February 4, 2019 the Honorable Wilbur L. Ross, Jr. Secretary Of

Barcode:3789316-01 A-570-102 INV - Investigation -

PUBLIC VERSION

February 4, 2019

DOC Investigation Nos. A-122-864, A-201-850, A-570-102, C-122-865, C-201-851, C-570-103 USITC Investigation Nos. 701-TA-_ and 731-TA- By ELECTRONIC FILING Total Pages: 9 The Honorable Wilbur L. Ross, Jr. Investigation Secretary of Commerce AD/CVD Operations International Trade Administration Petitioner's Business Proprietary Information Removed from the attached: Attn: Enforcement and Compliance Volume I at 2,3, 12, 13,25-27,29-34,37,38,42, APO/Dockets Unit, Room 18022 Exhibit List, and Exhibits 1-2, 1-3, 1-4, 1-10, 1-14, U.S. Department of Commerce 1-15,1-16,1-19 1401 Constitution Avenue, NW Volume II at Pages 3-5, 7-14, 16,20, Exhibit List, Washington, DC 20230 and Exhibits 11-2, 11-3, 11-4, 11-7, 11-9, II-10, 11-12B, 11-13, 11-23 Volume III at Pages 3-12, 14, 15, 18, Exhibit List, By HAND DELIVERY and Exhibits III-2, III-5, III-8, 111-9, III-II, III-14, The Honorable Lisa R. Barton III-17, III-21 Secretary Volume IV at Pages 3,5-8, 11, 13, 14, 16,20, U.S. International Trade Commission Exhibit List, and Exhibits IV-3, IV-5, IV-7, IV-9A, IV-9B, IV-12 , IV.13, IV-14, IV-18, IV-22 500 E Street, SW, Room 112A PUBLIC VERSION Washington, DC 20436

RE: Petitions for the Imposition of Antidumping and Countervailing Duties on Certain Fabricated Structural Steel from Canada, Mexico, and the People's Republic of China

Dear Secretary Ross and Secretary Barton:

On behalf of the American Institute of Steel Construction, LLC ("Petitioner" or "AISC"), we hereby submit to the U.S. Department of Commerce ("the Department") and the U.S.

International Trade Commission ("the Commission") petitions for the imposition of antidumping and countervailing duties on U.S. imports of fabricated structural steel from Canada, Mexico, and the People's Republic of China (the "Petitions"), pursuant to sections 701, 702(b), 731, and 732(b)

1776 KFiled Street By: NW [email protected], I Washington, DC 20006 Filed I Date:202.719.7000 2/1/19 6:12 PM, Submission Status: wileyrein.comApproved Barcode:3789316-01 A-570-102 INV - Investigation - The Honorable Wilbur L. Ross, Jr. The Honorable Lisa R. Barton February4,2019 PUBLIC VERSION Page 2

of the Tariff Act of 1930, as amended (the "Act") (19 U.S.C. '§§ 1671, 1671a(b), 1673 and

1673a(b)). The members of AISC are producers in the United States of the domestic like product

and are thus "interested parties" within the meaning of 19 U.S.C. § 1677(9)(C). Pursuant to the

Department's regulations codified at 19 C.F.R. § 351.202(c), we hereby certify that the Petitions

and required copies are being tiled today with the U.S. International Trade Commission (the

"Commission").

Volume I of the petitions contains general information and the allegations of injury, along

with associated exhibits. Volumes II-IV contain antidumping duty allegations and associated

exhibits. Volume V - VII contain the countervailing duty allegations and associated exhibits. There

are proprietary and public versions of Volumes I, II, III, and IV, while Volumes V, VI, VII are

public in their entirety.

Pursuant to 19 C.F.R. §§ 351.202(d) and 351.304 of the Department's regulations, and

19 C.F.R. § 201.6(b) of the Commission's rules, we request business proprietary treatment for the

bracketed information in the narratives and exhibits of these petitions as detailed below.

Disclosure of this information, which is not otherwise publicly available, would cause substantial

harm to the competitive position of the submitter and would impair the ability of the Department

and the Commission to obtain information in the future necessary to fulfill their statutory functions.

Volume I (General Information and Injury):

(1) Exhibit 1-16: Prices of individual sales, likely sales, or other offers (but not components of prices, such as transportation, if based on published schedules, dates of sale, product descriptions (other than business or trade secrets described in paragraph (c)(I) of this section), or order numbers) (19 C.F.R. § 351.105(c)(5)).

(2) Exhibit 1-16: Names of particular customers, distributors, or suppliers (but not destination of sale or designation of type of customer, distributor, or supplier, unless the destination or designation would reveal the name) (19 C.F.R. § 351.105(c)(6)). (3) Pages 25, 33, ExhibitList, and Exhibits 1-3,1-4,1-14 through 1-16, 1-19: The names of particular persons from whom business proprietary information was obtained (19 C.F.R. § 351.105(c)(9)). (4) Pages 2,3, 12, 13,25-27,29-34,37,38,42, Exhibit List, and Exhibits 1-2 through 1-4, 1-10,1-14,1-15,1-16,1-19: Any other specific business information the release of which to the public would cause substantial harm to the competitive position of the submitter (19 C.F.R. § 351.105(c)(11)). Volume II (Canada AD Allegation):

(1) Page 14, and Exhibits 11-2, 11-12B, 11-13, 11-23: Business or trade secrets concerning the nature ofaproductor production process (19 C.F.R. § 351.105(c)(1)). (2) Page 20, and Exhibits 11-2, 11-13, 11-23: Production costs (but not the identity of the production components unless a particular component is a trade secret) (19 C.F.R. § 351. 105 (c)(2)). (3) Pages 3, 5, 7,8, 10, and Exhibits 11-2, 11-3, 11-4, 11-7, 11-9, II-10, 11-23: Distribution costs (but not channels of distribution) (19 C.F.R. .§ 351.105(c)(3)). (4) Pages 3-5, 7, 9,10, and Exhibits 11-2, 11-3, 11-12B, 11-23: Terms of sale (but not terms of sale offered to the public) (19 C.F.R. § 351.105(c)(4)). (5) Pages 3, 9, 10, and Exhibits 11-2, 11-3, 11-23: Prices of individual sales, likely sales, or other offers (but not components of prices, such as transportation, if based on published schedules, dates of sale, product descriptions (other than business or trade secrets described in paragraph (c)(I) of this section), or order numbers) (19 C.F.R. § 351.105(c)(5)). (6) Pages 3, 4, 10, and Exhibits 11-2, 11-3, 11-23: Names of particular customers, distributors, or suppliers (but not destination of sale or designation of type of customer, distributor, or supplier, unless the destination or designation would reveal the name) (19 C.F.R. § 351.105(c)(6)). (7) Pages 3, 8, 9, 11, 13, Exhibit List, and Exhibits 11-2, 11-7: The names of particular persons from whom business proprietary information was obtained (19 C.F .R. § 351.105(c)(9)). (8) Pages 3-5, 7-14, 16, 20, Exhibit List, and Exhibits 11-2, 11-3, 11-4, 11-7, 11-9, II-10, II-12B, 11-13, 11-23: Any other specific business information the release of which to the public would cause substantial harm to the competitive position of the submitter (19 C.F.R. § 351.105(c)(11)).

Volume III (Mexico AD Allegation):

(1) Page 12, and Exhibits 111-·2, 111-14, 111-17: Business or trade secrets concerning the nature of a product or production process (19 C.F.K § 351.105(c)(I)). (2) Page 18, and Exhibits 111-2, 111-14, 111-7, 111-21: Production costs (but not the identity of the production components unless a particular component is a trade secret) (19 C.F.R. § 351.105(c)(2)). (3) Pages 3, 5, 7, and Exhibits 111-2, 111-5, 111-8, 111-9, 111-11, 111-21: Distribution costs (but not channels of distribution) (19 C.F.R. § 351.105(c)(3)). (4) Pages 3-8, and Exhibits 111-2, 111-11, 111-21: Terms of sale (but not terms of sale offered to the public) (19 C.F.R. § 351.105(c)(4)). (5) Pages 3, 8, and Exhibits 111-2, 111-11, 111-21: Prices of individual sales, likely sales, or other offers (but not components of prices, such as transportation, if based on published schedules, dates of sale, product descriptions (other than business or trade secrets described in paragraph (c)(I) of this section), or order numbers) (19 C.F.R. § 351.105(c)(5)). (6) Pages 3, 4, 8, and Exhibits 111-2, 111-11, 111-21: Names of particular customers, distributors, or suppliers (but not destination of sale or designation of type of customer, distributor, or supplier, unless the destination or designation would reveal the name) (19 C.F.R. § 35 1. 1 05(c)(6)). (7) Pages 3, 7, 9, 11, 12, Exhibit List, and Exhibits 111-2, 111-8: The names of particular persons from whom business proprietary information was obtained (19 C.F.R. § 351.105(c)(9)). . (8) Pages 3-12, 14, 15, 18, Exhibit List, and Exhibits 111-2, 111-5, 111-8, 111-9, 111-11, 111-14,111-17, 111-21: Any other specific business information the release of which to the public would cause substantial harm to the competitive position of the submitter (19 C.F.R. § 35 1. 105(c)(1l)). Volume IV (People's Republic of China AD Allegation):

(1) Pages 11, and Exhibit IV-14: Business or trade secrets concerning the nature of a product or production process (19 C.F.R. § 351.1 05( c)(1 )). (2) Page 20, and Exhibits IV-14, IV-22: Production costs (but not the identity of the production components unless a particular component is a trade secret) (19 C.F.R. § 351.105(c)(2)). (3) Page 3, and Exhibits IV-3, IV-5, IV-7, IV-9A, IV-13, IV-18, IV-22: Distribution costs (but not channels of distribution) (19 C.F.R. § 351.105(c)(3)). (4) Pages 3,8, Exhibit List, and Exhibits IV -3, IV -22: Terms of sale (but not terms of sale offered to the public) (19 C.F.R. § 351.105(c)(4)).

(5) Pages 3, 8 and Exhibits IV-3, IV-22: Prices of individual sales, likely sales, or other offers (but not components of prices, such as transportation, if based on published schedules, dates of sale, product descriptions (other than business or trade secrets described in paragraph (c)(I) of this section), or' order numbers) (19 C.F.R. § 351.105(c)(5». (6) Pages 3, 8 and Exhibit IV-3: Names of particular customers, distributors, or suppliers (but not destination of sale or designation of type of customer, distributor, or supplier, unless the destination or designation would reveal the name) (19 C.F.R. § 351.105(c)(6». (7) Pages 11, 13, 14, Exhibit List, and Exhibits IV-12, IV-13: The names of particular persons from whom business proprietary information was obtained (19 C.F .R. § 351.105(c)(9». ' (8) Pages 3, 5-8, 11, 13, 14, 16,20, Exhibit List, and Exhibits IV-3, IV-5, IV-7, IV-9A, IV .. 9B, IV-12, IV-13, IV-14, IV-18, IV-22: Any other specific business information the release of which to the public would cause substantial harm to the competitive position of the submitter (19 C.F.R. § 351.105(c)(11)).

The requisite certification that substantially identical information is not available to the

public is set forth as an attachment to this letter, in accordance with section 201.6(b)(3)(iii) of the

Commission's rules. Also attached are the requisite company and counsel certifications regarding

the completeness and accuracy of the information contained in the petitions.

Pursuant to section 351.304(b)(1) of the Department's regulations, Petitioner agrees in

principle to permit disclosure of business proprietary information contained in the petitions under

an appropriately drawn administrative protective order ("APO"). Petitioner respectfully reserves

the right, however, to comment on all APO applications prior to disclosure.

Pursuant to section 351.202( c) of the Department's regulations, we certify that the petitions

and all required copies were filed today with both the Department and the Commission. The

petitions are being filed electronically on the Department's ACCESS filing system. An original

and eight paper copies of the business proprietary version and an original and two paper copies of

the public version of the narrative portions of each volume, along with CDs containing the

associated business proprietary and public version exhibits, are being filed manually at the

Commission.

If you have any questions regarding this petition, please contact us.

Respectfully submitted,

lsi Alan H Price Alan H. Price, Esq. Christopher B. Weld, Esq. Stephanie M. Bell, Esq.

Counsel for Petitioner American Institute of Steel Construction, LLC

COMPANY CERTIFICATION

I, Charles J. Carter, currently employed as President of the American Institute of Steel

Construction, LLC, certify that I prepared or otherwise supervised the preparation of the attached

submission, Petitions for the Imposition of Antidumping and Countervailing Duties pursuant

to Sections 701 and 731 of the Tariff Act of 1930, As Amended on Certain Fabricated Structural

Steel from Canada, Mexico and the People's Republic of China (Investigation Nos. A-122 ... 864,

A-570-102, A-201-850, C-122-865, C .. 570-103, and C-201-851), dated February 4,2019. I certify

that the public information and any business proprietary information of American Institute of Steel

Construction, LLC contained in this submission is accurate and complete to the best of my

knowledge. I am aware that the information contained in this submission may be subject to

verification or corroboration (as appropriate) by the U.S. Department of Commerce. I am also

aware that U.S. law (including, but not limited to, 18 U.S.C. 1001) imposes criminal sanctions on

individuals who knowingly and willfully make material false statements to the U.S. Government.

In addition, I am aware that, even if this submission may be withdrawn from the record of the

AD/CVD proceeding, the U.S. Department of Commerce may preserve this submission, including

a business proprietary submission, for purposes of determining the accuracy of this certification.

I certify that a copy of this signed certification will be filed with this submission to the U.S.

Department of Commerce.

Signature: cQc_~- C~er

Date: ~ '$ \ 'U»~

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved Barcode:3789316-01 A-570-102 INV - Investigation -

REPRESENTATIVE CERTIFICATION

I, Christopher B. Weld, with Wiley Rein LLP, counsel to the American Institute of Steel

Construction, LLC, certify that I have read the attached submission, Petitions for the Imposition of Antidumping and Countervailing Duties Pursuant to Sections 701 and 731 of the Tariff Act of

1930, As Amended, In the Matter of Certain Fabricated Structural Steel From Canada, Mexico, and the People's Republic of China (Investigation Nos. A-122-864, A-570-102, A-201-850,

C-122-865, C-570-103, and C-201-851), dated February 4, 2019. In my capacity as Counsel, I certify that the information contained in this submission is accurate and complete to the best of my knowledge. I am aware that U.S. law (including, but not limited to, 18 U.S.C. 1001) imposes criminal sanctions on individuals who knowingly and willfully make material false statements to the U.S. Government. In addition, I am aware that, even if this submission may be withdrawn from the record of the AD/CVD proceeding, the U.S. Department of Commerce may preserve this submission, including a business proprietary submission, for purposes of determining the accuracy of this certification. I certify that a copy of this signed certification will be filed with this submission to the U.S. Department of Commerce.

Date: February 4,2019

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved Barcode:3789316-01 A-570-102 INV - Investigation -

CERTIFICATION OF COUNSEL

City of Washington ) ) ss: District of Columbia )

In accordance with section 201.6(b)(3)(iii) of the Commission's regulations, 19 C.F.R. § 201.6(b)(3)(iii), I, Christopher B. Weld, of Wiley Rein LLP, counsel for the American Institute of Steel Construction, LLC, hereby certify that information substantially identical to the information for which we are requesting proprietary treatment in the attached submission is not available to the public.

In accordance with section 207.3(a) of the Commission's regulations, 19 C.F.R. § 207.3(a), I, further certify that (1) I have read the attached submission, and (2) the information contained in this submission is accurate and complete to the best of my knowledge.

In accordance with section 207.10(a) of the Commission's regulations, 19 C.F.R. § 207.10(a), I also certify that copies of this document are being filed with the Department of Commerce and the U.S. International Trade Commission on this date.

Dated: February 4,2019

Subscribed and sworn to before me on February 4,2019.

My Commission Expires: My Commission Expires 2128/2019

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved PUBLIC VERSION Barcode:3789316-02 A-570-102 INV - Investigation -

DOC Investigation Nos. A-122-864, A-201-850, A-570-102, C-122-865, C-201-851, C-570-103 USITC Investigation Nos. 701-TA-___ - ___ and 731-TA-___, ___ Total Pages: 176 Investigation AD/CVD Operations Petitioner’s Business Proprietary Information Removed from Pages 2, 3, 12, 13, 25-27, 29-34, 37, 38, 42, Exhibit List, and Exhibits I-2, I-3, I-4, I-10, I-14, I-15, I-16, and I-19 of this Volume PUBLIC VERSION

BEFORE THE INTERNATIONAL TRADE ADMINISTRATION OF THE U.S. DEPARTMENT OF COMMERCE AND THE U.S. INTERNATIONAL TRADE COMMISSION

PETITIONS FOR THE IMPOSITION OF ANTIDUMPING AND COUNTERVAILING DUTIES PURSUANT TO SECTIONS 701 AND 731 OF THE TARIFF ACT OF 1930, AS AMENDED VOLUME I: COMMON ISSUES AND INJURY PETITION

IN THE MATTER OF:

CERTAIN FABRICATED STRUCTURAL STEEL FROM CANADA, MEXICO, AND THE PEOPLE’S REPUBLIC OF CHINA

PETITIONER:

AMERICAN INSTITUTE OF STEEL CONSTRUCTION, LLC

COUNSEL: Alan H. Price, Esq. Christopher B. Weld, Esq. Stephanie M. Bell, Esq. WILEY REIN LLP 1776 K Street, NW Washington, DC 20006 (202) 719-7000 February 4, 2019

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved Barcode:3789316-02 A-570-102 INV - Investigation - PUBLIC VERSION

TABLE OF CONTENTS Page

I. COMMON ISSUES 1 A. Contact Information for the Petitioner (19 C.F.R. § 351.202(b)(1)) 1 B. Identity of the Industry on Whose Behalf the Petitions are Filed (19 C.F.R. § 207.11(b)(2)(ii); 19 C.F.R. § 351.202(b)(2)) 2 C. Information Relating to the Degree of Industry Support for the Petition (19 C.F.R. § 351.202(b)(3)) 2 D. Previous Requests for Import Relief for the Merchandise (19 C.F.R. § 351.202(b)(4)) .4 1. AD/CVD Litigation 4 2. Other Forms ofRelief 4 E. Scope of the Investigation and a Detailed Description of the Subject Merchandise (19 C.F.R. § 351.202(b)(5)) 5 1. Scope of Investigation 5 2. Technical Characteristics and Uses 7 3. Production Methodology 8 4. Tariff Classification 9 F. Names of the Subject Countries and the Name of Any Intermediate Country Through Which the Merchandise Is Transshipped (19 C.F.R. § 351.202(b)(6)) 9 O. Names and Addresses of Each Person Believed to Sell the Merchandise at Less than Normal Value and the Proportion of Total Exports to the United States (19 C.F.R. § 351.202(b)(7)(i)(A)) 9 H. All Factual Information Related to the Calculation of Export Price, the Constructed Export Price of the Subject Merchandise, and the Normal Value of the Foreign Like Product for Market Economy Countries (19 C.F.R. § 351.202(b)(7)(i)(B)) 10 I. Factual Information Related to the Calculation of Normal Value of the Foreign Like Product in Non-Market Economy Countries (19 C.F.R. § 351.202(b)(7)(i)(C)) 10 J. The Names and Addresses of Each Person Believed to Benefit from a Countervailable Subsidy Who Exports the Subject Merchandise to the United States and the Proportion of Total Export to the United States (19 C.F.R. § 351.202(b)(7)(ii)(A)) 10

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved 1 Barcode:3789316-02 A-570-102 INV - Investigation - PUBLIC VERSION

TABLE OF CONTENTS (cont'd) Page

K. The Alleged Countervailable Subsidy and Factual Information Relevant to the Alleged Countervailable Subsidy (19 C.F.R. § 351.202(b)(7)(ii)(B)) 11 L. The Volume and Value of the Merchandise Imported During the Most Recent Two-Year Period (19 C.F.R. § 351.202(b)(8)) 11 M. Contact Information for Each Entity the Petitioner Believes Imports or Is Likely to Import the Subject Merchandise (19 C.F.R. § 207.11(b)(2)(iii); 19 C.F.R. § 351.202(b)(9)) 12 II. MATERIAL INJURY, CAUSATION, AND THREAT 12 A. Introduction 12 B. The Domestic Like Product Consists ofFSS Covered by the Scope 14 C. There Is a Single Domestic Industry Consisting of All Domestic Producers 16 D. Subject Imports Are Causing Material Injury to the Domestic Industry 16 1. All Subject Imports Should Be Cumulated 17 2. The Volume of Subject Imports Is Significant 20 3. The Price Effects of Subject Imports Is Significant.. 23 4. The Subject Imports Have Had a Negative Impact on the Domestic Industry 28 E. Subject Imports Threaten Additional Material Injury to the Domestic Industry 36 1. The Commission Should Cumulate Subject Imports for the Purpose of Its Threat Analysis .36 2. Subject Imports Threaten Domestic Producers with Additional Material Injury 36 III. CONCLUSION ' 41

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved 11 Barcode:3789316-02 A-570-102 INV - Investigation - PUBLIC VERSION

These Petitions are presented on behalf of the American Institute of Steel Construction,

LLC ("AISC" or "Petitioner"). Petitioner alleges that certain fabricated structural steel ("FSS") imported from Canada, Mexico, and the People's Republic of China ("China") is being or is likely to be sold at less than normal value within the meaning of Section 731 of the Tariff Act of

1930, as amended ("the Act"), 19 U.S.C. § 1673. Petitioner further alleges that FSS imported from Canada, Mexico, and China is subsidized within the meaning of Section 701 of the Act,

19 U.S.C. § 1671. Petitioner also alleges that these unfairly traded imports have materially injured the U.S. domestic industry producing FSS and threaten to cause further material injury if remedial action is not taken. These Petitions contain information reasonably available to

Petitioner in support of these allegations.

Separate volumes regarding the allegations of dumping by producers in each subject country, as well as countervailable subsidies provided to producers in these countries, are being filed simultaneously at both the U.S. Department of Commerce (the "Department") and the U. S.

International Trade Commission (the "Commission"). Petitioner requests that antidumping

("AD") and countervailing duties ("CVD") be imposed to offset the dumping margins and subsidy rates detailed in the specific AD and CVD volumes.

I. COMMON ISSUES

This section contains information required in AD and CVD petitions by 19 C.F.R.

§§ 351.202(b)(1) to 351.202(b)(9) and 19 C.F.R. § 207.11.

A. Contact Information for the Petitioner (19 C.F.R. § 351.202(b)(l)

Petitioner was established in 1921 to serve the- structural steel industry in the United

States and is the primary trade association for domestic FSS producers. Petitioner is a domestic

Filed By: [email protected], Filed Date:1 2/1/19 6:12 PM, Submission Status: Approved Barcode:3789316-02 A-570-102 INV - Investigation - RANGED DATA PUBLIC VERSION interested party within the meaning of 19 U.S.C. § 1677(9)(E) and 19 C.F.R. § 351.102(b)(17).

Petitioner's contact information is provided in Exhibit 1-1.

B. Identity of the Industry on Whose Behalf the Petitions are Filed (19 C.F.R. § 207.11(b)(2)(ii);19 C.F.R. § 351.202(b)(2))

These Petitions are filed on behalf of the U.S. industry that produces FSS. Exhibit 1-2 contains contact information for known U.S. producers of FSS. According to the best information available to Petitioner, Exhibit 1-2 identifies all known producers of the domestic like product in the United States. 1

C. Information Relating to the Degree of Industry Support for the Petition (19 C.F.R. § 351.202(b)(3»

According to 19 U.S.C. §§ 1671a(c)(4)(A) and 1673a(c)(4)(A), a petition is filed by or on behalf of the domestic industry if: (l) domestic producers who support the petition account for at least 25 percent of the total production of the domestic like product, and (2) domestic producers who support the petition account for more than 50 percent of the production of the domestic like product produced by that portion of the industry expressing support for or opposition to the petition. Petitioner meets both requirements with respect to each Petition at issue here.

There are no publicly available sources regarding U.S. production of FSS. However,

Petitioner has estimated U.S. production based on the quantity of shipments of steel mill products, the primary input into FSS. Specifically, as detailed in Exhibit 1-3, Petitioner based its calculation on U.S. shipments of parallel flanges [

Exhibit 1-2 contains [

Filed By: [email protected], Filed Date:2 2/1/19 6:12 PM, Submission Status: Approved Barcode:3789316-02 A-570-102 INV - Investigation - RANGED DATA PUBLIC VERSION

]. Petitioner then made various adjustments to account for parallel

flanges that are not fabricated and/or are not used for the production of FSS and to account for other steel mill products that are used in the production of FSS. Petitioner believes that this methodology constitutes the best information reasonably available to Petitioner to identify the total quantity of production of the domestic like product. Based on this methodology, Petitioner estimates that, in 2017, the total quantity of U.S. shipments of the domestic like product was

3,418,290 short tons.

Petitioner's estimate of its share of total U.S. shipments of the domestic like product is shown below in Table 1. This represents the quantity of U.S. shipments for full members of

AISC. As explained in Exhibit 1-4, these data were obtained from [

TABLE 1 Petitioner's Share Of Domestic Production In 2017 (short tons)

Domestic Production 3,418,290 Supporters' Production [ -\-0",; ] Supporters' Share [ &/6 ]

As shown in the table above, Petitioner represents U.S. producers accounting for approximately

[ ] percent of domestic production of the domestic like product in 201 7. Petitioner therefore satisfies the requirement that they account for over 50 percent of total domestic production.

Filed By: [email protected], Filed Date:3 2/1/19 6:12 PM, Submission Status: Approved Barcode:3789316-02 A-570-102 INV - Investigation - PUBLIC VERSION

D. Previous Requests for Import Relief for the Merchandise (19 C.F.R. § 351.202(b)(4»

1. AD/CVD Litigation

In January 1988, a petition was filed on behalf of AISC alleging that an industry in the

United States was materially injured by dumped imports of fabricated structural steel from

Canada.' The Commission made a preliminary finding that there was no reasonable indication of material injury or threat thereof and thus no order was issued.' Petitioner is not aware of any other requests for antidumping and/or countervailing duties by the domestic industry with respect to FSS.

2. Other Forms of Relief

Pursuant to Section 301 of the Trade Act of 1974, on August 16, 2018, the U.S. Trade

Representative determined that it was appropriate to impose an ad valorem duty of 25 percent on various products from China, including some fabricated structural steel.4 Specifically, the 25 percent duty applies to the following tariff lines in the U.S. Harmonized Tariff Schedule

("HTSUS") under which FSS may enter the United States: 7308.90.30, 7308.90.60, and

7308.90.95.5 These tariffs became effective as of August 23,2018.6

In addition, certain HTSUS subcategories under which FSS may enter the United States are subject to ad valorem duties of 25 percent pursuant to Section 232 of the Trade Expansion

2 See Certain Fabricated Structural Steelfrom Canada, Inv. No. 731-TA-387, USITC Pub. 2062 (Feb. 1988) (Prelim.) at 1, excerpts attached as Exhibit 1-5. Id. at 1.

4 See Notice of Action Pursuant to Section 301: China's Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation, 83 Fed. Reg. 40,823 (Dep't Commerce Aug. 16,2018). Id. at 40,826. Id. at 40,823.

Filed By: [email protected], Filed Date:4 2/1/19 6:12 PM, Submission Status: Approved Barcode:3789316-02 A-570-102 INV - Investigation - PUBLIC VERSION

Act of 1962. Specifically, the following HTSUS subcategories under which FSS may enter the

United States are subject to duties under Section 232: 7216.99.0010, 7216.99.0090, and

7228.70.6000. These duties became effective as of March 23, 2018.7 AISC participated in the process through which interested parties could provide comments regarding the products to be

subject to duties.

E. Scope of the Investigation and a Detailed Description of the Subject Merchandise (19 C.F.R. § 351.202(b)(5))

1. Scope of Investigation

The physical characteristics of the covered products, which defines the scope, are as follows:8

The merchandise covered by this investigation includes carbon and alloy (including stainless) steel products such as angles, columns, beams, girders, plates, flange shapes (including manufactured structural shapes utilizing welded plates as a substitute for rolled wide flange sections), channels, hollow structural section (HSS) shapes, base plates, plate-work components, and other steel products that have been fabricated for assembly or installation into a structure (fabricated structural steel). Fabrication includes, but is not limited to, cutting, drilling, welding, joining, bolting, bending, punching, pressure fitting, molding, adhesion, and other processes. Fabricated structural steel products included in the scope of this investigation are products in which: (1) iron predominates, by weight, over each of the other contained elements; and (2) the carbon content is two percent or less by weight. Fabricated structural steel is covered by the scope of the investigation regardless of whether it is painted, varnished, or coated with plastics or other metallic or non-metallic substances. Fabricated structural steel may be either assembled; disassembled, but containing characteristics or items, such as holes, fasteners, nuts, bolts, rivets, screws, tongue and grooves, hinges, or joints, so that the product(s) may be joined, attached, or assembled to one or more additional

7 Proclamation 9705, Adjusting Imports of Steel into the United States, 83 Fed. Reg. 11,625 (Mar. 15,2018). The scope of this investigation includes certain exclusions that reference certain standards and specifications. These exclusions are based on the identified specifications and standards as they exist as of the filing of this Petition.

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product(s); or partially assembled, such as into modules, modularized construction units, or sub-assemblies of fabricated structural steel. Products under investigation include carbon and alloy steel products that have been fabricated for erection or assembly into structures, including but not limited to, buildings (commercial, office, institutional, and multi-family residential); industrial and utility projects; parking decks; arenas and convention centers; medical facilities; and ports, transportation and infrastructure facilities. Subject merchandise includes fabricated structural steel that has been assembled or further processed in the subject country or a third country, including but not limited to painting, varnishing, trimming, cutting, drilling, welding, joining, bolting, punching, bending, beveling, riveting, galvanizing, coating, and/or slitting or any other processing that would not otherwise remove the merchandise from the scope of the Investigation if performed in the country of manufacture of the fabricated structural steel. Fabricated structural steel may be attached, joined, or assembled with non-steel components at the time of importation. The inclusion, attachment, joining, or assembly of non-steel components with fabricated structural steel does not remove the fabricated structural steel from the scope. All products that meet the written physical description are within the scope of this investigation unless specifically excluded. Specifically excluded from the scope of this investigation is certain fabricated steel concrete reinforcing bar ("rebar"). Fabricated rebar is excluded from the scope only if (i) it is a unitary piece of fabricated rebar, not joined, welded, or otherwise connected with any other steel product or part; or (ii) it is joined, welded, or otherwise connected only to other rebar. Also excluded from this scope is fabricated structural steel used for bridges and bridge sections. For the purpose of this scope, fabricated structural steel used for bridges and bridge sections is defined as fabricated structural steel that is used in bridges and bridge sections and that conforms to American Association of State and Highway and Transportation Officials ("AASHTO") bridge construction requirements or any state or local derivatives of the AASHTO bridge construction requirements. Also excluded from this scope are pre-engineered metal building systems. For the purposes of this scope, pre-engineered metal building systems are defined as complete metal buildings that integrate steel framing, roofing and walls to form one, pre-engineered building system and are designed and manufactured to Metal Building Manufacturers Association guide specifications. Pre-engineered metal building systems are typically limited in height to no more than 60 feet or two stories. Also excluded from this scope are steel roof and floor decking systems designed and manufactured to Steel Deck Institute standards.

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Also excluded from the scope are open web steel bar joists and joist girders that are designed and manufactured to Steel Joist Institute specifications. The products subject to the investigation are currently classified in the Harmonized Tariff Schedule of the United States (HTSUS) under subheadings: 7308.90.9590, 7308.90.3000, and 7308.90.6000. The products subject to the investigation may also enter under the following HTSUS subheadings: 7216.91.0010, 7216.91.0090, 7216.99.0010, 7216.99.0090, 7228.70.6000, 7301.10.0000, 7301.20.1000, 7301.20.5000, 7308.40.0000, 7308.90.9530, and 9406.90.0030. The HTSUS subheadings above are provided for convenience and customs purposes only. The written description of the scope of the investigation is dispositive.

2. Technical Characteristics and Uses

As FSS is typically custom-manufactured for a specific project, FSS produced for one project will differ from FSS produced for another project. Nonetheless, all FSS consists of steel mill products, such as angles, columns, beams, plates, hollow structural shapes, channels, and other steel products, that have been fabricated into articles suitable for erection or assembly into a variety of structures." Typical fabrication processes include, cutting, drilling, welding, joining, bolting, bending, punching, pressure fitting, molding, adhesion, and other finishing processes.

Additionally, all FSS is intended to provide structural support and ensures that the structure can bear certain loads or weight. FSS is used in constructing a variety of structures, including buildings (commercial, office, institutional, and multi-family residential), industrial and utility projects, parking decks, arenas and convention centers, medical facilities, and ports, transportation and infrastructure facilities.

Petitioner does not intend to include in the scope steel mill products that are punched, drilled, or undergo similar processes solely for transportation, handling, or other non-structural purposes.

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3. Production Methodology

The production of FSS is typically done on a project-specific basis following a bidding process through which a bid is awarded to a FSS producer or group of producers. During this process, design and architectural plans are developed and agreed upon between the FSS producer and the contracting party. Once plans are finalized, the FSS producer will commence actual production work to fulfill the terms of the project. This entails the procurement of steel mill inputs, including structural steel such as wide flange beams, steel angles, steel channels, cut-to• length steel plate, hollow structural shapes, support materials (including steel nuts and bolts, steel studs, steel rivets, galvanized steel strand, and steel rope), welding process materials (including cutting gases, welding wire, welding gases, and welding fluxes), and other required material inputs (including galvanizing materials, protective paints and lacquers, insulating and thermal breaks, and lubricating oils).

