[Federal Register Volume 64, Number 154 (Wednesday, August 11, 1999)]
[Notices]
[Pages 43673-43677]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 99-20736]
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DEPARTMENT OF COMMERCE
International Trade Administration
[C-412-811]
Certain Hot-Rolled Lead and Bismuth Carbon Steel Products From
the United Kingdom; Final Results of Countervailing Duty Administrative
Review
AGENCY: Import Administration, International Trade Administration,
Department of Commerce.
ACTION: Notice of final results of countervailing duty administrative
review.
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SUMMARY: On April 7, 1999, the Department of Commerce (``the
Department'') published in the Federal Register its preliminary results
of administrative review of the countervailing duty order on certain
hot-rolled lead and bismuth carbon steel products (``lead bar'') from
the United Kingdom for the period January 1, 1997 through December 31,
1997. The Department has now completed this administrative review in
accordance with section 751(a) of the Tariff Act of 1930, as amended.
For information on the net subsidy for each reviewed company, and for
all non-reviewed companies, please see the Final Results of Review
section of this notice. We will instruct the Customs Service to assess
countervailing duties as detailed in the Final Results of Review
section of this notice.
EFFECTIVE DATE: August 11, 1999.
FOR FURTHER INFORMATION CONTACT: Gayle Longest or Stephanie Moore,
Group II, Office of CVD/AD Enforcement VI, Import Administration,
International Trade Administration, U.S. Department of Commerce, 14th
Street and Constitution Avenue, N.W., Washington, D.C. 20230;
telephone: (202) 482-2786.
SUPPLEMENTARY INFORMATION:
Background
Pursuant to 19 C.F.R. 351.213(b), this review covers only those
producers or exporters of the subject merchandise for which a review
was specifically requested. Accordingly, this review covers British
Steel plc./British Steel Engineering Steels Limited (formerly United
Engineering Steels Limited). This review also covers the period January
1, 1997 through December 31, 1997 and nine programs.
Since the publication of the preliminary results on April 7, 1999
(64 FR 16920), the following events have occurred. We invited
interested parties to comment on the preliminary results. On May 7,
1999 case briefs were submitted by British Steel Engineering Steels
Limited (``BSES''), which exported to the United States during the
review period (``respondent''), and Inland Steel Bar Co.
(``petitioner''). On May 12, 1999 rebuttal briefs were submitted by
BSES and Inland Steel Bar Co.
Applicable Statute
Unless otherwise indicated, all citations to the statute are
references to the provisions of the Tariff Act of 1930, as amended by
the Uruguay Round Agreements Act (``URAA'') effective January 1, 1995
(``the Act''). The Department is conducting this administrative review
in accordance with section 751(a) of the Act. All citations to the
Department's regulations reference 19 C.F.R. Part 351, (1998) unless
otherwise indicated.
Scope of the Review
Imports covered by this review are hot-rolled bars and rods of non-
alloy or other alloy steel, whether or not descaled, containing by
weight 0.03 percent or more of lead or 0.05 percent or more of bismuth,
in coils or cut lengths, and in numerous shapes and sizes. Excluded
from the scope of this review are other alloy steels (as defined by the
Harmonized Tariff Schedule of the United States (``HTSUS'') Chapter 72,
note 1 (f)), except steels classified as other alloy steels by reason
of containing by weight 0.4 percent or more of lead or 0.1 percent or
more of bismuth, tellarium, or selenium. Also excluded are semi-
finished steels and flat-rolled products. Most of the products covered
in this review are provided for under subheadings 7213.20.00.00 and
7214.30.00.00 of the HTSUS. Small quantities of these products may also
enter the United States under the following HTSUS subheadings:
7213.31.30.00, 60.00; 7213.39.00.30, 00.60, 00.90; 7213.91.30.00,
45.00. 60.00; 7213.99.00; 7214.40.00.10, 00.30, 00.50; 7214.50.00.10,
00.30, 00.50; 7214.60.00.10, 00.30, 00.50; 7214.91.00; 7214.99.00 and
7228.30.80.00, 80.50. Although the HTSUS subheadings are provided for
convenience and for Customs purposes, our written description of the
scope of this proceeding is dispositive.
