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pdfOMB No. 3117-0016/USITC No. 20-1-4333; Expiration Date: 6/30/2023
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U.S. PRODUCERS’ QUESTIONNAIRE
UTILITY SCALE WIND TOWERS FROM INDIA, MALAYSIA, AND SPAIN
This questionnaire must be received by the Commission by October 14, 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 duty and antidumping investigations concerning utility scale wind towers (“wind
towers”) from India, Malaysia, and Spain (Inv. Nos. 701-TA-660-661 and 731-TA-1543-1545 (Preliminary)). The
information requested in the questionnaire is requested under the authority of the Tariff Act of 1930, title VII. This
report is mandatory and failure to reply as directed can result in a subpoena or other order to compel the submission of
records or information in your firm’s possession (19 U.S.C. § 1333(a)).
Name of firm
Address
City
State
Zip Code
Website
Has your firm 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
Signature
Title of Authorized Official
Phone
Date
Email address
Business Proprietary
U.S. Producers’ Questionnaire - Wind towers (Preliminary)
Page 2
PART I.—GENERAL INFORMATION
Background.--This proceeding was instituted in response to petitions filed on September 30, 2020, by
the Wind Tower Trade Coalition (Arcosa Wind Towers Inc. (Dallas, Texas) and Broadwind Towers, Inc.
(Manitowoc, Wisconsin)). 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://usitc.gov/investigations/701731/2020/utility_scale_wind_towers_india_malaysia_and_spain/pr
eliminary.htm.
Wind towers covered by these investigations is certain wind towers, whether or not tapered, and
sections thereof. Certain wind towers 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, endfinish, 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.
Merchandise covered by these orders is currently classified in the Harmonized Tariff Schedule of the
United States (HTSUS) under subheading 7308.20.0020 or 8502.31.0000. 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). While the HTSUS subheadings are
provided for convenience and customs purposes, the written description of the scope of these orders is
dispositive.
Unit.—A unit, unless otherwise stated, is a complete wind tower (whether or not comprised of multiple
sections) or wind tower equivalent (e.g., one section of a wind tower comprised of four sections would
be equal to ¼ or 0.25 wind towers).
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.
Business Proprietary
U.S. Producers’ Questionnaire - Wind towers (Preliminary)
Page 3
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. In addition, if your firm is a U.S. producer, the information you
provide on your production and imports of wind towers and your responses to the questions in Part I of
the producer questionnaire will be provided to the U.S. Department of Commerce, upon its request, for
use in connection with (and only in connection with) its requirement pursuant to section
702(c)(4)/732(c)(4) of the Act (19 U.S.C. § 1671a(c)(4)/1673a(c)(4)) to make a determination concerning
the extent of industry support for the petition requesting this proceeding. Any information provided to
Commerce will be transmitted under the confidentiality and release guidelines set forth above. Your
response to these questions constitutes your consent that such information be provided to Commerce
under the conditions described above.
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 macroenabled MS Excel file available for download from the Commission's generic questionnaires webpage
(https://www.usitc.gov/trade_remedy/question.htm) called the "D-GRIDs tool." Use of this tool to help
your firm complete this questionnaire is optional. Firms opting to use the D-GRIDs tool to populate their
data into this questionnaire will need the D-GRIDs specification sheet PDF file specific to this proceeding
(available on the case page which is linked under the "Background" above) which includes the necessary
references relating to this questionnaire, as well as the macro-enable MS Excel D-GRIDs tool itself from
the generic questionnaires page. More detailed instructions on how to use the D-GRIDs tool are
available within the D-GRIDs tool itself.
Business Proprietary
U.S. Producers’ Questionnaire - Wind towers (Preliminary)
I-1a.
Page 4
OMB statistics.--Please report below the actual number of hours required and the cost to your
firm of completing this questionnaire.
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-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?
Yes
I-2a.
No
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
covered1
City, State
Zip (5 digit)
Description
1
2
3
4
5
6
1
Additional discussion on establishments consolidated in this questionnaire:
.
Business Proprietary
U.S. Producers’ Questionnaire - Wind towers (Preliminary)
Page 5
I-2b.
Stock symbol information.-- If your firm or parent firm is publicly traded, please specify the
stock exchange and trading symbol:
.
I-2c.
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):
I-3.
