Barcode:3927394-02 C-570-118 INV - InvestigationPUBLIC - VERSION

DOC Investigation Nos. A-351-583, A-570-117, and C-570-118 USITC Investigation Nos. 701-TA-___ and 731-TA-___-___ Total Pages: 159 Investigation AD/CVD Operations Petitioner’s Business Proprietary Information Removed from Pages 3, 4, 10, 17-19, 21-22, 24-27, EL-1, and Exhibits I-3, I-4, I-5, I-6, I-7, I-9, I-19, I-21 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 SECTION 701 AND 731 OF THE TARIFF ACT OF 1930, AS AMENDED VOLUME I: COMMON ISSUES AND INJURY PETITION

IN THE MATTER OF: WOOD MOULDINGS AND MILLWORK PRODUCTS FROM BRAZIL AND THE PEOPLE’S REPUBLIC OF CHINA

PETITIONER: COALITION OF AMERICAN MILLWORK PRODUCERS

ECONOMIC CONSULTANTS: COUNSEL: Richard F. DiDonna, Timothy C. Brightbill, Esq. International Trade Analyst Laura El-Sabaawi, Esq.

WR TRADE ANALYTICS GROUP WILEY REIN LLP 1776 K Street, NW 1776 K Street, NW Washington, DC 20006 Washington, DC 20006 (202) 719-7000 (202) 719-7000

January 8, 2020

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Barcode:3927394-02 C-570-118 INV - Investigation - PUBLIC VERSION

TABLE OF CONTENTS Page

I. COMMON ISSUES 1 A. The Name and Address of the Petitioner (19 C.F.R. § 351.202(b)(I)) 1 B. Identity of the Industry on Whose Behalf the Petition Is 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 E. Scope ofthe Investigation and a Detailed Description of the Subject Merchandise (19 C.F.R. § 351.202(b)(5)) .4 1. Scope of Investigation 4 2. Technical Characteristics and Uses 6 3. Production Methodology 7 4. Tariff Classification 9 F. The Names of the Home Market Countries and the Name of Any Intermediate Country Through Which the Merchandise Is Transshipped (19 C.F.R. § 351.202(b)(6)) 9 G. The 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)) 10 H. 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 Exports to the United States (19 C.F.R. § 351.202(b)(7)(ii)(A)) 11 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

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Barcode:3927394-02 C-570-118 INV - Investigation - PUBLIC VERSION

L. The Value of the Merchandise Imported During the Most Recent Three-Year Period (19 C.F.R. § 351.202(b)(8)) 11 M. The Names and Addresses of 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. DUMPED AND SUBSIDIZED BRAZILIAN AND CHINESE IMPORTS ARE A CAUSE OF MATERIAL INJURY AND THREAT THEREOF TO THE DOMESTIC WOOD MOULDINGS AND MILL WORK PRODUCTS INDUSTRY 12 A. Introduction 12 B. The Domestic Like Product Consists of Wood Mouldings and Millwork Products Covered by the Scope 13 C. There Is a Single Domestic Industry Consisting of All Domestic Producers 15 D. Subject Imports Are Causing Material Injury to the Domestic Industry 15 1. The Volume of Subject Imports Is Significant. 15 2. The Subject Imports Have Had Negative Price Effects on the Domestic Like Product 20 3. The Adverse Impact of Subject Imports on the Domestic Industry Is Significant 23 E. Conclusion 26 F. Subject Imports Threaten Material Injury to the Domestic Industry 27 III. CONCLUSION 31

11 Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Barcode:3927394-02 C-570-118 INV - Investigation - PUBLIC VERSION

These Petitions are presented on behalf of the Coalition of American Millwork Producers

(the "Coalition" or "Petitioner"). The Coalition is comprised of Bright Wood Corporation,

Cascade Wood Products, Inc., Endura Products, Inc., Sierra Pacific Industries, Sunset Moulding,

Woodgrain Millwork Inc., and Yuba River Moulding ("Petitioners").