Subsidies Value Information
Change in Ownership
(I) Background
On March 21, 1995, British Steel plc (``BS plc'') acquired all of
Guest, Keen & Nettlefolds' (``GKN'') shares in United Engineering
Steels (``UES''), the company which produced and exported the subject
merchandise to the United States during the original investigation.
Thus, UES became a wholly-owned subsidiary of BS plc and was renamed
British Steel Engineering Steels (``BSES'').
Prior to this change in ownership, UES was a joint venture company
formed in 1986 by British Steel Corporation (``BSC''), a government-
owned company, and GKN. In return for shares in UES, BSC contributed a
major portion of its Special Steels Business, the productive unit which
produced the subject merchandise. GKN contributed its Brymbo Steel
Works and its forging business to the joint venture. BSC was privatized
in 1988 and now bears the name BS plc.
In the investigation of this case, the Department found that BSC
had received a number of nonrecurring subsidies prior to the 1986
transfer of its Special Steels Business to UES. See Final Affirmative
Countervailing Duty
[[Page 43674]]
Determination: Certain Hot-Rolled Lead and Bismuth Carbon Steel
Products From the United Kingdom, 58 FR 6237, 6243 (January 27, 1993)
(``Lead Bar''). Further, the Department determined that the sale to UES
did not alter these previously bestowed subsidies, and thus the portion
of BSC's pre-1986 subsidies attributable to its Special Steels Business
transferred to UES. Lead Bar, 58 FR at 6240.
In the 1993 certain steel products investigations, the Department
modified the allocation methodology developed for Lead Bar.
Specifically, the Department stated that it would no longer assume that
all subsidies allocated to a productive unit follow it when it is sold.
Rather, when a productive unit is spun-off or acquired, a portion of
the sales price of the productive unit represents the reallocation of
prior subsidies. See the General Issues Appendix (``GIA''), appended to
the Final Countervailing Duty Determination; Certain Steel Products
From Austria, 58 FR 37217, 37269 (July 9, 1993) (``Certain Steel''). In
a subsequent Remand Determination, the Department aligned Lead Bar with
the methodology set forth in the ``Privatization'' and
``Restructuring'' sections of the GIA. Certain Hot-Rolled Lead and
Bismuth Carbon Steel Products from the United Kingdom: Remand
Determination (October 12, 1993) (``Remand'').
On March 21, 1995, BS plc acquired 100 percent of UES. In
determining how this change in ownership affects our attribution of
subsidies to the subject merchandise, we relied on section 771(5)(F) of
the Act, which states that a change in ownership does not require a
determination that past subsidies received by an enterprise are no
longer countervailable, even if the transaction is accomplished at
arm's length. The Statement of Administrative Action, H.R. Doc. No.
316, Vol. 1, 103d Cong., 2d Sess. (1994) (``SAA''), explains that the
aim of this provision is to prevent the extreme interpretation that the
arm's length sale of a firm automatically, and in all cases,
extinguishes any prior subsidies conferred. While the SAA indicates
that the Department retains the discretion to determine whether and to
what extent a change in ownership eliminates past subsidies, it also
indicates that this discretion must be exercised carefully by
considering the facts of each case. SAA at 928.
In accordance with the Act and the SAA, we examined the facts of BS
plc's acquisition of GKN's 50 percent ownership stake in UES, and we
determined that the change in ownership does not render previously
bestowed subsidies attributable to UES no longer countervailable.
However, we also determined that a portion of the purchase price paid
for UES is attributable to its prior subsidies. Therefore, we reduced
the amount of the subsidies that ``traveled'' with UES to BS plc,
taking into account the allocation of subsidies to GKN, the former
joint-owner of UES. See Certain Hot-Rolled Lead and Bismuth Carbon
Steel Products From the United Kingdom; Final Results of Countervailing
Duty Administrative Review, 62 FR 53306 (October 14, 1997) (``Lead Bar
95 Final Results'') and Certain Hot-Rolled Lead and Bismuth Carbon
Steel Products From the United Kingdom; Preliminary Results of
Countervailing Duty Administrative Review, 62 FR 16555 (April 7, 1997)
(``Lead Bar 95 Preliminary Results''). To calculate the amount of UES's
subsidies that passed through to BS plc as a result of the acquisition,
we applied the methodology described in the ``Restructuring'' section
of the GIA. See GIA, 58 FR at 37268-37269. This determination is in
accordance with our changes in ownership finding in Final Affirmative
Countervailing Duty Determination; Pasta From Italy, 61 FR 30288,
30289-30290 (June 14, 1996), and our finding in the 1994 administrative
review of this case, in which we determined that ``[t]he URAA is not
inconsistent with and does not overturn the Department's General Issues
Appendix methodology or its findings in the Lead Bar Remand
Determination.'' Certain Hot-Rolled Lead and Bismuth Carbon Steel
Products From the United Kingdom; Final Results of Countervailing Duty
Administrative Review, 61 FR 58377, 58379 (November 14, 1996).