Petitioner status.--Is your firm a petitioner in this proceeding or a member firm of the
petitioning entity?
No
I-4.
Petition support.--Does your firm support or oppose the petition?
Country
India
Investigation type
AD
Support
Oppose
Take no position
CVD
Malaysia
AD
CVD
AD
Spain
I-5.
Yes
Ownership.--Is your firm owned, in whole or in part, by any other firm?
No
Firm name
Yes--List the following information, relating to the ultimate parent/owner.
Country
Extent of
ownership
(percent)
Business Proprietary
U.S. Producers’ Questionnaire - Wind towers (Preliminary)
I-6.
Related importers/exporters.--Does your firm have any related firms, either domestic or
foreign, that are engaged in importing wind towers from India, Malaysia, or Spain into the
United States or that are engaged in exporting wind towers from India, Malaysia, or Spain to the
United States?
No
Firm name
I-7.
Page 6
Yes--List the following information.
Country
Affiliation
Related producers.--Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of wind towers?
No
Firm name
Yes--List the following information.
Country
Affiliation
Business Proprietary
U.S. Producers’ Questionnaire - Wind towers (Preliminary)
Page 7
PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Calvin Chang (202-205-3062,
[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 wind towers since January 1, 2017.
(check as many as appropriate)
plant openings
plant closings
relocations
expansions
acquisitions
consolidations
prolonged shutdowns or
production curtailments
revised labor agreements
other (e.g., technology)
(If checked, please describe the nature, date(s), and
significance of any such reported changes as well as the
business reasons for them; leave completely blank if not
applicable)
Business Proprietary
U.S. Producers’ Questionnaire - Wind towers (Preliminary)
II-2b.
COVID-19 pandemic.-- Since January 1, 2020, has the COVID-19 pandemic or have any
government actions taken to contain the spread of the COVID-19 virus resulted in changes in
relation to your firm's supply chain arrangements, production, employment, and sales relating
to wind towers?
No
II-3a.
Page 8
Yes
If yes, describe these changes including a separate discussion of the (a)
supply chain impact, (b) production and sales impact, and (c) employment
impact of the COVID-19 pandemic.
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.
Exclude any capacity of a facility or location in your reported overall capacity that did not
actually produce any wind towers at any time since January 1, 2017, even if that facility's or
location’s capacity could theoretically be diverted to wind tower production given the right
market conditions.
“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.
Business Proprietary
U.S. Producers’ Questionnaire - Wind towers (Preliminary)
II-3a.
Page 9
Production using same machinery.—Continued
Quantity (in units)
Calendar year
Item
Overall production capacity
2017
2019
2019
2020
1
Production of:
Wind towers2
Other products
2018
January-June
0
0
0
0
0
0
0
0
0
0
3
Total production using same
machinery or workers
Data reported for capacity (first line) should be greater than data reported for total production (last line).
Data entered for production of wind towers will populate here once reported in question II-7.
3
Please identify these products:
.
1
2
II-3b.
Operating parameters.--The production capacity reported in II-3a is based on the following
operating paramaters:
Hours per week
Weeks per year
II-3c.
Capacity calculation.--Please describe the methodology used to calculate overall production
capacity reported in II-3a, and explain any changes in reported capacity.
II-3d.
Production constraints.--Please describe the constraint(s) that set the limit(s) on your firm’s
production capacity.
Business Proprietary
U.S. Producers’ Questionnaire - Wind towers (Preliminary)
II-4.
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
(b)
II-5.
Page 10
Yes
If yes—(i.e., have produced other products or are able to produce other
products) Please identify other actual or potential products.
Please describe the factors that affect your firm’s ability to shift production capacity
between products (e.g., time, cost, relative price change, etc.), and the degree to which
these factors enhance or constrain such shifts.
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 (Preliminary)
II-6.
Page 11
Foreign trade zones.-Firm's FTZ operations.--Does your firm produce wind towers in and/or admit wind
towers 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 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 firm’s operations in FTZs and identify
the specific FTZ site(s).
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?
(b)
No
Yes
If yes--Identify the firms and the FTZs.
Business Proprietary
U.S. Producers’ Questionnaire - Wind towers (Preliminary)
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).
•
Exclude any capacity of a facility or location in your reported average production
capacity that did not actually produce any wind towers at any time since January 1,
2017, even if that facility's or location’s capacity could theoretically be diverted to wind
tower production given the right market conditions.
