15, III‐16, and III‐17 differ by country, please
describe these differences and, as applicable, indicate which country or countries your response refers
to in the relevant form fields.
III‐15. Effects of imports on investment.‐‐Since January 1, 2017, has your firm experienced any actual
negative effects on its return on investment or the scale of capital investments as a result of
imports of wind towers from Canada, Indonesia, Korea, and Vietnam?
No
Yes
If yes, my firm has experienced actual negative effects as follows.
(check as many as appropriate)
(please describe)
Cancellation, postponement,
or rejection of expansion
projects
Denial or rejection of
investment proposal
Reduction in the size of
capital investments
Return on specific
investments negatively
impacted
Other
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U.S. Producers’ Questionnaire ‐ Wind Towers (Final)
Page 30
III‐16. Effects of imports on growth and development.‐‐Since January 1, 2017, has your firm
experienced any actual negative effects on its growth, ability to raise capital, or existing
development and production efforts (including efforts to develop a derivative or more advanced
version of the product) as a result of imports of wind towers from Canada, Indonesia, Korea, and
Vietnam?
No
Yes
If yes, my firm has experienced actual negative effects as follows.
(check as many as appropriate)
(please describe)
Rejection of bank loans
Lowering of credit rating
Problem related to the issue
of stocks or bonds
Ability to service debt
Other
III‐17. Anticipated effects of imports.‐‐Does your firm anticipate any negative effects due to imports of
wind towers from Canada, Indonesia, Korea, and Vietnam?
No
Yes
If yes, my firm anticipates negative effects as follows.
III‐18. Other explanations.‐‐If your firm would like to further explain a response to a question in Part III
for which a narrative box was not provided, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Wind Towers (Final)
Page 31
PART IV.‐‐PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from John Benedetto (202‐205‐
3270, [email protected]).
IV‐1. Contact information.‐‐Please identify the individual that Commission staff may contact
regarding the confidential information submitted in part IV.
Name
Title
Email
Telephone
BID DATA
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U.S. Producers’ Questionnaire ‐ Wind Towers (Final)
Page 32
IV‐2a. Bid Data.— Please fill out the table below for the fifteen largest wind tower projects or processes that your firm bid on since January 1, 2017. The
bid and contract sales values should be reported on an ex‐works or FOB mill basis (i.e., the value should be net of freight), and include amounts for
any services, such as installation or training, included in the requests for quotation (RFQs). Include bids submitted whether or not your firm won
the bid.
Wind tower description
Year and
month
OEM/ project
name
Bid information
Hub height
Number of
of tower Weight of towers bid
Tower type (meters) tower (kgs)
on
Initial bid
price (per
tower)
If project won
Purchase
price
Contracted
(f.o.b.
number of works, per
towers
tower)
Length of
Contract
(months)
Winning
bidder, if
known
Reason bid accepted or rejected (if
known)
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U.S. Producers’ Questionnaire ‐ Wind towers (Final)
Page 33
IV‐2b. Bid data methodology.‐‐Please describe the method and the kinds of documents/records that
were used to compile your bid data.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records used in
the preparation of the price data, as Commission staff may contact your firm regarding questions on the
price data. The Commission may also request that your company submit copies of the supporting
documents/records (such as sales journal, invoices, etc.) used to compile these data.
IV‐3. Price setting.‐‐How does your firm determine the prices that it charges for sales of wind towers
(check all that apply)? If your firm issues price lists, please submit sample pages of a recent list.
Transaction
by
transaction
Contracts
IV‐4.
Other
If other, describe
Discount policy.‐‐Please indicate and describe your firm’s discount policies (check all that apply).
Annual
total
volume
discounts
Quantity
discounts
IV‐5.
Set
price
lists
No
discount
policy
Other
Describe
Pricing terms.‐‐On what basis are your firm’s prices of domestic wind towers usually quoted
(check one)?
Delivered
F.o.b.
IV‐6.
If f.o.b., specify point
Contract versus spot.‐‐Approximately what share of your firm’s sales of its U.S.‐produced wind
towers in 2019 was on a (1) short‐term contract basis, (2) annual contract basis, (3) long‐term
contract basis, and (4) spot sales basis?