Petitioners allege that wood mouldings and millwork products ("WMMP") imported from

Brazil and the People's Republic of China are being or are likely to be sold at less than normal value within the meaning of section 731 of the Tariff Act of 1930, as amended, 19 U.S.C. § 1671 and § 1673 (hereinafter "the Act"). Petitioners further allege that WMMP imported from China are subsidized within the meaning of section 701 of the Act. These unfairly traded imports have materially injured the United States domestic industry producing WMMP and threaten to cause further material injury if remedial action is not taken. These Petitions contain information reasonably available to Petitioners in support of these allegations.

Separate volumes regarding the allegations of dumping by subject producers, as well as countervailable subsidies provided to subject producers from China, are being filed simultaneously at the U.S. Department of Commerce (the "Department") and the U.S. International Trade

Commission (the "Commission"). Petitioners request that antidumping and countervailing duties be imposed to offset the dumping margins and countervailable subsidies detailed in the antidumping and countervailing duty volumes.

I. COMMON ISSUES

A. The Name and Address of the Petitioners (19 C.F.R. § 351.202(b)(l))

The Petitioner is the Coalition of American Millwork Producers. Petitioner is a domestic interested party within the meaning of 19 U.S.C. § 1677(9) and 19 C.F.R. § 351.102(b)(17). The

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Barcode:3927394-02 C-570-118 INV - Investigation - PUBLIC VERSION names, addresses, and telephone numbers of the companies comprising the Coalition are provided in Exhibit 1-1.

B. Identity of the Industry on Whose Behalf the Petition Is 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 United States industry that produces WMMP. In addition to the information relating to the Petitioners in Exhibit 1-1, the names, addresses, and telephone numbers of other producers ofWMMP in the United States are provided in Exhibit 1-2.

According to the best information available to Petitioners, Exhibits 1-1 and 1-2 identify all known producers of the merchandise under consideration in the United States.

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

Under the relevant statutory provisions, 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% of the total production of the domestic like product, and (2) domestic producers who support the petition account for more than 50% of the production of the domestic like product produced by that portion of the industry expressing support for or opposition to the petition. 1 Petitioners meet both of these requirements.

Petitioners' estimate of total U.S. production ofWMMP for 2018 is in the table below. To estimate domestic industry production, Petitioners gathered actual 2018 production data from each

Petitioner company and additional companies supporting these investigations. 2 To this total,

Petitioners added estimated 2018 production figures for other major U.S. producers, obtained from

19 U.S.C. §§ 1671a(c)(4)(A) (countervailing duty petitions) and 1673a(c)(4)(A) (antidumping petitions). See Industry Support Calculation, attached as Exhibit 1-3; Declaration of Frank DeMott, attached as Exhibit 1-4; Declaration of Philip J. Menzner II, attached as Exhibit 1-5.

2 Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Barcode:3927394-02 C-570-118 INV - Investigation - NGED PUBLIC VERSION the Moulding and Millwork Producers Association ("MMP A"). 3 The estimates for these other major U.S. producers are based on their MMPA dues category, which reflects each producer's

2018 production level. As explained further in Exhibit 1-3, reported production levels are rounded to the middle of each MMP A production category. These production level estimates are conservative, as they may account for some production of non-subject products, including MDF products."

The MMP A comprises the largest WMMP producers in the United States and accounts for at least [ d') 0] of domestic WMMP production. 5 Petitioners have not included in their estimates any MMPA members that are foreign producers, importers and/or distributors, or that otherwise do not manufacture the domestic like product in the United States." To be conservative, Petitioners have also included an amount representing an additional 25% of domestic production, attributable to smaller, non-MMPA member manufacturers of WMMP. A large portion of this remaining amount of production is attributable to members of the Architectural Woodwork Institute," an association of woodworking companies that has taken no position on and does not oppose these investigations. 8

As Table 1 shows, Petitioners' estimated share of U.S. production ofWMMP products well exceeds the statutory standards.