“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 (Preliminary)
II-7.
Page 13
Production, shipment, and inventory data.—Continued
Quantity (in units) and value (in $1,000)
Calendar year
Item
Average production capacity
(quantity) (A)
2017
2018
January-June
2019
2019
2020
1
Beginning-of-period inventories
(quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:2
Quantity (F)
Value2 (G)
Transfers to related firms:2
Quantity (H)
Value2 (I)
Export shipments:3
Quantity (J)
Value (K)
End-of-period inventories (quantity)
(L)
The production capacity reported is based on operating
hours per week,
weeks per year. Please describe
the methodology used to calculate production capacity, and explain any changes in reported capacity
.
2
Internal consumption and transfers to related firms must be valued at fair market value. 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.
3
Identify your firm’s principal export markets:
.
1
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
B + C – D – F – H – J – L = should equal
zero ("0") or provide an explanation.1
2017
2018
0
January-June
2019
0
2019
0
2020
0
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate:
.
1
0
Business Proprietary
U.S. Producers’ Questionnaire - Wind towers (Preliminary)
Page 14
U.S. shipments by region.--Report your firm’s U.S. shipments (i.e., inclusive of commercial U.S.
shipments, internal consumption, and transfers to related firms) to each of the specified regions
during the specified period.
II-8.
"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.
Quantity (in units)
Calendar year
Geographic region
2017
2018
January-June
2019
2019
2020
Northeast (M)
Upper Midwest (N)
Lower Midwest (O)
Upper Southeast (P)
Lower Southeast (Q)
Central Southwest (R)
Mountains (S)
Pacific Coast (T)
Other (U)
RECONCILIATION OF SHIPMENTS BY GEOGRAPHIC REGION.--Please ensure that the quantities reported
for shipments by region (i.e., lines M through U) equal the quantities reported for U.S. shipments (i.e.,
lines D,F, and I). 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
Quantity: M + N + O + P + Q + R +
S + T + U – D – F – H = zero ("0"),
if not revise.
2017
2018
0
January-June
2019
0
2019
0
2020
0
0
Business Proprietary
U.S. Producers’ Questionnaire - Wind towers (Preliminary)
Page 15
II-9.
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-10 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-10.
Employment data.--Report your firm’s employment-related data related to the production of
wind towers and provide an explanation for any trends in these data.
“Production and Related Workers” (PRWs) includes working supervisors and all nonsupervisory
workers (including group leaders and trainees) engaged in fabricating, processing, assembling,
inspecting, receiving, storage, handling, packing, warehousing, shipping, trucking, hauling,
maintenance, repair, janitorial and guard services, product development, auxiliary production
for plant’s own use (e.g., power plant), recordkeeping, and other services closely associated with
the above production operations. Average number employed may be computed by adding the
number of employees, both full time and part time, for the 12 pay periods ending closest to the
15th of the month and divide that total by 12. For the January to June periods, calculate
similarly and divide by 6.
If your firm had the same number of PRWs in all calendar year and had not experienced
any changes in PRWs in the most recent interim period, you would have the same
number of PRWs for the interim periods, regardless of whether the interim periods are
Jan-Mar (Q1), Jan-2019 (Q1+Q2), or Jan-Sept (Q1+Q2+Q3).”
“Hours worked” includes time paid for sick leave, holidays, and vacation time. Include overtime
hours actually worked; do not convert overtime pay to its equivalent in straight time hours.
“Wages paid” –Total wages paid before deductions of any kind (e.g., withholding taxes, old-age
and unemployment insurance, group insurance, union dues, bonds, etc.). Include wages paid
directly by your firm for overtime, holidays, vacations, and sick leave.
Calendar year
Item
Average number of PRWs (number)
Hours worked by PRWs (1,000 hours)
Wages paid to PRWs ($1,000)
Explanation of trends:
2017
2018
January-June
2019
2019
2020
Business Proprietary
U.S. Producers’ Questionnaire - Wind towers (Preliminary)
Page 16
II-11.
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.
II-12.
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 year
Item
2017
2018
January-June
2019
2019
2020
Purchases from U.S. importers of
wind towers from—
India
1
Malaysia
Spain
All other sources
Purchases from domestic producers2
Purchases from other sources3
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 U.S. producer(s) from which your firm purchased this product:
.