Based upon the architectural blueprints and drawings, highly skilled welders, crane operators, and machine operators will then fabricate the various inputs and convert them to FSS through processes such as cutting operations, welding operations, drilling and punching operations, bending operations, painting and galvanizing operations, and partial assembly operations to the extent practicable at the FSS producer's production facilities. Some of the work is performed through the assistance of mechanized and automated machinery while other steps must be partially or wholly performed by hand. Once each component of FSS has been manufactured, it is prepared for shipment to a marshalling yard or to the job erection site itself or stored until shipment.

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4. Tariff Classification

FSS is currently classified under the following HTSUS subheadings: 7308.90.9590,

7308.90.3000, and 7308.90.6000. FSS may also enter under the following HTSUS subheadings:

7216.91.0010, 7216.91.0090, 7216.99.0010, 7216.99.0090, 7228.70.6000, 7301.10.0000,

7301.20.1000, 7301.20.5000, 7308.40.0000, 7308.90.9530, and 9406.90.0030.

Although the HTSUS subheadings are provided for convenience and u.s. Customs

purposes, the written description of the merchandise under investigation is dispositive. Excerpts

from the current HTSUS are attached as Exhibit 1-6. The most favored nation duty rate for

imports under these HTSUS subheadings is free for all HTSUS subheadings except

9406.90.0030, which has an ad valorem rate of 2.9 percent. The tariff numbers are provided for

the convenience of the U.S. Government and do not define the scope of the Petitions.

F. Names of the Subject Countries and the Name of Any Intermediate Country Through Which the Merchandise Is Transshipped (19 C.F.R. § 351.202(b)(6»

FSS covered by these Petitions is manufactured in and exported to the United States from

Canada, China, and Mexico. Petitioner does not have any evidence indicating that the subject

merchandise is produced in a country other than that from which it is exported.

G. Names and Addresses of Each Person Believed to Sell the Merchandise at Less than Normal Value and the Proportion of Total Exports to the United States (19 C.F.R. § 351.202(b)(7)(i)(A»

The names and addresses of the entities believed by Petitioners to be producing and

exporting FSS subject to these Petitions are provided in Exhibit 1-7. In compiling this exhibit,

Petitioner relied primarily upon import data and information regarding producers of FSS that have received certifications from AISC, as well as upon the web sites of individual producers.

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Information reasonably available to Petitioner does not allow it to identify the proportion

of total exports to the United States accounted for during the most recent 12-month period by the

producers listed in this exhibit. Petitioner believes, however, that the companies listed in

Exhibit 1-7 account for the vast majority of subject exports.

H. All Factual Information Related to the Calculation of Export Price, the Constructed Export Price of the Subject Merchandise, and the Normal Value of the Foreign Like Product for Market Economy Countries (19 C.F.R. § 351.202(b)(7)(i)(B»

Volumes II and III of these Petitions contain the necessary information concerning the calculation of normal value of the foreign like product and the export price for merchandise produced and exported from the subject countries that are market economies.

I. Factual Information Related to the Calculation of Normal Value of the Foreign Like Product in Non-Market Economy Countries (19 C.F.R. § 351.202(b)(7)(i)(C»

China is the only non-market economy covered by these investigations. Volume IV of these Petitions contains information necessary to substantiate less-then-normal-value allegations and factual information relevant to China.

J. The Names and Addresses of Each Person Believed to Benefit from a Countervailable Subsidy Who Exports the Subject Merchandise to the United States and the Proportion of Total Export to the United States (19 C.F.R. § 351.202(b )(7)(ii)(A»

Volumes V, VI, and VII of these Petitions contain the necessary information regarding the countervailable subsidies from which subject producers benefit. The names and addresses of the entities believed by Petitioner to be benefitting from a countervailable subsidy and who have exported FSS subject to these Petitions are provided in Exhibit 1-7. Information reasonably available to Petitioner does not allow it to identify the proportion of total exports to the United

States accounted for during the most recent 12-month period by the producers listed in this

Filed By: [email protected], Filed Date:10 2/1/19 6:12 PM, Submission Status: Approved Barcode:3789316-02 A-570-102 INV - Investigation - PUBLIC VERSION exhibit. Petitioner believes, however, that the companies listed in Exhibit 1-7 account for the vast majority of subject exports.

K. The Alleged Countervailable Subsidy and Factual Information Relevant to the Alleged Countervail able Subsidy (19 C.F.R. § 351.202(b)(7)(ii)(B»

Volumes V, VI, and VII of these Petitions contain information concerning the alleged countervailable subsidies in the subject countries, as well as factual information relevant to the laws, regulations, and decrees under which the subsidies were bestowed, the manner in which the subsidies were granted, and Petitioner's estimation-to the extent practicable-of the value of the subsidies to the subject producers and exporters ofFSS.

L. The Volume and Value of the Merchandise Imported During the Most Recent Two-Year Period (19 C.F.R. § 351.202(b)(8»

Subject imports totaled 928,997 short tons in 2016 and 949,578 short tons in 2017.

Imports totaled 810,081 short tons from January to October 2017 and 898,927 short tons from

January to October 2018.10 By value, imports from the subject countries into the United States was $1,856,642,982 in 2016 and $1,906,548,603 in 2017.11 The value of imports in the period of

January to October 2017 was $1,605,481,975 and $1,923,802,787 in January through October of

10 See Official U.S. Import Statistics, attached at Exhibit 1-8. Subject imports have been measured based on data obtained from the U.S. International Trade Commission's Dataweb system for the following group of three HTSUS categories: 7308.90.3000, 7308.90.6000, and 7308.90.9590. the domestic industry believes that these HTSUS categories account for the vast majority of the FSS entering the United States. Additionally, these HTSUS categories are limited to FSS. The domestic industry recognizes that FSS may enter the United States under additional HTSUS categories; however, these categories also capture additional, non-FSS materials. Import data for the broader group ofHTSUS categories has also been provided in Exhibit 1-8. As can be seen, the import trends for the broader group ofHTSUS categories is consistent with that of the narrower group. In addition, import data have been converted from kilograms to short tons. 11 See id.

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2018Y These are the best data available to Petitioner. As discussed below, subject imports also increased on a relative basis from 2015 to 2017.

M. Contact Information for Each Entity the Petitioner Believes Imports or Is Likely to Import the Subject Merchandise (19 C.F.R. § 207.11(b)(2)(iii); 19 C.F.R. § 351.202(b)(9»

Contact information for known importers of FSS from the subject countries is listed in

Exhibit 1-9.13 However, Petitioner believes that there may be additional importers for FSS from the subject countries that could not be readily identified by Petitioner. Therefore, Petitioner respectfully requests that the Department obtain this information from u.s. Customs and Border

Protection.

II. MATERIAL INJURY, CAUSATION, AND THREAT

A. Introduction

A surge of dumped and subsidized FSS imports from Canada, China, and Mexico has materially injured the domestic industry and threatens the u.s. industry with further injury.

Between 2015 and 2017 ("the POI"),14 the volume of subject imports grew significantly, increasing by more than 20 percent, greatly outpacing the modest growth in apparent domestic consumption. As a result, subject producers increased their already significant share of the market at the direct expense of the domestic industry. This flood of dumped and subsidized FSS

12 Id. 13 In particular, Petitioner was able to obtain shipment information with respect to [

14 Petitioner intended to submit this petition on December 31, 2018, and the period examined in this volume, as well as in the volumes of this petition examining the level of dumping by and subsidization of FSS from Canada, China, and Mexico, is based on that filing date. However, due to extraordinary circumstances relating to the closure of the Federal Government on December 21, Petitioner was unable to file this petition on December 31. Petitioner is filing this petition promptly following the reopening of the Federal Government.

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During this time, subject imports also had significant negative price effects on the U.S. market. Subject producers were able to expand their presence in the U.S. market by offering unfair prices well below those of domestic producers, forcing U.S. prices down. This has placed domestic producers in the untenable position of maintaining sales for little to no profit or losing sales altogether. The domestic industry has reported numerous instances in which the prices of subject imports were well below U.S. producers' costs, resulting in [ \)0...\\)'- ] of lost sales and revenue for the domestic industry during the PO I.

The negative impact that the large volume of unfairly-traded subject imports had on U.S. producers is evident from the domestic industry's plummeting financial performance during the

POI. Virtually all of the domestic industry's trade and financial indicia declined during the POI, as subject imports surged into the market, undersold domestic producers by substantial margins, and depressed and suppressed U.S. prices. The causal link between subject imports and the domestic industry's deteriorating performance is corroborated by the [ \) CA.\.vt..- ] of sales and revenue lost due to low-priced subject imports. With a loss in sales and market share and downward pressure on pricing, the available data show that the domestic industry's operating income fell by [ ] percent and net income fell by [ ] percent between 2015 and 2017.15 The deterioration of the domestic industry's performance continued in the first half of2018, with U.S.

15 The Domestic Industry's Trade and Financial Data, attached as Exhibit I-10, are based on data provided by [ t-.> (,\,'('( CA.~ VC-- ]. These [ 10..) Cl-Y" (C\..""-.: ~

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producers' net income margin remaining below the already low levels experienced in 2015 and

2016, and sales and production on track to remain far below 2015 and 2016 levels." Thus, the

domestic industry has suffered, and continues to suffer, material injury by reason of subject

imports.

Subject imports also threaten the domestic industry with further material injury.

Significant volumes of low-priced subject imports adversely affected the domestic industry

during the POI, resulting in domestic producers operating at unsustainably low margins and

leaving the industry highly vulnerable to additional injury. The significant increase in subject

imports during the POI demonstrates subject producers' ability to enter the u.S. market quickly

and in large quantities. Additionally, significant underselling by subject imports and the

resulting loss of massive volumes of sales by u.S. producers demonstrate the negative price

effects of subject imports on the u.S. market. Moreover, subject producers have the capacity and

ability to further increase exports to the United States, and market conditions-namely the global

oversupply of steel and the imposition of duties on upstream products-will encourage subject

producers to do so. Given these factors, subject imports will cause additional injury to the

domestic industry.

B. The Domestic Like Product Consists of FSS Covered by the Scope

In determining whether an industry in the United States is materially injured or threatened

with material injury by reason of subject imports, the Commission first defines the domestic like product. 17 The "domestic like product" is defined as "a product which is like, or in the absence

16 Id.

17 See NEC Corp. v. Dep 't Commerce, 36 F. Supp. 2d 380,382 (Ct. Int'l Trade 1998).

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of like, most similar in characteristics and uses with, the article subject to an investigation .... ,,18

In an investigation, the like product determination is a factual one made on a case-by-case basis." In making this determination, the Commission generally considers the following factors:

(1) physical characteristics and uses; (2) interchangeability; (3) channels of distribution;

( 4) customer and producer perceptions of the products; (5) common manufacturing facilities, production processes and production employees; and, where appropriate, (6) price.i" In evaluating these factors, the Commission looks for clear dividing lines and disregards minor variations."

The Commission should find that there is a single domestic like product co-extensive with the scope. In particular, the Commission should find that fabricated structural steel used for bridges and bridge sections, which is expressly excluded from the scope, is not included in the domestic like product. In this regard, Petitioner notes that, in the prior investigation regarding fabricated structural steel, the Commission found that fabricated structural steel for bridges was not included in the domestic like product covering fabricated structural steel for buildings.F In that proceeding, the Commission explained that "the record supported a finding that FSS for bridges differs from FSS for buildings with regard to weight and size, use, and customer and producer perceptions and to some extent the materials from which it is made. In addition, the two kinds of FSS are generally produced in different facilities.Y' In the subject proceeding, the

18 19 U.S.c. § 1677(10). 19 See, e.g., NEC Corp., 36 F. Supp. 2d at 383. 20 See Cleo Inc. v. United States, 501 F.3d 1292 (Fed. Cir. 2007). 21 Id. at 1292, 1295. 22 See USITC Pub. 2062 at 5-6, excerpts attached as Exhibit 1-5. 23 Id.

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Commission should again make this determination, i. e., that the domestic like product is coextensive with the scope and does not include fabricated structural steel used for bridges and bridge sections.

C. There Is a Single Domestic Industry Consisting of All DomesticProducers

Section 771(7)(4) of the Act defines the domestic industry as the domestic "producers as a whole of a domestic like product, or those producers whose collective output of a domestic like product constitutes a major proportion of the total domestic production of the product.Y" The

Commission should find that there is a single domestic industry composed of entities producing

FSS. In this regard, Petitioner notes that, to the extent a company performs erection or other on- site services, such services should not be considered the production ofFSS. As discussed above, the merchandise is shipped to the job site for eventual erection after FSS components have been manufactured. Thus, erection companies should not be included in the domestic industry as they do not manufacture the domestic like product, but instead assemble it after it has been produced.

D. Subject Imports Are Causing Material Injury to the DomesticIndustry

In determining whether a domestic industry is experiencing present material injury caused by unfairly traded imports, the Commission is directed by law to consider:

(1) the volume of imports of the subject merchandise;

(2) the effect of imports of that merchandise on prices in the United States for domestic like products, and

(3) the impact of imports of such merchandise on domestic producers of domestic like products.f

24 19 U.S.C. § 1677(4)(A). 25 Id. § 1677(7)(B).

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As demonstrated below, the evidence bearing upon these factors shows that the domestic

FSS industry is suffering from material injury by reason of subject imports.

1. All Subject Imports Should Be Cumulated

For purposes of evaluating the volume and price effects for a material injury determination, 19 U.S.C. § 1677(7)(G)(i) requires the Commission to cumulate subject imports from all countries as to which petitions were filed on the same day, if such imports compete with each other and with the domestic like product in the u.s. market." In assessing whether subject imports compete with each other and with the domestic like product, the Commission generally considers four factors:

(l) the degree of fungibility between subject imports from difference countries and between subject imports and the domestic like product, including consideration of specific customer requirements and other quality-related questions;

(2) the presence of sales or offers to sell in the same geographic markets of subject imports from different countries and the domestic like product;

(3) the existence of common or similar channels of distribution for subject imports from different countries and the domestic like product; and

(4) whether the subject imports are simultaneously present in the market.27

While no single factor is necessarily determinative, and the list of factors is not exhaustive, these factors are intended to provide the Commission with a framework for

26 Id. § 1677(7)(G)(i). None of the exceptions to cumulation apply. Id. at § 1677(7)(G)(ii).

27 See Certain Cast-Iron Pipe Fittings from Brazil, the Republic of Korea, and Taiwan, Inv. Nos. 731-T A- 278-280, USITC Pub. 1845 (May 1986) (Final), aff'd, Fundicao Tupy, S.A. v. United States, 678 F. Supp. 898 (Ct. Int'} Trade 1988), aff'd, 859 F.2d 915 (Fed. Cir. 1988).

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determining whether the subject imports compete with each other and with the domestic like product. 28 Only a "reasonable overlap" of competition is required. 29

a. Imports from All Subject Countries Are Fungible

FSS are customized products produced for a specific project and, with few exceptions, no two projects are exactly alike. Accordingly, FSS manufactured for one project would not be interchangeable with FSS manufactured for another project, regardless of where the FSS was manufactured. Nonetheless, FSS from Canada, China, and Mexico are still fungible with each other and with the domestic like product. As an initial matter, all FSS consists of steel mill products that have been fabricated into articles suitable for erection or assembly into a structure.

In addition, as discussed above, FSS is typically sold through a bidding process. During the POI,

FSS producers in Canada, China, and Mexico, as well as in the United States, bid on many of the same projects. That bids were solicited from producers in the subject counties and in the United

States for the same projects demonstrates that FSS produced in the subject countries and in the

United States are fungible.'?

b. All Subject Imports Compete in the Same Geographic Market

The record here will show that imports from each of the subject countries compete with imports from the other subject countries and with the ~omestic like product throughout the U.S.

28 See, e.g., Wieland Werke A.G. v. United States, 718 F. Supp. 50 (Ct. Int'l Trade 1989).

29 Uruguay Round Agreements Act, Statement of Administrative Action, H.R. Doc. No. 103-316, vol. I at 84 (1994) ("SAA") (stating that "the new section will not affect current Commission practice under which the statutory requirement is satisfied if there is a reasonable overlap of competition."); see Goss Graphic Sys., Inc. v. United States, 33 F. Supp. 2d 1082, 1087 (Ct. Int'l Trade 1998) ("{C}umulation does not require two products to be highly fungible"); Wieland Werke A.G., 718 F. Supp. at 52 ("Completely overlapping markets are not required").

30 See Large Newspaper Printing Presses and Components Thereof, Whether Assembled or Unassembled, from Germany and Japan, Inv. Nos. 731-TA-736 and 737, USITC Pub. 2988 (Aug. 1996) (Final) at 26 ("The fact that purchasers solicited detailed initial bids from both German and Japanese producers as well as domestic

Filed By: [email protected], Filed Date:18 2/1/19 6:12 PM, Submission Status: Approved Barcode:3789316-02 A-570-102 INV - Investigation - PUBLIC VERSION market. As is evident from the sales and revenue lost by the domestic industry, subject imports compete with each other and with the domestic like product across the United States. Indeed, subject imports often travel substantial distances after entering the United States to be delivered to a project site; thus, for example, FSS produced in Canada may enter the United States at the

Canadian-U.S. border and then be transported to a site in Texas, and Mexican FSS may enter the

United States at the Mexican-U.S. border and be transported to a site in New York. Moreover, official import statistics show that, during the POI, FSS imports from Canada, China, and

Mexico entered the United States in ports throughout the United States, with imports from the subject countries overlapping at various ports of entry, further demonstrating that subject imports compete in the same geographic markets."

c. Subject Imports Are Sold Through the Same Channels of Distribution

Subject imports from each subject country and the domestic like product are sold through the same channels of distribution. The vast majority of FSS, regardless of whether it is imported or manufactured in the United States, is sold through a bidding process. Through this process, a customer issues a request for proposal for a specific project, receives bids from various producers, and awards the bid to a particular producer. This bidding process is the same regardless of where the FSS is manufactured, and subject producers have competed with each other and with domestic producers ofFSS for the same projects.

producers ... indicates to us that purchasers perceived a reasonable degree of fungibility among various producers' presses at the initial bid stage."). 31 Official U.S. Import Statistics, attached as Exhibit 1-8.

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d. Subject Imports Were Simultaneously Present in the U.S. Market

Information reasonably available to Petitioner demonstrates that Canadian, Chinese, and

Mexican FSS were simultaneously present in the U.S. market throughout the POI. Specifically, official import statistics show that imports from each subject country entered the United States in every single month from January 2015 through October 20 18 (the latest month for which data are availablej.F

e. Conclusion

Substantial quantities of FSS imports from Canada, China, and Mexico, as well as FSS produced in the United States, were present across the United States and throughout the POI.

Most all FSS, regardless of where it is produced, is sold through a bidding process, and subject imports from each country compete with each other and with the domestic like product for the same bids. Thus, the record shows that subject imports from each country compete with each other and with the domestic like product. Therefore, the Commission should cumulate subject imports for purposes of its material injury analysis.

2. The Volume of Subject Imports Is Significant

a. Substantial and Increasing Volumes of Subject FSS Imports Are Entering the United States

During the POI, significant quantities of FSS imports from Canada, China, and Mexico entered the United States. Between 2015 and 2017, subject imports grew by 21 percent, increasing from 783,641 short tons to 949,578 short tons.P As a result, by 2017, subject imports

32 Id.

33 Id.

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captured 20 percent of the market." This surge in imports has continued in 2018. From January

through October of 2018 (the most recent import data available), subject imports reached

898,927 short tons, an increase of 11 percent compared to the same period in 2017.35

b. Subject Imports Have Gained Market Share at the Direct Expense of the Domestic Industry

Subject imports have also increased relative to consumption, capturing market share

directly from the domestic industry. During the POI, while subject imports surged, apparent

domestic consumption grew by only 7.9 percent." As a result, subject imports were able to

increase their already significant share of the market, growing from 18.5 percent in 2015 to 20.4

percent in 2017.37 This increase came at the direct expense of the domestic industry, which saw

its market share decrease by a corresponding amount during the POI.

These data establish that the volume of subject imports and the increase in imports was

significant both absolutely and on a relative basis."

34 Market Share Analysis, attached as Exhibit 1-3. 35 Official U.S. Import Statistics, attached as Exhibit 1-8. 36 Market Share Analysis, attached as Exhibit 1-3. 37 Id.

38 See, e.g., 1,1, 2-Tetrafluoroethane (R-134a)from China, Inv. No. 731-TA-1313, USITC Pub. 4679 (Apr. 2017) (Final) at 14 (finding the volume of and increase in subject imports significant absolutely and relative to consumption where subject imports' market share increased from 19.3% to 21.9%); Stainless Steel Sheet and Strip from China, Inv. Nos. 701-TA-557 and 731-TA-1312, USITC Pub. 4676 (Mar. 2017) (Final) at 15-16 (finding the volume of and increase in subject imports significant in absolutely and relative to consumption where such imports captured 3.3% to 7.4% of the market); Common Alloy Aluminum Sheetfrom China, Inv. Nos. 701-TA-591 and 731- TA-1399 (Preliminary), USITC Pub. 4757 (Jan. 2018) (Prelim.) at 20-21 (finding the volume of and increase in subject imports significant absolutely and relative to consumption where market share increased from 11.0% to 15.3%); Heavy Walled Rectangular Welded Carbon Steel Pipe and Tubes from Korea, Mexico, and Turkey, Inv. Nos. 701-TA-539 and 731-TA-1280-1282, USITC Pub. 4633 (Sept. 2016) (Final) at 21 (finding the volume of subject imports significant where subject imports' market share ranged from 8.1 percent to 10. 7 percent).

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c. All Imports Are Non-Negligible

The Commission will consider imports from a subject country to be negligible if they account for less than three percent of total imports of the merchandise under consideration, or four percent for developing countries subject to a countervailing duty investigation." The

Commission may make its determination using "reasonable estimates on the basis of available statistics.T'" The Commission may rely on official import statistics, questionnaire data, or some combination of sources." In assessing negligibility, the Commission will examine "the most recent 12-month period for which data are available that precedes the filing of the petition.t'f

The most recent 12-month period for which data are available is November 2017 through

October 2018. As shown in Table 2, the official import data establishes that, during this period, imports from each subject country exceeded the negligibility threshold.

TABLE 2 u.s. Imports OfFSS From November 2017 - October 201843

Quantity (Short Tons) % of Total Canada 255,866 20.1% China 481,887 37.9% Mexico 300,680 23.6% All Others 234,453 18.4% Total 1,272,886 100%

39 19 U.S.C. §§ 1677(24)(A)(i), (B).

40 Certain Oil Country Tubular Goods from India, Korea, the Philippines, Taiwan, Thailand, Turkey, Ukraine, and Vietnam, Inv. Nos. 701-TA-499-500 and 731-TA-1215-1217 and 1219-1223, USITC Pub. 4489 (Sept. 2014) (Final) at 16.

41 See, e.g., Certain Cold-Rolled Steel Products from Argentina, Brazil, Japan, Russia, South Africa, and Thailand, Inv. Nos. 701-T A-393 and 731-T A-829-830, 833-834, 836, and 838, USITC Pub. 3283 (Mar. 2000) (Final) at 8. 42 19 U.S.c. § 1677(24)(A)(i). 43 Official U.S. Import Statistics, attached as Exhibit 1-8.

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3. The Price Effects of Subject Imports Is Significant

Dumped and subsidized FSS imports have had significant negative price effects on the domestic industry. Throughout the POI, subject producers undersold the domestic like product by large margins, forcing domestic manufacturers to lower their sales prices, lose sales, or both.

This aggressive pricing by subject producers is particularly harmful given the nature of the FSS industry. Demand for FSS is based on the existence of new projects that require FSS. The vast majority ofFSS is sold through a bidding process, through which a customer issues a request for proposal for a specific project." The customer will receive bids from various FSS producers, frequently engage in negotiations resulting in new bids, and award the bid to a particular company.

During this process, price is the primary factor considered by customers in determining to whom a bid is awarded.f So long as a bid meets the customer's technical requirements, a customer will typically select the lowest-priced bid." Price plays such an important role, in fact, that there have been instances where a U.S. producer has been awarded a bid only for it to be later pulled back because a subject producer has subsequently offered an even lower price.

44 See Structural Steel: An Industry Overview, American Institute of Steel Construction (Oct. 2017), at 6, attached as Exhibit 1-11; USITC Pub. 2062 at A-35, excerpt attached as Exhibit 1-5.

45 See Conditions of Competition Between Certain Domestic and Imported Fabricated Structural Steel Products, Inv. No. 332-181, USITC Pub. 1601 (Nov. 1984) at xiv (highlighting the "price advantage of imports as the principal determinant of overall competitive advantage in the U.S. market" and noting that "U.S. purchasers cited price as the foremost factor in electing to import foreign fabricated steel"), excerpt attached as Exhibit 1-12.

46 See Dumping and Subsidizing, Finding and Reasons, Inquiry No. NQ-2016-004 Certain Fabricated Industrial Steel Components, Canadian International Trade Tribunal (June 9, 2017) at 17 (noting that a majority of responding purchasers identified price as "very important" and finding "generally that, as {FSS} is typically purchased as part of a competitive RFQ process, price is determinative in deciding among bids that are technically compliant"), excerpts attached as Exhibit 1-13; cf Large Power Transformers from Korea, Inv. No. 731-TA-1189, USITC Pub. 4346 (Aug. 2012) (Final) at II-15 (identifying price/cost as the second most important factor behind "meeting specifications" and noting that price/cost was one of the most commonly cited top factors in purchasing decisions).

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Throughout the bidding process, purchasers will also use competing subject import prices to leverage U.S. producers' prices down.

Thus, demand for FSS relies on the existence of new projects and new bids.

Additionally, demand for FSS is highly inelastic, such that changes in price are not likely to substantially change demand for FSS in the short-term. As such, a project awarded to a subject producer, in part or in full, typically means a sale lost by a domestic producer, and if a domestic producer loses a bid, it will not have an opportunity to make another sale until a new request for proposal is issued. Additionally, many projects can be quite large; a single project can provide work for an entire facility and its employees for a year or more. Thus, losing even a single project, or even part of a project, to unfairly traded imports has an immense effect on a company's profitability and employment.'? and it may be months before another opportunity to place a bid arises. Moreover, if a U.S. producer loses a project to dumped and subsidized imports, that producer may be forced to bid on another project that it would not have otherwise bid on and, as a result, cause another U.S. producer to lose a project. Adverse price effects would likewise be transmitted throughout the market. Thus, the loss of a project to unfairly traded imports is felt throughout the industry.

a. Subject Imports Are Underselling the Domestic Like Product

During the POI, subject producers undersold domestic fabricators by significant margins.

This is evident from numerous bids placed throughout the POI in which domestic producers were forced to lower their offered prices to meet those of subject producers or, more frequently, were

47 See Dumping and Subsidizing, Finding and Reasons, Inquiry No. NQ-2016-004 Certain Fabricated Industrial Steel Components, Canadian International Trade Tribunal (June 9, 2017) at 17, excerpts attached as Exhibit 1-13.

Filed By: [email protected], Filed Date:24 2/1/19 6:12 PM, Submission Status: Approved Barcode:3789316-02 A-570-102 INV - Investigation - RANGED DATA PUBLIC VERSION simply unable to match Canadian, Chinese, and Mexican fabricators' prices and lost the sale."

For example:

• Domestic fabricator [ c.o~\. ] explained with respect to its bid on the ,..:> C>/'(C-A "'\L• ]-a project that was ultimately awarded to a Chinese company-"[ }..>CNIV"~\JIl-

• With respect to a [ }JCJ((c...-\.:."e- ], which was awarded to a Chinese company, U.S. producer [ C.OM.~Y"'''''\. ] explained that "[ IV ~(tA~vt...

• A recent proj ect, the [ ~ c.x(C). ~VL awarded to a Canadian fabricator whose bid was approximately ], below that of U.S. fabricator [ COt'\~,\ ].51

• U.S. producer [&~~\. ] reported losing the [JV~'\..~ ] project to a Canadian fabricator whose bid was almost [ u~",.v-] below the domestic fabricator's price. 52

• [C.6(Y\?CoV'I>~ ] reported that, in bidding on a [J.:jvl'("tA,\...vI-- ], the winning company, a Mexican fabricator, bid at approximately [ ,,",CN'C""-tv<... ].53

48 While the Commission typically relies on pricing products to undertake its price effects analysis, in industries such as the FSS industry, where products are custom-built, and sales are based on a bidding process, the Commission has also considered bid information in its analysis. See, e.g., USITC Pub. 4346 at 18; USITC Pub. 2988 at 29-31. 49 ], attached as Exhibit 1-14. 50 ], attached as Exhibit 1-15.

51 Lost Sales and Revenue Data, attached as Exhibit 1-16. Pursuant to 19 C.F.R. § 207.11(b)(2)(v), Petitioner has provided information on lost sales and lost revenue that is reasonably available to it. This information is also being submitted electronically as required by the Commission's regulations. 52 Lost Sales and Revenue Data, attached as Exhibit 1-16. 53 Id.

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These experiences are not unique. Indeed, numerous other domestic fabricators report being underbid by subject producers by significant amounts." This is evident from the massive volume-more than [ \)C\.\..vt-- ]-of sales and revenue lost due to lower priced offerings from subject producers from 2015 through the first three quarters of2018.55

b. Low-Priced Subject FSS Imports Force Domestic Producers to Lower Prices

Due to significant underselling by subject producers during the POI, the domestic industry was forced to reduce its prices to compete with subject imports. The domestic industry reports numerous instances of being forced to lower bids in the face of subject import competition in order to win projects during the POl.56 The price depressing and suppressing effects of subject imports are shown by the decline in the domestic industry's unit gross profit during the POI, as domestic producers were forced to lower prices to compete with subject imports. 57 However, even where a domestic producer lowered its bid price, subject producers were frequently still able to capture the sale by dropping prices even further. Moreover, as tariffs under Section 232 and Section 301 increase the price of inputs, it will become even more difficult for U.S. producers to lower prices to compete with subject imports.

The price depressing and suppressing effects of subject imports are also evidenced by the downward trend of subject imports' and, consequently, U.S. fabricators' average unit values.

During the POI, as the average unit value of subject imports declined." the domestic industry

54 Id. 55 Id. 56 Id. 57 The Domestic Industry's Trade and Financial Data, attached as Exhibit 1-10. 58 Official u.s. Import Statistics, attached as Exhibit 1-8.

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was forced to likewise decrease prices. However, despite the fact that the average unit value of

FSS sold by domestic fabricators for whom data were collected declined by [ ] percent from

2015 to 2017, subject imports' average unit values remained well below domestic industry prices throughout the POl.59

c. Identification of Products for Which Petitioner Requests Collection of Price Data (19 C.F.R. § 207.11(b)(2)(iv»

.As discussed above, most all FSS is custom-made for a specific project that is awarded through a bid process. Petitioner recognizes that, in certain prior proceedings addressing custom- built products sold through a bidding process, the Commission has collected data on bid prices instead of traditional "pricing products.v'" Given the nature of FSS, as well as the bidding process, bid price data and traditional pricing products data both present certain limitations.

However, Petitioner believes that the way in which certain FSS is sold may allow for a usable pricing product analysis. In addition, there are challenges to obtaining the requisite information for a proper comparison of bid prices, particularly given the time constraints of the preliminary investigation. Accordingly, for the purposes of the preliminary investigation, Petitioner requests that the Commission collect pricing data on the following products for the preliminary phase of the investigation:

Product I.-Fabricated light structural,' Grade 50, 0-19 lbs. per linear foot, sold for industrial? projects.

59 Id.; The Domestic Industry's Trade and Financial Data, attached as Exhibit 1-10.

60 See, e.g., Large Power Transformer from Korea, Inv. No. 731-TA-1l89, USITC Pub. 4256 (Sept. 2011) (Prelim.) at 16, V-2 (explaining that the Commission's "conventional approach to pricing analysis" was not useful in the investigation given the custom nature of the products and the manner through which they are sold and therefore requesting that U.S. producers and importers provide data on their largest bids during the POI); USITC Pub. 2988 at 29.

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Product 2. -Fabricated medium structural,' Grade 50, 20-119Ibs. per linear foot, sold for industrial/ projects.

Product 3. -Fabricated extra heavy structural, 1 Grade 50, 120 lbs. or greater per linear foot, sold for industriaf projects.

Product 4.-Fabricated structural steel" sold for schools, libraries, labs, and hospitals, 2-4 stories.

Product 5.-Fabricated structural steel" sold for office buildings, multi-family residential buildings, and mixed-use buildings, 5-19 stories.

Product 6.-Fabricated structural steel" sold for office buildings, multi-family residential buildings, and mixed-use buildings, 20 stories and greater.

1 The term "structural" includes beams, columns, and vertical bracing.

2 The term "industrial project" includes electric power facilities; oil, gas, and refined products production, processing and storage facilities; alternative fuels facilities; petroleum refining facilities; chemical processing facilities; and metals and minerals processing facilities.

3 The term "fabricated structural steel" includes the merchandise defined in the scope of this investigation and does not include merchandise excluded from the scope.

4. The Subject Imports Have Had a Negative Impact on the Domestic Industry

The domestic industry has suffered material injury by reason of subject imports, as demonstrated by the massive volume of sales lost to subject imports, lost revenue, and depressed and suppressed U.S. prices. Subject imports have undersold domestically produced FSS, resulting in price depression and suppression, significant lost sales, and financial deterioration, as evidenced by the domestic industry's inadequate net and operating income margins that declined significantly over the POI. These data, as described in more detail below, demonstrate the causal link between the unfairly traded subject imports and the material injury being suffered by the domestic industry and show that the domestic industry would have been substantially better off but for competition from unfairly traded imports.