Item
Share of 2019
sales
Short‐term
contracts
(multiple
deliveries for
less than 12
months)
%
Type of sale
Long‐term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
more than 12
months)
months)
%
%
Spot sales
(for a single
delivery)
%
Total
(should
sum to
100.0%)
0.0
%
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U.S. Producers’ Questionnaire ‐ Wind towers (Final)
IV‐7.
Page 34
Contract provisions.—
(a) Please fill out the table regarding your firm’s typical sales contracts for U.S.‐produced wind
towers (or check “not applicable” if your firm does not sell on a short‐term, annual and/or
long‐term contract basis).
Short‐term contracts Annual contracts
(multiple deliveries
(multiple
for less than 12
deliveries for 12
months)
months)
Long‐term contracts
(multiple deliveries
for more than 12
months)
Typical sales
contract provisions
Item
Average contract
duration
No. of
days
Price renegotiation
(during contract
period)
Yes
No
Quantity
Price
Both
Yes
No
Fixed quantity
and/or price
Indexed to raw
material costs1
Not applicable
365
1
Please identify the indexes used: .
(b) Are any of your contracts with U.S. Original Equipment Manufacturers (OEMs) conversion
price contracts? That is, did the negotiated price include labor and mark‐up, but not major
input costs, such as steel?
Yes—All contracts are conversion
price contracts. Please answer part
(c)
Yes—Some contracts are
conversion price contracts.
Please answer part (c)
No.
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U.S. Producers’ Questionnaire ‐ Wind towers (Final)
(c)
Page 35
List the top 5 OEMs with which you have or had conversion price contracts since January
1, 2017, and complete the table below.
Inputs Not Included in Conversion Price
Fixtures
(ladders,
elevators,
Steel doors, etc.) Paint Bus bars
OEM
Power
cables
Platforms
Other (please describe)
IV‐8.
Lead times.‐‐What is your firm’s share of sales from inventory and produced to order and what
is the typical lead time between a customer’s order and the date of delivery for your firm’s sales
of its U.S.‐produced wind towers?
Lead time (Average
Source
Share of 2019 sales number of days)
From inventory
%
Produced to order
%
Total (should sum to 100.0%)
IV‐9.
0.0 %
Shipping information.‐‐
(a)
(b)
What is the approximate percentage of the total delivered cost of U.S.‐produced wind
towers that is accounted for by U.S. inland transportation costs? percent
If your firm does not know, please explain.
Who generally arranges the transportation to your firm’s customers’ locations?
Your firm Purchaser (check one)
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U.S. Producers’ Questionnaire ‐ Wind towers (Final)
(c)
Page 36
Indicate the approximate percentage of your firm’s sales of wind towers that are
delivered the following distances from its production facility.
Distance from your firm’s U.S. point of shipment
Within 100 miles
%
101 to 500 miles
%
501 to 1,000 miles
%
Over 1,000 miles
%
Total (should sum to 100.0%)
(d)
Share
0.0 %
Are your FOB prices for the same wind tower models consistent across all shipping
distances or do they vary by shipping distances? Please explain.
IV‐10. Geographical shipments.—
(a) Report your firm’s shipments of its U.S.‐produced wind towers based on the U.S. geographic
market area(s) in which the wind towers were installed, during the specified periods. If exact
data are not readily available from your records, provide carefully prepared estimates.
2017
2018
2019
Geographic area
Number of wind towers produced
Northeast.–CT, ME, MA, NH, NJ, NY, PA, RI, and VT.
Upper Midwest.–MI, MN, NE, ND, SD, and WI.
Lower Midwest.–IL, IN, IA, KS, OH, and MO.
Upper Southeast.–DE, DC, MD, VA, and WV.
Lower Southeast.–AL, FL, GA, KY, MS, NC, SC, and TN.
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.
(b) Describe the importance, if any, of geographic location in your firm’s sales of wind towers.
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Page 37
IV‐11. Demand trends.‐‐Indicate how demand within the United States and outside of the United
States (if known) for wind towers has changed since January 1, 2017. Explain any trends and
describe the principal factors that have affected these changes in demand.
Market
Fluctuate
Overall
No
Overall
with no
increase change decrease clear trend
Explanation and factors
Within the
United
States
Outside the
United
States
IV‐12. Product changes.‐‐Have there been any significant changes in the product range, product mix,
or marketing of wind towers since January 1, 2017?