3
Please list the name of the firm(s) from which your firm purchased this product:
.
1
Business Proprietary
U.S. Producers’ Questionnaire - Wind towers (Preliminary)
II-13.
Page 17
Imports.--Since January 1, 2017, has your firm imported wind towers?
No
Yes
If yes--COMPLETE AND RETURN A U.S. IMPORTERS’ QUESTIONNAIRE
II-14.
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- Skip to question II-17
II-15.
Yes- Complete questions II-15 and II-16
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 2019 quantities reported in question II-7 (lines F and H).
Quantity (in units)
Calendar year 2019
Item
Internal consumption
Sold as is (Re-entry into
merchant market)
Transfers to related firms
NA
Assembled into wind turbines
Assembled into other
products1
Please describe these products:
1
.
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 in 2019.
Reconciliation
Calendar year 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 2019 quantities reported in question II-7 (lines F and H). If not,
please revise.
Business Proprietary
U.S. Producers’ Questionnaire - Wind towers (Preliminary)
II-16.
Page 18
Wind towers share contribution to wind turbines.--Does your firm or a related firm produce
wind turbines using your firm's U.S.-produced wind towers?
No
Yes
If yes-- please report the average share that wind towers accounts for of
wind turbines (since January 2017).
Material inputs used in wind turbine
production
Share of value
accounted for in wind
turbines (percent)
Share of the quantity
accounted for in wind
turbines (percent)
Wind towers
All other material inputs
Total (should sum to 100.0%)
II-17.
0.0
0.0
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.
Business Proprietary
U.S. Producers’ Questionnaire - Wind towers (Preliminary)
Page 19
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.—Please provide the following information on 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:
Note.--Please note that we are requesting that firms report their financial
data on a calendar year basis.
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.
3.
4.
Does your firm prepare profit/loss statements for wind towers:
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,
10 Qs,
monthly,
quarterly,
semi-annually,
annually
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.
Business Proprietary
U.S. Producers’ Questionnaire - Wind towers (Preliminary)
Page 20
III-3.
Cost accounting system.--Briefly describe your firm’s cost accounting system (e.g., standard
cost, job order cost, etc.).
III-4.
Background questions
A.
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 and the extent to which this
varies by input/component. Please specify the extent to which “directed buy”
arrangements are or are not prevalent and to which input/component they apply.
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.
Business Proprietary
U.S. Producers’ Questionnaire - Wind towers (Preliminary)
III-4.
III-5.
Page 21
Background questions.--Continued
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.
E.
Conversion pricing.--Please describe the extent to which a specific wind tower
conversion price is or is not negotiated directly with the customer in conjunction with
direct pass through of raw material costs. If a specific conversion price is not negotiated
directly in conjunction with pass through of raw material costs, please describe how
wind tower sales values are established/determined.
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
2019
Products
Wind towers
Share of 2019
sales
%
%
%
%
%
Business Proprietary
U.S. Producers’ Questionnaire - Wind towers (Preliminary)
III-6.
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 units within the same company)?
Yes--Continue to question III-7
III-7.
No—Skip 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 “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:
III-8.
Page 22
Share of total 2019
COGS
%
%
%
%
Inputs purchased from related suppliers.--Please confirm that the inputs purchased from
related suppliers, as identified in III-7, are 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 (Preliminary)
Page 23
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 the specified calendar
year and interim periods.
Quantity (in units) and value (in $1,000)
Calendar year
Item
2017
2018
January-June
2019
2019
2020
Net sales quantities:
Commercial sales (“CS”)
2
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
Total net sales quantities
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Net sales values:
Commercial sales
2
Internal consumption
Transfers to related firms
Total net sales values
Cost of goods sold (COGS):
Steel plate (HSLA and/or alloy)
3
Flanges
Other raw materials
Raw material costs
Direct labor
Other factory costs
Total COGS
Gross profit or (loss)
Selling, general, and administrative (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
Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding
shipment quantities and values reported in Part II of this questionnaire.
3 COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
1
2
Note --The table above contains calculations that will appear when you have entered data in the MS
Word form fields.
Business Proprietary
U.S. Producers’ Questionnaire - Wind towers (Preliminary)
Page 24
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), 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
III-9c.
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.