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a. The Domestic Industry's Production, Capacity Utilization, and Shipments Declined Due to Unfair Import Competition

As reviewed above, during the POI, subject imports entered the United States in massive and increasing volumes, despite only limited growth in apparent domestic consumption. As a result of this surge of unfairly traded imports, the domestic industry's production and shipments suffered significantly." But for the competition from large volumes of unfairly traded subject imports, the domestic industry would have been able to produce and sell substantially greater quantities of the domestic like product. This can be seen from the data collected from a sample of U.S. producers, which show a significant decline in production and U.S. shipments from 2015 to 2017, and production and shipments remained low in the first half of2018.62 Additionally, as a result of stifled sales and production, capacity utilization for the U.S. producers for whom data were collected dropped from an already low [ ] percent in 2015 to an anemic [ ] percent in

2017 and remained critically low at only [ ] percent in the first half of 2018.63 In the absence of competition from unfairly traded subject imports, the domestic industry could have increased production and operated at a substantially higher capacity utilization rate.

Notably the domestic industry has significant excess capacity that could be used to serve the U.S. market. "In fact, there is enough capacity to meet any increase in demand that results from additional investment in infrastructure projects and projected increases in private construction activity.t''" However, due to the large volumes of low-priced subject imports

61 The Domestic Industry's Trade and Financial Data, attached as Exhibit 1-10. 62 ld. 63 ld.

64 Testimony of Jeff Sterner, attached as Exhibit 1-17.

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h. Unfair Import Competition Has Caused the Domestic Industry's Financial Performance to Plummet

The financial performance of the domestic industry has also deteriorated as a result of competition with unfairly traded FSS imports. The significant presence of unfairly traded imports throughout the POI placed the domestic industry in the untenable position of losing sales to low-priced imports or lowering prices (and sacrificing profits) to maintain sales. The injury to the domestic industry caused by this choice is evident from its poor financial performance during the POI.65 Notably, the data collected from a sample of domestic producers show a significant decline in sales value, reflecting both the decline in sales quantity and price depression experienced during the POI.66 Indeed, the increasing volume oflow-priced subject imports that undercut the domestic industry's prices and took sales from U.S. producers resulted in steep declines in operating and net income. The data collected from a sample of U.S. producers show that, from 2015 to 2017, operating income dropped by [ ] percent and its net income dropped by [ ] percent. 67 Operating and net income margins likewise declined over the POI, such that the domestic industry's already low margins were at unsustainable levels by 2017.68

65 See USITC Pub. 4633 at 29 (finding material injury where the domestic industry cut prices to retain market share, resulting in a decline in revenues); Steel Concrete Reinforcing Bar from Japan and Turkey, Inv. Nos. 701-TA- 564 and 731-TA-1338 and 1340, USITC Pub. 4705 (July 2017) (Final) at 26 (noting that the domestic industry decreased prices to maintain market share and finding that "{ a} s a result of the significant volume of low prices subject imports, the domestic industry's output and revenues were lower than they would have been otherwise"). 66 The Domestic Industry's Trade and Financial Data, attached as Exhibit 1-10. 67 Id. 68 Id.

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The domestic industry continued to experience poor financial performance in the first half of 2018. Notably, in the first half of 2018, the domestic industry's operating margins remained far below the already low operating margins experienced in 2015 and 2016. Moreover, in interim 2018, numerous domestic producers experienced [ \~t,r\J ] net and operating income and/or [\(~J. ]. In addition, domestic producers have been forced to shutter FSS operations as a result of competition with unfairly traded FSS imports. For example, in [

] announced that it was closing [ 1VW'~-k\,L...- ]. Likewise,

[ ]. This deterioration in the domestic industry's financial performance was the result of increased volumes of unfairly traded subject imports.

c. The Sales and Revenues Lost to Unfairly Priced Subject Imports Are Massive

The decline in the domestic industry's sales, market share, and production is a result of unfairly traded subject imports, as confirmed by the massive volume of sales and revenue lost by domestic fabricators to' subject producers because of price. During the POI, the domestic industry lost more than ["* ] sales to subject imports and were forced to lower their bid prices for multiple other projects because of unfairly traded imports. As a result, the domestic industry experienced [ \)(4 we..... ] in lost sales and revenues.f" Between 2015 and the first three quarters of 2018, the U.S. producers from whom data were collected lost at least [\)C4.\~ ] in sales and revenue as a result of unfairly traded FSS from Canada, China, and Mexico.?? The lost sales represent projects totaling [~ ] short tons, which could have supported more than

69 Lost Sales and Revenue Data, attached as Exhibit 1-16.

70 Id.

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[~ ] U.S. jobs," and which were lost because of unfairly traded subject imports. Losses of such magnitude negatively affected the domestic industry, as can be seen in the decline in the domestic industry's production, employment, and operating and net income margins. These lost sales likewise have significant long-term effects on the domestic industry's trade and financial performance, including capacity utilization. As FSS producers will only bid on projects for which they have capacity, a lost sale results in capacity that will go unused, potentially for a significant amount of time, depending on when a producer is able to next win a bid. And the effect of these substantial lost sales and lost revenues have likely not been fully felt by the domestic industry yet. There is often a significant lag (anywhere from several months to several years) between when a project is bid, when the project begins (i.e., when imports would begin to enter the United States), and when a project is completed; thus, the full price and volume effects of bids lost during the POI are not yet reflected in the domestic industry's financial performance or employment data. 72

Not only is the sheer volume of sales lost to subject imports significant, but even a single project, or even part of a project, lost to unfair competition can have a significant negative effect on the domestic industry and its workers for an extended period. For example, for one of the

Hudson Yards projects in New York City, U.S. fabricators submitted bids, but a subject

71 Total jobs is based on AISC's estimate that one American job is created for every 45 short tons of structural steel that is produced, fabricated, and erected in the United States. Made in America Structural Steel is Produced and Fabricated in America, American Institute of Steel Construction, https://www.aisc.org/why-steel/made-in• america/, attached as Exhibit 1-18.

72 See, e.g., USITC Pub. 2988 at 17 (" {A} fter finalization of the sales contract, there is generally a lengthy production and delivery period. Completion and installation of an LNPP or press addition can take from several months to three years after execution of the sales contract. Thus, there can be a substantial lag between award of a sales contract and shipments of the merchandise to be delivered thereunder. Similarly, because payment on the contract is made in installments over the life of the production process, the full financial impact of a sale (or its loss) is often not reflected in a producer's financial records for two or more years after the date of the sale.").

Filed By: [email protected], Filed Date:32 2/1/19 6:12 PM, Submission Status: Approved Barcode:3789316-02 A-570-102 INV - Investigation - RANGED DATA PUBLIC VERSION fabricator was ultimately awarded part of the project by providing a bid far below what domestic fabricators could offer; in fact, the winning bid was approximately $100 million below U.S. producers' bids." There is simply no way for domestic fabricators to compete with such drastically low prices. As a result of the subject producer's bid on the Hudson Yards project, the domestic industry lost a project for 3.6 million square feet of commercial construction, which would have supported 1.3 million man hours of production." To put that in perspective, this single project could have supported more than 600 American workers, full time for an entire year.

Moreover, there are numerous projects for which domestic producers either did not place a bid or were not permitted to place a bid due to competition from subject imports. Many purchasers will not even request a proposal from U. S. fabricators, because the purchasers already know that the subject fabricators' bids will be far lower than what domestic producers could provide. During the POI, there were at least [ ], for which the domestic industry did not place a bid (or were precluded from bidding) given their inability to compete with unfairly traded subject imports." These projects likewise represent sales that the domestic industry could have captured in the absence of unfair trade competition,

], attached as Exhibit 1-19.

74 !d.

75 Lost Sales and Revenue Data, attached as Exhibit 1-16. The projects for which no bids were made largely took place toward the latter portion of the POI, as substantial volumes of increasingly low-priced subject imports entered the U.S. market.

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d. Subject Imports Have Severely Harmed American Workers

In light of the adverse effects on the domestic industry's sales and production, the domestic industry's employees were negatively impacted during the POI as well. As the production of FSS is highly labor-intensive, suppressed production greatly affected hours worked."? Between 2015 and 201 7, and continuing into the interim period, the number of workers, hours worked, and wages paid suffered and would have been much higher in the absence of competition from unfairly traded imports." Moreover, the jobs affected by the domestic industry's decline extends beyond domestic fabricators' production related workers. In fact, Petitioner estimates that one American job is created for every 45 short tons of structural steel that is produced, fabricated, and erected in the United States;79 this means that in 2017 more than [. ] jobs were supported as a result of domestic fabrication. These jobs are increasingly at risk due to subject import competition. Indeed, had the domestic industry not lost substantial sales due to underselling by unfairly traded subject imports, the domestic industry could have supported more than [~ ] additional jobs. Without relief, the domestic industry

76 These projects likely would have resulted in [\)(.A.\lL- ] of additional revenue for the domestic industry. While value information for the projects are not available, as no bid was made, relying on the lowest average unit value for the domestic industry during the POI [ IV Q.(tl:A.-kJJc.- ].

77 AISC estimates that 15 to 30 hours of shop time are required for every short ton of fabricated structural steel. Structural Steel: An Industry Overview, American Institute of Steel Construction (Oct. 2017), at 4, attached as Exhibit 1-20. 78 The Domestic Industry's Trade and Financial Data, attached as Exhibit 1-10.

79 Made in America Structural Steel is Produced and Fabricated in America, American Institute of Steel Construction, https:llwww.aisc.org/why-steel/made-in-america/,attached as Exhibit 1-18.

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American jobs will be jeopardized.

e. Conclusion

The data provided herein demonstrate material injury to the domestic industry by reason of dumped and subsidized subject imports. During the POI, subject imports surged into the u.s. market, increasing by more than 20 percent despite an increase in apparent domestic consumption of only 7.9 percent. This significant increase in the volume of subject imports resulted in subject producers growing their market share at the direct expense of the domestic industry. Subject imports did so using aggressive and unfair pricing, which had significant negative price effects on u.S. producers and the u.S. market overall. Dumped and subsidized subject imports undersold domestically-produced FSS by substantial margins, forcing domestic producers to lower prices, lose sales, or both. Consequently, domestic producers experienced massive volumes of lost sales and lost revenues during the POI.

Competition from unfairly traded subject imports forced the domestic industry to either lose sales or sacrifice profit to maintain sales; as a result, the domestic industry's production, capacity, and employees were all adversely impacted. By 2017, the domestic industry's income had plummeted, and U.S. producers were operating at unsustainably low margins. The deterioration in the U.S. industry's performance has continued in the first half of 2018, with capacity utilization remaining abysmal, operating margins remaining well below 2015 and 2016 levels, and production and sales well below what they would have been in the absence of competition from unfairly traded imports. Thus, the domestic industry has been materially injured by reason of subject imports during the POI.

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E. Subject Imports Threaten Additional Material Injury to the Domestic Industry

. The above discussion establishes that the subject imports have caused material injury to the domestic FSS industry. In addition, evidence available to Petitioner demonstrates that the subject imports also threaten the domestic industry with further material injury. In assessing threat, the Commission should cumulate imports from all subject countries.

1. The Commission Should Cumulate Subject Imports for the Purpose of Its Threat Analysis

In evaluating threat of material injury, the Commission may cumulatively assess the volume and price effects of imports of subject merchandise from all countries with respect to which the petitions were filed on the same day "if such imports compete with each other and with domestic like products in the United States market.t''" As these Petitions cover all subject countries, the first requirement is met. And, as discussed above, subject imports all compete with each other and with the domestic like product in the U.S. market. Thus, the statutory requirements for cumulation in a threat investigation have been satisfied.

2. Subject Imports Threaten Domestic Producers with Additional Material Injury

In determining whether subject imports threaten a domestic industry with material injury, the Commission must consider a number of factors, including:

• A significant rate of increase in the volume or market penetration of imports of the subject merchandise;

• Price effects of the subject imports;

• The nature of any countervailable subsidies;

80 19 U.S.C. § 1677(7)(G).

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• Existing unused production capacity or potential increases in production capacity in the exporting country;

• Inventories of the subject merchandise; and

• The potential for product-shifting."

In addition, because some bids have been recently awarded to producers in the subject countries, the Commission can identify specific amounts of FSS likely to enter the United States in the near future. These factors support an affirmative threat determination. Therefore, the

Commission should find that the domestic FSS industry is vulnerable and that subject imports threaten the domestic industry with material injury.

a. The Domestic FSS Industry Is Vulnerable to Material Injury from Subject Imports

During the POI, substantial volumes of low-priced subject imports entered the United

States and captured sales and market share from the domestic industry. As a direct result of competition with unfairly traded subject imports, the domestic industry's trade and financial indicators were adversely impacted. Notably, data collected from a sample of U.S. producers show that the domestic industry is operating at only [ ] percent capacity utilization as of the first half of 2018 and had unsustainably low operating margins. Consequently, the domestic industry has been left in a weakened state and is extremely vulnerable to further material injury from additional volumes of unfairly traded subject imports.

81 !d. § 1677(7)(F)(i).

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b. Subject Imports Have Rapidly and Significantly Increased in Volume and Market Share

There has been a substantial increase in both the volume and market share of subject imports over the POI.82 As discussed above, the volume of subject imports increased significantly during the POI, growing by more than 20 percent and significantly outpacing the growth in apparent domestic consumption. 83 This surge of subject imports is continuing, with the volume of subject imports from January through October of 2018 increasing 11 percent compared to the same period in 2017.84 Additionally, because of the lag between when a project may be awarded and when the FSS for that project actually enters the United States, all or some of the FSS for projects awarded in 2018 and 20 17 (and possibly even 2016) may not yet have been imported. For example, the domestic industry has identified lost sales in the first three quarters of 2018 for projects totaling [ -1'OC\.S ], and it is likely that much of the FSS associated with these projects has not yet entered the United States.85

c. Subject Imports Have Demonstrable Adverse Price Effects That Are Likely to Continue

As discussed above, subject imports have had significant price depressing and suppressing effects.i" During the POI, subject FSS substantially undersold domestically

82 Id. § 1677(F)(i)(III) (stating that "a significant rate of increase of the volume or market penetration of imports of the subject merchandise" shall be considered in determining whether the domestic industry is threatened with material injury from subject imports).

83 Market Share Analysis, attached as Exhibit 1-3. 84 Official U.S. Import Statistics, attached as Exhibit 1-8. 85 Lost Sales & Revenue Data, attached as Exhibit 1-16.

86 19 U.S.C. § 1677(7)(F)(i)(IV) (stating that, in determining whether the domestic industry is threatened with material injury, "whether imports of subject merchandise are entering at prices that are likely to have a significant depressing or suppressing effect on domestic prices, and are likely to increase demand for further imports" should be considered).

Filed By: [email protected], Filed Date:38 2/1/19 6:12 PM, Submission Status: Approved Barcode:3789316-02 A-570-102 INV - Investigation - PUBLIC VERSION

produced FSS, forcing domestic producers to lower prices and lose sales. Given that subject

imports have continued to enter the United States in large volumes and at prices well below those

of domestically produced FSS, it is likely that domestic producers' prices will continue to decline

without relief. Thus, subject imports' adverse price effects indicate that the domestic industry is

further threatened with additional material injury.

d. Subject Producers Have Substantial Capacity That Can Be Directed at the United States

Subject producers' capacity to produce significant volumes of FSS, as well as the ability

to export additional volumes and target them at the United States, indicate that the domestic

industry is threatened with further injury.87 Information reasonably available indicates that the

subject countries have substantial capacity to produce FSS. There are over 130 AISC-certified

steel fabricators in Canada, China, and Mexico.t" However, there appear to be significantly more

steel fabricators in the subject countries; in fact, it is estimated that, in 2016, there were approximately 8,644 entities in the Chinese metal fabrication industry-a majority of which are believed to be steel fabricators.f" The subject countries also have significant capacity to produce upstream goods. For example, in 2015, the subject countries produced over 16 million short tons of heavy sections and over 200 million short tons of plate." Moreover, given the massive global excess steel capacity, particularly with respect to China, subject FSS producers undoubtedly have

87 Id. § 1677(7)(F)(i)(II) (explaining that "any existing unused production capacity or imminent, substantial increase in production capacity in the exporting country indicating the likelihood of substantially increased imports" should be considered in examining the threat of material injury). 88 AISC Certified Company Data, attached as Exhibit 1-20.

89 See Analysis of Australia's Steel Manufacturing and Fabricating Markets Report to the Commissioner of the Anti-dumping Commission, Australian Government Department of Industry, Innovation and Science, Antidumping Commission (Nov. 2017) at 34, excerpts attached as Exhibit 1-21.

Filed By: [email protected], Filed Date:39 2/1/19 6:12 PM, Submission Status: Approved Barcode:3789316-02 A-570-102 INV - Investigation - PUBLIC VERSION access to enormous additional volumes of upstream merchandise for fabrication. The substantial availability of upstream goods provides subject producers with the ability to greatly increase production of FSS.

Information reasonably available also indicates that subject producers are likely to substantially increase production and exportation of FSS. Specifically, global steel excess capacity coupled with duties that have been placed on upstream merchandise provide a significant incentive for subject producers to further increase exports to the United States." This will only accelerate as additional tariffs on steel mill products have been imposed under Section

232 of the Trade Expansion Act of 1962 and under Section 301 of the Trade Act of 1974.92

Similarly, Chinese producers of mill products will have an increased incentive to ship goods to other export markets - such as Canada and Mexico - and enable producers of downstream products in these countries to manufacture increasing volumes of low-priced FSS, which will then be targeted at the United States. Accordingly, subject producers have both the ability and incentive to increase exports of FSS to the United States, threatening the domestic industry with further injury.

90 Steel Statistical Yearbook 2018, World Steel Association at Table 15 & Table 20, excerpts attached as Exhibit 1-22.

91 See Analysis of Australia's Steel Manufacturing and Fabricating Markets Report to the Commissioner of the Anti-dumping Commission, Australian Government Department of Industry, Innovation and Science, Antidumping Commission (Nov. 2017) at 6 ("The demand/production imbalance for primary steel can flow through into the steel fabrication market and lead to imbalance in the steel fabrication industry. In addition, the primary steel demand/production imbalance may create distortions in markets for steel fabricated products as a result of responses by some exporters to trade remedies on primary steel products that are being dumped or subsidised."), excerpts attached as Exhibit 1-21.

92 See id. (noting a finding in Australia that "imports of some steel fabricated products had increased following the imposition of measures on the primary steel input to their production").

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e. Subject Producers Received Significant Countervailable Subsidies

The subsidies received by subject producers provide additional evidence that the domestic industry is threatened with material injury." The substantial subsidies provided by the

Government of China to its steel industry and to encourage.exports is well documented.?" These include the provision of major inputs for less than adequate remuneration, tax reductions and exemptions, preferential loans, and grants." The Canadian and Mexican Governments likewise provides numerous countervailable subsidies that are available to FSS producers and exporting entities, including preferential tax rates, grants, and export financing." These subsidies encourage subject producers' exportation of significant volumes of merchandise and contribute to subject producers' ability to undersell domestically produced FSS by substantial margins.

III. CONCLUSION

The domestic FSS industry is currently experiencing material injury, and is threatened with further material injury, by reason of unfairly traded imports from Canada, China, and

Mexico. Between 2015 and 2017, and throughout 2018, subject imports surged into the United

States and captured market share at the direct expense of the domestic industry. Subject producers entered the U.S. market in such large and increasing quantities by offering unfair prices well below those of domestically produced FSS, forcing domestic producers to lower

93 19 U.S.c. § 1677(7)(F)(i)(I) (directing consideration of whether subject producers receive countervailable subsidies and the nature of such subsidies in making a determination of threat of material injury).

94 See, e.g., Issues and Decision Memorandum accompanying Certain Carbon and Alloy Steel Cut-to-Length Plate From the People's Republic of China, 82 Fed. Reg. 8507 (Dep't Commerce Jan. 26, 2017) (final affirm. countervailing duty deter.) at 8-9. 95 !d. 96 See Volumes V & VI, infra.

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prices and resulting in the domestic industry losing [ \J e, \ve,... ] of sales and revenue to lower-priced subject imports. The negative impact of this unfair subject import competition on the domestic industry is clear. During the POI, as subject imports increased and undersold domestically produced FSS, the domestic industry experienced declines in essentially all trade and financial indicia, including production, capacity utilization, sales, employment, and operating and net income.

Moreover, the significant volume of unfairly traded imports that entered the U.S. market during the POI has left the domestic industry in an extremely vulnerable state. As subject producers have the ability and the incentive to continue to send massive volumes of dumped and subsidized FSS imports to the United States, the domestic industry's performance will continue to deteriorate in the absence of trade relief. As such, relief from dumped and subsidized FSS imports from Canada, China, and Mexico is critical to the domestic industry and its workers.

Respectfully submitted,

/s/Alan H. Price Alan H. Price, Esq. Christopher B. Weld, Esq. Stephanie M. Bell, Esq. WILEY REIN LLP 1776 K Street, NW Washington, DC 20006 (202) 719-7000

Counsel to Petitioner American Institute of Steel Construction, LLC

Dated: February 4,2019

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EXHIBIT LIST

EXHIBIT No. DESCRIPTION STATUS

I-I Petitioner's Contact Information Public

1-2 List of U.S . Producers BPI

1-3 Market Share Analysis BPI

1-4 Standing Analysis BPI

Certain Fabricated Structural Steel from Canada, Inv. No. 731- 1-5 Public TA-387, USITC Pub. 2062 (Feb. 1988) (Prelim.) (excerpts)

1-6 U.S. Harmonized Tariff Schedule (2018) (excerpts) Public

1-7 List of Subject Producers and Exporters Public

1-8 Official U.S. Import Statistics Public

1-9 List of U. S. Importers Public

1-10 Domestic Industry's Trade and Financial Data BPI

Structural Steel: An Industry Overview, American Institute of 1-11 Public Steel Construction (Oct. 2017) (excerpt) Conditions of Competition Between Certain Domestic and 1-12 Imported Fabricated Structural Steel Products, Inv. No. 332-181, Public USITC Pub. 1601 (Nov. 1984) (excerpts) Dumping and Subsidizing, Finding and Reasons, Inquiry No. NQ- 1-13 2016-004 Certain Fabricated Industrial Steel Components, Public Canadian International Trade Tribunal (June 9, 2017) (excerpts)

1-14 [ ~rc.e_ ] BPI

1-15 [ ~v..rU!- ] BPI

1-16 Lost Sales and Revenue Data BPI

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EXHIBIT LIST

EXHIBIT No. DESCRIPTION STATUS

1-17 Testimony of Jeff Sterner Public Made in America Structural Steel is Produced and Fabricated in 1-18 America, American Institute of Steel Construction, Public https:llwww.aisc.org/why-steellmade-in-america/ [ ~ of,Jt..,(" UL.. 1-19 BPI

]

1-20 AISC Certified Company Data Public Analysis of Australia's Steel Manufacturing and Fabricating Markets Report to the Commissioner of the Anti-dumping 1-21 Commission, Australian Government Department of Industry, Public Innovation and Science, Antidumping Commission (Nov. 2017) (excerpts) Steel Statistical Yearbook 2018, World Steel Association 1-22 Public (excerpts)

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EXHIBIT I-1

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American Institute of Steel Construction, LLC 130 East Randolph Street Suite 2000 Chicago, IL 60601 Phone: (312) 670 – 5444 Website: https://www.aisc.org/

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EXHIBIT I-2

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EXHIBIT NOT CAPABLE OF PUBLIC SUMMARY

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EXHIBIT I-3

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Summary of Calculation of u.s. Production of FSS

There are no publicly available sources regarding U.S. production of FSS. Accordingly,

Petitioner estimated U.S. production based on the quantity of shipments of steel mill products, the primary input into FSS. The starting point for Petitioner's calculation is U.S. shipments of parallel flanges as reported in the [ ]. Petitioner then made adjustments, as described below, to account for parallel flanges that are not used to produce FSS and for other steel mill products that are used to produce FSS.

First, Petitioner deducted the quantity of U.S. shipments of'H pilings, bantam beams, super- light beams, and I beams, as well as other parallel flanges that are not used to produce FSS. These steel mill products typically are not fabricated or are used in non-structural applications, such as mobile homes and trailers, single-family residential construction, and shipbuilding applications.

Second, Petitioner made an upward adjustment to account for other steel mill products that are used in the production of FSS, namely angles and channels, hollow structural shapes, and plate.'

Third, because Petitioner relied on the quantity of steel mill shipments, an adjustment was made to account for the steel waste that is generated in the process of manufacturing FSS. Fourth, because the scope of this investigation does not include fabricated structural steel used in bridges and bridge sections, Petitioner made a deduction to account for the steel that is used to manufacture bridges and bridge sections that would have been captured in the calculation. Finally, because some FSS produced in the United States is made from steel mill products manufactured outside of the United States, Petitioner has made an upward adjustment to account for these products.

Petitioner's calculation and supporting documentation is attached hereto.

Petitioner notes that is has made these adjustments based on conservative estimates. For example, the adjustment made for plate is consistent in each year of the POI; however, demand for plate used for fabricated structural steel has decreased in recent years relative to demand for plate in other sectors. This serves to overstate U.S. shipments in the latter portion of the POI.

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PAGE NOT CAPABLE OF PUBLIC SUMMARY

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Apparent Domestic Consumption (Short Tons) 2017 Jan. ‐ 2018 Jan. ‐ Jan. ‐ June % 2015 2016 2017 June June 15‐17 % Change Change Filed By:[email protected], Filed Date:2/1/196:12PM,Submission Status:Approved U.S. Shipments 3,215,672 3,067,875 3,418,290 1,796,059 1,938,105 6.30% 7.91% China 368,637 476,814 492,833 272,385 247,360 33.69% ‐9.19% Canada 168,828 227,763 235,997 107,280 126,834 39.79% 18.23% China + Canada 537,465 704,577 728,830 379,665 374,194 35.61% ‐1.44% Mexico 246,176 224,420 220,748 112,508 146,605 ‐10.33% 30.31%

China + Canada + Mexico 783,641 928,997 949,578 492,173 520,799 21.18% 5.82% Barcode:3789316-02 A-570-102INV-Investigation All Others 244,300 292,137 277,256 149,674 123,280 13.49% ‐17.63% Apparent Domestic Consumption 4,243,613 4,289,009 4,645,124 2,437,906 2,582,185 9.46% 5.92%

Share of Apparent Domestic Consumption 2017 Jan. ‐ 2018 Jan. ‐ Jan. ‐ June % 2015 2016 2017 June June 15‐17 % Change Change U.S. Shipments 75.78% 71.53% 73.59% 73.67% 75.06% ‐2.19% 1.38% China 8.69% 11.12% 10.61% 11.17% 9.58% 1.92% ‐1.59% Canada 3.98% 5.31% 5.08% 4.40% 4.91% 1.10% 0.51% China + Canada 12.67% 16.43% 15.69% 15.57% 14.49% 3.02% ‐1.08% Mexico 5.80% 5.23% 4.75% 4.61% 5.68% ‐1.05% 1.06% China + Canada + Mexico 18.47% 21.66% 20.44% 20.19% 20.17% 1.98% ‐0.02% All Other 5.76% 6.81% 5.97% 6.14% 4.77% 0.21% ‐1.37% Page 8 of 129 PUBLIC VERSION Barcode:3789316-02 A-570-102 INV - Investigation -

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DECLARATION

[ N ~L ] declares and states that: 1. I am employed as [ -r ,H e- c. ~~ '-'\ ], a u.s. producer of [ ?rod.v c..k• ]. I have served in this position since 2016. Prior to that, I was the [ \" ,\-\t.,. .] for approximately [1f1 years and the [ -r\;.\c,. .. d~ ""U\~S ].I have a total of ( ... ] years' experience in the l?f'~ ] industry. 2. [Co .....?

3. One of the [ ,.., eo.'('r ~4-\\)e,.... ] parallel flange sections. While parallel flange sections are typically fabricated, certain types of parallel flange sections are not sold for fabrication. In particular. H-pilings are not typically fabricated or sold for fabrication. Attached hereto is information on the size of the U.S. H-pilings market. This is based on data [ Scu.t'G.t-

]. 4. Similarly, bantam beams, super-light beams, and I -beams are typically not fabricated or sold for fabrication. Instead, they are typically used for mobile homeslRV s and guard posts. I estimate that the total quantity of bantam beams, super-light beams, and I• beams produced and sold in the United States in 2017 was between [ .J30 f 000 ]. 5. In addition to r /-) ""f"C'"CA"'vL- ].I estimate that the total quantity of other angles and channels that are fabricated is equal to approximately [ "It) ,.., o.rc~ 4..:\1(... ]. 6. The other main category of [ No-fro--\.: ,,(..... l- Based on my knowledge of the market, I estimate that the quantity of HSS and plate that is fabricated is equal to r #I/o ,..,o.rro..:\....va.-- ]. 7. The text surrounded. by brackets contains business proprietary information, the release of which would cause serious commercial harm to the submitter.

8. I declare under penaJty of peljury under the laws

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DECLARATION

) declares and states that:

1. I am employed as [ -) \~\c.. c.t),.....~~\ ]~ a domestic producer of [ '?"od.u tJr J. I have served as the [ "\ ~-\\.-t,.. ] for ["Q:. ] years and have a total of [ ~] years' experience in the Frolci] industry.

2. [~'\] manufactures a wide variety of [ ~("\)tl{,l~ ], including products that are [ ..,('JI((CA ~ vt- , ]. In my role as [ -r ~ -tle..... ], I am very familiar with the products' we sell and the markets into which those products are sold, including how such products are typically used.

3. One of the product categories [ }oJo.(r(>.:\\.ve_. ] parallel flange sections. While a large portion of parallel flange sections are fabricated, not all types of parallel flange sections are sold to structural steel fabricators or used in fabrication. For example, bantam beams, super-light beams, and l-beams are typically not sold to structural steel fabricators but to other types of steel manufactures. I estimate that the total quantity of bantam beams, super-light beams, and J-beams produced and sold in the United States in 2017 was approximately [~,oI006 ].

4. In addition to parallel flange sections, [ ~()\('("o.~"l-- [, I estimate that the total quantity of other angles and channels that are fabricated is equal to approximately [ tilt) ,..., o.(r~"'~ }.

5. The text surrounded by brackets contains business proprietary information, the release of which would cause serious commercial harm to the submitter.

6. I declare under penalty of perjury under the laws of the United States of America that to the best of my knowledge, the foregoing is true and correct.

Executed August30, 2018, in I L.o~ J.

1 [

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DECLARATION

[....,~ 1 declares and states that:

1. I am employed as [ "\ \ ~\'- ], through which I serve as a consultant to [ "'C)."'~ ve.....- ]. Until [ \)o:lc(..,

]. I worked for [ ~(o..~\It- ] for approximately [*'] years, and I have [-t\-] years of experience in the fabricated structural steel industry.

2. Based on my knowledge of the U.S. market for fabricated structural steel produced for structures such as buildings and industrial and infrastructure facilities, I believe the best means for measuring the size of the U.S. market is based on steel mill shipments. As reviewed below, the size of the U.S. fabricated structural steel market can be estimated using [ 56(...11.( u.... foJCA(ro<"" ve- ]. Specifically, this estimate is based on [ }Joirq.,.4:;, ~

3. First, certain types of [

4. Second, a portion of [

]. I estimate that approximately [ ] are not fabricated or are used for non-structural applications. Based on my knowledge of the industry, I believe that this is a conservative estimate.

5. Third, r ]. Specifically, a portion of [ rVc..('r(L~1JL- 1 that are produced in the United States are used to manufacture fabricated structural steel. Based on [ TV (i.J('( 0..~ \J<--

8/0 ].

6. Fourth, because this analysis is based on the quantity of [ ""Q.t'co-"",~ ]. Based on a survey conducted of AISC member fabricators" I estimate that approximately [ Oft> JVc>&"rc"':~\Jt...., ]. In other words, if r J-JO«~ve-

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7. Following this methodology provides a reasonable estimate of the quantity of fabricated structural steel produced using steel mill products manufactured in the United States. I would note that this estimate includes certain quantities of steel mill products [ ,l.)O('('~vL-• ] used in the production of fabricated steel for bridges and bridge sections. Accordingly, to measure the size of the market excluding fabricated structural steel used for bridges and bridge sections, these quantities would have to be excluded.

8. Finally, while [

]. Based on [

9. I believe that the methodology described above provides a complete and accurate estimate of the size of the U.S. fabricated structural steel market. Based on this methodology, I believe that total U.S. producer shipments of fabricated structural steel in 2017, excluding fabricated structural steel used in bridges and bridge sections, was approximately [ 3. \ "",\\;Ot'\ ].

10. It is my understanding that the members of AISC account for a substantial portion of the U.S. fabricated structural steel market. Based on my [ tv CAtfo\'~\I(...- ], as well as my industry knowledge, I believe that AISC members account for approximately 70% of the fabricated structural steel manufactured in the United States.

11. The text surrounded by brackets contains business proprietary information, the release of which would cause serious commercial harm to the submitter.

12. I declare under penalty of perjury under the laws of the United States of America that to the best of my knowledge, the foregoing is true and correct.

Executed December 11,2018, in [ Lo~'CJf'.... ].

] [ ]

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DECLARATION

[ ~~ ] declares and states that:

1. I am employed as [ ..,.. \-\-\t_ c.o~c.4'''1 ], a 'position which I have held since [\)O\~ [. Prior to [ uo.f"('"~Vl- ], I have held various roles within [ toto"'(\) c;.y....~ ], and I have [*] years of experience in the fabricated structural steel industry.

