20-3-4335 U.S. purchasers' questionnaire

OMB No. 3117-0016/USITC No. 20-3-4335; Expiration Date: 6/30/2023
(No response is required if currently valid OMB control number is not displayed)

LOST SALES AND LOST REVENUE SURVEY
UTILITY SCALE WIND TOWERS FROM INDIA, MALAYSIA, AND SPAIN
This survey must be received by the Commission by October 14, 2020
See last page for filing instructions.
The information called for in this survey is for use by the United States International Trade Commission in connection
with its countervailing duty and antidumping investigations concerning wind towers from India, Malaysia, and Spain (inv.
Nos. 701-TA-660-661 and 731-TA-1543-1545 (Preliminary)). The information requested in the survey 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 possession (19 U.S.C. § 1333(a)).
Further information on this survey can be obtained from Amelia Preece (202-205-3250, [email protected]).

Name of firm
Address
City

State

Zip Code

Website
Has your firm purchased, 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 survey to the Commission)

YES

(Complete all parts of the survey, and return the entire survey 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 this survey 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 submitting this certification I
also grant consent for the Commission, and its employees and contract personnel, to use the information provided in this survey
and throughout this proceeding in any other import-injury proceedings conducted by the Commission on the same or similar
merchandise.
I, the undersigned, acknowledge that information submitted in response to this request for information and throughout this
investigation or other proceeding may be disclosed to and used: (i) by the Commission, its employees and Offices, and contract
personnel (a) for developing or maintaining the records of this or a related proceeding, or (b) in internal investigations, audits,
reviews, and evaluations relating to the programs, personnel, and operations of the Commission including under 5 U.S.C.
Appendix 3; or (ii) by U.S. government employees and contract personnel, solely for cybersecurity purposes. I understand that all
contract personnel will sign appropriate nondisclosure agreements.
Name of Authorized Official

Title of Authorized Official

Date

Signature

Phone

Email address

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Lost Sales and Lost Revenue Survey- wind towers

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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.

Business Proprietary
Lost Sales and Lost Revenue Survey-Wind towers (Preliminary)

Page 3

Confidentiality.--The data furnished in response to this survey 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.
Release of information.--The information provided by your firm in response to this survey, 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. Please also retain a copy of the final document that you submit.
Contact information.--Please identify the responsible individual and the manner by which Commission
staff may contact that individual regarding the confidential information submitted in this survey. This
may or may not be the person whose signature is at the bottom of page 1.
Name
Title
Email
Telephone
Firms operating more than one establishment should combine the data for all establishments into a
single response.

Business Proprietary
Lost Sales and Lost Revenue Survey-Wind towers (Preliminary)

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PURCHASE INFORMATION
1. Purchases and imports.— Report separately your firm’s domestic purchases and imports of wind
towers.
“Purchase” – Purchase from a U.S. entity such as a U.S. producer, a U.S. importer, or other U.S.
firm.
“Import” – Purchase directly from a foreign supplier and your firm is the importer of record.
2017
Item

2018

2019

Quantity (in wind towers)

Purchases of wind towers produced
in—
United States
India
Malaysia
Spain
All other countries1
Sources unknown2
Total purchases

0

0

0

0

0

0

Imports of wind towers from—
India
Malaysia
Spain
All other countries1
Total imports3

Please identify these countries:
Please indicate the firm(s) from which you purchased this merchandise:
3
If your firm imported wind towers at any time since January 1, 2017, please also complete
and return a U.S. importers' questionnaire in this proceeding.
1
2

Business Proprietary
Lost Sales and Lost Revenue Survey-Wind towers (Preliminary)

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2. Changes in purchasing patterns.—Please indicate how the shares of your firm’s purchases of wind
towers from different sources have changed since January 1, 2017.
Source of
purchases

Did not
purchase Decreased Increased

Constant Fluctuated

Explanation for trend

United States

India

Malaysia

Spain
All other
countries
Sources
unknown
3. Major purchasing factors.--Please list, in order of their importance, the main factors your firm
considers in deciding from whom to purchase wind towers.
1.
2.
3.
Please list any other factors that are very important in your purchase decisions:

Business Proprietary
Lost Sales and Lost Revenue Survey-Wind towers (Preliminary)

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4. Purchasing subject imports rather than domestic products.—
(a)

Since January 2017, did your firm import and/or purchase imports of wind towers from
India, Malaysia, and Spain instead of purchasing U.S.-produced wind towers? Respond
for each subject country.

Source

Yes
(also respond to parts (b) and (c))

No
(If “No” for all countries, skip to next
question)

India
Malaysia
Spain
(b)

If you responded “Yes” to part (a), was the imported product priced lower than the
domestic product?
Source

Yes

No

India
Malaysia
Spain
(c)

If you responded “Yes” to part (a), was price a primary reason for importing and/or
purchasing subject imports rather than domestic product?

Source

India
Malaysia
Spain

Yes

If Yes, estimate the quantity
of imports purchased and/or
imported instead of domestic
product since January 2017
(in wind towers)

No

If No, please indicate the
reason your firm imported
and/or purchased imports
instead of domestic product

Business Proprietary
Lost Sales and Lost Revenue Survey-Wind towers (Preliminary)

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5. U.S. producers and import competition.—
(a)

Since January 1, 2017, in connection with a sale or offer to sell wind towers to your firm,
did U.S. producers reduce their prices of domestically produced wind towers in order to
compete with lower-priced imports of wind towers from the subject countries?
Respond for each subject country.
Yes (also respond to
question part (b))

Source

No (If “No” for all countries,
skip to next question)

Don’t know

India
Malaysia
Spain
(b)

If your firm responded “yes” to any of the above countries, please provide an estimate
of the reduction in U.S. producers’ prices and any additional explanations.

Source

Estimated
reduction in U.S.
prices
(percent)

India

%

Malaysia

%

Spain

%

Additional explanation, including such information as
timing (e.g., months/years), frequency of price
reductions, or other market/competitive factors

6. Other explanations--Please provide any additional comments in this box.

7. Stock symbol information.-- If your firm or parent firm is publicly traded, please specify the stock
exchange and trading symbol:
.
8. 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
Lost Sales and Lost Revenue Survey-Wind towers (Preliminary)

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

Dollars

The questions in this survey 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 survey is estimated to average 4 hours per response,
including the time for reviewing instructions, gathering data, and completing and reviewing the
survey.
We welcome comments regarding the accuracy of this burden estimate, suggestions for reducing
the burden, and any suggestions for improving this survey. Please attach such comments to your
response or send to the Office of Investigations, USITC, 500 E St. SW, Washington, DC 20436.

HOW TO FILE YOUR SURVEY RESPONSE
Please do not attempt to modify the format or permissions of the survey document.
Please submit the completed survey using one of the methods noted below. If your firm
is unable to complete the MS Word survey 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 survey 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 survey to [email protected]; include a scanned copy of the signed
certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic documents that are
electronically transmitted to the Commission to protect your sensitive information from unauthorized
disclosure. The USITC secure drop-box system and the Electronic Document Information System (EDIS)
use Federal Information Processing Standards (FIPS) 140-2 cryptographic algorithms to encrypt data in
transit. Submitting your nonpublic documents by a means that does not use these encryption algorithms
(such as by email) may subject your firm’s nonpublic information to unauthorized disclosure during
transmission. If you choose a non-encrypted method of electronic transmission, the Commission warns
you that the risk of such possible unauthorized disclosure is assumed by you and not by the Commission.
If your firm did not purchase this product, please fill out page 1, print, sign, and submit a scanned copy
to the Commission.