Effects on financial performance of COVID-19.--Please explain how the COVID-19 pandemic has
affected the financial performance of your firm’s operations on wind towers as reported in III9a.
Business Proprietary
U.S. Producers’ Questionnaire - Wind towers (Preliminary)
Page 25
III-10. Nonrecurring items (charges and gains) included in the subject product financial results.--For
each annual and interim period for which financial results are reported in question III-9a, please
specify all material (significant) nonrecurring items (charges and gains) in the schedule below,
the specific question III-9a line item where the nonrecurring items are included, a brief
description of the relevant nonrecurring items, and the associated values (in $1,000), as
reflected in question III-9a; i.e., if an aggregate nonrecurring item has been allocated to question
III-9a, only the allocated value amount included in question III-9a should be reported in the
schedule below. Note: The Commission’s objective here is to gather information only on
material (significant) nonrecurring items which impacted the reported financial results of the
subject product in question III-9a.
Calendar year
Item
2017
2018
January-June
2019
2019
2020
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
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7
Income statement classification of the
nonrecurring item
Business Proprietary
U.S. Producers’ Questionnaire - Wind towers (Preliminary)
Page 26
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-12a. 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 the specified calendar year.
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.
Value (in $1,000)
Calendar year
Item
2017
2018
2019
Total assets (net)
III-12b. Description of reported assets.-- Please describe the main asset categories (both current and
long-term assets) in the above response. 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.
III-13a. Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development expenses for wind towers. Provide data for the
specified calendar year and interim periods.
Value (in $1,000)
Calendar year
Item
Capital expenditures
Research and development
expenses
2017
2018
January-June
2019
2019
2020
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U.S. Producers’ Questionnaire - Wind towers (Preliminary)
Page 27
III-13b. Description of reported capital expenditures.-- Please describe the nature, focus, and
significance of your firm’s reported capital expenditures in the above response. If no capital
expenditure data were reported, please explain the reason.
III-13c. Description of reported R&D expenses.-- Please describe the nature, focus, and significance of
your firm’s reported R&D expenses in the response above. If no R&D expenses were reported,
please explain the reason.
III-14. Data consistency and reconciliation.-- Please confirm that your firm’s financial data for
questions III-9a, 12a, and 13a are reported on a calendar year basis:
Please note the quantities and values reported in question III-9a should reconcile with the data
reported in question II-7 (including export shipments).
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. 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.
Calendar year
Reconciliation
2017
2018
January-June
2019
2019
2020
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
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
0
0
Do these data in question III-9a reconcile with data in question II-7?
Yes
No
If no, please explain.
Business Proprietary
U.S. Producers’ Questionnaire - Wind towers (Preliminary)
Page 28
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 India, Malaysia, and Spain?
No
Yes
If yes, my firm has experienced actual negative effects as follows.
(check as many as appropriate)
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
(please describe)
Business Proprietary
U.S. Producers’ Questionnaire - Wind towers (Preliminary)
Page 29
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 India, Malaysia, and Spain?
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 India, Malaysia, and Spain?
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 (Preliminary)
Page 30
PART IV.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Amelia Preece (202-2053250, [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
PRICE DATA
IV-2.
This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. customers since January 1, 2017 of the following products produced by your
firm.
Product 1.— Wind towers, more than 80 meters but less than or equal to 90 meters in height
Product 2.—Wind towers, more than 90 meters but less than or equal to 100 meters in height
Product 3.—Wind towers, more than 100 meters but less than or equal to 110 meters in height
Product 4.—Wind towers, more than 110 meters but less than or equal to 120 meters in height
Please note that values should be f.o.b., U.S. point of shipment and should not include U.S.-inland
transportation costs. Values should reflect the final net amount paid to your firm (i.e., should be net
of all deductions for discounts or rebates).
IV-2a. During January 2017-June 2020, did your firm produce and sell to unrelated U.S. customers any
of the above listed products (or any products that were competitive with these products)?
Yes.--Please complete the following pricing data table(s) as appropriate.
No.--Skip to question IV-3.
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U.S. Producers’ Questionnaire - Wind towers (Preliminary)
Page 31
IV-2b. Price data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
Report data in units and actual dollars (not 1,000s).