2. In my role as [ "\ \ +\(.., ], I am involved with the compilation of data to estimate the [ f'w) V\ frCA.~vt-

]. While the ["-'ot(C.(-k\.(... ] of fabricated structural steel produced in the United States is made from steel mill products manufactured in the United States, U.S. fabricators also produce fabricated structural steel from steel mill products manufactured outside of the United States.

3. Based on my work at [c""(""i1 and my knowledge of the fabricated structural steel market, I estimate that the quantity of fabricated structural steel produced in the United States that is made from [ ~ (.Io'l'f(A~\'c""-- 0f.o

4. Based on [ tv ~ ... (~"'-\A:--' ], I am also familiar with the size of the U.S:- fabricated structural steel industry and the extent to which AISC represent the U.S. industry. It is my belief that AISC represents approximately 70 percent of the U.S. fabricated structural steel industry.

5. The text surrounded by brackets contains business proprietary information, the release of which would cause serious commercial harm to the submitter.

6. I declare under penalty of perjury under the laws of the United States of America that to the best of my knowledge, the foregoing is true and correct.

Executed December ~l, 2018, in [~~CI' J.

1 [ J

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EXHIBIT I-4

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Su~mary of Calculation of Petitioner's U.S. Shipments

To calculate the total quantity of U.S. shipments accounted for by Petitioner, Petitioner relied on [ ~ ouret- ]. [ JV()..f(CA~vt----

Specifically, [

However, [ tv CAN C\.-\:Vt,...

]. For example, [

]. Additionally, each company [

]. Thus, it is possible for companies to [ f'J o.f(CA."'vt_..., ].

Based on the above, Petitioner has estimated its total production as follows. First,

Petitioner converted the [

]. Second, Petitioner compared the total production quantity [

]. Third, Petitioner used this [

Petitioner's calculation and supporting documentation is attached hereto.

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Calculation of Petitioner's U.S. Shipments

2017 r 1 Fabricated Structural Steel for Buildings r 1 [ 1 r 1 Total 2017 [ 11 [ 1 Total 2017 [ 1 r 1 Actual Total2017[ ] r 1 Ratio of [ 1 [ 1 Estimated Actual r 1 Production r 1

Petitioner notes that, for [ ]. Accordingly, as a conservative estimate, Petitioner assumed that the [ ].

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RANGED DATA PUBLIC VERSION

DECLARATION

[ tv ~ ] declares and states that:

1. I am employed as I "\'\~\t... c_o"",~ep...\ ]. I have served as [ -"\ \ -\-\(_ ] for [~ years.

2. As part of my role as [ "\ \ ~e... ], I am involved in the collection of [ ,..., o..frCAo-k. vt.- ]. [ }J(J.'{'('~vL- ). Specifically,

], the amount that each company [ ,uc)'f((.t~\.f- ]. This is largely based on two factors. First, [ J.J 0.'( rCA-\.: v(......

]. Second, each company [ ].

4. In 2017, the I

5. The text surrounded by brackets contains business proprietary information, the release of which would cause serious commercial harm to the submitter.

6. I declare under penalty of perjury under the laws of the United States of America that to the best of my knowledge, the foregoing is true and correct.

Executed December ~ 2018, in [l.,oc..Ct'Cli"'. ].

1 [ ]

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EXHIBIT I-5

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CERTAIN FABRICATED STRUCTURAL STEEL FROM CANADA

Determination of the Commission in Investigation No. 731-TA-387 (Preliminary) Under the Tariff Act of 1930, Together With the Information Obtained in the Investigation

USITC PUBLICATION 2062

FEBRUARY 1988

United States International Trade Commission / Washington, DC 20436

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved Page 26 of 129 Barcode:3789316-02 A-570-102 INV - Investigation -

UNITED STATES INTERNATIONAL TRADE COMMISSION Washington, DC

Investigation No. 73i-TA-387 (Preliminary)

CERTAIN FABRICATED STRUCTURAL STEEL FROM CANADA

Determination

On the basis of the record 1/ developed in the subject investigation, the

Commission determines, 2/ 3/ pursuant to section 733(a)., of .the'Tariff Act of

1930 (19 U.S.C. § 1673b(a)), that there is no reaspnable indication that,/an

industry in the United States is materially injured or threatened with

material injury, or that the establishment of an industry in the United States

is materially retarded, by reason of imports from Canada of certain fabricated

structural steel, provided for in items 609.84, 609.86, 652.94, 652.95,

652.96, and 653.00 4/ of the Tariff Schedules of the United States, which are

alleged to be sold in the United States at less than fair value (LTFV).

Background

On January 11, 1988, a petition was filed with the Commission and the

Department of Commerce by counsel on behalf of the American Institute of Steel

Construction (AISC), alleging that an industry in the United States is

materially injured by reason of LTFV imports of certain fabricated structural

steel from Canada. Accordingly, effective January 11, 1988, the Commission

instituted preliminary antidumping investigation No. 731-TA-387 (Preliminary).

1/ The record is defined in sec. 207.2(i) of the Commission's Rules of- Practice and Procedure (19 CFR § 207.2(i)). 2/ Commissioner Eckes determines that there is a reasonable indication that an industry in the United States is materially injured or threatened with material injury by reason of imports of certain fabricated structural steel from Canada, which were allegedly sold in the United States at less than fair value. 3/ Commissioner Cass did not participate in this determination. 4/ Under the proposed Harmonized Tariff Schedule of the United States, this product will be covered by subheadings 7216.90.00, 7222.40.60, 7301.20 10 7301.20.50, 7308.90.30, 7308.90.60, and 7308.90.90.

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Petitioner, the ihnerican Institute of Steel Construction, Inc. (AISC), and the respondents agree that the like product is domestically produced FSSV for buildings. Based on the record in this investigation, and in light of the accord between the parties on this question, we determine that the like product in this investigation is FSS for buildings. The Commission did consider broadening the Hke product definition to include FSS for bridges. However, the record supported a finding that FSS for bridges differs

9/ Fabricated Structural Steel from Canada: Inv. No. 731 TA 387: Petitioner’s Postcbnference Brief (Petitioner's Brief) at 5; Responses to Questions Posed by the Commission Staff at the Preliminary Conference, filed by the respondents, Canron, Inc., Dominion Bridge, Frankel Steel Ltd., Ocean Steel and Construction, Ltd., and Canadian Institute of Steel Construction at 6. Although petitioner agrees that the like product should be FSS for buildings, it suggested in its post-conference brief that the Commission might consider limiting the like product to FSS for buildings that require,1000 tons of FSS or more. Petitioner's Brief at 9. We considered this suggestion an

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from FSS for buildings With regard to weight and size, use, and customer and

producer perceptions and to some extent the materials from which it is made.

In addition, the two kinds of FSS arc generally produced in different

facilities.r -i i.. —12/

For these reasons, we determine that FSS for buildings is the like

product in this investigation. We further determine that the domestic 13/ industry consists of all U.S. producers of FSS for building?. —

Condition of the domestic industry

In assessing the condition of the domestic industry, the Commission

considers, among other factors, domestic consumption, production, capacity.

11/ Transcript of the Conference (Tr.) at 88 92. 12,/ Id. Even if the Commission were to have included bridges in the like product definition, the Petitioner's case would not have improved. Including FSS for bridges as part of the like product would increase the market share of the U.S. producers and decrease the already small market share held by the Canadians. In addition, according to available data the FSS industry (Which includes FSS for buildings and bridges) was not materially injured. Consumption of FSS increased; FSS shipments increased through 1986; capacity, capacity utilization, and production capacity all rose during the entire period of investigation; and the FSS industry as a whole was profitable from 1985 through the first nine months of 1987. See Report at A 17, A 25, A-23, and A-31. 13/ Neither party to this investigation argued that the two domestic producers affiliated with Canadian FSS producers should be excluded from the domestic industry for the purposes of this investigation under 19 U.S.C. § 771(4)(B). However, we considered whether Steel Structures Corp. and Canron Construction Corp., Eastern Div. should be excluded from the domestic industry. The record indicates that their performance differs somewhat from the rest of the domestic industry, but their data do not represent sufficient production to skew the injury information on the whole industry. We recognize that these companies do enjoy some benefit from the availability of Canadian imports for their use, and we did consider this when we looked at information concerning causation.

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A-35

1986, before declining to 1.5 percent in 1987. The Increase in market share on the part of Canada generally came at the expense of other foreign corintries; as the table indicates, the percent of U.S.. constimption accounted for by domestic producers remained generally constant throughout the period, except for a slight rise in 1987.

Prices

Questionnaire respondents were requested to describe the bidding process. Additional Information regarding the solicitation, negotiation, and award of contracts for fabricated structural steel for buildings was also obtained from parties to the investigation.

The demand for fabricated structural steel for buildings is derived from the demand for buildings. The primary substitute for the product under Investigation is concrete, which accounts for approximately 50 percent of the market for building frames. Although price is an important factor, the determining factor when choosing fabricated structural steel or concrete is the designer's preference.

Buildings range in size from modest structures requiring several hundred tons of steel to multistory complexes, such as the "60 Wall Street Project" In New York City, which required approximately * * * tons of fabricated structural steel. In general, large structures require 8,000 tons or more of fabricated structural steel, with buildings requiring at least 15,000 tons considered by the industry as major projects. For the most part, buildings, especially large structures, have unique designs.

Usually, after a developer has a building design for a project, the developer will solicit bids for construction from general contracting firms. 1/ These firms develop the probable costs of the entire project and submit bids to the developer. Once a general contractor is selected, that firm solicits bids for different aspects or portions of the construction of the project. One of these portions involves both the fabricated structural steel and the erection of the building frame.

To reduce overall costs, a developer may elect to fast-track construction; the general contractor is selected and all subcontract work is awarded prior to the completion of a building's design. Fast-tracking can be cost advantageous because, although construction costs may be higher if design changes are necessary, overall costs on a project may be reduced because interest rates paid on money borrowed during the construction phase of a project are considerably higher than the mortgage.rates applicable when the project is completed-

On large projects, general contractors, usually solicit bids from a limited number of fabricators with whom they have worked or that have been preqiiallfled. In these cases, the general contractor may prefer to deal with fabricators it knows because the cost of the project is too great to take a chance with a fabricator with an unknown or .poor reputation. Sometimes the general contractor invites prequalified fabricators to bid on a project. The '

1/ Sometimes the developer also acts as the general contractor on a project, in which case no other general contractors are requested to submit bids.

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EXHIBIT I-6

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved Page 31 of 129 Harmonized Tariff Schedule of the United States (2018) Revision 14 Barcode:3789316-02 A-570-102 INV - Investigation - Annotated for Statistical Reporting Purposes XV 72-23 Heading/ Stat. Unit Rates of Duty Subheading Suf- Article Description of 1 2 fix Quantity General Special 7216 Angles, shapes and sections of iron or nonalloy steel: 7216.10.00 U, I or H sections, not further worked than hot-rolled, hot-drawn or extruded, of a height of less than 80 mm...... Free 1/ 2% 10 U sections...... kg 50 Other...... kg L or T sections, not further worked than hot-rolled, hot-drawn or extruded, of a height of less than 80 mm: 7216.21.00 00 L sections...... kg...... Free 1/ 2% 7216.22.00 00 T sections...... kg...... Free 1/ 2% U, I or H sections, not further worked than hot-rolled, hot-drawn or extruded, of a height of 80 mm or more: 7216.31.00 00 U sections...... kg...... Free 1/ 2% 7216.32.00 00 I sections (standard beams)...... kg...... Free 1/ 2% 7216.33.00 H sections...... Free 1/ 2% 30 Weighing not more than 11.3 kg per 30.5 cm, with a web depth measuring 102 mm to 356 mm...... kg 60 Weighing more than 11.3 kg but not more than 27.2 kg per 30.5 cm, with a web depth measuring 203 mm to 457 mm...... kg 90 Other...... kg 7216.40.00 L or T sections, not further worked than hot-rolled, hot-drawn or extruded, of a height of 80 mm or more...... Free 1/ 2% 10 L sections...... kg 50 Other...... kg 7216.50.00 00 Other angles, shapes and sections, not further worked than hot-rolled, hot-drawn or extruded...... kg...... Free 1/ 2% Angles, shapes and sections, not further worked than cold-formed or cold-finished: 7216.61.00 00 Obtained from flat-rolled products...... kg...... Free 2/ 20% 7216.69.00 00 Other...... kg...... Free 2/ 20% Other: 7216.91.00 Cold-formed or cold-finished from flat-rolled products...... Free 2/ 20% 10 Drilled, notched, punched or cambered...... kg 90 Other...... kg 7216.99.00 Other...... Free 1/ 20% 10 Drilled, notched, punched or cambered...... kg 90 Other...... kg

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved 1/ See note 16 to subchapter III, chapter 99 and related tariff provisions for this duty treatment. 2/ See 9903.88.03. Page 32 of 129 Harmonized Tariff Schedule of the United States (2018) Revision 14 Barcode:3789316-02 A-570-102 INV - Investigation - Annotated for Statistical Reporting Purposes XV 72-45 Heading/ Stat. Unit Rates of Duty Subheading Suf- Article Description of 1 2 fix Quantity General Special 7228 (con.) Other bars and rods of other alloy steel; angles, shapes and sections, of other alloy steel; hollow drill bars and rods, of alloy or non-alloy steel: (con.) 7228.50 Other bars and rods, not further worked than cold-formed or cold-finished: 7228.50.10 Of tool steel (other than high-speed steel)...... Free 1/ 29% 10 Of ball-bearing steel...... kg Other: With a maximum cross-sectional dimension of less than 18 mm: 20 Of round or rectangular cross section with surfaces ground, milled or polished...... kg 40 Other...... kg With a maximum cross-sectional dimension of 18 mm or more: 60 Of round or rectangular cross section with surfaces ground, milled or polished...... kg 80 Other...... kg 7228.50.50 Other...... Free 1/ 28% 05 Of high-nickel alloy steel...... kg Other: 15 With a diameter of less than 76 mm...... kg 40 With a diameter of 76 mm or more but not exceeding 228 mm...... kg 70 With a diameter exceeding 228 mm...... kg 7228.60 Other bars and rods: 7228.60.10 Of tool steel (other than high-speed steel)...... Free 1/ 29% 30 Of ball-bearing steel...... kg 60 Other...... kg Other: 7228.60.60 00 Not cold-formed...... kg...... Free 1/ 28% 7228.60.80 00 Cold-formed...... kg...... Free 1/ 28% 7228.70 Angles, shapes and sections: 7228.70.30 Hot-rolled, not drilled, not punched and not otherwise advanced...... Free 1/ 10% 10 U, I, H and T sections...... kg Other: With a maximum cross-sectional dimension of 76 mm or more: 20 Angles...... kg 41 Other...... kg With a maximum cross-sectional dimension of less than 76 mm: 60 Angles...... kg 81 Other...... kg 7228.70.60 00 Other...... kg...... Free 1/ 28% 7228.80.00 00 Hollow drill bars and rods...... kg...... Free 1/ 30%

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved

1/ See note 16 to subchapter III, chapter 99 and related tariff provisions for this duty treatment. Page 33 of 129 Harmonized Tariff Schedule of the United States (2018) Revision 14 Barcode:3789316-02 A-570-102 INV - Investigation - Annotated for Statistical Reporting Purposes XV 73-2 Heading/ Stat. Unit Rates of Duty Subheading Suf- Article Description of 1 2 fix Quantity General Special 7301 Sheet piling of iron or steel, whether or not drilled, punched or made from assembled elements; welded angles, shapes and sections, of iron or steel: 7301.10.00 00 Sheet piling...... kg...... Free 1/ 2% 7301.20 Angles, shapes and sections: 7301.20.10 00 Of iron or nonalloy steel...... kg...... Free 2/ 20% 7301.20.50 00 Of alloy steel...... kg...... Free 2/ 28% 7302 Railway or tramway track construction material of iron or steel, the following: rails, check-rails and rack rails, switch blades, crossing frogs, point rods and other crossing pieces, sleepers (cross-ties), fish-plates, chairs, chair wedges, sole plates (base plates), rail clips, bedplates, ties and other material specialized for jointing or fixing rails: 7302.10 Rails: 7302.10.10 Of iron or nonalloy steel...... Free 1/ 1% New: Not heat treated: 10 Standard tee rails over 30 kg per meter.... kg Other: 15 Over 30 kg per meter...... kg 25 Other...... kg Heat treated: 35 Standard tee rails over 30 kg per meter.... kg Other: 45 Over 30 kg per meter...... kg 55 Other...... kg Used: 65 Railway rails for rerolling...... kg 75 Other...... kg 7302.10.50 Of alloy steel...... Free 1/ 9% 20 New...... kg Used: 40 Railway rails for rerolling...... kg 60 Other...... kg 7302.30.00 00 Switch blades, crossing frogs, point rods and other crossing pieces...... kg...... Free 2/ 45% 7302.40.00 00 Fish-plates and sole plates...... kg...... Free 1/ 2% 7302.90 Other: 7302.90.10 00 Sleepers (cross-ties)...... kg...... Free 1/ 2% 7302.90.90 00 Other...... kg...... Free 1/ 45% 7303.00.00 Tubes, pipes and hollow profiles, of cast iron...... Free 2/ 33% 30 Soil pipe...... kg 60 Pressure pipe with an inside diameter of less than 356 mm...... kg 90 Other...... kg

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved 1/ See note 16 to subchapter III, chapter 99 and related tariff provisions for this duty treatment. 2/ See 9903.88.03. Page 34 of 129 Harmonized Tariff Schedule of the United States (2018) Revision 14 Barcode:3789316-02 A-570-102 INV - Investigation - Annotated for Statistical Reporting Purposes XV 73-23 Heading/ Stat. Unit Rates of Duty Subheading Suf- Article Description of 1 2 fix Quantity General Special 7308 Structures (excluding prefabricated buildings of heading 9406) and parts of structures (for example, bridges and bridge sections, lock gates, towers, lattice masts, roofs, roofing frameworks, doors and windows and their frames and thresholds for doors, shutters, balustrades, pillars and columns) of iron or steel; plates, rods, angles, shapes, sections, tubes and the like, prepared for use in structures, of iron or steel: 7308.10.00 00 Bridges and bridge sections...... kg...... Free 1/ 45% 7308.20.00 Towers and lattice masts...... Free 1/ 45% 20 Tubular, whether or not tapered, and sectional components thereof...... kg 90 Other...... kg 7308.30 Doors, windows and their frames and thresholds for doors: 7308.30.10 00 Of stainless steel...... kg...... Free 2/ 35% 7308.30.50 Other...... Free 2/ 25% 15 Windows and their frames...... kg 25 Thresholds for doors...... kg 50 Other...... kg 7308.40.00 00 Equipment for scaffolding, shuttering, propping or pit- propping...... kg...... Free 2/ 45% 7308.90 Other: Columns, pillars, posts, beams, girders and similar structural units: 7308.90.30 00 Not in part of alloy steel...... kg...... Free 1/ 20% 7308.90.60 00 Other...... kg...... Free 1/ 30% Other: 7308.90.70 00 Steel grating...... kg...... Free 1/ 45% 7308.90.95 Other...... Free 1/ 45% 30 Sheet-metal roofing, siding, flooring and roof drainage equipment...... kg Other: 60 Architectural and ornamental work...... kg 90 Other...... kg 7309.00.00 Reservoirs, tanks, vats and similar containers for any material (other than compressed or liquefied gas), of iron or steel, of a capacity exceeding 300 liters, whether or not lined or heat insulated, but not fitted with mechanical or thermal equipment...... Free 2/ 45% 30 Tanks...... No. kg 90 Other...... No. kg

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved 1/ See 9903.88.02. 2/ See 9903.88.03. Page 35 of 129 Harmonized Tariff Schedule of the United States (2018) Revision 14 Barcode:3789316-02 A-570-102 INV - Investigation - Annotated for Statistical Reporting Purposes XX 94-20 Heading/ Stat. Unit Rates of Duty Subheading Suf- Article Description of 1 2 fix Quantity General Special 9406 Prefabricated buildings: 9406.10.00 00 Of wood...... No...... 2.6% 1/ Free (A, AU, BH, 33 1/3% kg CA, CL, CO, D, E, IL, JO, KR, MA, MX, OM, P, PA, PE, SG) 9406.90.00 Other...... 2.9% 1/ Free (A, AU, BH, 45% CA, CL, CO, D, E, IL, JO, KR, MA, MX, OM, P, PA, PE, SG) Of metal: Greenhouses: 10 Commercial...... No. m2 20 Other...... No. m2 30 Other...... No. m2 Other: 50 Animal sheds of plastic...... No. kg 90 Other...... No.

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved

1/ See 9903.88.03. Page 36 of 129 Barcode:3789316-02 A-570-102 INV - Investigation -

EXHIBIT I-7

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Canadian Producers and Exporters of Fabricated Structural Steel Company Address Country Phone Number Web Site 12349 104th Avenue Surrey, BC A.I. Industries V3V 3H2 Canada (604) 583‐2171 www.ai‐industries.com 200 Avenue des Ateliers Montmagny, QC Acier Fortin, Inc G5V 3L6 Canada (418) 248‐7904 www.acierfortin.com 301 Henry‐Bessemer Terrebonne, Quebec ADF Group, Inc. J6Y 1T3 Canada (514) 965‐1911 www.adfgroup.com 783 Polymoore Drive Corunna, Ontario ANJ Industrial Fab Ltd. N0N 1G0 Canada (519) 336‐4265 http://www.anjindustrial.com/ 600, 1re Avenue, Parc Industriel Sainte‐Marie QC Beauce Atlas Steel Fabricators G6E 1B5 Canada (418) 387‐4872 http://www.beauceatlas.ca/ 500 Sagard Street St.‐Bruno de Montarville, Quebec Breton Steel 2016, Inc J3V 6C2 Canada (450) 653‐9999 www.bretonsteel.com 40 Citron Court Vaughan, Ontario Burnco Mfg Inc. L4K 2P5 Canada https://www.burncomfg.com/ 11505, 1re Avenue, Bureau 500 Saint‐Georges, Quebec Canam Buildings and Structures Inc. G5Y 7X3 Canada (418) 582‐3331 www.groupecanam.com 2885, Boul. Frontenac Est Thetford Mins, Quebec Canatal Industries G6G 6P6 Canada (418) 330‐6044 www.canatal.net

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Canadian Producers and Exporters of Fabricated Structural Steel Company Address Country Phone Number Web Site 1355 Saskatchewan Ave. Winnipeg, Manitoba Capitol Steel Corp. R3E 3K4 Canada 20‐784‐8210 www.capitolsteel.ca 1380 rue Graham Bell Boucherville, Quebec Charpentes d' Acier Sofab Inc. J4B 6H5 Canada (450) 641‐2618 http://www.sofab.ca/index.asp?lang=en 570 Wilkinson Avenue Dartmouth, Nova Scotia Cherubini Metal Works Limited B3B 0J4 Canada (902) 468‐5630 www.cherubinigroup.com

430 Industrial Street Beresford Industrial Park Beresford, New Brunswick Coastal Metals Limited E8K 2C2 Canada (506) 783‐0999 http://coastalmetals.ca/ 516 Route 172 Saint‐Nazaire Lac‐Saint‐Jean, Quebec Constructions Proco Inc. G0W 2V0 Canada (418) 668‐3333 www.proco.ca 1515 Kingsway Avenue Port Coquitlam, BC Dynamic Attractions V3C 1S2 Canada (604) 468‐7631 www.dynamicattractions.com 212 ‐ 3601 82 Avenue Leduc, AB JV Driver Fabricators Inc. T9E 0H7 Canada (587) 671‐0448 http://www.jvdriverfabricators.com/ 817 ‐ 50 Street East Saskatoon, Saskatchewan IWL Steel Fabricators LP S7K 3Y5 Canada (306) 242‐4077 https://www.iwlsteel.com/ 300, de la Jacques‐Cartier, Victoriaville, Quebec Les Aciers Solider Inc.? G6T 1Y3 Canada (819) 758‐2897 www.solider‐inc.com

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Canadian Producers and Exporters of Fabricated Structural Steel Company Address Country Phone Number Web Site 600 1re Ave. du Parc‐ Industriel Sainte‐Marie, QC Les Constructions Beauce Atlas, Inc. G6E 1B5 Canada (418) 387‐4872 http://www.beauceatlas.ca/ 2045 4e Rue Saint‐Romuald, QC Les Structures CDL, Inc. G6W 5M6 Canada (418) 839‐1421 https://structurescdl.com/?lang=en 168 Industrial Drive Borden‐Carleton, PE MacDougall Steel Erectors, Inc. C0B 1X0 Canada (902) 855‐2100 http://mseinc.ca/main/ 99 Windsor Junction Road Windsor Junction, Nova Scotia Marid Industries Limited B2T 1G7 Canada 902‐860‐1138 ext 235 https://marid.ca/ 167, rue Armand‐ Bombardier C.P. 4029 Donnacona, Quebec Metal Perreault Inc. G3M 2X2 Canada +1 418 285 4499 www.metalperreault.com

P.O. Box 3586, Main Office 2676 Commerce Street Tracadie‐Sheila, NB MQM Quality Manufacturing, Ltd. E1X 1G5 Canada (506) 395‐7777 https://mqm.ca/ 23 Smith Street St. Catharines, ON Niagara Structural Steel L2P 3J7 Canada 1‐888‐853‐4346 www.niagarastructuralsteel.com 1005, rue Pere‐Daniel Trois‐Rivieres, Quebec Nico Metal Inc. G9A 2W9 Canada (819) 375‐6426 http://www.nico‐metal.com/content en/metal accueil.asp

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Canadian Producers and Exporters of Fabricated Structural Steel Company Address Country Phone Number Web Site 791, 8e Rue La Guadeloupe, Quebec Norgate Metal 2012 Inc. G0M 1G0 Canada 418‐459‐6988 www.norgatemetal.com 550 Wilsey Road Fredericton, NB Ocean Steel & Construction Ltd. E3B 7K2 Canada (506) 632‐2600 http://www.oceansteel.com/home.aspx

400 Chesley Drive Saint John, New Brunswick Ocean Steel & Construction, Ltd E2K 5L6 Canada (506) 632‐2600 http://www.oceansteel.com/home.aspx 7170 Tranmere Drive Pittsburgh Steel Group (2061810 Mississauga, Ontario Ontario Inc.) L5S 1L9 Canada 905‐362‐5097 www.pittsburghsteelgroup.com 516 Route 172 Saint‐Nazaire Lac‐Saint‐Jean, Quebec Proco Construction Inc. G0W 2V0 Canada http://www.proco.ca/ 10496 21 Street NW Edmonton, AB Quality Fabricating and Supply LP T6P 1W4 Canada (780) 468‐6762 http://www.supremegroup.com/quality‐fabricating‐‐supply/ 1145 Industril Drive Armstrong, BC Rapid Span Structures, Limited V0E 1B6 Canada (250) 546‐9676 http://rapidspan.com/ 2 Marconi Road P.O. Box 990 Oxbow, Saskatchewan Saskarc Fabrication S0C 2B0 Canada 1‐800‐667‐5155 http://saskarc.com/ 105, Montee Industrielle Rimouski, Quebec Structures GB Ltee G5M 1A8 Canada (418) 724‐9433 http://structuresgb.com/

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Canadian Producers and Exporters of Fabricated Structural Steel Company Address Country Phone Number Web Site 35B, rue Industrielle St‐Benoit‐Labre, Quebec Structure SBL Inc. G0M 1P0 Canada 418‐230‐3140 www.structuresbl.com 3005, rue des Batisseurs Terrebonne, Quebec Structures XL J6Y 0A2 Canada 450 968‐0800 www.structuresxl.com 600 Jean‐Marchand Levis, Quebec Sturo Metal, Inc. G6Y 9G6 Canada (418) 833‐2107 www.sturometal.com 375, rue de Courcelette Sherrooke, QC Supermetal Structures, Inc J1H 3X4 Canada (418) 834‐1955 https://www.supermetal.ca/ 1955 5e Rue Levis, QC Supermetal Structures, Inc. G6W 5M6 Canada (418) 834‐7691 https://www.supermetal.ca/ 28169 96 Ave. Acheson, AB Supreme Group LP T7X 6J7 Canada (780) 483‐3278 http://www.supremegroup.com/ 1 North Corman Industrial Park Saskatoon, SK Supreme Steel LP S7K 3P5 Canada 306‐975‐1177 www.supremegroup.com 1001 Jarvis Avenue Winnipeg, MB Supreme Steel LP R2X 0A1 Canada (204) 589‐7371 x 242 www.supremegroup.com 1168 Derwnet Way, Annacis Island Delta, BC Supreme Steel Vancouver V3M 5R1 Canada 780‐483‐3278 www.supremegroup.com 5190, rang St‐Mathieu Shawinigan, Quebec TecFab International, Inc. G0X 1L0 Canada 1‐877‐536‐4445 www.tecfab.qc.ca

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Canadian Producers and Exporters of Fabricated Structural Steel Company Address Country Phone Number Web Site 1440, 3e Avenue, Parc Industriel Est Sainte‐Marie‐de‐Beauce, Quebec Trimax Steel, Inc. G6E 3T9 Canada 418‐387‐7798 225 www.trimaxsteel.com 10030 ‐ 34 Street NW Edmonton, Alberta Waiward Steel LP T6B 2Y5 Canada 780‐485‐4794 http://www.waiward.com/ 30 Brentwood Drive Princeton, Ontario Walters Inc. (Princeton Plant) N0J 1V0 Canada 905‐388‐7111 https://www.waltersgroupinc.com/ 1318 Rymal Road East Hamilton, Ontario Walters, Inc. L8W 3N1 Canada (905) 388‐7111 https://www.waltersgroupinc.com/ 12720 ‐ 82nd Avenue Surrey, BC X.L. Ironworks Company V3W 3G1 Canada (604) 596‐1747 http://xliron.com/home.html

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Chinese Producers and Exporters of Fabricated Structural Steel Company Address Phone Number Web Site Floor 5, Room 506 Jingong Building 28 Am Global Shipping Lines Tianjin 022‐23112105 Room 1906, BM Tower 218 Wusong Road Hongkou District, Shanghai American International Cargo Service 200082 Pangang Jinmao Mansion No. 266 Shawan Road Chengdu, Sichuan Angang Group International Panzhihua Company Ltd. 610031 86‐28‐87708865 Fuhuang Industrial Park Huanglu Township Chaohu City Anhui Fuhuang Steel Structure Co., Ltd. Anhui Province 86‐551‐88562928 http://www.fuhuang.cn/ 39# Hongqi South Road Maanshan, Anhui Anhui Masteel Engineering & Technology Group Co., Ltd. 213000 No. 19 South Hongqi Road Economic Tech Development Zone Maanshan, Anhui Anhui Masteel Holly Industrial 243000 86‐555‐8886‐136 No. 26 Qiyun Road Economic Development Zone Hefei Anhui Yingliu Electromechanical Co., Ltd. 230601 86‐551‐382‐1999 http://www.yingliugroup.com/yljten/article/?1/ No. 25 Tongxing Street Anshan Luso Energy Co., Ltd. Zhongshan, Dalian No. 555 Anteng Road Qianshan District Anshan Zizhu International Trading Co. Ltd. Anshan, Liaoning Province No. 15 Anhai Road Qianshan District Anshan Zizhu Material Co., Ltd. Anshan, Liaoning Province http://en.aszizhu.com/

Unit 1902, Building No. 1, Xinyue Square No. 155 Songbao Road Shanghai Auriga Shanghai Enterprise Co., Ltd. 200940 86‐1381897362 http://aurigaeast com/ Unit 1608, Yingqiao Building No. 58 Jinxin Road Pudong, Shanghai Auriga Shanghai Enterprise Co., Ltd. 210206 Baosteel Administrative Center No. 885 Fujin Road Baoshan District, Shanghai Baoshan Iron & Steel Co., Ltd. 201900 +86 21 26647000

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Chinese Producers and Exporters of Fabricated Structural Steel Company Address Phone Number Web Site 2001 Baoyang Road Baoshan District Shanghai Baosteel Construction Co., Ltd. 201900 86‐21‐56123456 www.grandtower.com

No. 95 Minjiang Road 86+0532‐85225888 Jiaozhou Economic and Technological Development Zone Beckmann Volmer Steel Technology Co., Ltd. Qingdao http://www.beckmann‐volmer cn/index.html No. 6 South Street Songzhuang Town Tongzhou District Beijing Beijing Chendong International Modular Housing Corporation 101118 86 10 6959 7331 No. 6 South Street Songzhuang Town Tongzhou District Beijing Beijing Chenghong Waterworks Foundry Co. Ltd. 101118 86 10 6959 7331 A‐318 Huaye International Center No. 39 East 4th Ring Road Beijing Beijing Oriental Technologies 100025 15 Pingguoyuan Road Shijingshan District Beijing Beijing Shougang Mining Construction CO., LTD 100041 86‐010‐88759998 http://www.sgjs.com/ens/

23 Floor, Greenland Commercial Centre No. 1258 Yu Yuan Road Chang Ning District Shanghai C.H. Robinson Worldwide (China), Ltd. 200050 +86 (21) 61020303

13th Floor No. 1258 Yu Yuan Road, Chang Ning District Shanghai C.H. Robinson Worldwide (China), Ltd. 200050 Unit A & B 15/F Chinaweal Centre No. 414 ‐ 424 Jaffe Road Wan Chai Central Oceans Hong Kong Ltd. Hong Kong 0852‐28929205 Changjiang Jinggong Industrial Park Economic Tech. Development Zone Liuan, Anhui Changjiang & Jinggong Steel Building Group Co., Ltd. 237161 86‐564‐3630909