With the acquisition of UES, we also determined that BS plc's
remaining subsidies are attributable to the subject merchandise, now
produced by BS plc's wholly-owned subsidiary, BSES. Where the
Department finds that a company has received untied countervailable
subsidies, to determine the countervailing duty rate, the Department
attributes those subsidies to that company's total sales of
domestically produced merchandise, including the sales of 100-percent-
owned domestic subsidiaries. If the subject merchandise is produced by
a subsidiary company, and the only subsidies in question are the untied
subsidies received by the parent company, the countervailing duty rate
calculation for the subject merchandise is the same as described above.
Similarly, if such a company purchases another company, as was the case
with BS plc's purchase of UES, then the current benefit from the parent
company's allocable untied subsidies is attributed to total sales,
including the sales of the newly acquired company. See, e.g., GIA, 58
FR at 3762 (``the Department often treats the parent entity and its
subsidiaries as one when determining who ultimately benefits from a
subsidy''). Accordingly, in the Lead Bar 95 Final Results, we
determined that it is appropriate to collapse BSES with BS plc for
purposes of calculating the countervailing duty for the subject
merchandise. BSES, as a wholly-owned subsidiary of BS plc, continues to
benefit from the remaining benefit stream of BS plc's untied subsidies.
In collapsing UES with BS plc, we also determined that UES's untied
subsidies ``rejoined'' BS plc's pool of subsidies with the company's
1995 acquisition. All of these subsidies were untied subsidies
originally bestowed upon BSC (BS plc). After the formation of UES in
1986, the subsidies that ``traveled'' with the Special Steels Business
were also untied, and were found to benefit UES as a whole. See Lead
Bar 95 Final Results; Lead Bar 95 Preliminary Results.
(II) Calculation of Benefit
To calculate the countervailing duty rate for the subject
merchandise in 1997, we first determined BS plc's benefits in 1997,
taking into account all spin-offs of productive units (including the
Special Steel Business) and BSC's full privatization in 1988. See Final
Affirmative Countervailing Duty Determination; Certain Steel Products
from the United Kingdom, 58 FR 37393 (July 9, 1993) (``UK Certain
Steel''). We then calculated the amount of UES's subsidies that
``rejoined'' BS plc after the 1995 acquisition, taking into account the
reallocation of subsidies to GKN. See Lead Bar 95 Final Results; Lead
Bar 95 Preliminary Results. As indicated above, in determining both
these amounts, we followed the methodology outlined in the GIA. After
adding BS plc's and UES's benefits for each program, we then divided
that amount by BS plc's total sales of merchandise produced in the
United Kingdom in 1997.
Allocation Methodology
In British Steel plc v. United States, 879 F. Supp. 1254 (CIT 1995)
(``British Steel''), the U.S. Court of International Trade (``the
Court'') ruled against the allocation period methodology for non-
recurring subsidies that the Department has employed for the past
decade, a
[[Page 43675]]
methodology that was articulated in the General Issues Appendix (58 FR
at 37226). In accordance with the Court's decision on remand, the
Department determined that the most reasonable method of deriving the
allocation period for nonrecurring subsidies is a company-specific
average useful life (``AUL'') of non-renewable physical assets. For
British Steel, we determined this allocation period to be 18 years.
This remand determination was affirmed by the Court on June 4, 1996.
British Steel, 929 F. Supp. 426, 439 (CIT 1996).
The Department's acquiescence to the CIT's decision in the Certain
Steel cases resulted in different allocation periods between the UK
Certain Steel and Lead Bar proceedings (18 years vs. 15 years).
