Comment from Andrew Kruse, Southwest Windpower, Inc.

I would ask that the USTR look into an additional area of concern. That has to do with possible fraudulent product certification. In order to receive a State incentive, most require some sort of certification. State incentives are worth up to 50% of the installed cost. Certification demonstrates to the user that the product is independently tested to a specific U.S. Recognized standard. SOLAR: All States require that the panel is “UL Listed” or NRTL equivalent in order for them to be eligible for the incentive. I do know that non-UL Listed PV panels are being sold in the U.S. I do not know if there are any efforts to place fake UL-Listed labels on PV Panels. The person who may know is: Charles Rego – Corporate Council. His email is: Charles.A.Rego@us.ul.com SMALL WIND: There is no national standard for small wind systems. To give consumers confidence that a wind turbine has been tested, California’s “California Energy Commission” uses a third party organization called KEMA. Manufacturers are required to demonstrate their product has performed for at least one year without problems or they are certified to an international standard. The Eligible list is: http://www.consumerenergycenter.org/cgi-bin/eligible_smallwind.cgi. Most states offering incentives use the CEC list. In speaking to KEMA and reviewing Chinese websites, both claim some of the Chinese turbines are “IEC certified”. Based on my 23 years of experience, it is doubtful the Chinese machines are certified. However, I do not have access to the proof. KEMA holds the largest list of certified wind turbines and it is not available to the public. There are also numerous reports people investing $15-30,000 in Chinese turbines have failed and are now finding replacement parts impossible to find. Contact Nellie Tong at KEMA: nellie.tong@kema.com – Ask for all Chinese wind turbines that submitted an IEC-Certificate and do research on the viability of that certificate. You are welcome to contact me.