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Chinese Producers and Exporters of Fabricated Structural Steel Company Address Phone Number Web Site Kangzhuang Industrial Park Changzhi City Shanxi Province Changzhi Qinghua Steel Construction Co., Ltd. 046100 86‐355‐3911116 www.qhm.cn

Yinban Village Industrial Concentration Area Henglin Town, Wujin District Changzhou City, Jiangsu Province Changzhou Xinya Outdoor Metal Products Co., Ltd. 213101 0086‐519‐85190068 http://www.xinya com.cn/

88 Qixianghe Avenue Nanjing Economic & Technology Development Zone Jiangsu Province China Construction Equipment & Engineering Co.,Ltd. 210034 86‐025‐85595000 www.cc‐hi.com 33rd Floor, CCSC Buiding 3331 Aohai Central Street Nanshan District Shenzhen Guangdong Province China Construction Steel Structure Corp. LTD 518054 86‐755‐86518668 sstr.cscec com

Flat C & D, 33/F Tower 9 Grand Regentville 9 Wo Mun Street Fanling, N.T. China Grand Engineering Ltd. Hong Kong (852) 2600 4078 http://www.cgrand.com/en/index.aspx Room 2311, 23/F Jin Tian Building No. 1199 Heping Road Luoho District Shenzhen China MAC Cargo Co., Ltd. 518001 85 755 2558 4420 16 Xingfu Road Fengrun District Tangshan City Hebei Province China MCC22 Group Corporation Co., Ltd 064000 86‐315‐3220055 www.22mcc.com.cn 1 Wangjiang Road Yiling District Yichang City Hubei Province China Nuclear Industry 22nd Construction Co., LTD 443100 86‐717‐7850935 http://www.cni22.com.cn No. 587 Chenguang Road Qinzhou Port, Guangxi China Petroleum 6th Construction Company 535008 80 Qingjiang Road Baoji City Shaanxi Province China Railway Baoji Bridge Group Co., Ltd. 721006 86‐917‐3351818 www.crbbi.com

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Chinese Producers and Exporters of Fabricated Structural Steel Company Address Phone Number Web Site 35 Nanhai West Road Shanhaiguan District Qinhuangdao City Hebei Province China Railway Shanhaiguan Bridge Group Co., Ltd. (CRSBG) 066205 86‐335‐7940128 www.crsbg com 15 Sanlihe Road Haidan District Beijing China State Construction Engineering Corporation 100037 86‐10‐8808‐3288 http://www.cscec.com/

Floor 18, Suite 3, Yao Jiang International Tower 308 Wu Song Road City Ocean International (Shanghai Branch) Shanghai China 86‐021‐31319000

Unit 2504, International Capital Plaza 1318 Sichuan Road North Hongkou District Shanghai Conceptum Logistics (China) Co., Ltd. 200080 86 21 36 56 61 00 Unit 703B, R&F Square No. 16 Machang Road Tianhe District Guangzhou, Guangdong Concord Freight System Co., Ltd. 510623 99 Pinggang Road Gaolan Port Economic Zone Zhuhai City Guangdong Province COOEC‐Fluor Heavy Industries Co., Ltd. 519000 86‐756‐6966339 http://www.cooecfluor.com 1 Zhongyuan Avenue Yinyang Township Qidong City Jiangsu Province COSCO (Qidong) OFFSHORE CO., LTD. 226005 86 15951314781 http://www.cosco‐shipyard.com

139 Furao Road Longhe Economic Development Zone Anci District Langfang City CSCEC2BAZ Langfang Steel Structure Manufacturing CorporationHebei Province 86‐316‐2809797 http://www.cscecazgg.com

West Sanshili Viullage, Sanshilibao Street Puwan New District Dalian City, Liaoing Province Dalian Huaxin Heavy Industry Steel Structure Co., Ltd. 116600

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Chinese Producers and Exporters of Fabricated Structural Steel Company Address Phone Number Web Site No. 18 Yaojin Street Ganjingzi District Dalian, Liaoning Dalian Jiazhuo Offshore and Marine Equipment Co., Ltd. 116037 Room 1903, Van Palace 572 Zhongshan Road Dalian, Liaoning Dalian Wan Gao Dricve Tech. Ltd. 116023 No. 316 Huangshi Avenue Huangshi Daye Special Steel Co., Ltd. 435001 0714 ‐6297373

19# Dongfeng 3rd Road, Wuhan Economic & Technological Development Zone,Wuhan City, Hubei Province, Diamond Power Machine (Hubei) Co., Inc. PRC 43005 86 27 5922 2295 Nanmian Industrial Zone Xiegang Town Dongguan, Guangdong Dongguan Grand Machinery & Equipment Co., Ltd. 523603 (86) 769 8210 5668 Lianxing Industrial Area Qishi Town, Dongguan City Dongguan Qiguang Dynamic Steel Structure Co., Ltd. 523500 86‐769‐86789868 http://www.qdsjv.com/en/ Building No. 14, Block 16 188 West Road South 4th Ring Road Fengtai District DUOWEI UNION GROUP CO., LTD Beijing 86‐10‐56305077 http://dwsteelbuilding.com/ 7 Tongfuyu Xufa Industrial Zone Shangcun Village, Gongming Town Ever Blooming Industrial Shenzhen City, Guangdong Room 1705, No. 17 Building No. 39 Jian Wai SOHO East 3rd‐Ring Road Chao Yang District Beijing Expotransworld, Ltd. 100022 (8610) 5869 5300 http://www.expotransworld.com/wordpress/ Shangsan Village #288 Xindeng Town Famous Steel Engineering Company Fuyan City, Hangzhou 86‐571‐87688170 http://www.structural‐steelbuilding.com/ 10th Floor, Ben Ben Mansion No. 300, Xi Kang Road Shanghai FedEx Trade Network Co. Ltd. 200040 86.21.6138.0800 Daqiuzhuang Industrial Park Jinghai District Five Steel (Tianjin) Tech Co., Ltd. Tianjin City 0086 22 5938 5986 https://www.fivesteeltech.com/

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Chinese Producers and Exporters of Fabricated Structural Steel Company Address Phone Number Web Site

Guangyun Road, National Highway 321 Muyuan Village Shishan Town, Nanhai District Foshan Desuman Building Materials Technology Co., Ltd. Foshan City, Guangdong Province 0757‐81163178 http://en.desuman.net/ No. 855 Chaoran Street Hi‐Tech Development Zone Changchun, Jilin Fredenhagen Conveyor Systems (Changchun) Co., Ltd. 130103 86‐43181925858 http://www.fredenhagen.com/yw/Html/Page/AboutUs.html 5 Yanxi Road Hongkuan Industrial Village Yangxia Township Fuqing City Fujian Province Fujian Tung Kang Steel Co., Ltd. 350323 86‐591‐8529‐5118 http://www.tunghosteel.com/ Yingdu Valve Base Nanan, Fujian Fujian Yingtekai Construction and Development Co., Ltd. 362400 86‐633‐8802369

Unit 1161, 11th Floor, Kowloon Bay International Trade & Exhibition Centre 1 Trademart Drive, Kowloon Bay Genegron Engineering Co., Ltd. Kowloon, Hong Kong Xiajie, Lianxing Industrial Park Qishi Town, Dongguan Guandong Qiguang Group Co., Ltd. 523500 0769‐86736888

15/F, Luhui International Hotel No. 12, Yanda 1st Road, Huicheng District Guangdong FY Steel Structure Engineering Co., Ltd. Huizhou, Guangdong 86‐752‐6298999 Jianshe Avenue, China‐ASEAN Nanning Airport Economic Zone Guangxi FY Steel Structure Co., Ltd. Nanning, Guangxi 86‐771‐7668888

3 Jinxiu Road West Section of Guangzhou Economic & Technical Development District Guangzhou, Guandong Guangzhou Delsun Steel Structure Co. Ltd. 510730 86‐20‐82208828 http://www.gzdelsun.com/en/index aspx No. 232 Fuxing Road Fuxing District Handan, Hebei Handan Iron and Steel Group Import & Export Co., Ltd. 056015 86‐310‐6079‐202

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Chinese Producers and Exporters of Fabricated Structural Steel Company Address Phone Number Web Site

45 Yinhu North Road Wuhu Economic & Technology Development Zone Wuhu City Anhui Province Hangxiao Steel Structure (Anhui) Co., Ltd. 241009 86‐55‐3596‐3003 http://www.hxss.com cn/sub_company/i=40&comContentId=40.html 669 North Ring Road Yutian County Tangshan City Hebei Province Hangxiao Steel Structure (Hebei) Construction Co., Ltd 064100 86‐315‐6128636 http://www.hxss.com cn/sub_company/i=41&comContentId=41.html

923 Qinglan Avenue Nanchang City Economic & Technology Development Zone Nanchang City Jiangxi Province Hangxiao Steel Structure (Jiangxi) Co., Ltd. 330013 86‐791‐87601988 http://www.hxss.com cn/sub_company/i=44&comContentId=44.html

No. 8 Jiaozhouwan Industrial Park Phase 2 Jiaozhou City Qingdao 266300 Hangxiao Steel Structure (Shandong ) Co., Ltd 86‐532‐87273788 http://www.hxss.com cn/sub_company/i=43&comContentId=43.html Ruifeng Building No. 3 258 River Road Central Central Shangcheng District Hangzhou City Zhejiang Province Hangxiao Steel Structure Co.,LTD 310003 86‐571‐82645988 www.hxss.com.cn 8, Xiaoran (E) Road Xiaoshan District Hangzhou, Zhejiang Hangzhou East China Steel Structure Co., Ltd. 311201 Hezhuang Street Shunan Village, Xiaoshan District Hangzhou, Zhejiang Hangzhou Hanyu Grid Structure Co., Ltd. 311222 Dayuanxi Road No. 168 Tonglu Town Hangzhou Weidu Steel Structure Co., Ltd. Hangzhou, Zhejiang 86‐571‐64379107 No. 125 Lugang Road Jingxiu District Hebei Construction Group Co., Ltd. Boading City, Hebei Province 86‐312‐3311000 http://www.hebjs.com.cn/

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Chinese Producers and Exporters of Fabricated Structural Steel Company Address Phone Number Web Site No. 1 Jing 15 Road Yanjin County Xinxiang City Henan Province 453000 Henan D.R. Construction Group Steel Structure Co.,Ltd 18303656319 Room 702 Unit 2 Building 2 13 Aoyuan International Apartment Shangwu‐Neihuan Road Zhengzhou, Henan Henan Founder Beyond Industrial Co., Ltd. 450008 86‐371‐6919‐1526 No. 27 Shangwu Neihuan Road Zhengdong New District Zhengzhou, Henan Henan Jiayuan Aluminum Co., Ltd. 450046 86‐371‐6910 2935 http://www.jyalco.com/en/ No. 29 Industrial Park Dinghuo Town, Jiangdu District Hengyuan International Engineering Group Co., Ltd. Yangzhou, Jiangsu 0514‐85338572 http://www.hengyuangroup.com/en/ 8 Automobile Museum East Road Huadian Industrial Park, Building B Fengtai District Huadian Heavy Industries Co., Ltd. Beijing 86‐10‐5196891 www.hhi.com.cn No. 1111 Yuegong Road Huafon Nikkei Aluminium Corporation Jinshan, Shanghai 021‐67276665 http://al.huafeng.com/en/ 151 Dayun Road Zhenhai District Ningbo Province Huaye Steel Structure Co., Ltd. 315221 860574 862‐6034 No. 151 Dayun Road Jiaochuan Str., Zhenhai District Ningbo, Zhejiang Huaye Steel Structure Co., Ltd. 315221 0574‐86262897 Huaye Steel Structure Nuclear Power Equipment Co., Ltd 138‐0663‐6404 289 Yudai North Road Wusong Jiang Development Zone Kunshan City Jiangsu Province Huayin Steel Structure Engineering (China) Co., Ltd 215300 86‐51257599367 www.far‐east‐eng.com 316 Huangshi Avenue Huangshi Hubei Hubei XinYegang Steel Ltd. 435001 Shantou Highway Longxi Town, Bouo County Huizhou Fengyuan Steel Structure Co., Huizhou, Guangdong 86‐752‐6860338 Room 1507, No. 57 Nanyang Plaza Hongtu Road Jangho Curtain Wall Hong Kong Co., Ltd. Kowloon, Hong Kong 852 3499 1645

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Chinese Producers and Exporters of Fabricated Structural Steel Company Address Phone Number Web Site No. 55 Shanghai Road Zhangjiangang Free Trade Zone Zhangjiangang, Jiangsu Jiangsu China Nuclear Industry Libert Inc. 215634 86‐0512‐82008833 http://www.cnlbt.com/ Baijia Village Zhangzhu Township Yixing City http://www.jshngj com/ Jiangsu Province Jiangsu Huning Steel Structure & Machinery Company Ltd. 214231 86‐21 63375270 81 Shidai Avenue Liuhe Economic Development Zone Nanjing City Jiangsu Province Jiangsu Jianghang Construction Engineering Co., Ltd 211500 (86)15952566992 www.jsjhcec.com 3001 Haigong Boulevard Qidong City Jiangsu Province Jiangsu Jinghu Heavy Industry Co., Ltd. 226200 86‐21‐63375270 Chengdong Industrial Park Taixing City Jiangsu Keeboss Steel Structure Co.,Ltd. Jiangsu Province 86‐15261063855 http://www.keeboss.com/ Jiangsu NEW ZTSS Bridge Steel Structure Engineering Co., Ltd. N/A 86‐52384633001 www.ztsschina.com 1 Xiyuan Road Tianmu Lake Industrial Park Liyang, Jiangsu Jiangsu Tianyu Gangwan Heavy Indsutry Co., Ltd. 213300 25 Panlongshan Road Jiangyin City, Jiangsu Jiangyin HRL Equipment Co., Ltd. 214400 0086‐51086198 No. 297 Binjian East Road Jiangsu Province, Jiangyin Jiangyin Xingcheng Special Steel Works Co., Ltd. 6267 Jichang Road Licheng District Jinan City, Shandong Province Jinan Laigang Steel Structure Co., Ltd. 250107 Jinggong Plaze No. 112 Jinkeqiao Road Keqiao District Shaoxing Jinggong Group Corporation 312030 86‐575‐84138666 No. 169 Xihuan Road Xinqiao Town Jiangyin, Jiangsu Jingyin Jianhe Steel Co., Ltd. 214426 86‐13913611332

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Chinese Producers and Exporters of Fabricated Structural Steel Company Address Phone Number Web Site

160 Huanghe Avenue Shijiazhuang High Tech Industrial Development Zone Hebei Province Jinhuan Construction Group Co., Ltd. 050035 86‐311‐85963688 http://www.jinhuansteel.com

No. 160 Huanghe Road Shijiazhuang High Tech Industrial Development Zone Hebei JinHuan Construction Group Co., Ltd. 050035 86 311 85095600 http://www.en jinhuansteel.com/ Suite 3201, Huaying Building No. 5 West Road Qingdao K‐Apex Logistics (Qingdao) Co., Ltd. 266071 86 532 81979982 https://www.apexshipping.com/

Room 713‐715, 7F Taipingyang Commercial Trade Building Jiabin Road Shenzhen City King Compas Logistics Ltd. Guangdong, Hong Kong

Flat F, 10/F Block 1 Golden Dragon Industrial Centre No. 152‐160 Tai Lin Pai Road Kwai Chung, N.T. Kingway Transportation Co., Ltd. Hong Kong (852) 3679 3355 http://www.kw‐log.com/ No. 1399 Feng Xing Road Hua Qiao Town Kun Shan City Kunshan Luvo Greenhouse Co., Ltd. Jiangsu Province No. 8 Hongmen Industrial Area Haizhou Lianyungang Zhenrong Power Transmission Co., Ltd. Lianyungang City, Jiangsu 86‐518‐85280161 http://zrlyg.cn/en/home.htm B2, 8th Floor, 9th Building Jiaoda Kejiyuan Hunan Road Liaocheng, Shandong Liaocheng Suny International Co., Ltd. 252000 86‐635‐7117266 http://www.sunyinternational.com/ 1‐1906 Wang Jing Soho Tower 2 No. 10 Wangjing Street Chao Yang District Beijing LM Wind Power Blades Co., Ltd. (Business Office) 100102 86 10 5796 2100 No. 65 Longhai Road Qinhuangdao Economic and Technological Development Zone Heibei, Qinhuangdao LM Wind Power Blades Co., Ltd. (Qinhuangdao) 66004 86 0335 530 3200

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Chinese Producers and Exporters of Fabricated Structural Steel Company Address Phone Number Web Site

No. 8 Laiyuan Road, Wuqing Development Area Tianjin LM Wind Power Blades Co., Ltd. (Tianjin) 301700 86 22 8219 3100 11th Floor Centro No. 568 Heng Feng Road Shanghai M+R Forwarding (China) Ltd. 200070 86 21 6143 1000 https://www.mrspedag.com/ 388 North Ring Road Wuqiao Village Fengxian District Shanghai Mageba (Shanghai) Bridge Products Co., Ltd. 201402 86‐21‐57407637‐850 https://www.mageba.cn/zh/ 88 West Road No. 2 Konggang Economic Zone Tianjin MCC TianGong Equipment Ltd. 300308 86‐22‐67158666 www.ctmcc.cn 6th Floor, Beijing Changfugong No. 6008 Office Building No. 26 Jian Guo Men Wai Avenue Beijing Mitsubishi Heavy Industries (China) Co., Ltd. 100022 86‐10‐6512‐4321 169 Longjiang Road Taicang Port Development Zone Jiangsu Province Modern Heavy Industries (China) Co., Ltd 215433 86‐13901692764 http://www.mdhichina.com No. 1 Sensong Road Changjiang Town (Rugao Port Area) Morimatsu (Jiangsu) Heavy Industry Co., Ltd. Rugao city, Jiangsu 86‐513‐6600‐9300 Nanjie Resources Co., Ltd. No. 1288 Jiangdong 2nd Road

88# Qixianghe Road Economic and Technical Development Zone Nanjing China Construction Chemical Equipment Nanjing, Jiangsu Manufacturing Co., Ltd. 210034 86‐25‐8559‐5020 http://www.cc‐hi.com/m/?Home.html No. 500 Yagang Road Malu Town Jiading District National Oilwel Varco Petroleum Equipment (Shanghai) Co., Shanghai Ltd. 201801 Suite 1618‐1622, Hitime Mansion No. 289 Wujin road Hongkou District Neptune Shipping Ltd. Shanghai No. 308 Chengdong Hualun Industrial Zone Housuo Village, Chaiqiao Town Ningbo G.C. Steel Products, Co., Ltd. Ningbo, Zhejiang

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Chinese Producers and Exporters of Fabricated Structural Steel Company Address Phone Number Web Site Shounan Chating Industry Park Mingguang Road No. 1852 Yinzhou District Ningbo High Quality Machinery Co., Ltd. Ningbo 0086‐574‐88162088 http://www.qualitynb.com Xiangxi Industrial Zone Xizhou Town, Xiangshan County Ningbo Ningbo Lehui International Engineering Equipment Co., Ltd. 315723 86‐574‐6583‐2846 82 Fengheng Road Baidu Industrial Zone Ningbo Tuoxing Precision Casting Co., Ltd. Xiwu Town, Ningbo City 0086‐574‐88545657 http://www.tosing‐casting com/honour1/ 5th Floor, No. 438 Zhujiang Road Beilun Ningbo, Zhejiang Ningbo Zhongjiang High Strenght Structure Co., Ltd. 315800

Floor 9 International Business Garden Lane 280 Linhong Road Changning Shanghai Ningbo Zhongjiang High Strength 200335 438 South Zhujiang Road, Building 5 Beilun District Ningbo City Zhejiang Province Ningbo Zhonglian Steel Structure Co., Ltd. 315800 86‐57486839333 www.nssteel.com cn No. 9 Dazhai Road Minying Industrial Zone Fuqiao Twon, Taicang NRS Jiangsu Machinery and Heavy Industry Co., Ltd. 215434 0512‐82780866 http://www.nrsjs.com/ No. 3 Ronghaierlu Road Qingda Industrial Zone Ocean Master Steel and Plastic Co., Ltd. Chengyang, Qingdao 86 ‐ 0532‐5567‐8908 http://en.haishuo.cn/ No. 199 Haibin 15 Road Tianjin Port Free Trade Zone Tianjin Offshore Oil Engineering Co., Ltd. 300461 86‐22‐5989‐8888 http://www.cnoocengineering.com/ No. 117 Baichuan Road Caotang, Sanzao Town Zhuhai City, Guangdong Oneworld Composite Fabrication 519040 18 Floor, Times Square 52 Hong Kong Mid Road Orient Express Container Group (Qingdao) Qingdao 86‐532‐83990000 Unit B, 6th Floor United Overseas Plaza 11 Lai Yip Street Oriental Air Transport Service Ltd. Kwun Tong, Kowloon, H.K. (852) 2363 9265

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Chinese Producers and Exporters of Fabricated Structural Steel Company Address Phone Number Web Site

9 Fuxing Road North District, Zhangjiagang Economic Development Zone Zhangjiagang City Jiangsu Province Peikko Construction Accessories (Zhangjiagang) Co., Ltd 215600 86‐512‐58309902 www.peikko.com Xingangcun Lingang Industrial Zone Changxindao, Dalian POSCO‐China Dalian Steel Fabricating Center 332512

No. 28 Chuanghe Steel Structure Road Qingdao International Industrial Zone Qingda, Shandong Qingdao Baorun Steel Structure Engineering Co., Ltd. 266000 0086‐532‐66005022 http://www.cnbaorunsteel.com/ No. 566 Tongan Road Qingdao Qingdao Eagle Power Industrial Co., Ltd. 266300 86‐0532‐88786159 http://www.chinaeaglepower.com/ No. 777 Shanhai Road Zhangjialou Industrial Partk Huangdao District Qingdao, Shandong Qingdao Havit Steel Structure Co., Ltd. 266000 0086‐532‐86607727 https://www.havitsteelstructure.com/ Three City Road 86‐1 South Village Guo Zhuang 0532‐82328888 Pingdu City, Qingdao Qingdao Tianxiang Foods Group Co., Ltd. 266737 http://www.tianxianggroup.cn/ Room 3D, Area A, Fullhope Plaza No. 12 Hongkong Mid‐Road Qingdao Qingdao Tony Machinery & Equipment Co., Ltd. 266071 0086 532 85710072 http://www.tonymachinery.com.cn/ 8 Puji Industrial Zone No. 2 Qingdao Jiaozhou City Shandong Province 266326 Qingdao Yinglong Machinery Co, Ltd 86‐0371‐6578‐6089 http://www.qdyinglong.com/ No. 81 Taiyuan Road Rizhao, Shandong Rizhao DingLi Steel Structure, Co., Ltd. 276800

No. 1388 East Xiushan Road Haimen Economic Technology Development Zone Haimen, Nantong Rotary Lift Consolidated Co., Ltd. 226100 86 13 8222 1748

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Chinese Producers and Exporters of Fabricated Structural Steel Company Address Phone Number Web Site No. 50, Lane 100, Jiaqian Road Nanxiang Town, Jiading District Rough Brothers Greenhouse Manufacturing (Shanghai) Co., Shanghai Ltd. 201802 0086‐21‐69173540 http://www.roughbroschina.com/ Suite 17F,G Jin An Tower No. 908 Da Ming Road East Shanghai SeaTrade International (Shanghai) Inc. 200082 021‐65959001

1996 Century Ave. Mingshui Economic Development Zone Jinan City Shandong Province Shandong Haiyang Fenghui Equipment Technology Co; LTD 250200 18663800119 www.fhjs.net No. 318, Xingye 6 Road Economic Development Zone Shandong Huaxing Steel Structure Co., Ltd Boxing County, Shandong Province 86‐543‐2127969 http://www.hxstructure com/ No. 233 Nan'er Road Dongying City, Shandong 1 86 400 8129003 Shandong Kerui Petroleum Equipment Co., Ltd. 257067 http://petroleum.keruigroup com/kr/en/ 1 Kangtai Road Shizhong District Jining City Shandong Province Shandong Luneng Guangda Steel Structure Co., Ltd 272015 86.0537.2351019 No. 858 North of yikang Road Tengzhou, Shandong Shandong Sunway Steel Building Co., Ltd. 277500 www.svbuilding.com

04899 Haifeng Road Advance Manfuactruing Industrial Park Binhai Economic Development Zone Weifang City Shandong Yijie Hongfeng Energy Equipment CO., LTD Shandong Province 05362099701/18053603308 www.htgsteel.com cn No. 176 New Nanhuan Road Liaocheng City Shandong Zhongao Blanket & Carpet Engineering Co., Ltd. Shandong Province

16th Floor, Industry & Commercial Building No. 45 East Yan'An Road Shanghai Asian Development Prosperous Import and Export Shanghai Co., Ltd. 200002 400‐852‐6692 http://www.adpsh.com/ Lane 550, Keshan Road Baoshan District, Shanghai Shanghai Baosteel Engineering & Technology Group Co., Ltd. 201999 86 021 26087934 http://www.baosteelengineering.com/en/

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Chinese Producers and Exporters of Fabricated Structural Steel Company Address Phone Number Web Site 77 Qing'an Road Baoshan District Shanghai Shanghai Baoye Group Corp., Ltd. 200941 86‐215664 www.sbc‐mcc.com 3768 Panjing Road Baoshan District Shanghai Shanghai COSCO Kawasaki Heavy Industry Steel Structure CO. 201908 86‐13501781901 No. 2501 Xuanhuang Road Nanhui Industrial Park Shanghai Shanghai Eastern Sun Steel Structure Co., Ltd. 201300 86‐021‐68015986 www.en.essschina.com/

12th Floor, 2nd Building, Shanghai International Design Exchange Center No. 1080 Changyang Road Yangpu District Shanghai Shanghai Everest International Logistics Co., Ltd. 200082 86‐21‐65958899 http://www.everest‐china com/en/index/ Room 324, 227 Rushan Road Pudong District 201204 Shanghai Greenland International Co., Ltd. Shanghai 86‐21‐68873115 http://www.greenlandsh.com/contact.htm 12th Floor Tongji‐Jingdu Building 25 Yixian Road Yangpu District Shanghai Shanghai Hope Steel Structure Co., Ltd. 200437 86‐021‐55880031 http://www.hope‐steel.com/

Suite 3602, No. 3000 North Zhongshan Road Shanghai Shanghai International Aerotech Trading Co., Ltd. 200063 No. 815 North Xizha Road Xidu Town Fengxian District Shanghai Shanghai Matsuo Fashion Co., Ltd. 201401 815 Xixha Road Fengxian District Shanghai Shanghai Matsuo Steel Structure Co., Ltd 201401 02‐1‐57158080 http://www.matsuo com.cn/e/gsjj.asp No. 815 North Xizha Road Xidu Town Fengxian District Shanghai Shanghai Matsuo Steel Structure Co., Ltd. 201401 86 21 5715 8080

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Chinese Producers and Exporters of Fabricated Structural Steel Company Address Phone Number Web Site 777 Pangu Road Shanghai SHANGHAI MCC20 Construction Co.,Ltd 201900 86‐86213621378 20th Floor Yuan Mansion 783 Dongfang Road Shanghai Shanghai Metal Corporation 200122 86‐21‐5830‐9368 https://www.shanghaimetal.com/

14th Floor Rongsheng Building No. 2 Shanghai Shanghai Modern Steel Co.,Ltd. 200120 86 13127550045 No. 3111 West Huancheng Road FengPu Industrial Park Shanghai Shuangyan Chemical Equipment Manufacturing Co., Shanghai Ltd. 201401 0086‐21336550

Room 618 No. 580 West Nanjing Road Shanghai Shanghai Solex Logistics 200041 996 Shenzhen Road Binjiang Street Haimen City Jiangsu Province Shanghai Steel Structure Construction (Jiangsu) Co., Ltd 226100 0513‐68909090

Room 703, No. 2, Lane 99 Baotun Road HuangPu district Shanghai Shanghai Xin Yi Tong Import & Export Co., Ltd. 200120 1459 Canggong Road Fengxian District, Shanghai Shanghai Yanda Engineering Co., Ltd. 201417 86‐2157448229 http://yanda.com.cn/ 3261 Dongfang Road New Pudong District Shanghai Shanghai Zhenhua Heavy Industries Co, Ltd. 200125 86‐021‐31193417 www.zpmc.com Fenghui Village Industrial Park Shangyu District Shaoxing City Zhejiang Province Shaoxing Feng'an Steel Structure Co., Ltd. 312361 0575‐82877211 http://www.sxfengan.com/index.php Unit 1608, Yingqiao Building No. 58 Jinxin Road Pudong, Shanghai Shenji International Company 210206

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Chinese Producers and Exporters of Fabricated Structural Steel Company Address Phone Number Web Site 40 Xihe Road Jiajiang County Sichuan Province Sinohydro Jiajiang Hydraulic Machinery Co., Ltd 614100 86‐2887777561 http://www.jhmw.com/en/

Haiqiang Road East Taishang City Haigang Development Zone Laoting County Tangshan City Hebei Province Sinoma Tangshan Port Equipment Manufacture Co., LTD 063611 15100527228 www.sinomazchg.com

No. 8 Building, Shenggu Home, Shenggu Middle Road Chaoyang District Beijing Sinopec Engineering (Group) Co., Ltd. 100029 0086‐10‐56730600 http://www.segroup.cn/segroup/en/ 168 Siyuan Road Shanghai Steel Structure Eng Company of SH Baoye Group Corp., Ltd. 200941 86‐13801842287

9‐11F, SUMEC Building, 198 Changjiang Road Nanjing SUMEC International Technology Co., Ltd. 210018 86 25 84531171 http://technology sumec.com/en/

Room 2918 Lane Sheng Mori Building 51 Tibet Road Pudong New Area Sunhel Heavy Industry Group Co., Ltd. (AKA Seward Group Co. Shanghai Ltd.) 201206

No. 288 Yitang Road Wujiang Economic Development District Suzhou ACE Sheet Metal Manufacturing Co., Ltd. Suzhou 0512‐6363‐8081 http://www.ace‐sz.com/en/ 1700 Air China Plaza 36 XiaoYun Lu Chaoyang District Takraf Tenova Mining Technology Co., Ltd. Beijing

14 4th Avenue Economic & Technology Development Zone Tianjin Tianjin Bomesc Offshore Engineering Company Limited 300457 86‐2266299900‐6303 http://www.bomesc.com/index.html 1 Kaihua Road New Technolgoy Industrial Park Nankai District Tianjin Tianjin Eng& Con Corporation Steel Structure Company 300384 86‐022‐28553806 [email protected]

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved Page 60 of 129 Barcode:3789316-02 A-570-102 INV - Investigation -

Chinese Producers and Exporters of Fabricated Structural Steel Company Address Phone Number Web Site 139 Xiamen Road Tanggu Binhai New District Tianjin Tianjin Heavy Steel Mechanical Equipment Co., Ltd 300459 022‐25214991 No. 18 Xiangshan Road Hangu Modern Industrial Park Teda, Tianjin Tianjin Xingchuan Heavy Machinery Co., Ltd. 300480 9 Xuri Street Yingcheng Industrial Park Hangu, Tianjin Tianjin Zhenhan Steel Mechanical Equipment Co., Ltd. 300480

Building A, Kuangshi International Building Xiangluowan Business District Binhai New District Tianjin Tianjin Zhongji Equipment Manufacture Co., Ltd. 300450 8622‐25268950 http://www.tjzjem.com/index.html 3rd Industrial Zone Tangxiayong Songgang Top Direction Machinery (Shenzhen) Co., Ltd. Shenzhen

20th Floor, 3rd Bldg Shang Dong Business Centre No. 1926 Cang Hai Road Jiang Dong District U.S. United Logistics Inc. Ningbo, Zhejiang Province 0086‐574‐87170700 http://www.cnuul.com/ Room 1805 Guangzhou Window Business Port 368 Lijiao Road Haizhu District Guangzhou City Guangdong Province United Steel Structure, Ltd. 510000 86 20 81592409‐309 www.ussl.com Balitai Industrial Park Jinnan District Tianjin USP Tianjin Wanlite Constrution Steel Products Co., Ltd. 300350 http://en.uspchina.com/comcontent detail/i=18&comContentId=18.html

100 Rongchang Road Songjiang Industry Development Zone Shanghai Valmont Industries (China) Co., Ltd 201611 B2507, No. 5111 Shengli East Street Weifang Wilda International Trading Co., Ltd. Weifang, Shandong

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved Page 61 of 129 Barcode:3789316-02 A-570-102 INV - Investigation -

Chinese Producers and Exporters of Fabricated Structural Steel Company Address Phone Number Web Site No. 189 Jianghi Road 3rd Port Industrial District Technological Development Zone Nantong Wilson (Nantong) Heavy Industry Co., Ltd. 226009 8 Wanchun Middle Road Jiujiang, Wuhu Wuhu Tianhang Technology (Group) Co., Ltd 241007 86‐0553‐5720397 http://www.tianhanggroup.com/ Yangnan Road Luoshe Town, Wuxi City Wuxi ABK Machinery Co., Ltd. 214154 86‐510‐83555592 http://m.weldc.com/index.html Yangshi Township Huishan Distict Wuxi City Jiangsu Province WUXI CHUXIN STEEL STRUCTURE PROJECT LIMITED CORPORATIO214154 86 510 53 555 222 www.chuxinsteel.com No. 32 Xinshun Road Luoshe Town Wuxi Shuanghuan Heavy Indsutry Co., Ltd. Wuxi, Jiangsu 86‐0510‐83832267 http://www.wxshuanghuan.com/en/index.asp Jiulong Industrial Park Hua'an County Zhangzhou City Fujian Province Xiamen NCC Steel Engineering Co., Ltd (Zhangzhou factory) 363800 0086‐13959291660 www.nccst.com No. 39 Xingbei Road Jimei District Xiamen New Changcheng Steel Engineering Co., Ltd. Xiamen 86‐0592‐6666688 www.nccst.com