See Industry Support Calculation, attached as Exhibit 1-3; Declaration of [ ], attached as Exhibit 1-6. 4 Declaration of [ NAmG ], attached as Exhibit 1-6. See id. See Declaration of [ N AM E. ], attached as Exhibit 1-7. About Us, Architectural Woodwork Institute, attached as Exhibit 1-8. Declaration of Doug Hague, attached as Exhibit 1-9.

3 Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Barcode:3927394-02 C-570-118 INV - Investigation - ANGED PUBLIC VERSION

TABLE 1 PETITIONERS' SHARE OF DOMESTIC PRODUCTION 2018 (Board Feet) Estimate of Total U.S. Production [z.b9'2.,3?;'(\~Ml Petitioners' and Supporters' Production [,5100"3'2-'2'1,\1 ] Petitioners' and Supporters' Share of Total Production of the Domestic Like 58% Product Production by Portion of the Industry Minus Those Taking No Position [-z.3~22.5\ 'W'\I Petitioners' and Supporters' Share of Production by the Portion of the Industry 67% Minus Those Taking No Position on the Petitions

Thus, Petitioners have sufficient industry support to file these petitions on behalf of the domestic industry.

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

Petitioners have not previously filed for antidumping or countervailing duty relief on imports of WMMP and are not aware of any outstanding antidumping or countervailing duty orders on this merchandise. Petitioners have not filed for relief from imports of the subject merchandise under sections 337 of the Act, section 301 of the Trade Act of 1974, or section 232 of the Trade Expansion Act of 1962.

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 define the scope, are as follows:

The merchandise subject to this investigation consists of wood mouldings and millwork products that are made of wood (regardless of wood species), laminated veneer lumber (LVL), or of wood and composite materials (where the composite materials make up less than 50 percent of the total merchandise), and which are woodwork or building materials that are produced in a mill or otherwise undergo remanufacturing.

The covered products include, but are not limited to, the following: interior and exterior door frames or jambs (including split, flat, stop applied, single- or double• rabbeted), frame or jamb kits, packaged door frame trim or casing sets, mullions,

4 Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Barcode:3927394-02 C-570-118 INV - Investigation - PUBLIC VERSION

mull posts, mouldings (crowns, beds, coves, quarter rounds, half rounds, base shoes, astragals, shelf edge/screen moulds, glass bead mouldings, base caps, brickmould, panel mouldings, drip caps, corner guards, shingle/panel mouldings, battens, closet rod, hand rails, rounds, squares, screenl"surfaced on 4 sides" (S4S) and/ or "surface 1 side, 2 edges" (S 1 S2E) stock (also called boards) that are finger jointed and/or coated with any surface coating (including primed), lattice, dowels, picture moulding, wainscot/ply cap, back bands, chair rails), stops, sashes, base mouldings, casing, trim, panel strips, shelf cleats, chamfer strips, inside corners, window stools (flat/rabbeted), sills, door stiles, thresholds/saddles, decorative wood mouldings (embossed, dentil, carved rope moulding), rosettes, plinth blocks, interior siding, including nickel gap or shiplap, that is LVL or finger jointed and/or coated with any surface coating (including primed), and finger-jointed or edge• glued moulding or millwork blanks (whether or not resawn).

The covered products may be solid wood, laminated, finger-jointed, edge-glued, or otherwise joined in the production or remanufacturing process and are covered by the scope whether imported raw, coated (e.g., gesso, polymer, or plastic), primed, painted, stained, wrapped (paper or vinyl overlay), any combination of the aforementioned surface coatings, treated, or which incorporate rot-resistant elements (whether wood or composite). The covered products are covered by the scope whether or not any surface coating(s) or covers obscures the grain, textures, or markings of the wood, whether or not they are ready for use or require final machining (e.g. endwork/dado, hinge/strike machining, weatherstrip or application thereof, mitre) or packaging.