Period of shipment
2017:
January-March
April-June
July-September
October-December
2018:
January-March
April-June
July-September
October-December
2019:
January-March
April-June
July-September
October-December
2020:
January-March
April-June
(Quantity in units, value in dollars)
Product 1
Product 2
Product 3
Quantity
Value
Quantity
Value
Quantity
Value
Product 4
Quantity
Value
Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned goods), f.o.b. your
firm’s U.S. point of shipment. Please subtract any discounts, rebates, and returns from the quarter in which the sale occurred.
2 Pricing product definitions are provided on the first page of Part IV.
1
Note.--If your firm’s product does not exactly meet the product specifications but is competitive with the specified product, provide a description
of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:
Product 4:
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U.S. Producers’ Questionnaire - Wind towers (Preliminary)
Page 32
IV-2c. Price data checklist.--Please check that the pricing data in question IV-2(b) has been correctly
reported.
Are the price data reported above:
√ if Yes
In actual dollars (not $1,000)?
In number of wind towers (full unit equivalents)?
F.o.b. U.S. point of shipment (i.e., does not include U.S. transport costs)?
Net of all discounts and rebates?
Have discounts, rebates, and returns been credited to the quarter in which the
sale occurred?
Quantities do not exceed commercial shipments in question II-7 in each year?
Explanation(s) for any boxes not checked:
IV-2d. Pricing data methodology.--Please describe the method and the kinds of documents/records
that were used to compile your price data.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records used in
the preparation of the price data, as Commission staff may contact your firm regarding questions on the
price data. The Commission may also request that your company submit copies of the supporting
documents/records (such as sales journal, invoices, etc.) used to compile these data.
Business Proprietary
U.S. Producers’ Questionnaire - Wind towers (Preliminary)
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
IV-4.
Contracts
Annual
total
volume
discounts
Other
If other, describe
No
discount
policy
Other
Describe
Pricing terms.--On what basis are your firm’s prices of domestic wind towers usually quoted
(check one)?
Delivered
IV-6.
Set
price
lists
Discount policy.--Please indicate and describe your firm’s discount policies (check all that apply).
Quantity
discounts
IV-5.
Page 33
F.o.b.
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
Type of sale
Long-term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
more than 12
months)
months)
Short-term
contracts
(multiple
deliveries for
less than 12
months)
%
%
%
Total
(should
sum to
100.0%)
Spot sales
(for a single
delivery)
%
0.0
%
Business Proprietary
U.S. Producers’ Questionnaire - Wind towers (Preliminary)
IV-7.
Page 34
Contract provisions.--Please fill out the table regarding your firm’s typical sales contracts for
U.S.-produced wind towers (or check “not applicable” if your firm does not sell on a short-term,
annual and/or long-term contract basis).
Typical sales
contract provisions
Item
Average contract
duration
No. of
days
Price renegotiation
(during contract
period)
Yes
Fixed quantity
and/or price
Short-term contracts
(multiple deliveries
for less than 12
months)
Annual contracts
(multiple
deliveries for 12
months)
Long-term contracts
(multiple deliveries
for more than 12
months)
365
No
Quantity
Indexed to raw
material costs1
Price
Both
Yes
No
Not applicable
1
Please identify the indexes used:
IV-8.
.
Lead times.--What share of your firm’s sales is 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?
Source
Lead time (Average
Share of 2019 sales number of days)
From inventory
%
Produced to order
%
Total (should sum to 100.0%)
0.0
%
Business Proprietary
U.S. Producers’ Questionnaire - Wind towers (Preliminary)
IV-9.
Page 35
Shipping information.-(a)
What is the approximate percentage of the cost of wind towers you sell that is
accounted for by U.S. inland transportation costs?
percent.
(b)
Who generally arranges the transportation to your firm’s customers’ locations?
Your firm
Purchaser (check one)
(b)
Who generally arranges the transportation to your firm’s customers’ locations?
Your firm
Purchaser (check one)
(c)
When your firm sells wind towers from where is it shipped?
Production facility
Storage facility (check one)
Additional explanation if needed:
(d)
Indicate the approximate percentage of your firm’s sales of wind towers that are
delivered the following distances from your firm’s U.S. point of shipment.
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 that you pay for the same wind tower models consistent across all
shipping distances or do they vary by shipping distances? Please explain.
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U.S. Producers’ Questionnaire - Wind towers (Preliminary)
Page 36
IV-10. 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
Overall
increase
Fluctuate
No
Overall
with no
change decrease clear trend
Explanation and factors
Within the
United States
Outside the
United States
IV-11. 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.