Bai Ta Market, West of 107 State Road Qiaodong District Xingtai City, Hebei Province Xingtai Anju Guardrail Co., Ltd. 054100 1‐707, Building 4, Xichenghuating Quanshan Dist. Xuzhou LF Engineering & Construction Co., Ltd. Xuzhou, Jiangsu 1459 Cangong Road Fengxian District Shanghai Yanda (Haimen) Heavy Equipment Manufacturing CO., Ltd 201417 86‐139‐1243‐9400 http://yanda.com.cn

Fangxiang Industrial Concentration Zone Northern Suburbs, Yangzhou Yangzhou Xiangyuan Electrical Equipment Co., Ltd. 225117 0514‐87385218 http://en.yzxiangyuan.cn/ Chemical Road South Lingang Chemical Park Cangzhou Yinghai (Cangzhou) Aroma Chemical Co., Ltd. 061108 0317‐5687865 http://www.yinghai.com/

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved Page 62 of 129 Barcode:3789316-02 A-570-102 INV - Investigation -

Chinese Producers and Exporters of Fabricated Structural Steel Company Address Phone Number Web Site 34 Anle Street Tiedong District Anshan City Liaoning Province Yingkou Steel Structure Sub‐Co. of Ansteel Construction Group 114004 086‐0417‐619448 184 West Suxi Road Huazhuang Town Wuxi City, Jaingsu Yitai Heavy Machinery Company Limited (Jiangsu) 214132 0510‐85615158 http://www.yitaizg.com/ No. 19 Chenxin Road Yangshe Town Zhangjiangang City Zhangjiangang Furui Special Equipment Co., Ltd. 215637 86‐0512‐58982158 http://www.furuise.com/ 6 Qiannong First Road Qianjiang Farm Hangzhou City Zhejiang Province Zhejiang Dadi Steel Structure Co., Ltd. 311231 86‐571‐8283‐0633 Floor 2, Comprehensive Market Fuyu, Lishui Zhejiang Jiacheng Construction Engineering Co., Ltd. 310024 86‐13394117355 No. 62Yashan Road, Zhapu Jiaxing City Zhejiang Jiangnan Steel Structure Co., Ltd. Zhejiang Province 86‐0573‐85118888 http://www.zjcne.com 29th Floor Asia Financial Center 999 Li'an Road Minhang District Shanghai Zhejiang Jinggong Heavy Steel Structure Co., Ltd. 201199 86‐575‐89185989 www.600496.com 27 Linhai Road Zhenhai District Ningbo City Zhejiang Province Zhejiang Provincial Erjian Steel Structure Co., Ltd. 315207 13777222766 Yaqian Road Yaqian Industrial Zone Xiaoshan District Hangzhou City Zhejiang Province Zhejiang SouthEast Space Frame Co., Ltd 311209 86‐571‐82782741 www.dongnanwangjia.com No. 245 Binkang Road Bingjiang Hangzhou Zhejiang Zhongnan Steel Structure Co., Ltd. 310052 086‐571‐8662 4508

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved Page 63 of 129 Barcode:3789316-02 A-570-102 INV - Investigation -

Chinese Producers and Exporters of Fabricated Structural Steel Company Address Phone Number Web Site 11F, 98 West Zhongshan Road Zhenjiang Jiangsu Zhenjiang Great Honest Inc. 86‐511‐85898001 http://www.zjghi.com/Demo elinkus.asp

Jumin Road No. 66 Dongqiao Town, Xiangcheng District Zhong Yifeng Construction Group Co., Ltd. ‐ Steel Structure Suzhou, Jiangsu Branch 215152 26 Weiyi Road Liaocheng Phoenix Industrial Park Shandong Province Zhongtong Steel Structure Co., Ltd. 252000 86‐635‐2126610 www.cztss.com 10/F Ciwan Petroleum Building Shekou, Shenzhen Zhuhai Jutal Offshore Oil Services Limited 518068 86‐755‐26837508 http://www.jutal.com/

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved Page 64 of 129 Barcode:3789316-02 A-570-102 INV - Investigation -

Mexican Producers and Exporters of Fabricated Structural Steel Company Address Phone Number Web Site

Camino a Los Borregos 1105 Pte. Clenega de Flores, N.L ACERO TECNOLOGIA, S.A. DE C.V. C.P. 65550 52‐81‐8154‐5650 www.atecno.com.mx

Prolongacion Carretera San Roque No. 502 Colonia Los Ebanitos Juarez, Nuevo Leon Aceros Lozano S.A. de C.V. C.P. 67279 52 81 8127 9000 www.aceroslozano.com

Calle J. Guadalupe Gallo No. 16 Col La Tijera Tlajomulco de Zuniga, JAL Acesta S.A. de C.V. C.P. 45647 +52 33 3283 0500 www.acesta.com.mx Carr. Chihuahua ‐ Delicias Em. 207 + 700 Mts. Ejido Santa Eulalia Aquiles Serdan, CHH Aciarium Estructuras S.A. de C.V. (614) 429‐6600 ext 313 http://emycsa.com/ Calle Huetamo #81 Jardines del Pedregal Tecate, BCN ASI Baja, S. de R.L. de C.V. C.P. 21460 (770) 490‐8341 www.aimsteelbaja.com Calle Cinco Norte No. 3 Parque Industrial Toluca, EM BBM‐CPG Mexicana S.A. de C.V. C.P. 50233 722‐2497070 Lote 13, Manzana 2 Parque Industrial Tula Atitalaquia, Hidalgo Construcciones Industriales Tapia S.A. de C.V. C.P. 42970 01(773)1006100 www.citapia.com.mx Carretera a la Capilla Km 1.5 San Jose del Castillo Corey S.A. de C.V. El Salto, Jalisco 52‐33‐3668‐0644 www.corey.com.mx

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved Page 65 of 129 Barcode:3789316-02 A-570-102 INV - Investigation -

Mexican Producers and Exporters of Fabricated Structural Steel Company Address Phone Number Web Site Cerrada del Petroleo 8 Mesta del Chema Estructuras Metalicas la Popular S.A. de Tijuana, Baja California C.V./MSCI C.P. 22224 (664) 626‐85‐90 www.estructurasmetalicaslapopular.com

Antiguo Camino a la Capilla No. 1980 La Capilla Exportadora de Postes GDL S.A de C.V Ixtlahuacan de los Membrillos, JAL GRUPO POLESA C.P. 45870 52 (33) 3668 6300 www.polesa.com.mx Av. Jatnil #58 Cucapah Industrial Park Mexicali, BC Grupo Industrial Persal S.A. de C.V C.P. 21210 (619) 400‐4134 www.persal.com.mx Lemans #900 Col. Guadalupe Industrias Metalicas De Monclova S.A. De Monclova, COA C.V. (IMMSA) C.P. 25750 52‐866 6341860 https://www.immsa.com/web/index.php/es/ Camino el Carricito S/N Tijuana, Baja California KS Fabrication de Mexico C.P. 22260 011‐52 (664) 188 6081 www.ksfab.com.mx

Carretera 30 Km 10.2 No. 1262 Fraccionamiento, San Antonio Frontera, Coahuila Montajes Frontera S.A. C.P. 25628 52(866)6342593 http://www.montajesfrontera.com/

Lago Zurich No. 245 Edificio Frisco Plaza Carso, 2nd Floor Col. Granada Ampliacion Mexico City, DF Operadora CICSA, S. A. de C. V. C.P. 11529 521 7838390086 www.swecomex.com.mx Calle 5 No. 899 Zona Industrial Operadora CICSA, S. A. de C. V. Swecomex ‐ Guadalajara, Jalisco Guadalajara C.P. 44940 52 38811400 www.swecomex.com.mx

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved Page 66 of 129 Barcode:3789316-02 A-570-102 INV - Investigation -

Mexican Producers and Exporters of Fabricated Structural Steel Company Address Phone Number Web Site

Carretera Fedeeral 140 Xalapa‐Veracruz km 93 S/N Colonia Bruno Pagliai. Veracruz Veracruz Preacero Pellizzari Mexico S.A. de C.V. C.P. 91697 58 276 3563022 http://preacero.com/home/ Carretera a Laredo Km. 21 Apodaca, NL Valmont Monterrey, S. de R.L. de C.V. C.P. 66600 www.valmontutility.com

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved Page 67 of 129 Barcode:3789316-02 A-570-102 INV - Investigation -

EXHIBIT I-8

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved Page 68 of 129 Public Data Barcode:3789316-02 A-570-102 INV - Investigation -

U.S. Imports for Consumption of Certain Fabricated Structural Steel*

Calendar Year January ‐ October 12‐Months Ending Oct 2018 Source 2015 2016 2017 2017 2018 % Change Tons % of Total Quantity (Short Tons) World 1,027,942 1,221,135 1,226,834 1,049,578 1,095,618 4.4% 1,272,874 100.0%

Canada 168,828 227,763 235,997 193,412 213,279 10.3% 255,863 20.1% China 368,637 476,814 492,833 430,899 419,948 ‐2.5% 481,883 37.9% Mexico 246,176 224,420 220,748 185,770 265,700 43.0% 300,677 23.6% Subtotal 783,641 928,997 949,578 810,081 898,927 11.0% 1,038,424 81.6% % of Total 76.2% 76.1% 77.4% 77.2% 82.0% 81.6%

All Others 244,300 292,137 277,256 239,497 196,691 ‐17.9% 234,450 18.4%

* Certain Fabricated Structural Steel includes imports under HTS Codes 7308.90.3000, 7308.90.6000, and 7308.90.9590. The data were reported in kilograms and converted to short tons using 2.2046 pounds per kilogram and 2,000 pounds per short ton.

Source: U.S. International Trade Commission, DataWeb service, available at https://dataweb.usitc.gov/. Data downloaded on 12/21/2018.

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved Page 69 of 129 Public Data Barcode:3789316-02 A-570-102 INV - Investigation -

U.S. Imports for Consumption of Certain Fabricated Structural Steel*

Calendar Year January ‐ October 12‐Months Ending Oct 2018 Source 2015 2016 2017 2017 2018 % Change Value % of Total Customs Value (U.S. Dollars) World $3,045,785,195 $3,342,162,278 $3,473,806,190 $2,907,904,517 $3,193,438,777 9.8% $3,759,340,450 100.0%

Canada $466,170,593 $627,856,076 $658,252,574 $540,886,036 $596,663,779 10.3% $714,030,317 19.0% China $711,970,762 $827,492,335 $841,679,628 $728,692,089 $808,226,490 10.9% $921,214,029 24.5% Mexico $512,004,630 $401,294,571 $406,616,401 $335,903,850 $518,912,518 54.5% $589,625,069 15.7% Subtotal $1,690,145,985 $1,856,642,982 $1,906,548,603 $1,605,481,975 $1,923,802,787 19.8% $2,224,869,415 59.2% % of Total 55.5% 55.6% 54.9% 55.2% 60.2% 59.2%

All Others $1,355,639,210 $1,485,519,296 $1,567,257,587 $1,302,422,542 $1,269,635,990 ‐2.5% 1,534,471,035 40.8%

* Certain Fabricated Structural Steel includes imports under HTS Codes 7308.90.3000, 7308.90.6000, and 7308.90.9590.

Source: U.S. International Trade Commission, DataWeb service, available at https://dataweb.usitc.gov/. Data downloaded on 12/21/2018.

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved Page 70 of 129 Public Data Barcode:3789316-02 A-570-102 INV - Investigation -

U.S. Imports for Consumption of Certain Fabricated Structural Steel* From Canada, China, and Mexico Have Entered The U.S. Every Month Since January 2015

Period Canada China Mexico Subject Jan‐15 10,699 25,949 14,818 51,466 Feb‐15 8,498 21,905 14,164 44,567 Mar‐15 12,613 32,155 15,764 60,532 Apr‐15 11,477 29,288 15,903 56,668 May‐15 11,894 31,158 19,209 62,261 Jun‐15 16,485 30,988 21,660 69,133 Jul‐15 16,770 28,144 25,367 70,280 Aug‐15 14,580 21,782 24,997 61,360 Sep‐15 16,830 28,099 21,553 66,482 Oct‐15 18,071 30,619 25,304 73,993 Nov‐15 16,635 44,585 24,949 86,169 Dec‐15 14,275 43,965 22,489 80,730 Jan‐16 14,623 48,764 20,231 83,618 Feb‐16 16,839 42,242 13,121 72,202 Mar‐16 16,206 43,432 15,197 74,835 Apr‐16 17,548 49,225 17,199 83,972 May‐16 21,619 43,755 18,074 83,448 Jun‐16 20,953 42,031 18,655 81,639 Jul‐16 22,816 38,000 18,023 78,839 Aug‐16 19,491 39,137 21,580 80,208 Sep‐16 16,890 35,110 21,016 73,016 Oct‐16 21,777 29,563 20,132 71,472 Nov‐16 19,938 34,703 20,325 74,966 Dec‐16 19,064 30,850 20,866 70,781 Jan‐17 17,654 38,920 20,536 77,111 Feb‐17 16,283 60,655 16,581 93,520 Mar‐17 18,750 38,354 19,340 76,443 Apr‐17 17,589 40,317 17,650 75,556 May‐17 19,160 48,936 19,127 87,222 Jun‐17 17,843 45,200 19,273 82,317 Jul‐17 19,857 48,891 18,795 87,543 Aug‐17 21,687 41,756 16,710 80,153 Sep‐17 18,561 34,457 17,552 70,570 Oct‐17 26,028 33,411 20,207 79,647 Nov‐17 21,980 30,537 17,779 70,296 Dec‐17 20,604 31,398 17,198 69,201 Jan‐18 18,677 37,282 22,640 78,599 Feb‐18 20,975 41,287 21,272 83,533 Mar‐18 18,825 32,926 24,227 75,978 Apr‐18 21,286 39,148 24,843 85,277 May‐18 23,280 50,505 25,053 98,839 Jun‐18 23,789 46,210 28,570 98,569 Jul‐18 23,037 57,616 28,311 108,964 Aug‐18 20,700 59,033 32,439 112,172 Sep‐18 19,014 26,008 26,826 71,848 Oct‐18 23,695 29,934 31,520 85,149

CY 2015 168,828 368,637 246,176 783,641 CY 2016 227,763 476,814 224,420 928,997 CY 2017 235,997 492,833 220,748 949,578

Jan‐Oct 2017 193,412 430,899 185,770 810,081 Jan‐Oct 2018 213,279 419,948 265,700 898,927

Source: U.S. International Trade Commission, DataWeb service, available at https://dataweb.usitc.gov/. Data downloaded on 12/21/2018.

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved Page 71 of 129 Public Data Barcode:3789316-02 A-570-102 INV - Investigation -

Subject U.S. Imports of Certain Fabricated Structural Steel* Compete With U.S. Production And Other Subject Imports Throughout The U.S.

Calendar Year Jan‐Oct Customs Distric Source 2015 2016 2017 2018 Anchorage, AK Canada 202 239 99 95 China 6 2,609 180 2 Baltimore, MD China 4,047 5,331 4,650 33,000 Boston, MA Canada 1 0 2 0 China 3,933 5,207 3,101 4,081 Mexico 03 00 Buffalo, NY Canada 24,784 30,397 48,000 38,182 China 172 262 176 201 Mexico 0121 0 Charleston, SC Canada 0 0 0 0.4 China 11,100 11,158 18,639 9,298 Charlotte, NC Canada 0 3 0 0 China 683 1,941 1,397 1,088 Chicago, IL Canada 0 0 0 1 China 19,657 19,221 25,220 17,710 Mexico 01 00 Cleveland, OH Canada 12 1 21 4 China 9,370 8,772 8,300 7,820 Mexico 02 00 Columbia‐Snake, OR Canada 0 0.2 0 0 China 3,522 5,853 5,430 5,133 Dallas‐Fort Worth, TX China 11,224 12,692 12,012 10,193 Mexico 12 00 Detroit, MI Canada 31,148 47,920 45,814 42,362 China 2,043 2,326 2,652 2,414 Mexico 12 11 Duluth, MN Canada 56 6 0 67 China 3,616 2,203 2,012 1,876 El Paso, TX Canada 0 0 0 5

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved Page 72 of 129 Public Data Barcode:3789316-02 A-570-102 INV - Investigation -

Subject U.S. Imports of Certain Fabricated Structural Steel* Compete With U.S. Production And Other Subject Imports Throughout The U.S.

Calendar Year Jan‐Oct Customs Distric Source 2015 2016 2017 2018 China 488 5,032 10,171 1,528 Mexico 20,177 17,706 24,418 26,398 Great Falls, MT Canada 3,980 3,737 6,395 8,084 China 16,449 13,857 7,103 6,630 Mexico 11 00 Honolulu, HI Canada 18 66 294 181 China 521 2,331 817 7,523 Mexico 24 53 0 3 Houston‐Galveston, TX Canada 124 0 98 14 China 45,370 39,252 35,767 57,197 Mexico 20,969 1,754 3 0 Laredo, TX Canada 8 0 10 0 China 24 157 46 85 Mexico 165,230 165,283 152,822 178,606 Los Angeles, CA Canada 0 10 0 0 China 112,738 131,977 143,679 115,861 Mexico 22 7 1 0 Miami, FL Canada 0 0 8 0 China 3,887 4,609 5,554 5,785 Mexico 03 00 Milwaukee, WI China 20 011 Minneapolis, MN Canada 0 0.3 0 0 China 8,788 26,130 19,461 16,614 Mexico 10 00 Mobile, AL China 2,170 4,520 6,747 5,068 New Orleans, LA Canada 18 13 3 2 China 7,378 20,582 2,664 4,983 Mexico 173 0 1 237 New York, NY Canada 1 0 1 0 China 30,201 43,114 39,713 29,877 Mexico 11 16 Nogales, AZ

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved Page 73 of 129 Public Data Barcode:3789316-02 A-570-102 INV - Investigation -

Subject U.S. Imports of Certain Fabricated Structural Steel* Compete With U.S. Production And Other Subject Imports Throughout The U.S.

Calendar Year Jan‐Oct Customs Distric Source 2015 2016 2017 2018 Canada 1 0 0 0 China 5 23 129 31 Mexico 1,187 2,212 1,153 1,591 Norfolk, VA China 6,603 12,152 8,924 9,968 Ogdensburg, NY Canada 42,289 48,708 52,011 38,423 China 250 407 154 210 Mexico 050290 Pembina, ND Canada 5,656 4,946 6,894 4,431 China 18 3 138 144 Mexico 1521 0 Philadelphia, PA Canada 0 0 1 0 China 5,011 1,726 1,307 3,639 Port Arthur, TX China 0 6,634 35,159 1,529 Portland, ME Canada 13,904 24,197 26,841 21,085 China 3 32 1 29 Mexico 0 3 13 2 San Diego, CA Canada 1 0 0 4 China 39 9 21 302 Mexico 38,303 37,162 42,107 58,740 San Francisco, CA Canada 0 2 0 0 China 15,301 19,051 15,836 8,822 San Juan, PR Canada 9 21 21 65 China 684 16,321 1,099 807 Mexico 0 32 132 25 Savannah, GA China 19,287 18,290 43,689 24,322 Seattle, WA Canada 10,002 19,851 15,600 20,693 China 13,262 22,964 21,137 15,559 Mexico 03 023 St. Albans, VT Canada 36,611 47,647 33,882 39,578 China 101 14 9 36 Mexico 1203241

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved Page 74 of 129 Public Data Barcode:3789316-02 A-570-102 INV - Investigation -

Subject U.S. Imports of Certain Fabricated Structural Steel* Compete With U.S. Production And Other Subject Imports Throughout The U.S.

Calendar Year Jan‐Oct Customs Distric Source 2015 2016 2017 2018 St. Louis, MO China 8,111 4,899 5,195 5,313 Tampa, FL Canada 0 0.04 0 0 China 2,572 5,072 4,523 5,256 Mexico 82 57 34 24 Virgin Islands of the United States Canada 2 0 0 0 China 076150 Washington, DC China 06 64

Grand Tota Canada 168,828 227,763 235,997 213,279 China 368,637 476,814 492,833 419,948 Mexico 246,176 224,420 220,748 265,700

Subject 783,641 928,997 949,578 898,927

Source: U.S. International Trade Commission, DataWeb service, available at https://dataweb.usitc.gov/. Data downloaded on 12/21/2018.

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved Page 75 of 129 Public Data Barcode:3789316-02 A-570-102 INV - Investigation -

U.S. Imports for Consumption of Certain Fabricated Structural Steel (Broad Group)*

Calendar Year January ‐ October 12‐Months Ending Oct 2018 Source 2015 2016 2017 2017 2018 % Change Tons % of Total Quantity (Short Tons) World 1,441,939 1,601,540 1,656,319 1,396,117 1,457,329 4.4% 1,717,531 100.0%

Canada 202,981 265,292 275,931 227,807 248,465 9.1% 296,589 17.3% China 536,073 650,165 700,269 606,470 628,957 3.7% 722,756 42.1% Mexico 266,004 249,800 236,371 199,876 281,518 40.8% 318,013 18.5% Subtotal 1,005,058 1,165,257 1,212,572 1,034,153 1,158,940 12.1% 1,337,358 77.9% % of Total 69.7% 72.8% 73.2% 74.1% 79.5% 77.9%

All Others 436,881 436,283 443,747 361,964 298,389 ‐17.6% 380,172 22.1%

* Certain Fabricated Structural Steel includes imports principally under HTS Codes 7308.90.3000, 7308.90.6000, and 7308.90.9590. Secondary codes include 7216.91.0010, 7216.91.0090, 7216.99.0010, 7216.99.0090, 7228.70.6000, 7301.10.0000, 7301.20.1000, 7301.20.5000, 7308.40.0000, 7308.90.9530, and 9406.90.0030. The data were reported in kilograms and converted to short tons using 2.2046 pounds per kilogram and 2,000 pounds per short ton.

Source: U.S. International Trade Commission, DataWeb service, available at https://dataweb.usitc.gov/. Data downloaded on 12/21/2018.

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved Page 76 of 129 Public Data Barcode:3789316-02 A-570-102 INV - Investigation -

U.S. Imports for Consumption of Certain Fabricated Structural Steel (Broad Group)*

Calendar Year January ‐ October 12‐Months Ending Oct 2018 Source 2015 2016 2017 2017 2018 % Change Tons % of Total Customs Value (U.S. Dollars) World $3,045,785,195 $3,342,162,278 $3,473,806,190 $2,907,904,517 $3,193,438,777 9.8% $3,759,340,450 100.0%

Canada $528,171,576 $694,746,587 $770,652,710 $637,401,916 $712,141,842 11.7% $845,392,636 22.5% China $950,652,568 $1,060,987,994 $1,134,449,679 $974,993,831 $1,110,528,219 13.9% $1,269,984,067 33.8% Mexico $527,479,543 $429,761,226 $420,922,799 $348,055,462 $535,538,267 53.9% $608,405,604 16.2% Subtotal $2,006,303,687 $2,185,495,807 $2,326,025,188 $1,960,451,209 $2,358,208,328 20.3% $2,723,782,307 72.5% % of Total 65.9% 65.4% 67.0% 67.4% 73.8% 72.5%

All Others $1,039,481,508 $1,156,666,471 $1,147,781,002 $947,453,308 $835,230,449 ‐11.8% $1,035,558,143 27.5%

Source: U.S. International Trade Commission, DataWeb service, available at https://dataweb.usitc.gov/. Data downloaded on 12/21/2018.

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved Page 77 of 129 Barcode:3789316-02 A-570-102 INV - Investigation -

EXHIBIT I-9

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved Page 78 of 129 Barcode:3789316-02 A-570-102 INV - Investigation -

Company Address Phone Number Web Site 7755 Paragon Road Suite 104 Dayton, OH A1 Fastener 45459 937‐433‐7200 http://a‐1fastener.com/

AARDING THERMAL ACOUSTICS USA, INC. 50 COBHAM DRIVE, ORCHARD PARK, NY 14127 (716) 662‐6540 186 Intermodal Parkway Fort Worth, TX Advantage Feeders 76177 AHMSA INTERNATIONAL 5150 N. LOOP 1604 E., SAN ANTONIO, TX 78249 9807 Katy Freeway, Suite 100 Houston, TX Air Liquide E&C 77024 https://www.airliquide.com/united‐states‐america

ALONZO CANTU CONSTRUCTION, INC. 5221 N. MCCOLL Road, MCALLEN, TX 78502 956) 631‐1273 [email protected] 5050 Hazelgreen Road, NW Salem, OR Alpha Nursery 97305 503‐390‐1286 https://www.alphanursery.com/contact.html 1 Power Lane Charleroi, PA Alstom Grid 15022 724‐483‐7308 1180 Private Road 2906 Giddings, TX Altman Plants 78942 979‐542‐1165 https://altmanplants.com/about‐us/locations/giddings‐tx/ 11105 Knott Ave, Suite D Cypress, TX AMC North American 90630 4500 East Pacfic Coast Highway, Suite 200 Long Beach, CA American International Cargo Service 90804 138 Bevers Road Liberty Hill, TX Amifast Corp. 78642 512‐778‐6577 http://amifast.com/ 5405 Windward Parkway, Suite 100W Alpharetta, GA Andritz, Inc. 30004‐3894 770‐640‐2500 https://www.andritz.com/ 961 Marcon Boulevard Allentown, PA Anshan Zizhu Trading 18109 http://en.aszizhu.com/ 206 Utah Avenue South San Francisco, CA Apex Shipping 94080 650‐589‐2575 https://www.apexshipping.com/ 6424 E. Greenway Parkway, Suite 100 Scottsdale, AZ ArcelorMittal 85254 https://corporate.arcelormittal.com/ 4511 Riviera Shores Street #40 San Diego, CA Ark Innovations 92154 619‐791‐6209

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Company Address Phone Number Web Site 80 Sand Island Access Road, Suite 209 Honolulu, HI Armstrong Building Products 96819 808‐848‐2484 https://www.armstrongbuilders.com 2718 Loyaga Drive Round Rock, TX ATC Solar 78681 400 Broadacres Drive, Suite 415 Bloomfield, NJ Atlantic Track and Turnout 07003 973‐748‐5885 https://www.atlantictrack.com/ 1701 Barrett Lakes Boulevard Barrett Lakes Center I, Suite 450 Kennesaw, GA Aumund USA 30144 770‐590‐3800 https://www.aumund.de/en/aumund/ueber_uns/aumund_gruppe_weltweit/usa 9988 Hibert Street, Suite 102 San Diego, CA Babcock & Wilcox SPIG, Inc. 92131 1‐877‐955‐7744 https://www.babcock.com/en/locations/north‐america 11603 N. Houston Rosslyn Road, Building 2 Houston, TX Backwater Leasing 77086 832‐680‐6107 85 Chestnut Ridge Road Montvale, NJ Baosteel America 07645 201‐307‐3358 http://baosteelus.com/ 402 North 44th Avenue Phoenix, AZ Bayne Machine Works 85043 800‐535‐2671 https://www.baynethinline.com/ BBM‐CPG TECHNOLOGY INC. 1239 VERN CORA ROAD, LAURENS, SC 29360 (864) 683‐0024 sales@bbm‐cpg.com 35 East Wacker Drive, Suite 1300 Chicago, IL Beamco Incorporated 60601 3000 Post Oak Boulevard PO Box 2166 Houston, TX Bechtel Oil, Gas & Chemicals 77056 713‐235‐2000 https://www.bechtel.com 13865 Lake Drive NE Columbus, MN Bergren's Greenhouses 55025‐944 651‐464‐5866 http://www.bergensgreenhouses.com/ 4411 Shaefer Avenue China, CA Bestocean Worldwide Logistics 91710 909‐219‐8000 http://www.bestocean.com/ 2027 State Highway 198 Osceola, AR Big River Steel 72370 870‐819‐3031 https://bigriversteel.com/ BILT INDUSTRIES, INC. 801 MARKEY ROAD, BELTON, MO 64012 (913) 685‐7400 [email protected] 65 Lawrence Bell Drive Amherst, NY Birdair, Inc. 14221 716‐633‐9500 http://www.birdair.com/ 5205 5th Avenue North Lipscomb, AL Birmingham Rail & Locomotive 35020 205‐424‐7245 https://bhamrail.com/

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Company Address Phone Number Web Site BLUESCOPE BUILDINGS NORTH AMERICA INC 1540 GENESSEE STREET, KANSAS CITY, MO 64102 (816) 245‐6000 [email protected] 14950 Heathrow Forest Parkway, Suite 500 Houston, TX Braid Logistics 77032 281‐219‐4222 https://www.braidco.com/ 7954 Painesville Ravenna Road Concord, OH Bremec Garden Center 44077 440‐357‐0906 https://bremec.com/ 2501 NW 34th Place, Suite B21 Poppano Beach, FL Bruzzone Shipping, Inc. 33069 954‐960‐5891 http://bruzzone.com/ BUNGER STEEL, INC 8112 WEST BUCKEYE ROAD, PHOENIX, AZ 85043 623) 936‐7181 BUTLER MFG. BLUESCOPE BUILDINGS NORTH AMERICA, INC. 1540 GENESSEE ST., KANSAS CITY, MO 64102 (816) 968‐3000 [email protected] 350 West 2500 North Logan, UT C&S Worldwide 84341 2925 Briarpark Drive, Suite 1000 Houston, TX Cameron LNG 77042 337‐680‐4777 https://cameronlng.com/ 4010 Clay Street Point of Rocks, MD Canam Steel Corp. 21777 301‐874‐5141 1215 East 143rd Street East Chicago, IN Capital Sales 46312 3245 Meridian Parkway Weston, FL Carnival Paradise 33331 6301 Beach Boulevard #227 Buena Park, CA Caronex Worldwide 90621 714‐522‐2911 14523 Carowinds Boulevard Charlotte, NC Carowinds Waterpark 28273 704‐588‐2600 https://www.carowinds.com/play/carolina‐harbor 30 Sherman Avenue Seaside Heights, NJ Casino Beach Pier 08751 100 Northeast Adams Street Peoria, IL Caterpillar 61629 309‐675‐1000 https://www.caterpillar.com 6001 Rogerdale Road Houston, TX CB&I Zachry Joint Venture 77072 Suite 200 Westchase Park Plaza 11490 Westheimer Road Houston, TX CBI America 77077

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Company Address Phone Number Web Site 689 Berkmar Circle, Suite 3 Charlottesville, VA Central Oceans USA 22901 https://www.centraloceans.com/ 65 Jackson Drive 2nd Floor Cranford, NJ CH Robinson Worldwide 07016‐3516 201‐865‐4557 https://www.chrobinson.com/en‐us/ 17301 Lincoln Ave. Parker, CO Challenger Recreation Center 80134 720‐733‐6990 http://parkerrec.com/246/Challenger‐Regional‐Park Peninsula Waipio Point Access Road Waipio Peninsula Waipahu, HI Channel Electric EEC 96797 35 East Wacker Drive, Suite 1300 Chicago, IL Clayco 60601 25700 Interstate 45 North, Suite 420 Spring, TX 77386 Conceptum Logistics 281‐298‐6410 http://www.conceptum‐logistics.com/index.php/en/usa 1006 East Oakland Avenue Ponca City, OK Continental Carbon 74601 580‐763‐8102 http://www.continentalcarbon.com/index.asp 670 1 KOLL CENTER PARKWAY #150, PLEASANTON, CA CONXTECH INC. 94566 (510) 264‐9111 [email protected] 6347 Northfield Road West Bloomfield, MI Crown Rail 48322 248‐593‐7100 http://crownrail.com/crownindex.htm DEACERO USA INC 8411 IRVINGTON BLVD SUITE B, HOUSTON, TX 77022 (713) 697‐1500 DONALDSON COMPANY INC 1400 WEST 94TH STREET, MINNEAPOLIS, MN 55431 (952) 887‐3131 164 Milestone Way, Suite 100 Greenville, SC Dongguan Technology Import & Export 29607 4000 Town Center Boulevard Canonsburg, PA DRA Taggart LLC 15317 724‐754‐9800 DUGGINS CONSTRUCTION INC. 341 CROWN CT, IMPERIAL, CA 92251 (760) 355‐5600 PO Box 84160 Baton Rouge, LA Edgen Corporation 70884 EDISON MATERIAL SUPPLY LLC C/O SOUTHERN CALIFORNIA 2244 WALNUT GROVE, ROSEMEAD, CA 91770 300 Union Boulevard, Suite 350 Lakewood, CO Enexio US LLC 80228 303‐987‐0123 https://www.enexio.com/us/ EXTERRAN ENERGY SOLUTIONS, L.P. 4444 BRITTMOORE ROAD, HOUSTON, TX 77060 (281) 836‐7000 FAGIOLI, INC 21310 HWY 6, MANVEL, TX 77578 281‐997‐3434 [email protected] FEATHERLAND EGG FARM, INC 1255 STOLTE RD, MARION, TX 78124 (830) 914‐4949

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved Page 82 of 129 Barcode:3789316-02 A-570-102 INV - Investigation -