Moreover, UES became a wholly-owned subsidiary of BS plc in 1995. In
the 1995 review of Lead Bar, in order to maintain a consistent
allocation period across the UK Certain Steel and Lead Bar proceedings,
as well as in the different segments of Lead Bar, we altered the
allocation methodology previously used to determine the allocation
period for non-recurring subsidies previously bestowed on BSC and
attributed to UES. In the 1995 review, we applied the company-specific
18-year allocation period to all non-recurring subsidies. See Lead Bar
95 Final Results. Based on our decision in the 1995 administrative
review of this order, we determine that it is appropriate in this
review to continue to allocate all of BSC's non-recurring subsidies
over BS plc's company-specific average useful life of renewable
physical assets (i.e., 18 years).
Analysis of Programs
Based upon the responses to our questionnaire and written comments
from the interested parties we determine the following:
I. Programs Conferring Subsidies
A. Programs Previously Determined to Confer Subsidies
1. Equity Infusions
In the preliminary results we found that this program conferred
countervailable subsidies on the subject merchandise. Our review of the
record shows that no new information has been placed on it which shows
that this program does not continue to confer countervailable
subsidies. This and our analysis of the comments submitted by the
interested parties, summarized below, has not led us to change our
findings from the preliminary results. Accordingly, the net subsidies
for this program, which is 4.07 percent ad valorem, remains unchanged
from the preliminary results.
2. Regional Development Grant Program
In the preliminary results we found that this program conferred
countervailable subsidies on the subject merchandise. Our review of the
record shows that no new information has been placed on it which shows
that this program does not continue to confer countervailable
subsidies. This and our analysis of the comments submitted by the
interested parties, summarized below, has not led us to change our
findings from the preliminary results. Accordingly, the net subsidies
for this program, which is 0.14 percent ad valorem, remains unchanged
from the preliminary results.
3. National Loan Funds Loan Cancellation
In the preliminary results we found that this program conferred
countervailable subsidies on the subject merchandise. Our review of the
record shows that no new information has been placed on it which shows
that this program does not continue to confer countervailable
subsidies. This and our analysis of the comments submitted by the
interested parties, summarized below, has not led us to change our
findings from the preliminary results. Accordingly, the net subsidies
for this program, which is 0.43 percent ad valorem, remains unchanged
from the preliminary results.
II. Programs Found To Be Not Used
In the preliminary results we found that the producers and/or
exporters of the subject merchandise did not apply for or receive
benefits under the following programs:
A. New Community Instrument Loans
B. NLF Loans
C. Regional Selective Loans
D. ECSC Article 56(b)(2) Redeployment Aid
E. Inner Urban Areas Act of 1978
F. LINK Initiative
We did not receive any comments on these programs from the
interested parties, and our review of the record has not led us to
change our findings from the preliminary results.
III. Other Programs Examined
BRITE/EuRAM and Standards Measurement and Testing Program
BS plc received assistance under these two European Union programs
to fund research and development. The European Union claimed that
assistance provided under both of these programs is non-countervailable
in accordance with Article 8.2(a) of the WTO Agreement on Subsidies and
Countervailing Measures and section 771(5B)(B) of the Act (which
provide that certain research and development subsidies are not
countervailable). We determine that it is not necessary to address
whether BRITE/EuRAM and the Standards Measurement and Testing Program
qualify for non-countervailable treatment because combined, the
assistance provided under both of these programs would result in a rate
of less than 0.005 percent ad valorem, and thus would have no impact on
the overall countervailing duty rate calculated for this POR. For the
same reason we have not conducted a specificity analysis of these
programs. See, e.g., Final Affirmative Countervailing Duty
Determination: Steel Wire Rod from Germany, 62 FR 54990, 54995-54996
(October 22, 1997).
Analysis of Comments
Comment 1: Application of the Repayment Methodology
According to the petitioner, the Department's subsidy repayment
methodology is inconsistent with the countervailing duty statute, basic
economic principles, and evidence produced in this proceeding. The
petitioner contends that the Department's subsidy credit methodology is
invalid, that there is no evidence of repayment, and that BS plc's
acquisition of GKN's shares does not differ from sales of shares traded
daily on the stock market. Because BSES is in the same position as
BSC's special steels business in 1985, all of UES's subsidies should
travel back to BS plc, subsequent to GKN's sale of UES shares to BS
plc. Furthermore, the petitioner asserts that the GIA and Certain Pasta
from Italy are distinguishable from the current case.