No
Yes
If yes, please describe and quantify if possible.
IV‐13. Conditions of competition.‐‐
(a) Is the wind towers market subject to business cycles (other than general economy‐wide
conditions) and/or other conditions of competition distinctive to wind towers? If yes,
describe.
Check all that apply.
Please describe.
No
Skip to question IV‐14.
Yes‐Business cycles (e.g.
seasonal business)
Yes‐Other distinctive
conditions of competition
(b) If yes, have there been any changes in the business cycles or conditions of competition for
wind towers since January 1, 2017?
No
Yes
If yes, describe.
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Page 38
IV‐14. Supply constraints.‐‐Has your firm refused, declined, or been unable to supply wind towers
since January 1, 2017 (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‐15. Raw materials.—
(a) How have wind towers raw material prices changed since January 1, 2017?
Fluctuate
Overall
No
Overall
with no
increase change decrease clear trend
Explain, noting how raw material price changes
have affected your firm’s selling prices for wind
towers.
(b) Has information on raw material prices affected your firm’s negotiations or contracts to
produce wind towers since 2017?
No
Yes Explain
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U.S. Producers’ Questionnaire ‐ Wind towers (Final)
Page 39
IV‐16. Impact of the section 232 investigation.‐‐This question concerns the section 232 investigation
and subsequent tariffs imposed on imported steel products.
(a) Did the imposition of tariffs on imported steel products beginning in March 2018 have an
impact on the wind towers market?
Yes—Please answer part (b)
No
Don’t know
(b) Assessment of impact of the section 232 tariffs.‐‐Please indicate the impact of the
imposition of 232 tariffs on imported steel products beginning in March 2018.
Item
Fluctuate
with no
clear
No
trend
Increase change Decrease
Explanation and factors
Prices for wind towers
in the U.S. market
Raw material costs for
wind towers in the
U.S. market
Business Proprietary
U.S. Producers’ Questionnaire ‐ Wind towers (Final)
Page 40
IV‐17. Impact of the CTL Plate AD/CVD orders.‐‐This question concerns the most recent antidumping
and countervailing duty orders on CTL (cut‐to‐length) plate.
(a) Did the issuance of antidumping and countervailing duty orders over the first half of 2017
have an impact on the market for wind towers?
Yes—Please answer part (b)
No
Don’t know
(b) Assessment of impact of the CTL Plate AD/CVD orders.‐‐ Please indicate the impact of the
issuance of antidumping and countervailing duty orders over the first half of 2017.
Fluctuate
with no
clear
No
trend
Increase change Decrease
Item
Explanation and factors
Prices for wind towers
in the U.S. market
Raw material costs for
wind towers in the
U.S. market
IV‐18. Impact of the section 301 actions.—This question concerns the section 301 investigation and
subsequent announcement of additional tariffs that apply to wind towers, which were proposed
and implemented by the United States in response to Chinese trade practices. Has the
implementation of tariffs in the section 301 investigation impacted your firm or the U.S. wind
towers market?
No
Yes
If yes, describe.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Wind towers (Final)
Page 41
IV‐19. Impact of the PTC expiration and wind‐down.—This question concerns the anticipated
expiration of the Federal wind energy production tax credit (PTC).
(a) Has the anticipated expiration of the PTC at the end of 2019 had an impact on the U.S.
market for wind towers?
Yes—Please answer part (b)
No
Don’t know
(b) Assessment of impact of the anticipated PTC expiration.‐‐ Please indicate the impact of the
anticipated expiration of the Federal wind energy PTC.
Item
Fluctuate
with no
clear
No
trend
Increase change Decrease
Explanation and factors
Production of wind
towers by your firm
Financial performance
of your firm
Demand for wind
towers in the U.S.
market
Prices for wind towers
in the U.S. market
Timing of U.S. wind
energy projects in the
development pipeline
Business Proprietary
U.S. Producers’ Questionnaire ‐ Wind towers (Final)
Page 42
IV‐20. Interchangeability.‐‐Are wind towers produced in the United States and in other countries
interchangeable (i.e., can they physically be used in the same applications)?