Company Address Phone Number Web Site 2040 Avenue C Bethlehem, PA FLSmidth 18017 610‐264‐6011 https://www.flsmidth.com/ FRAZIER INDUSTRIAL COMPANY 91 FAIRVIEW AVENUE, LONG VALLEY, NJ 07853 908) 876‐3001 [email protected] 1 Power Lane Charleroi, PA GE Grid Solutions 15022 724‐483‐7308 http://www.gegridsolutions.com/ 8301 Scenic Highway Pensacola, FL GE Wind Pensacola 32514 850‐474‐4011 2 Main Street Garden City, GA Georgia Ports Authority 31408 912‐964‐3811 http://gaports.com/ 8401 Chagrin Road, Suite 14A Chagrin Falls, OH Global Metal Services 44023 440‐591‐1264 http://www.gmsamerica.com/ 5628 Clifford Circle Birmingham, AL Graphite Electrodes Sales, Inc. 35210 866‐472‐1861 10707 NW Front Avenue Portland, OR Harmer Steel Co. 97231 503‐286‐3691 http://www.harmersteel.com/ 694 Kraybill Church Road Mount Joy, PA Haygrove, Inc. 17552 717‐492‐4955 HUDSON YARDS CONSTRUCTION LLC 60 COLUMBUS CIRCLE, NEW YORK, NY 10023 (212) 801‐1000 [email protected] 10 Finderne Avenue Bridgewater, NJ ICI Americas, Inc. 08807 908‐203‐2800 3455 High Ridge Road Boynton Beach, FL International Marine Services 33426 561‐396‐2264 https://www.internationalmarineservice.com/default.asp IRL‐MEX, INC 1880 NIRVANA AVENUE, CHULA VISTA, CA 91911 JMS RUSSEL METALS CO 25 COLLEGE PARK COVE, JACKSON, TN 38301 (731) 984‐8121 11920 East Apache Street Tulsa, OK John Zink Hamworthy Combustion 74116 918‐234‐1800 https://www.johnzinkhamworthy.com/ JTR METALS LLC 406 US‐62 , SEMINOLE, TX 79360 (432) 758‐6161 4463 Pahee Street, Suite 1 Lihue, HI Kauai Island Utility Coop 96766‐2000 http://website.kiuc.coop/ 1916 Route 9W Ravena, NY Lafarge North America 12143 https://www.lafargeholcim.us/ 415 Holiday Drive Pittsburgh, PA LB Foster Co. 15220 412‐928‐3400 https://www.lbfoster.com/en/contact

LOWER COLORADO RIVER AUTHORITY 3700 LAKE AUSTIN BLVD, AUSTIN, TX 78703 (512) 473‐3200

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Company Address Phone Number Web Site 555 Katy Fort Bend Road Katy, TX LSL Waterpark 77494 832‐426‐7071 909 County Highway 9 Vernon AL Marathon Equipment 35592 205‐695‐9105 https://www.marathonequipment.com/ MARMAC HEAVY EQUIPMENT INC 4114 S CAGE BLVD, PHARR, TX 78577 956) 607‐8501 MICHELIN NORTH AMERICA INC. 1101 MICHELIN ROAD, ARDMORE, OK 73401 (580) 226‐1200 120 Schor Avenue Leonia, NJ Minmetals 07605 201‐809‐1898 http://usa.minmetals.com.cn/ 5218 Spencer Highway Pasadena, TX Monadelphous Sinostruct 77505 281‐998‐3000 https://www.sinostruct.com/ NATIONAL OILWELL VARCO CADC 220 WEAKLEY STREET, CALEXICO, CA 92231 164 Milestone Way, Suite 100 Greenville, SC NEM USA Corp. 29607 864‐400‐6200 NEW MILLENNIUM BUILDING SYSTEMS, LLC 7575 WEST JEFFERSON BLVD., FORT WAYNE, IN 46804 (260) 969‐3500 1509 Ocello Drive St. Louis, MO Nooter Eriksen 63026 636‐651‐1000 http://ne.com/ 3207 Innovation Plaza Youngstown, OH Northers States Metals Co. 44509 330‐799‐1855 http://extrusions.com/ 12000 AEROSPACE AVENUE, SUITE 300, HOUSTON, TX ORION MARINE CONSTRUCTION, INC. 77034 (713) 852‐6500

OTAY FORWARDING PARTNERS INC 6960 CAMINO MAQUILADORA, SAN DIEGO, CA 92154 (619) 606‐0678. 16902 Millikan Ave. Irvine, CA Outdoor Product Technologies 92606 949‐209‐9519 http://outdoorproducttechnologies.com/ PACIFIC GAS AND ELECTRIC CO. 245 MARKET ST, SAN FRANCISCO, CA 94177 (800) 743‐5000 168 Willie Paulk Parkway P‐D Valmiera Glass USA Corp. Dublin, GA 31021 (478) 410‐3441 https://www.valmiera‐glass.com/ PENINSULA STEEL INC 6553 STAR COURT, LAREDO, TX 78041 (844) 783‐0373 [email protected] PRAXAIR INC 175 EAST PARK DRIVE, TONAWANDA, NY 14151 (716) 879‐7300 1 Waterfront Street New Haven, CT PSEG Power Connecticut 06512‐1714 203‐974‐5000 PUK GROUP GMBH &CO.KG NOBELSTRASSE, EAGLE BRIDGE, NY 12057 1223 HIGHLAND AVE STE 106, RANCHO CUCAMONGA, CA S.E. WELCO, INC. 91739 (909) 945‐7114 16945 NORTHCHASE DRIVE SUITE 1910, HOUSTON, TX SAE TOWERS LTD 77060 (281) 763.2282 [email protected] 75 State Street 5th Floor Santander Bank North America Boston, MA 02109 (617) 757‐3435 https://www.santanderbank.com/us/personal 12120 Wickchester Lane Sasol Chemicals North America LLC Houston, TX 77079 (281) 588‐3000 http://sasolnorthamerica.com/contact‐us

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved Page 84 of 129 Barcode:3789316-02 A-570-102 INV - Investigation -

Company Address Phone Number Web Site 12120 Wickchester Lane Sasol North America Houston, TX 77079 (281) 588‐3000 http://sasolnorthamerica.com/contact‐us 3003 N. Central Aveue Suite 1500 Schuff Steel Company Phoenix, AZ 85012 (602) 252‐7787 http://www.schuff.com/

SCHUFF STEEL COMPANY 3003 N. CENTRAL AVE. SUITE 700, PHOENIX, AZ 85012 (602) 252‐7787 [email protected] 7007 Sea World Dr. Seaworld Parks and Entertainment, Inc. Orlando, FL 32821 (407) 363‐2404 http://www.seaworld.com SEYCO JOIST CO. 1350 E NASA PKWY #130, HOUSTON, TX 77058 (281) 333‐4299 6040 Northbelt Drive, Suite C Norcross, GA Shanghai Aerotech USA 30071 770‐729‐6226 http://shanghaiaerotech.com/ 6040 Northbelt Drive Suite C Shanghai Aerotech USA Inc. Norcross, GA 30071 (770) 792‐6226 http://shanghaiaerotech.com/ SHELL CHEMICAL APPALACHIA LLC 901 LOUISIANA STREET, HOUSTON, TX 77002 (855) 697‐4355 910 Louisiana Street Shell Chemical LP Houston, TX 77002 (1‐800) 697‐4355 https://www.shell.com/business‐customers/chemicals.html 8201 Edgewater Drives Suite 202 Shimmick Construction Company, Inc. Oakland, CA 94621 (510) 777‐5000 http://www.shimmick.com/ SIEMENS ENERGY, INC 4400 N. ALAFAYA TRAIL, ORLANDO, FL 32826 (407) 736‐2000 300 New Jersey Avenue Suite 1000 Siemens USA Washington, D.C. 20001 (1‐800) 743‐6367 https://www.siemens.com/us/en/home.html SIERRA UTILITY SALES INC 1054 41ST AVENUE, SANTA CRUZ, CA 95062 (831) 464‐2250 [email protected] SIGOSA STEEL COMPANY 2025 N CENTRAL AVE, BROWNSVILLE, TX 78521 (956) 546‐3122 27843 N. Hwy. 95 Silverwood Theme Park Athol, ID 83801 (208) 683‐3400 https://www.silverwoodthemepark.com/?ADT=113

SIMEC USA, CORPORATION 1700 CLEVELAND AVE.SUITE B, NATIONAL CITY, CA 91950 (619) 474‐4081 3 Riverway Ste 1425 Sinopec Engineering Group America, L.L.C Houston, TX 77056 (713) 303‐4888 2201 Road to Six Flags Six Flags Over Texas Arlington, TX 76010 (817) 640‐8900 https://www.sixflags.com/ 3505 Veterans Memorial Highway Suite K‐1 SOC America, Inc. Ronkonkoma, NY 11779 (631) 427‐6666 http://www.socamericaninc.com 1131 SW Klickitat Way SSA Marine Seattle, WA 98134 (206) 623‐0304 http://www.ssamarine.com/ STEEL SERVICES AND SUPPLIES, INC. CARRETERA 865, CAMPANILLA, TOA BAJA, PR 00949 1 (787) 794‐2250 3200 Myers Street Steel Unlimited Inc. Riverside, CA 92503 (800) 544‐6453 http://www.steelunlimited.com/ EL CARMEN EDIF CENTRO DOS CAMINOS, RUSSELL, MA STIPA INGENIERIA C.A. 1071 10150 Old Columbia Road Structural Technologies, Inc. Columbia, MD 21046 (410) 859‐6539 http://www.structuraltechnologies.com/

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Company Address Phone Number Web Site 414 Oak Street Suite 101 StructurFlex Kansas City, MO 64106 (816) 889‐9000 https://www.structurflex.com/ 1550 Wet Glenlake Avenue Suntrans International, Inc. Itasca IL, 60143 (630) 285‐9900 http://www.suntrans.com/en/ 407 West Gardena Boulevard Surelock Fence Products, Inc. Gardena, CA 90248 (818) 946‐0858 260 Townsend Street Swinerton Incorporated San Franscisco, CA 94107 (415) 421‐2980 https://www.swinerton.com/ TENNESSEE VALLEY AUTHORITY 1101 MARKET STREET, CHATTANOOGA, TN 37402 (865) 632‐2101 [email protected] Corporate Center Drive 100 Tenova Inc. Corapolis, PA 15108 (412) 262‐2240 https://www.takraf.tenova.com/

THE DOW CHEMICAL COMPANY 2301 N. BRAZOSPORT BOULEVARD, FREEPORT, TX 77541 (979) 238‐2011 THETA PROPERTIES LLC 2021 N GRAND AV, NOGALES, AZ 85621 16285 Park Ten Place thyssenkrupp Industrial Solutions (USA) Suite 150 https://www.thyssenkrupp‐industrial‐solutions.com/en/locations/europe‐cis/uhde‐ Inc. Houston TX, 77048 (281) 600‐5770 fertilizer‐technologies/ Copper and Brass Sales 22355 W 11 Mile Road thyssenkrupp Materials NA Southfield, MI 48033 (800) 926‐2600 https://www.thyssenkrupp‐materials‐na.com/ TRANSAMERICAN POWER PRODUCTS, INC 2427 KELLY LANE, HOUSTON, TX 77066 (281) 444‐8277 Transcontinental Distribution Services 14213 Transportation Ave. Inc. Laredo, TX 78045 (956) 725‐1604 http://www.transcontinentalinc.com/ 532 Jack Enders Blvd. Trelleborg Marine Systems USA, Inc. Berryville, VA 22611 (540) 667‐5191 https://www.trelleborg.com

TRINITY MEYER UTILITY STRUCTURES, LLC 2388 W RISINGER ROAD, FORT WORTH, TX 76134 (817) 632‐1389 1760 Westwood Way University of Alaska Press Fairbanks, AK 99709 (907) 474‐5502 https://www.alaska.edu/uapress/ 2 Northpoint Drive Suite 213 UTC Overseas, Inc. Houston, TX 77060 (713) 422‐2850 http://www.utcoverseas.com/global_offices.html One Valmont Plaza Valmont Industries Inc. Omaha, NE 68154 (402) 963‐1000 http://www.valmont.com/ 887 West Marietta Street NW Suite M201 Vector Global Logistics LLC Atlanta, GA 30318 (404) 554‐1150 http://www.vectorgl.com/index.html 3005 Highland Parkway Suite 200 Vehicle Services Group Downers Grove, IL 60515 (800) 640‐5438 http://www.vsgdover.com/ 1417 NW Everett Street Vestas ‐ American Wind Technology Inc. Portland, OR 97209 (503) 327‐2000 http://www.vestas.com 1500 East Crown Prince Blvd. Building N Vestas Nacelles America Inc. Brighton, CO 80603 www.vestas.com 2815 Coliseum Center Drive Suite 450 Vossloh North America Charlotte, NC 28217 (980) 500‐7252 http://www.vossloh‐north‐america.com/us/contact/index.php

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Company Address Phone Number Web Site PO Box 14146 Vossloh Track Material Ink Reading, PA 19605 (1‐800) 554‐0554 http://www.vossloh‐north‐america.com/us/ 900 Bayou Casotte Pkwy. VT Halter Marine, Inc. Pascagoula, MS 39581 (228) 696‐6888 http://www.vthm.com/ Walt Disney Imagineering Research & 1401 Flower Steet Development, Inc. Glendale, CA 91201 (818) 544‐6500 3100 WEST 40TH STREET NORTH MUSKOGEE, WHEELER METALS, INC MUSKOGEE, OK 74401 (918) 682‐1083 WHITES STEEL, INC. 45524 TOWNE STREET, INDIO, CA 92201 (760) 347‐3401 [email protected] 901 South Bond Street Suite 600 William Scotsman International, Inc. Baltimore, MD 21231 (410) 931‐6000 https://www.willscot.com/ 3250 Van Ness Ave. Williams‐Sonoma, Inc. San Francisco, CA 94109 (415) 421‐7900 http://www.williams‐sonomainc.com/ 25801 Northline Commerce Drive Worldwide Logistics Inc. Taylor, MI 48180 (416) 213‐9522 http://www.ww‐logistics.com/

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EXHIBIT I-10

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved Page 88 of 129 Barcode:3789316-02 A-570-102 INV - Investigation -

EXHIBIT NOT CAPABLE OF PUBLIC SUMMARY

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved Page 89 of 129 Barcode:3789316-02 A-570-102 INV - Investigation -

EXHIBIT I-11

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved Page 90 of 129 Barcode:3789316-02 A-570-102 INV - Investigation -

Structural Steel: An Industry Overview

A White Paper by the American Institute of Steel Construction October 2017 Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved Page 91 of 129 Barcode:3789316-02 A-570-102 INV - Investigation -

Fabricators Following a determined sequence that is There are more than 1,700 steel fabricators optimized for shop flow and project schedule, in the United States supplying fabricated the appropriate structural steel members are structural steel for building and bridge projects then cut to the proper length and drilled, plasma and 931 of these are AISC members. Among cut or punched, and all additional shop work these 1,700 fabricators are 1,070 facilities is performed on the member. When required, certified for the fabrication of buildings and 362 the member is cleaned and coated with paint facilities certified for the fabrication of bridges. or galvanized. The members are then grouped The typical steel fabricator is a family-owned in the order in which they will be erected in business employing from 10-to-100 people. the field, placed on a truck for shipping and Employee classifications include salespeople, delivered to the project site. engineers, project managers, detailers, shop Bridges follow a similar fabrication process workers, equipment operators, welders, painters, that diverges in key areas. Design drawings are inspectors, delivery drivers, and administrative developed by a licensed state bridge engineer or personnel. Projects may range from the bridge design consultant, which are then used fabrication of several tons of structural steel for as part of the bid process. For cost savings many a small retail store to 25 tons for a rural overpass steel bridges utilize weathering steel although to tens of thousands of tons for a large, high-rise many bridges are still coated with paint, structure or major bridge. A very rough rule of galvanizing or metalizing. thumb is that one ton of steel is required for The steel bridge industry is driven by funds every 200 square feet of building area. provided by the federal government and a The fabrication process for a building competitive bid letting process for selecting is driven by plans developed and sealed by fabricators. licensed structural engineers which specify all A typical fabrication project will require design aspects of the structural components between 15 and 30 hours of shop time per based on the building layout developed by ton of fabricated steel. Material costs account an architect. Upon award of the project the for between 25% and 30% of the final cost fabricator typically is responsible for creating of the fabricated and erected structural steel. detail drawings of each piece of structural steel Fabrication and erection costs for structural steel which are developed from a 3D model of the vary greatly based on the type of structure being structural frame. These details are produced constructed, the number of pieces, local labor by a steel detailer to develop a dimensionally conditions and the complexity of the connections. accurate drawing of each fabrication piece, An AISC member fabricator in the area of the including all connection details. Steel detailers project (a list of member fabricators is available either work directly on the staff of the on the AISC website www.aisc.org) is the best fabricator or on a sub-contract basis. The detail source for fabrication costs for a specific project. drawings are then submitted to the structural The practice of minimizing the weight of the engineer for approval. structural steel in a building is often short-sighted

Structural Steel: An Industry Overview | Page 4 of 8 Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved Page 92 of 129 Barcode:3789316-02 A-570-102 INV - Investigation -

as lighter sections, while satisfying the strength project site. Most building erection is performed requirements of the structure, may result in more under the same contract as the steel fabrication, costly connections and fabrication procedures. with the fabricator either providing in-house In May 2012, NSBA conducted a nationwide erection services or sub-contracting the erection study to determine the capacity of the domestic work to a qualified firm. Field erection involves steel bridge fabrication industry. The survey assembling the structural components in proper asked U.S. bridge fabricators to state their 2010 sequence while maintaining the structural plant use as a percentage of their overall capacity. stability of the partially completed structure. Survey results determined that, on average, Stringent safety standards have significantly our nation’s significant steel bridge fabricators reduced the number of injuries occurring used only 67% of their total plant capacity in during steel erection. The erection team also 2010. This result is conservative as stimulus is responsible for bringing the final building funding from the 2009 American Recovery structure into plumbness, level and alignment and reinvestment Act (ARRA) created a higher within the required tolerances. demand than would have been typical at the time Over the years, the bridge design and of the survey. construction industry has looked for ways to Many fabricators, both AISC members and reduce delivery time of a bridge project through non-members, have taken the additional step the implementation of Accelerated Bridge of obtaining AISC Quality Certification. This Construction (ABC). ABC represents a wide program is similar to an ISO certification range of technologies including Prefabricated program but specialized for the intricacies of Elements and Systems (PBES), a nod toward steel fabrication. Companies are audited on modular construction and its ability to reduce an annual basis; while the program doesn’t cost, reduce schedule, reduce traffic delays, and certify product, it does verify that the fabricator improve the safety of both construction workers has the processes, equipment, manpower, as well as commuters. For more information commitment, and experience to perform the about Accelerated Bridge Construction, necessary work and meet a minimum level specifically on Prefabricated Bridge Elements of industry accepted quality standards. A list and Systems, visit the FHWA ABC website at of AISC certified fabricators is available at http://www.fhwa.dot.gov/bridge/abc/ or Florida www.aisc.org/certification. International University’s ABC-UTC website at www.abc-utc.fiu.edu. Erectors AISC offers a Certification Program for Erectors are the most visible component of erectors and currently 374 erectors are certified. the structural steel supply chain, because they A list of AISC certified erectors is available at perform the actual construction work at the www.aisc.org/certification.

Structural Steel: An Industry Overview | Page 5 of 8 Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved Page 93 of 129 Barcode:3789316-02 A-570-102 INV - Investigation -

Marketplace Demand for Structural Steel Structural steel is the leading structural framing has grown significantly over the past five years material for buildings in the United States, with and is currently 40%. a 49% market share for 2016 for non-residential The remaining demand for structural steel is and multi-story residential construction. comprised of two market segments: The market share for the closest competing • Non-building structures, which includes material—reinforced concrete—is only 32%, open-air stadiums, process and chemical indicating a strong market preference for plants, power plants, petroleum refineries, structural steel. and other buildings that do not have a roof. Market share values for all structural framing Structural steel maintains a dominant share materials over the past nine years for non- in these markets with these non-building residential and multi-story residential building structures generating approximately 40% construction based on square footage are as of the demand for structural steel. shown in the following table. The increasing • Non-structural applications such as rack proportion of residential construction since systems, marine applications, trailers, 2011 has resulted in an overall decrease in steel transportation and mobile homes market share. comprise 15% of the overall demand for Non-residential construction represented structural products. 34% of the overall demand for structural steel Bridges are a special case in that the majority with each point of market share being equivalent of bridge structures are fabricated from plate to 40,000 tons of structural steel. Multi-story steel rather than hot-rolled shapes or HSS. Plate residential construction accounted for 6% of steel is not considered in the supply or demand the overall demand for structural steel with each calculations presented above. Hot-rolled shapes point accounting for 500 tons of structural steel. for bridges comprise 6% of the overall market Structural steel’s multi-story residential market for structural steel and are included in the non- share, which includes hotels and dormitories, building structures referenced above.

Market Share by 2017 2009 2010 2011 2012 2013 2014 2015 2016 Construction Material YTD Structural Steel 56% 58% 56% 51% 47% 49% 48% 49% 47% Concrete 20% 21% 22% 28% 31% 31% 33% 32% 34% Wood 7% 7% 8% 8% 9% 8% 8% 9% 9% Pre-engineered 7% 6% 6% 6% 6% 5% 5% 4% 3% Masonry 10% 9% 7% 7% 7% 7% 6% 6% 6% Source: Dodge Analytics

Structural Steel: An Industry Overview | Page 6 of 8 Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved Page 94 of 129 Barcode:3789316-02 A-570-102 INV - Investigation -

EXHIBIT I-12

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved Page 95 of 129 Barcode:3789316-02 A-570-102 INV - Investigation - CONDITIONS OF COMPETITION BETWEEN CERTAIN DOMESTIC AND IMPORTED FABRICATED STRUCTURAL STEEL PRODUCTS

Report to the Subcommittee on Trade, Committee on Ways and Means, U.S. House of Representatives on investigation No. 332-181 Under Section 332(b) of the Tariff Act of 1930

USiTC PUBLiCATION 1601

NOVEMBER 1984

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved United States International Trade Commission / Washington, D.C. 20436 Page 96 of 129 Barcode:3789316-02 A-570-102XIV INV - Investigation -

o The competitive position of Ulcstern U.S. fabricators was seen by these fabricators as having been affected by discriminatory pricing of raui materials during 1981-84.

Western U.S. fabricators have alleged that Japanese steel exporters sold, or offered to sell, wide-flange beams to Korean firms at prices about 20 percent beloM those offered to U.S. firms during 1981-84. Japanese firms reportedly began to eliminate the discount practice early in 1983 to establish parity between Korean and U.S. sales prices. An examination of official Japanese trade statistics of exports of wide-flange beams indicates that unit values of exports to the United States exceeded those of exports to Korea during 1981-83; however, the values had converged by the third quarter of 1983. It should be noted that the trade data may not represent a comparable product mix, which could affect unit values.

o Imported fabricated structural steel is designated as having the overall competitive advantage in the U.S. market in product-related characteristics, and lower purchase price is overwhelmingly cited as the principal reason.

On the basis of responses to the Commission questionnaire, U.S. fabricators and purchasers indicate that domestically produced fabricated structural steel has competitive strengths, especially with respect to Korea and Japan, in marketing-related factors such as transportation, supplier reliability, availability of material, delivery time, and servicing capability, where proximity to end markets is an important factor; however, these favorable characteristics are apparently not sufficient to overcome the price advantage of imports as the principal detenninant of overall competitive advantage in the U.S. market. In addition, performance features like design and quality are considered only marginally better, if not equal, for U.S. products relative to foreign merchandise. Canadian fabricated steel is largely considered to be on an equal footing with that of the United States in its principal marketing region of the Northeas^tern United States.

o U.S. purchasers of fabricated structural steel indicate that price figures most prominently in their purchasing decisions.

During 1979-83, U.S. purchasers cited price as the foremost factor in electing to import foreign fabricated steel. A review of selected projects indicates that U.S. fabricators have, on average, been underbid by about 15 percent on west coast building projects in which Korean firms were awarded projects. Information on oil platforms suggests Japanese and Korean margins of underbidding ranging from 20 to 30 percent during 1979-84. U.S. purchasers also ranked other factors as having an important influence on their buying decisions, including product quality, the reliability of suppliers, and the availability of material.

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EXHIBIT I-13

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved Page 98 of 129 Barcode:3789316-02 A-570-102 INV - Investigation - Canadian International Tribunal canadien du Trade Tribunal commerce exterieur

Canadian International Trade Tribunal Dumping and Subsidizing Finding and Reasons

Inquiry No. NQ-2016-004

Certain Fabricated Industrial Steel Components

Finding issued Thursday, May 25, 2017

Reasons issued Friday June 9,2017

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appropriate duration or how far back the starting point of an investigation may be. Moreover, the Tribunal fails to see how an injury inquiry covering only 12 months would be appropriate in view of the recommendation of the WTO Committee on Anti-Dumping Practices that “the period of data collection for injury investigations normally should be at least three years. .. Since the three-year period in the Committee's guidelines is the recommended minimum period, the four-year period selected by the Tribunal for this investigation is not only consistent with the three-year minimum period recommended by the Committee's guidelines, but exceeds it and therefore leads to a higher degree of adherence with the recommendation.

The Importance of Price

78. FISC is not a commodity product.^® As discussed above, FISC is used to construct large-scale capital projects (for the end uses specified in the product definition) and, in lesser volumes, to fulfill the ongoing operational needs of these projects. As such, demand for FISC is heavily influenced by capital spending, which is in turn heavily influenced by commodity prices.Because FISC is procured on a project by project basis, and orders for FISC can often be quite large, the loss (or gain) of a single project can significantly impact a producer's profitability.

79. Unlike purchases of commodity products, which are often based primarily on price, the evidence indicates that there are non-price considerations which play a significant role in a purchaser's decision¬ making process. When asked about the importance of price in purchasing decisions, 14 out of 23 respondents to the Tribunal's questionnaire ranked the lowest delivered net price as “very importanf’.'’^ However, factors such as product quality, meeting technical specifications, delivery time and terms, and the ability to meet schedules ranked higher, with between 21 and 23 respondents indicating that these factors are “very importanf’.'’^ hr addition, the Tribunal heard testimony that acceptance of commercial terms and conditions are key considerations for some purchasers.Further, for purchases with lower lead times, the ability to deliver the product on time may figure prominently into the decision.'’^

80. Nonetheless, the Tribunal finds generally that, as FISC is typically purchased as part of a competitive RFQ process, price is determinative in deciding among bids that are technically compliant.'’'’ This is true whether it is the project owner or an EPC procuring the goods. The Tribunal heard evidence that project owners/developers and EPCs are increasingly price sensitive due to low commodity prices, particularly the price of oil.'’^ In addition, some EPCs are employing a lump sum turnkey business model.

58. Ibid. 59. ExhibitNQ-2016-004-B-03 atpara. 82, Vol. 11;ExhibitNQ-2016-004-H-01 atpara. 110, Vol. 13. 60. Exhibit NQ-2016-004-15.09, Vol. 5 at 90; Exhibit NQ-2016-004-V-03 at para. 13, Vol. IIA; Exhibit NQ-2016-004-A-03 atpara. 91, Vol. 11; Transcript of Public Hearing,Wo\. 3,3 May 2017, at 316,348. 61. Exhibit NQ-2016-004-B-03 at para. 137, Vol. 11; Exhibit NQ-2016-004-C-04 (protected) at para. 71, Vol. 12; Transcript of Public Hearing, Vol. 2, 2 May 2017, at 227; Transcript of Public Hearing, Vol. 1, 1 May 2017, at

86. 62. ExhibitNQ-2016-004-06A,Table9,Vol. I.IA. 63. Ibid. 64. Transcript of Public Hearing, Vol. 3, 3 May 2017, at 328; Transcript of Public Hearing, Vol. 4, 4 May 2017, at 437,442. 65. Transcript of Public Hearing, Vol. 3, 3 May 2017, at 323, 325; Transcript of In Camera Hearing, Vol. 1, 1 May 2017, at 42-43; Transcript of In Camera Hearing, Vol. 2,2 May 2017, at 88. 66. Transcript of Public Hearing, Vol. 1, 1 May 2017, at 102; Transcript of Public Hearing, Vol. 3, 3 May 2017, at 327-328; Transcript of Public Hearing, Vol. 4,4 May 2017, at 408,443. 67. Exhibit NQ-2016-004-B-03 at para. 82, Vol. 11; Transcript of Public Hearing, Vol. 3,3 May 2017, at 329-330.

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EXHIBIT I-14

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EXHIBIT NOT CAPABLE OF PUBLIC SUMMARY

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EXHIBIT I-15

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EXHIBIT NOT CAPABLE OF PUBLIC SUMMARY

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EXHIBIT I-16

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EXHIBIT NOT CAPABLE OF PUBLIC SUMMARY

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EXHIBIT I-17

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved Page 107 of 129 Barcode:3789316-02 A-570-102 INV - Investigation -

Good afternoon,

My name is Jeff Sterner and I am President and Chief Operating Officer of High Industries based in Lancaster, Pennsylvania. High is one of the largest fabricators of steel bridges in the United States, and as a member of the board of directors of the American Institute of Steel Construction, I am here to request that the Administration add the principal HTS codes for fabricated structural steel, 730810 and 730890, to the Section 301 tariff list.

Steel assemblies that fall under these two codes represented $831 million of imports in 2017, or nearly 2% of the Section 301 target value. Adding these codes is critically important because the U.S. structural steel supply chain currently suffers from the effects of unfair Chinese industrial policies related to steel production and fabrication.

Because our nation has ample domestic capacity to meet the nation’s demand for fabricated structural steel, including fabricated structural steel on the 301 tariff list would cause minimal consumer impact and no greater disruption to the U.S. economy than the tariffs already applied to imported mill steel under Section 232 and various other trade orders. The tariffs would also have little impact on U.S. consumers because fabricated structural steel is not a consumer- oriented product.

Offshore Fabricated Steel Imports Have More Than Doubled in 5 years

Structural steel fabricators are the manufacturers in the supply chain who cut, drill, bolt, and weld the steel shapes and plate produced by steel mills to create the actual bridges, buildings, and infrastructure projects that use structural steel. While major steel projects have historically been fabricated in American plants, our trade policies have made the American construction market a rich target for foreign steel interests. They have expanded from just exporting mill steel, to exporting fabricated steel to evade and dilute the effect of tariffs.

In the past five years, imported fabricated structural steel has increased by 136% -- far exceeding the growth of the U.S. construction market.

The U.S. structural steel fabrication industry is running at a 63% capacity utilization rate. There is nearly 4 million tons of excess capacity in place to meet current domestic demand for fabricated structural steel. In fact, there is enough capacity to meet any increase in demand

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that results from additional investment in infrastructure projects and projected increases in private construction activity.

Structural Steel Supply Chain Left Unprotected by the Section 232 Order

Structural steel is the backbone of our nation’s infrastructure system. It includes buildings, bridges, power, water and other public projects. By excluding tariffs on fabricated structural steel under the Section 232 Order, a major portion of the structural steel supply chain was left unprotected, allowing China to circumvent the mill steel tariffs.

Including fabricated steel assemblies in any action taken under Section 301 would close the 232 circumvention loophole and protect U.S. businesses in the design and construction industries.

The value of the current list of products benefitting from Chinese industrial policies is roughly $50 billion. In 2017, nearly 500,000 tons of fabricated structural steel were imported into the United States from China, valued by U.S. Customs at over $831 million. AISC believes these import values are conservative because they do not take into account fabricated steel that is rolled in China and then transhipped into the United States through other countries not subject to tariffs.

The problem is much greater than this snapshot of 2017 data. Since 2010, imports of Chinese fabricated structural steel have increased by 290% and now represent more than 30% of the world’s fabricated structural steel imported into this country. In fact, of all the fabricated steel imported into the U.S., China’s share has more than doubled in the last decade and will continue to increase unless action is taken. Over the past decade, China has been subject to anti-dumping and other trade remedies on raw steel products. In response and in an effort to evade those U.S. trade actions and grow the market for its steel, China retooled its subsidized manufacturing apparatus to produce more downstream fabricated products which are not subject to existing trade remedies.

Examples of Effect of Imported Fabricated Steel along the Gulf Coast

Over the last 10 years, foreign steel fabricators have steadily increased imports to harmful levels, specifically affecting mega projects in the industrial and power markets along the Gulf Coast.

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In 2014 and 2015, one AISC member fabricated over 14,000 tons of structural steel for a chemical plant in South Texas. The next phase of this project is currently under construction totaling over 40,000 tons of fabricated structural steel modules, all imported tariff-free from foreign fabricators, not from an American fabricator.

In 2016, the same company fabricated 10,000 tons for a chemical plant in Louisiana. The scope was an early work phase, and the remaining 50,000 tons for the project were imported from international fabricators well below cost.

This is a trend that will continue on projects such as Driftwood LNG, Exxon Mobil/Sabic, Lake Charles Methanol and Lake Charles LNG just to name a few. These projects represent more than $40 billion in total investment where the vast majority of fabricated structural steel will be imported from cheap foreign fabricators without penalty. There is another 250,000 tons of structural steel fabrication on the line for fabricators in the Gulf Coast alone as more industrial projects begin to bid. AISC is calling for tariffs on imported fabricated steel to ensure all these requirements do not follow the recent pattern and go to foreign fabricators.

The current Section 301 schedule already includes 132 HTS codes related to steel, many of which represent products used in the construction industry. However, it does not close the circumvention loophole left open by Section 232 order because it does not currently include the codes for fabricated steel assemblies.

Adding fabricated steel assemblies under HTS codes 730810 and 730890 would be a logical extension of other tariffs already in the proposed Section 301 schedule in addition to those in the Section 232 Order. It will add real teeth to the effort to curb China’s policies and practices that adversely impact domestic steel fabrication and production.