In rebuttal, the respondent points out that the petitioner's
arguments with respect to the attribution of a portion of UES's
subsidies to GKN have been examined by the Department in the 1995 and
1996 administrative reviews and rejected by the Department. The
respondent argues that petitioner's contention that the Department's
repayment methodology should not be applied to the1986 privatization of
the assets of British Steel Corporation's Special Steel Division and BS
plc's 1995 acquisition of GKN is not correct. The respondent asserts
that these two transactions were authentic and substantive undertakings
enacted for separate and important commercial reasons. The respondent
further argues that these transactions were not carried
[[Page 43676]]
out for purposes of evading U.S. countervailing duties. Therefore, the
respondent asserts that the Department has no basis to disregard the
validity or substance of these transactions and there is no basis to
not apply the repayment methodology.
Department's Position
Our position with respect to the petitioner's comments was outlined
in detail in the 1995 review of this case. See Lead Bar 95 Final
Results, 62 FR at 53309-10. The petitioner has not presented any new
arguments or facts that would lead the Department to depart from its
original conclusion with respect to this issue. Further, the
Department's position was strengthened with the CAFC's holding in
British Steel, affirming the Department's discretion to apply the
repayment methodology. For these reasons, we continue to apply the
repayment methodology in these final results.
Comment 2: The ``Change in Ownership'' Issue
BSES argues that the Department should revisit its determinations
on the change-in-ownership issues in this case because the effect of
the URAA amendments on change in ownership transactions is currently
under consideration by the United States Court of Appeals for the
Federal Circuit (``CAFC'') in Delverde, SRL v. United States, 24
F.Supp.2d 314 (CIT 1998), appeal docketed, No. 99-1186 (Federal Circuit
Jan. 13, 1999). The respondent states that pursuant to consent motions,
the CIT has stayed the appeals of the Department's final results in
both the 1995 and 1996 administrative reviews of this case pending the
CAFC's decision in Delverde. According to the respondent, by raising
this issue again in this review, BSES preserves the possibility that
the final decision in Delverde may be applied to entries covered by
this administrative review.
The respondent claims that the Department countervailed BS plc's
1997 production without any analysis of its 1988 privatization. The
respondent also contends that to comply with the Change in Ownership
provision of the URAA, the Department is required to conduct an
analysis of the privatization transaction in order to determine whether
subsidies pass through. Moreover, the respondent argues that 19 U.S.C.
section 1677(5)(B) requires the Department to conduct an analysis to
determine whether the privatized company has received a financial
benefit from the past subsidies received by BSC. The respondent argues
that current production of BS plc subject to countervailing duties is
no longer subsidized because, as of the 1988 privatization, the company
bears its full cost of capital to its shareholders on all funds and
assets in the company. Moreover, the respondent contends that BSES
received no financial benefit from the past subsidies to BSC.
Therefore, the respondent argues that BSES cannot be subjected to
countervailing duties based on past subsidies.
In rebuttal, petitioner points out that BSES raises no new
arguments in its case brief and the Department has already addressed
and ruled against these arguments in Certain Hot-Rolled Lead and
Bismuth Carbon Steel Products From the United Kingdom (``Lead Bar 1994
Final Results''), 61 FR 58377 (November 14, 1996). According to
petitioner, the Department decided that its subsidy allocation
methodology was in agreement with the URAA and used its discretion in
determining the impact the change in ownership had on the
countervailability of BS plc's past subsidies. The petitioner asserts
that the Department has rejected BSES's claim that countervailable
subsidies must be current benefits and the CAFC has also rejected
similar arguments made by British Steel in Inland Steel Bar Co. v.
United States, 155 F.3d 1370 (Federal Circuit 1998).
The petitioner further argues that BSES has mischaracterized the
Department's analysis in the preliminary results of this review and in
the investigation and previous administrative reviews of this case in
claiming that the Department has refused ``to consider the effect of a
privatization'' and has used an ``irrebuttable presumption.'' The
petitioner contends that the Department has examined the specific facts
of this case and considered arguments raised by the parties in its
determination of the allocation of subsidies. The petitioner cites to
Comment 5 of the Lead Bar 1994 Final Results and asserts that the
Department considered interested parties arguments regarding the
``subsequent events rule'' and explained that the Department did not
rely on such a rule in its findings in that review. See 61 FR at 58381.