Please indicate A, F, S, N, or 0 in the table below:
A = the products from a specified country‐pair are always interchangeable
F = the products are frequently interchangeable
S = the products are sometimes interchangeable
N = the products are never interchangeable
0 = no familiarity with products from a specified country‐pair
Country‐pair
United States
Canada
Indonesia
Korea
Vietnam
Other countries
Canada
Indonesia
Korea
Vietnam
For any country‐pair producing wind towers that is sometimes or never interchangeable, identify the country‐
pair and explain the factors that limit or preclude interchangeable use:
Business Proprietary
U.S. Producers’ Questionnaire ‐ Wind towers (Final)
Page 43
IV‐21. Factors other than price.‐‐Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between wind towers produced
in the United States and in other countries a significant factor in your firm’s sales of the
products?
Please indicate A, F, S, N, or 0 in the table below:
A = such differences are always significant
F = such differences are frequently significant
S = such differences are sometimes significant
N = such differences are never significant
0 = no familiarity with products from a specified country‐pair
Country‐pair
United States
Canada
Indonesia
Korea
Vietnam
Other countries
Canada
Indonesia
Korea
Vietnam
For any country‐pair for which factors other than price always or frequently are a significant factor in your
firm’s sales of wind towers, identify the country‐pair and report the advantages or disadvantages imparted by
such factors:
Business Proprietary
U.S. Producers’ Questionnaire ‐ Wind towers (Final)
Page 44
IV‐22. Customer identification.‐‐List the names and contact information for your firm’s 10 largest U.S.
customers for wind towers since January 1, 2017. Indicate the share of the quantity of your
firm’s total shipments of wind towers that each of these customers accounted for in 2019.
Customer’s name
City
State
Share of 2019 sales (%)
1
2
3
4
5
6
7
8
9
10
IV‐23. Largest projects.—List the five largest U.S. projects for which your firm provided U.S.‐produced
wind towers since January 1, 2017.
Project/customer’s name
Location
Type of wind towers provided
(height, weight, other identifying
details)
Number of wind towers
provided
1
2
3
4
5
Business Proprietary
U.S. Producers’ Questionnaire ‐ Wind towers (Final)
Page 45
IV‐24. Competition from imports.‐‐
(a)
Lost revenue.‐‐Since January 1, 2017: To avoid losing sales to competitors selling wind
towers from Canada, Indonesia, Korea, and Vietnam, did your firm:
Item
No
Yes
(b)
Reduce prices
Roll back announced price increases
Lost sales.‐‐Since January 1, 2017: Did your firm lose sales of wind towers to imports of
this product from Canada, Indonesia, Korea, and Vietnam?
No
Yes
IV‐25. Other explanations.‐‐If your firm would like to further explain a response to a question in Part
IV for which a narrative response box was not provided, please note the question number and
the explanation in the space provided below. Please also use this space to highlight any issues
your firm had in providing the data in this section, including but not limited to technical issues
with the MS Word questionnaire.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Wind towers (Final)
Page 46
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/title_7/2020/utility_scale_wind_towers_canada_i
ndonesia_korea/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: WIND
• E‐mail.—E‐mail the MS Word questionnaire to [email protected]; include a scanned copy of the
signed certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic documents
that are electronically transmitted to the Commission to protect your sensitive information from
unauthorized disclosure. The USITC secure drop‐box system and the Electronic Document Information
System (EDIS) use Federal Information Processing Standards (FIPS) 140‐2 cryptographic algorithms to
encrypt data in transit. Submitting your nonpublic documents by a means that does not use these
encryption algorithms (such as by email) may subject your firm’s nonpublic information to unauthorized
disclosure during transmission. If you choose a non‐encrypted method of electronic transmission, the
Commission warns you that the risk of such possible unauthorized disclosure is assumed by you and not
by the Commission.
If your firm does not produce this product, please fill out page 1, print, sign, and submit a scanned copy
to the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, it is required to serve a copy of the
completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (202‐
205‐1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.
| File Type | application/pdf |
| File Title | Microsoft Word - US Producers Questionnaire--Wind Towers (F) |
| Author | ahdia.bavari |
| File Modified | 2020-02-25 |
| File Created | 2020-02-25 |