Established in 1921 and based in Chicago, AISC is a national non-profit, non-partisan trade association and technical institute serving the structural steel design and construction industries. AISC and its steel bridge division, the National Steel Bridge Alliance (NSBA) represent nearly 1,000 U.S. businesses that fabricate and install the structural steel that makes up America’s bridges, infrastructure, and skylines. AISC also represents more than 40,000 structural engineers, architects, steel erectors, general contractors, and students. Our broad membership works collaboratively on specification and code development, research, education, technical assistance, quality certification, and standardization to support safe and economic steel building and bridge design and construction.

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EXHIBIT I-18

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WHY STEEL > MADE IN AMERICA

Made in America

STRUCTURAL STEEL IS PRODUCED AND FABRICATED IN AMERICA

American structural steel supports American workers, American businesses and the American economy.

U.S. structural steel is made by American workers:

• More than a dozen mills throughout the U.S. produce various structural shapes and plate • There are more than 2,300 fabrication shops across the country, the vast majority of which are family businesses • One American Job is created for every 45 tons of structural steel produced, fabricated and erected in the United States. At the current rate of 7.2 million tons peryear, that's a total of 160,000 Jobs! • These workers provide steel for more than 8,000 projects annually across the United States.

U.S. structural steel is a locally sourced and recycled material:

• American structural steel is made of steel scrap collected in the U.S. • The industry average for recycled content in domestic structural steel is over 90% • Nearly all American structural steel (98%) is captured at the end of its life and recycled into new American steel products • Afive-story steel-framed office building uses 500 tons of American structural steel, this is equivalent to 360 shredded automobiles, 65 tons of curbside recycling, 79 tons of industrial scrap and 122 old appliances

U.S. structural steel industry meets domestic demand:

• American steel mills have the capacity to produce 9 million tons of structural steel each year • 7.2 million tons of structural steel were used in the U.S. in 2015 • Existing American structural steel manufacturers can easily meet all domestic demand

STILL NEED HELP? The Steel Solutions Center is for people who need technical assistance, innovative solutions, or tools to make structural steel design even easier.

VISIT THE STEEL SOLUTIONS CENTER

RETURN TO:

Architect

Building Owner

Code Official

General Contractor

Structural Engineer

lust Curious

Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved Page 112 of 129 MADE IN AMERICA Barcode:3789316-02 A-570-102 INV - Investigation -

VIEW PDF

130 EAST RANDOLPH, SUITE 2000, CHICAGO, IL, 60601

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EXHIBIT I-19

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EXHIBIT NOT CAPABLE OF PUBLIC SUMMARY

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EXHIBIT I-20

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Company Contact City State Country Certification Phone Number Web Site Anhui Fuhuang Steel Structure Co., Ltd. Mr. Yang Jiping Chaohu Anhui China BU, P2 86‐551‐88564303 http://www.fuhuang.cn/ Baosteel Construction Co., Ltd. Jiang Jun Shanghai Shanghai China BU, SBR 86‐21‐56123456 www.grandtower.com Beijing Shougang Mining Construction CO., LTD Liu Yanbing Qian'an Hebei China BU 15132547044 Changzhi Qinghua Steel Construction Co., Ltd. Han Xianwu Changzhi Shanxi China BU, P2 13835524916 China Construction Equipment & Engineering Co.,Ltd. Gary Xu Nanjing Jiangsu China BU, P1 86‐158‐5054‐0987 www.cc‐hi.com China Construction Steel Structure Co., Ltd (SiChuan) Yonggang Gao MeiShan Sichuan China BU, ABR, CBR, P2 086‐028‐36068818 http://sstr.cscec.com/ China Construction Steel Structure Corp. LTD JunPing Yuan Jiangyin City Jiangsu China BU, ABR, CBR, P2 086‐13506189626 China Construction Steel Structure Corp. LTD Tang Tao Wuhan City Hubei China BU, ABR, CBR, P2 8.6187E+12 China Construction Steel Structure Sunbright Huizhou Co., Ltd. Caizhong Zhang Huizhou City Guangdong China BU, IBR, CBR, P2 8.61867E+12 China Construction Steel Structure(Tianjin) Co., Ltd. Xinyu Shao Xiqing District Tianjin China BU, ABR, CBR, P2 China MCC22 Group Corporation Co., Ltd Xiaoyan Liu Tangshan City Hebei Province China BU, SBR, P2 86 315 3231163 www.22mcc.com.cn China Nuclear Industry 22ND Construction Co., LTD Xie Yingqi Jiaxing Zhejiang China BU, P2 13515736990 China Railway Baoji Bridge Group Co., Ltd. Ivan Zhang Yangzhou City Jiangsu China BU, ABR, CBR, FCE, P1 8.6187E+12 www.cribbi.com China Railway Shanhaiguan Bridge Group Co., Ltd. (CRSBG) Zhou Manrong Qinhuangdao City Hebei China BU, ABR, CBR, FCE, P1 86‐3357940128 www.crsbg.com/english/about/ COOEC‐Fluor Heavy Industries Co., Ltd. Liming Meng Zhuhai Guangdong China BU, P1 86‐756‐6966339 http://www.cooecfluor.com COSCO SHIPPING (QIDONG) OFFSHORE CO., LTD. Zhang Xinping Qidong Jiangsu China BU 86 15951314781 http://www.cosco‐shipyard.com CSCEC2BAZ Langfang Steel Structure Manufacturing Corporation Cheng Chang Langfang City Hebei Province China BU, P2 86‐316‐2809797 http://www.cscecazgg.com DUOWEI UNION GROUP CO., LTD Liu Qiang Langfang Hebei China BU, P2 185‐0005‐3153 Fujian Tung Kang Steel Co., Ltd. Li Jialong Fuqing City Fujian China BU 86 18657135190 http://www.tunghosteel.com/ Hangxiao Steel Structure (Hebei) Construction Co., Ltd Wang Lei Tangshan City Hebei China BU 86‐3156182200 ext 8003 www.hbhxsteel.com Hangxiao Steel Structure (Jiangxi) Co., Ltd. Li Yonglei Nanchang Jiangxi China BU 0791‐87601988 www.hxss.com.cn Hangxiao Steel Structure (Shandong ) Co., Ltd Wang Chunshun Qingdao Shandong China BU 86 018637960043 www.hxss.com.cn Hangxiao Steel Structure Co.,LTD Zhenhua Huang Hangzhou Zhejiang China BU 86‐05718264598 www.hxss.com.cn Henan D.R. Construction Group Steel Structure Co.,Ltd Luo Kai Xinxiang Henan China BU, P3 18303656319 Huadian Heavy Industries Co. Ltd. Li Shuliang Tianjin City Tianjin China BU, P2 8.62287E+11 www.hhi.com.cn Huadian Heavy Industries Co., Ltd. Zhang Bin Ezhou City Hubei China BU, P2 86‐10‐5196891 www.hhi.com.cn Huaye Steel Structure Co., Ltd. Xiong Weibing Ningbo City Zhejiang China BU, SBR, P2 860574 862‐6034 Huaye Steel Structure Nuclear Power Equipment Co., Ltd Gong Xuequn Jiaxing Zhejiang China BU, SBR, P2 138‐0663‐6404 Huayin Steel Structure Engineering (China) Co., Ltd Nanqi Gong Kunshan Jiangsu China BU 86‐51257599367 www.far‐east‐eng.com Jiangsu Huning Steel Structure & Machinery Company Ltd. Wang? Bo Yixing City Jiangsu China BU, IBR, CBR, FCE, P1 86‐21 63375270 Jiangsu Jianghang Construction Engineering Co., Ltd Wei Wu Nanjing City Jiangsu China BU, P2 (86)15952566992 www.jsjhcec.com Jiangsu Jinghu Heavy Industry Co., Ltd. Yu Yu Zhang Yixing City Jiangsu China BU, SBR 86‐21‐63375270 Jiangsu Keeboss Steel Structure Co.,Ltd. Vicky zhong Taixing Jiangsu China BU, P1 86‐15261063855 http://www.keeboss.com/ Jiangsu NEW ZTSS Bridge Steel Structure Engineering Co., Ltd. Lu Jianfen Jingjiang City Jiangsu China BU, ABR, CBR, FCE, P2 86‐52384633001 www.ztsschina.com Jinhuan Construction Group (Handan) Co., Ltd. Li Guihua Handan Hebei China BU, P2 0311‐85961038 http://www.jinhuansteel.com Jinhuan Construction Group Co., Ltd. Li Guihua Shijiazhuang City Hebei China BU, SBR, P2 15830968296 Mageba (Shanghai) Bridge Products Co., Ltd. Johney Huang Shanghai Shanghai China BU, CPT, P2 86‐21‐57407637‐850 MCC (Shanghai) Steel Structure Technology Corp., Ltd. Zhang Hui Shanghai Shanghai China BU, P1 86‐13801842287 MCC TianGong Equipment Ltd. Liang Haijiao Tianjin City Tianjin China BU, P2 86‐22‐67158666 www.ctmcc.cn Modern Heavy Industries (China) Co., Ltd George Jo Taicang Jiangsu China BU, P3 86‐13901692764 Ningbo Zhonglian Steel Structure Co., Ltd. Scott Bean Ningbo Zhejiang China BU 86‐57486839333 www.nssteel.com.cn Peikko Construction Accessories (Zhangjiagang) Co., Ltd Emma Zhang ZhangJiaGang Jiangsu China BU 86‐512‐58309902 www.peikko.com Qingdao East Steel Tower Stock Co. Ltd Zhenye Zhao Qingdao Shandong China BU, P2 86 532‐88056095 Shandong Haiyang Fenghui Equipment Technology Co; LTD Sun Zhihui Haiyang City Shandong Province China BU, P1 18663800119 www.fhjs.net Shandong Luneng Guangda Steel Structure Co., Ltd Liu Fengling Jining City Shandong China BU, P2 86.0537.2351019 Shandong Yijie Hongfeng Energy Equipment CO., LTD Yang Shuangling Weifang Shandong China BU, P1 05362099701/18053603308 www.htgsteel.com.cn Shanghai COSCO Kawasaki Heavy Industry Steel Structure CO. Yoshimoto? Shuichi Shanghai Shanghai China BU, P2 86‐13501781901 Shanghai Hope Steel Structure Co., Ltd. Li Qin Zhenjiang City Jiangsu China BU, P2 86‐021‐55880031 http://www.hope‐steel.com/ Shanghai Matsuo Steel Structure Co., Ltd Wang Xiaojie Shanghai Shanghai China BU, P2 02‐1‐57158080 SHANGHAI MCC20 Construction Co.,Ltd Liang? Ruizhi Shanghai Shanghai China BU, P2 86‐86213621378

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Shanghai Modern Steel Co., Ltd. Lana Ding Shanghai Shanghai China BU 86 13127550045 Shanghai Steel Structure Construction (Jiangsu) Co., Ltd Jun Jiang Haimen Jiangsu China BU, P2 0513‐68909090 Shanghai Zhenhua Heavy Industries Co, Ltd. Jian Hua Lu Shanghai Shanghai China BU, ABR, CBR, FCE, P1 86‐021‐31193417 www.zpmc.com Shanghai Zhenhua Heavy Industries Co, Ltd. Kang? Xue‐Zeng Nantong Jiangsu China BU, ABR, CBR, FCE, P1 86‐2158396666 Shaoxing Feng'an Steel Structure Co., Ltd. Yun Chen Shaoxing City Zhejiang China BU, P1 0575‐82877211 Tianjin Bomesc Offshore Engineering Company Limited Wei Dongchao Tianjin Tianjin China BU, SBR, P1 86‐13821792201 Tianjin Eng& Con Corporation Steel Structure Company Zheng Zihui Tianjin Tianjin China BU 86‐022‐28553806 [email protected] United Steel Structure, Ltd. Mira He Foshan Guangdong China BU, P2 86 20 81592409‐309 www.ussl.com United Steel Structures, Ltd. Steven Hou Zhongshan Guangdong China BU, P2 86‐2081592409 Wuhu Tianhang Technology (Group) Co., Ltd Miss Wang Yan Wuhu city Anhui China BU, P2 86‐0553‐5720397 http://www.tianhanggroup.com/ WUXI CHUXIN STEEL STRUCTURE PROJECT LIMITED CORPORATION Cao Xiaochun WuXi JianSu China BU, P2 86 510 53 555 222 www.chuxinsteel.com Xiamen NCC Steel Engineering Co., Ltd (Zhangzhou factory) Wu Zhiliang Zhangzhou Fujian China BU, P2 0086‐13959291660 www.nccst.com Yanda (Haimen) Heavy Equipment Manufacturing CO., Ltd Huang Song Haimen Jiangsu China BU 86‐139‐1243‐9400 http://yanda.com.cn Yingkou Steel Structure Sub‐Co. of Ansteel Construction Group Xuan Luo Liaoning Province Liaoning China BU 086‐0417‐619448 Zhejiang Dadi Steel Structure Co., Ltd. Jianguo Qu Hangzhou Zhejiang China BU 86 13606638548 www.cnzjdd.com Zhejiang Jinggong Heavy Steel Structure Co., Ltd. Chen Guodong Shoaxing City Zhejiang China BU 86‐575‐89185989 www.600496.com Zhejiang Provincial Erjian Steel Structure Co., Ltd. Zhang Guosong Ningbo, Zhejiang China BU, P2 13777222766 Zhejiang SouthEast Space Frame Co., Ltd Yaping Han Hangzhou City Zhejiang China BU, P2 86‐571‐82782741 www.dongnanwangjia.com Zhongtong Steel Structure Co., Ltd. Li Dongqiang Liaocheng Shandong China BU, P2 86‐635‐2126657 www.cztss.com

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Company Contact City State Country Certification Phone Number Web Site A.I. Industries M. Karim Walji Surrey BC Canada BU (604) 583‐2171 www.ai‐industries.com Acier Fortin, Inc Richard? Gagne Montmagny QC Canada BU (418) 248‐7904 www.acierfortin.com ADF Group, Inc. Eric Duchharme Terrebonne QC Canada BU, ABR, CBR, FCE, P1 450‐965‐1911 www.adfgroup.com ANJ Industrial Fab Ltd. Rob Maola Corunna ON Canada BU, P1 (519) 336‐4265 Breton Steel 2016, Inc Michel Arsenault St‐Bruno‐De‐Montarville QC Canada BU (450) 653‐9999 www.bretonsteel.com Canam Buildings and Structures Inc. Andre Clermont St‐Gedeon‐de ‐Beauce QC Canada BU, ABR, CBR, FCE, P1 (418) 582‐3331 www.groupecanam.com Canatal Industries Danny Lapointe Thetford Mines QC Canada BU (418) 330‐6044 www.canatal.net Capitol Steel Corp. Dave Hurd Winnipeg MB Canada BU, ABR, CBR, FCE 204‐784‐8210 www.capitolsteel.ca Charpentes d' Acier Sofab Inc. Claude Desrosiers Boucherville QC Canada BU (450) 641‐2618 Cherubini Metal Works Limited Danilo? Gasparetto Dartmouth NS Canada BU, ABR, CBR, FCE (902) 468‐5630 www.cherubinigroup.com Coastal Metals Limited Peter Girouard Beresford NB Canada BU (506) 783‐0999 Constructions Proco Inc. Carol Girard Saint Nazaire QC Canada BU, IBR, CBR, FCE, P1 (418) 668‐3333 proco.ca Dynamic Attractions Ltd. Dave? Halliday Port Coquitlam BC Canada BU, IBR, CBR, FCE, P1 (604) 468‐7631 www.dynamicattractions.com JV Driver Fabricators Inc. Jon Hrabiwchuk Nisku AB Canada BU 587‐671‐0448 http://www.jvdriverfabricators.com/ KAY‐SON Steel Fabricators Ltd. Tony Hernandez Coquitlam BC Canada BU 6045244471 Les Aciers Solider Inc.? Yannick Gardner Victoriaville QC Canada BU (819) 758‐2897 www.solider‐inc.com Les Constructions Beauce Atlas, Inc. Germain? Blais Saint Marie de Beauce QC Canada BU (418) 387‐4872 Les Structures CDL, Inc. Gilles Brisson St. Romuald QC Canada BU (418) 839‐1421 MacDougall Steel Erectors, Inc. Ron MacDougall Borden‐Carleton PE Canada BU (902) 855‐2100 Marid Industries Limited Greg Schofield Windsor Junction NS Canada BU 902‐860‐1138 ext 235 Metal Perreault Inc. Simon Harnois Donnacona QC Canada BU +1 418 285 4499 www.metalperreault.com Mometal Structures Inc. Marc‐Antoine Bienvenue Varennes QC Canada BU 450 929‐3999 www.mometal.com MQM Quality Manufacturing, Ltd. LeoPold Theriault Tracadie‐Sheila NB Canada BU (506) 395‐7777 Niagara Structural Steel Iain Fox St. Catharines ON Canada BU 1‐888‐853‐4346 www.niagarastructuralsteel.com Nico Metal Inc. Jocelyn Richard Trois‐Rivieres QC Canada BU (819) 375‐6426 Norgate Metal 2012 Inc. Danny Lefebvre La Guadeloupe QC Canada BU 418‐459‐6988 www.norgatemetal.com Ocean Steel & Construction Ltd. Harrison? Wilson Fredericton NB Canada BU, P1 (506) 632‐2600 Ocean Steel & Construction, Ltd Harrison? Wilson Saint John NB Canada BU, ABR, CBR, FCE, P1 (506) 632‐2600 Pittsburgh Steel Group (2061810 Ontario Inc.) Mick Joksimovic Mississauga ON Canada BU 905‐362‐5097 www.pittsburghsteelgroup.com Structure SBL Inc. Louis‐David Poirier P. Eng. Saint‐Beno?t‐Labre, Quebec Canada BU 418‐230‐3140 www.structuresbl.com Structures XL Frederic Tasse Terrebonne QC Canada BU 450 968‐0800 www.structuresxl.com Sturo Metal, Inc. Jean‐Louis Lemieux Levis QC Canada BU (418) 833‐2107 www.sturometal.com Supermetal Structures, Inc Jean Francois? Blouin Sherbrooke QC Canada BU (418) 834‐1955 Supermetal Structures, Inc. Jean Francois? Blouin L?vis QC Canada BU, P1 (418) 834‐7691 Supreme Steel Edmonton Sanjar Jilavi Acheson AB Canada BU 6055244421 Supreme Steel LP Chris Pierrard Saskatoon SK Canada BU 306‐975‐1177 [email protected] Supreme Steel LP Ken Warkentin Winnipeg, Manitoba Canada BU (204) 589‐7371 x 242 www.supremegroup.com Supreme Steel Vancouver Jeff Skibin Delta BC Canada BU, ABR, CBR, FCE, P1 780‐483‐3278 supremegroup.com TecFab International, Inc. Nicolas Massicotte Shawinigan QC Canada BU, IBR, CBR, FCE 1‐877‐536‐4445 www.tecfab.qc.ca Trimax Steel, Inc. Labbe Jacques Ste‐Marie Beauce QC Canada BU 418‐387‐7798 225 www.trimaxsteel.com Waiward Steel LP Eli Bruce Edmonton AB Canada BU 780‐469‐1258 Walters Inc Walt Koppelaar Princeton, Ontario Canada BU, P1 905‐388‐7111 Walters, Inc. Walter Koppelaar Hamilton ON Canada BU (905) 388‐7111 X.L. Ironworks Company Rick? Hounslow Surrey BC Canada BU (604) 596‐1747

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Company Contact City State Country Certification Phone Number Web Site ACERO TECNOLOGIA, S.A. DE C.V. Sergio Gonzalez Cienega de Flores NLE Mexico BU ‐13833 www.atecno.com.mx Aceros Lozano S.A. de C.V. Santos Herrera Cd. Benito Juarez, Nuevo Leon NLE Mexico BU, ABR, CBR, FCE, P2 52 81 8127 9000 www.aceroslozano.com Acesta S.A. de C.V. Eliseo Leon Tala JAL Mexico BU, SBR, P1 +52 33 3283 0500 www.acesta.com.mx Aciarium Estructuras S.A. de C.V. Rene Holguin Aquiles Serdan CHH Mexico BU (614) 429‐6600 ext 313 ASI Baja, S. de R.L. de C.V. Omar Ali Tecate BCN Mexico BU (770) 490‐8341 www.aimsteelbaja.com BBM‐CPG Mexicana S.A. de C.V. Daniel Mijares Toluca EM Mexico BU 722‐2497070 Construcciones Industriales Tapia S.A. de C.V. Emma Luz Flores Ceron Atitalaquia HGO Mexico BU, P3 01(773)1006100 www.citapia.com.mx Corey S.A. de C.V. Luis Herrera Rangel El Salto JAL Mexico BU, ABR, CBR, FCE, P2 52‐33‐3668‐0644 www.corey.com.mx Estructuras Metalicas la Popular S.A. de C.V./MSCI David Diaz Tijuana BCN Mexico BU (664) 626‐85‐90 www.estructurasmetalicaslapopular.com Grupo Industrial Persal S.A. de C.V Elias Robles Mexicali BCN Mexico BU (619) 400‐4134 www.persal.com.mx Industrias Metalicas De Monclova S.A. De C.V. (IMMSA) Sergio? De Luna Monclova COA Mexico BU 52‐866 6341860 KS Fabrication de Mexico Roberto Sainz Tijuana BCN Mexico BU 011 52 664 204 3504 www.ksfab.com.mx Montajes Frontera S.A. Gabriela Alvarez Gutierrez Frontera Coahuila Mexico BU, SBR 52(866)6342593 Operadora CICSA, S. A. de C. V. Guillermo Sanchez Cardonac Tuxpan VER Mexico BU 521 7838390086 www.swecomex.com.mx Operadora CICSA, S. A. de C. V. Swecomex ‐ Guadalajara Guillermo Sanchez Cardenas Guadalajara JAL Mexico BU 52 38811400 www.swecomex.com.mx Preacero Pellizzari Mexico S.A. de C.V. Alex Pellizzari Veracruz VER Mexico BU, P2 58 276 3563022 Valmont Monterrey, S. de R.L. de C.V. Apodaca NLE Mexico BU www.valmontutility.com

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EXHIBIT I-21

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Australian Government Antl'DUmpinQ Department of Industry, COITimiSSiOn Innovation and Science

ANALYSIS OF AUSTRALIA’S STEEL MANUFACTURING AND FABRICATING MARKETS REPORT TO THE COMMISSIONER OF THE ANTI-DUMPING COMMISSION

November 2017

adcommission.gov.au

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pressures give industries incentives to continually improve their productivity performance and strive to best meet their customers' needs. The system includes a number of checks and balances to ensure that trade remedies are limited to remedying the material injury caused by dumped and subsidised imports. These include ensuring that the Commission's operational policies and practices are consistent with the WTO framework.

1.4 Key findings

The Commission's analysis has found: • Performance has varied across sectors within the industry, which reflects the diversity of the steel fabrication industry in terms of products and end uses.

• On the demand side, three industries—the construction, manufacturing and mining industries— are the main consumers of steel fabricated products, comprising almost 90 per cent of demand for these products. Trends in the economic performance of these industries affect the performance of steel fabrication businesses, noting that businesses producing specialised products may be more affected by specific factors within the broader market.

• On the supply side, continuing global excess capacity and the demand/production imbalance for primary steel products—underpinned by government interventions and market distortions—are impacting on the global and Australian steel fabrication industries. The demand/production imbalance for primary steel can flow through into the steel fabrication market and lead to imbalance in the steel fabrication industry. In addition, the primary steel demand/production imbalance may create distortions in markets for steel fabricated products as a result of responses by some exporters to trade remedies on primary steel products that are being dumped or subsidised.

• Australia's imports of selected steel fabricated products decreased in 2016, but were historically high compared to a decade earlier. The Commission found that imports of some steel fabricated products had increased following the imposition of measures on the primary steel input to their production (although data and analytical constraints meant that a causal link could not be established). More than 50 per cent of total steel fabricated imports came from China and Thailand.

• While Australia's anti-dumping system provides a potential remedy to all industries that are suffering material injury caused by dumping or subsidisation, most applicants for anti-dumping measures on steel products have been from Australian industries producing primary steel products, with relatively few applications in respect of steel fabricated products. In Australia, there are currently two measures in place on steel fabricated products.

• Some Australian steel fabricators have argued that the costs of accessing the system (such as legal expenses), difficulties in meeting the requirement for standing due to the fragmented nature of some segments of the industry, and difficulties in obtaining the required evidence create barriers to applying for duties. Others have identified similar factors, as well as a lack of awareness and understanding of the system, as barriers to participating in investigations and applying for duty assessments and annual reviews. These difficulties are compounded by the large number of SMEs in the industry, which generally face greater challenges in interacting with the anti-dumping system than larger businesses. The challenges faced by SMEs in accessing the anti-dumping system—as applicants for measures, as industry participants wishing to make submissions to investigations, and as importers seeking duty assessments and/or reviews of measures—are well-known. The government and the Commission have implemented a number of actions to facilitate SME access to the anti-dumping system. Stakeholders have proposed further options for improving access—by further improving knowledge and awareness of the system, by simplifying the system and facilitating access to data, and by

6 Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved Page 123 of 129 Barcode:3789316-02 A-570-102 INV - Investigation - information in a December 2016 IBISWorld report on the Chinese metal fabrication industry. While the report discusses metal fabrication as a whole, steel fabricated products comprise the majority of industry output at 57.8 per cent, while the remainder of the industry consists of iron fabricated products 21.7 per cent, aluminium fabricated products 17.3 per cent, and other 3.2 per cent. In the five-year period through 2016, the Chinese metal fabrication industry grew at an average annualised rate of 8 per cent to reach $167 billion in 2016. In 2016, Chinese exports were estimated to total $16.0 billion and accounted for 9.6 per cent of total industry revenue.^® China Customs information indicated that the major export destinations in 2015 were Japan (10.6 per cent of export value). South Korea (7.6 per cent), the United States (6.5 per cent), and Australia (6.0 per cent).'^° In 2016, around 8,644 metal fabricating entities operated in China, an increase from 6,585 in 2011, reflecting annualised growth of 5.6 per cent over the period. Over the five years to 2021, the number of enterprises was forecast to increase at an annualised rate of 4.3 per cent to 10,689.The industry employed around 1.3 million workers in 2016.^^

4.2 Australian steel imports Australia is a net importer of crude steel. In 2015, Australia's production of crude steel was 4,925,000 metric tons, accounting for less than 0.3 per cent of world production. Australia's apparent steel consumption was 6,968,000, with net imports making up the difference between production and consumption.'^^ Australia is also a net importer of indirect steel. Indirect steel is the steel that is contained in manufactured goods, which includes fabricated and non-fabricated goods. In 2014, Australia exported 829,000 tons of indirect steel and imported 5,656,000 tons of indirect steel. The Commission has estimated that Australia imported $2.5 billion of selected steel manufactured/fabricated products (as defined in chapter 2) in 2016. More than 50 per cent of imports come from China (38.9 per cent) and Thailand (22.0 per cent). Chinese imports have grown by an average 15.4 per cent a year. This increase accounted for about half of the total increase in imports in the past decade.

IBISWorld Industry Report, Metal Fabrication in China, December 2016, p. 12. ibid. '*1 ibid., p. 7. '*2 ibid., p. 4. Steel Statistical Yearbook. ibid. 34 Filed By: [email protected], Filed Date: 2/1/19 6:12 PM, Submission Status: Approved Page 124 of 129 Barcode:3789316-02 A-570-102 INV - Investigation -

EXHIBIT I-22

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STEEL STATISTICAL YEARBOOK 2018

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Preface

This yearbook presents a cross-section of steel industry statistics that are exchanged or published by the World Steel Association. The co-operation of both members and non-members in supplying the information included in this publication is gratefully acknowledged. Further details of the statistical sources used are given in the Annex (p. 121). These contents were finalised in November 2018.

Data are expressed in thousand metric tons unless stated otherwise.

Zero indicates that the quantity concerned is less than 500 tonnes.

‘e’ indicates a figure that has been estimated by the World Steel Association.

Totals comprise listed countries only. Trade data totals include intra-regional exports and imports.

Three dots (...) indicate that an item of information was not available.

World Steel Association Economics Committee

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2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

Belgium 118 97 70 57 ...... Czech Republic 476 366 426 360 283 275 330 341 368 292 Germany 2 555 1 637 1 936 2 082 2 332 2 115 2 087 1 998 1 939 ... Italy 1 524 900 850 912 883 836 796 705 786 708 Luxembourg 1 785 1 447 1 807 1 853 2 007 1 882 1 984 1 909 1 932 1 895 Poland 1 542 1 086 1 243 1 371 1 431 1 243 1 250 1 267 1 360 1 384 Romania 142 84 122 ...... Spain 2 585 2 180 2 790 2 950 2 605 2 477 2 272 2 556 2 626 2 753 United Kingdom 851 574 656 501 425 487 546 671 846 736 European Union (28) 11 578 8 372 9 901 10 085 9 967 9 315 9 265 9 448 9 858 7 768

Kazakhstan ... 0 7 ...... 6 Russia ...... 1 502 1 736 1 774 1 693 1 739 1 601 1 589 1 522 Ukraine ...... 842 987 944 983 731 605 596 521 C.I.S. ... 0 2 351 2 723 2 718 2 676 2 470 2 206 2 185 2 049

Canada 313 147 173 183 199 263 183 192 207 205 Costa Rica 1 2 ...... Mexico 417 326 360 370 465 455 583 652 866 872 United States 6 501 3 763 4 701 5 184 5 031 5 577 5 571 5 299 5 717 5 434 North America 7 232 4 237 5 234 5 737 5 695 6 295 6 337 6 143 6 790 6 511

Argentina ...... 19 25 53 50 49 113 ...... Brazil 725 428 568 735 788 819 715 635 ...... Colombia 5 6 9 4 1 3 2 1 ...... Peru 3 1 1 6 4 3 ... 3 ...... Venezuela 95 76 59 66 71 69 45 ...... South America 828 511 655 836 917 944 811 753 ......

South Africa 509 ...... Africa 509 ......

Iran 1 704 1 846 2 230 2 223 2 087 1 948 1 788 1 286 974 966 Middle East 1 704 1 846 2 230 2 223 2 087 1 948 1 788 1 286 974 966

China 10 255 9 643 9 771 11 099 11 630 13 242 13 495 14 357 15 517 ... India 5 312 5 260 5 659 4 757 5 091 6 604 7 157 7 558 7 590 ... Japan 7 213 4 777 5 209 5 474 5 771 6 265 6 073 5 782 5 643 5 760 South Korea 4 320 3 842 3 830 4 255 4 380 4 248 4 218 4 140 4 045 4 165 Asia 27 099 23 521 24 468 25 585 26 872 30 359 30 943 31 837 32 796 9 925

World 48 950 38 487 44 839 47 189 48 256 51 538 51 614 51 673 52 602 27 218

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2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

Austria 757 555 627 746 669 727 811 852 900 983 Belgium 741 402 532 585 568 510 562 543 575 ... Bulgaria ... 51 ...... 274 204 264 210 ... 274 Czech Republic 702 503 687 730 563 530 431 432 376 439 Denmark 483 208 ...... Germany 3 871 2 898 3 312 3 601 3 207 2 803 3 088 3 141 3 024 ... Finland 712 360 ...... France 921 556 788 836 704 666 714 692 711 772 Hungary 140 74 ...... Italy 3 067 2 339 2 637 2 750 2 606 1 999 2 180 1 732 1 840 1 788 Netherlands 18 17 19 16 17 16 19 19 14 16 Poland 1 118 585 513 541 689 625 451 382 361 519 Slovenia 129 88 158 ...... Spain 665 355 313 360 378 498 504 546 516 531 Sweden 753 384 ...... United Kingdom 1 159 746 883 940 889 845 768 688 434 490 European Union (28) 15 237 10 121 10 469 11 105 10 565 9 422 9 791 9 236 8 750 5 813

Kazakhstan 39 13 34 69 39 21 90 85 118 96 Russia ...... 4 575 4 303 3 570 4 127 5 483 6 021 5 340 5 119 Ukraine ...... 2 778 3 683 3 096 2 828 2 485 1 527 1 906 1 922 C.I.S. 39 13 7 387 8 054 6 706 6 976 8 058 7 633 7 364 7 137

Canada 707 282 419 461 451 408 397 387 319 334 Mexico 569 317 477 597 610 628 742 535 745 719 United States 6 732 4 103 5 658 6 374 6 172 6 328 6 550 5 583 5 449 5 546 North America 8 008 4 702 6 555 7 431 7 233 7 364 7 689 6 505 6 514 6 599

Argentina 413 223 516 407 371 ...... Brazil 1 968 1 237 1 654 1 599 1 548 1 423 1 324 913 699 896 Venezuela 496 248 190 238 159 ...... South America 2 876 1 708 2 361 2 244 2 079 1 423 1 324 913 699 896

South Africa 1 138 ...... Africa 1 138 ......

Iran ...... 65 322 585 615 774 798 669 725 Middle East ...... 65 322 585 615 774 798 669 725

China 136 750 140 068 173 980 180 296 176 034 188 353 196 671 196 676 ...... India 3 957 3 969 4 126 4 283 4 472 3 889 4 492 4 293 4 320 ... Indonesia 835 787 822 811 806 539 1 539 1 326 1 500 1 887 Japan 16 290 12 838 14 657 14 488 13 399 12 863 13 145 11 872 12 315 11 036 South Korea 8 196 7 566 9 524 11 342 10 226 8 939 10 122 10 040 9 502 8 986 Malaysia 201 187 166 197 152 143 144 180 220 207 Taiwan, China 1 301 1 000 1 272 1 312 1 195 1 127 1 139 1 051 1 086 1 026 Thailand ... 308 392 370 389 ... 217 156 175 206 Asia 167 529 166 723 204 938 213 100 206 672 215 853 227 470 225 594 29 118 23 349

World 194 828 183 267 231 774 242 257 233 839 241 653 255 106 250 679 53 114 44 519

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