Department's Position
Our position with respect to the respondent's comments on these
``change in ownership'' issues was outlined in detail in the 1994
review of this case. See Lead Bar 1994 Final Results, 61 FR at 58378-
58380. The respondent has not presented any new arguments or facts that
would lead the Department to depart from its original conclusion with
respect to this issue. For these reasons, our preliminary determination
with respect to the changes in ownership remains unchanged in these
final results.
Final Results of Review
In accordance with 19 C.F.R. 351.221(b)(4)(i), we calculated an
individual subsidy rate for each producer/exporter subject to this
administrative review. As discussed in the ``Change in Ownership''
section of the notice, above, we are treating British Steel plc and
British Steel Engineering Steels as one company for purposes of this
proceeding. For the period January 1, 1997 through December 31, 1997,
we determine the net subsidy for British Steel plc/British Steel
Engineering Steels (BS plc/BSES) to be 4.64 percent ad valorem.
We will instruct the Customs Service (``Customs'') to assess
countervailing duties on entries of subject merchandise from BS plc/
BSES during the POR at 4.64 percent ad valorem. The Department will
also instruct Customs to collect a cash deposit of estimated
countervailing duties of 4.64 percent of the f.o.b. invoice price on
all shipments of the subject merchandise from BS plc/BSES entered, or
withdrawn from warehouse, for consumption on or after the date of
publication of the final results of this review.
Because the URAA replaced the general rule in favor of a country-
wide rate with a general rule in favor of individual rates for
investigated and reviewed companies, the procedures for establishing
countervailing duty rates, including those for non-reviewed companies,
are now essentially the same as those in antidumping cases, except as
provided for in section 777A(e)(2)(B) of the Act. The requested review
will normally cover only those companies specifically named. See 19
C.F.R. 351.213(b). Pursuant to 19 C.F.R. 351.212(c), for all companies
for which a review was not requested, duties must be assessed at the
cash deposit rate, and cash deposits must continue to be collected at
the rate previously ordered. As such, the countervailing duty cash
deposit rate applicable to a company cannot change, except pursuant to
a request for a review of that company. See Federal-Mogul Corporation
and The Torrington Company v. United States, 822 F.Supp. 782 (CIT 1993)
and Floral Trade Council v. United States, 822 F.Supp. 766 (CIT 1993).
Therefore, the cash deposit rates for all companies except those
covered by this review will be unchanged by the results of this review.
We will instruct Customs to continue to collect cash deposits for
non-
[[Page 43677]]
reviewed companies at the most recent company-specific or country-wide
rate applicable to the company. Accordingly, the cash deposit rates
that will be applied to non-reviewed companies covered by this order
will be the rate for that company established in the most recently
completed administrative proceeding conducted under the URAA. If such a
review has not been conducted, the rate established in the most
recently completed administrative proceeding pursuant to the statutory
provisions that were in effect prior to the URAA amendments is
applicable. See, Certain Hot-Rolled Lead and Bismuth Carbon Steel
Products from the United Kingdom; Final Results of Countervailing Duty
Administrative Review, 60 FR 54841 (October 26, 1995). These rates
shall apply to all non-reviewed companies until a review of a company
assigned these rates is requested. In addition, for the period January
1, 1997 through December 31, 1997, the assessment rates applicable to
all non-reviewed companies covered by this order are the cash deposit
rates in effect at the time of entry.
This notice serves as a reminder to parties subject to
administrative protective order (APO) of their responsibility
concerning the disposition of proprietary information disclosed under
APO in accordance with 19 C.F.R. Sec. 351.305(a)(3). Timely written
notification of return/destruction of APO materials or conversion to
judicial protective order is hereby requested. Failure to comply with
the regulations and the terms of an APO is a sanctionable violation.
This administrative review and notice are issued and published in
accordance with section 751(a)(1) and 777(i)(1) of the Act (19 U.S.C.
1675(a)(1) and 19 U.S.C. 1677f(i)(1)).
Dated: August 5, 1999.
Robert S. LaRussa,
Assistant Secretary for Import Administration.
[FR Doc. 99-20736 Filed 8-10-99; 8:45 am]
BILLING CODE 3510-DS-P