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Page 37
IV-12. Conditions of competition.-(a) Is the wind towers market subject to business cycles and/or other conditions of
competition distinctive to wind towers? If yes, describe.
Check all that apply.
Please describe.
No
Skip to question IV-13.
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.
IV-13. 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.
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U.S. Producers’ Questionnaire - Wind towers (Preliminary)
Page 38
IV-14. Raw materials.-(a) How have wind towers raw material costs 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 price for wind
towers.
(b) Has information on raw material prices affected your firm’s negotiations or contracts to sell
wind towers since 2017?
No
Yes Explain
(c) How did the imposition of tariffs under section 232 on imported steel/aluminum products
impact raw material costs for wind towers?
Fluctuate
with no
clear
Overall
No
Overall
Increase change Decrease
trend
Explanation
(d) How did the imposition of tariffs under section 232 on imported steel/aluminum products
impact your firm’s sales price for wind towers?
Fluctuate
with no
clear
Overall
No
Overall
Increase change Decrease
trend
Explanation
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U.S. Producers’ Questionnaire - Wind towers (Preliminary)
Page 39
IV-15. 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 2020 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
Acquisitions 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
Fluctuate
with no
No
clear
Increase change Decrease
trend
Explanation and factors
Business Proprietary
U.S. Producers’ Questionnaire - Wind towers (Preliminary)
Page 40
IV-16. Interchangeability.--Is wind towers produced in the United States and in other countries
interchangeable (i.e., can they physically be used in the same applications)?
Please indicate A, F, S, N, or 0 in the table below:
A = the products from a specified country-pair are always interchangeable
F = the products are frequently interchangeable
S = the products are sometimes interchangeable
N = the products are never interchangeable
0 = no familiarity with products from a specified country-pair
Country-pair
India
Malaysia
Spain
Other countries
United States
India
Malaysia
Spain
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 (Preliminary)
Page 41
IV-17. 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
India
Malaysia
Spain
Other countries
United States
India
Malaysia
Spain
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 (Preliminary)
Page 42
IV-18. 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
1
2
3
4
5
6
7
8
9
10
Contact person
Email
Telephone
City
State
Share
of
2019
sales
(%)
Business Proprietary
U.S. Producers’ Questionnaire - Wind towers (Preliminary)
Page 43
IV-19. Competition from imports.-(a)
Lost revenue.--Since January 1, 2017: To avoid losing sales to competitors selling wind
towers from India, Malaysia, and Spain, did your firm:
Item
No
Yes
Reduce prices
Roll back announced price increases
(b)
Lost sales.--Since January 1, 2017: Did your firm lose sales of wind towers to imports of
this product from India, Malaysia, and Spain?
No
(c)
Yes
The submission of lost sales/lost revenue allegations is to be completed only by NONPETITIONERS.
If your firm indicated “yes” to any of the above, your firm can provide the Commission
with additional information by downloading and completing the lost sales/lost revenues
worksheet at http://usitc.gov/trade_remedy/question.htm. Note that the Commission
may contact the firms named to verify the allegations reported.
Is your firm submitting the lost sales/lost revenues worksheet?
No—Please explain.
Yes—Please complete the worksheet and submit via the Commission dropbox.
https://dropbox.usitc.gov/oinv/. (PIN: WIND)
IV-20. 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 (Preliminary)
Page 44
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://usitc.gov/investigations/701731/2020/utility_scale_wind_towers_india_malaysi
a_and_spain/preliminary.htm
Please do not attempt to modify the format or permissions of the questionnaire
document. Please submit the completed questionnaire using one of the methods noted
below. If your firm is unable to complete the MS Word questionnaire or cannot use one
of the electronic methods of submission, please contact the Commission for further
instructions.
• Upload via Secure Drop Box.—Upload the MS Word questionnaire along with a scanned copy of the
signed certification page (page 1) through the Commission’s secure upload facility:
Web address: https://dropbox.usitc.gov/oinv/
Pin: 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 (202205-1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.
| File Type | application/pdf |
| File Title | USITCQUESTIONNAIRE |
| Subject | Title 7 investigations |
| Author | Chang, Calvin |
| File Modified | 2020-10-02 |
| File Created | 2020-10-02 |