All wood mouldings and millwork products are included within the scope even if they are trimmed; cut-to-size; notched; punched; drilled; or have undergone other forms of minor processing.

Subject merchandise also includes wood mouldings and millwork products that have been further processed in a third country, including but not limited to trimming, cutting, notching, punching, drilling, coating, or any other processing that would not otherwise remove the merchandise from the scope of the investigations if performed in the country of manufacture of the in-scope product.

Excluded from the scope of this investigation are exterior fencing, exterior decking and exterior siding products, finished and unfinished doors, flooring, and parts of stair steps.

Excluded from the scope of this investigation are all products covered by the scope of the antidumping and countervailing duty orders on Hardwood Plywoodfrom the

5 Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Barcode:3927394-02 C-570-118 INV - Investigation - PUBLIC VERSION

People's Republic of China. See Certain Hardwood Plywood Products from the People's Republic of China: Amended Final Determination of Sales at Less Than Fair Value, and Antidumping Duty Order, 83 FR 504 (January 4, 2018); Certain Hardwood Plywood Products from the People's Republic of China: Countervailing Duty Order, 83 FR 513 (January 4,2018).

Excluded from the scope of this investigation are all products covered by the scope of the antidumping and countervailing duty orders on Multilayered Wood Flooring from the People's Republic of China. Multilayered Wood Flooring From the People's Republic of China: Amended Final Determination of Sales at Less Than Fair Value and Antidumping Duty Order, 76 FR 76690 (December 8, 2011); Multilayered Wood Flooringfrom the People's Republic of China: Countervailing Duty Order, 76 FR 76693 (December 8, 2011).

Imports of wood mouldings and millwork products are primarily entered under the following Harmonized Tariff Schedule of the United States (HTSUS) numbers: 4409.10.4010, 4409.10.4090, 4409.10.4500, 4409.10.5000, 4409.22.4000, 4409.22.5000, 4409.29.4000, 4409.29.4100, 4409.29.5000, and 4409.29.5100. Imports of wood mouldings and millwork products may also enter under HTSUS numbers: 4409.10.6000, 4409.10.6500, 4409.22.6000, 4409.22.6500, 4409.29.6100,4409.29.6600,4418.99.9095 and 4421.99.9780. While the HTSUS subheadings are provided for convenience and customs purposes, the written description of the scope of these investigations is dispositive.

2. Technical Characteristics and Uses

Wood moulding and millwork products are manufactured from softwood, hardwood, laminated veneer lumber, or some combination of wood and composite materials, and are woodwork or building materials that are produced in a mill or otherwise undergo remanufacturing.

Wood mouldings and millwork products have a variety of exterior and interior uses, primarily in residential and non-residential construction. These products have both functional and decorative uses.

These uses include as crown mouldings, which are used where wall and ceiling meet to cover large angles, and cove mouldings, which have a concave profile and are used at corners, including as a ceiling cornice. Wood mouldings and millwork products are also used as interior and exterior door frames or jambs, and as astragals, which are attached to one of a pair of doors to

6 Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Barcode:3927394-02 C-570-118 INV - Investigation - PUBLIC VERSION keep the other from swinging through the opening and also can serve a decorative purpose. Wood mouldings and millwork products also include base caps, which are installed flush against the wall and the top of a baseboard, and corner guards, which are used to protect corners or cover ragged edges where wall coverings and painted surfaces meet at an outside corner. Additional uses, among others, include as base shoes, which are applied where base moulding meets the floor to protect the base from damage and/or to conceal uneven lines or cracks where the base meets the floor; as brickmoulds, which are used as an exterior door and window casing to provide a surface for brick or other siding to butt against; as drip caps, which are applied over exterior window and door frames to keep water from seeping under the siding and to direct water away from window glass; and as battens, which are used to conceal the line where two parallel boards or panels meet.

3. Production Methodology

WMMP are manufactured in several stages, including ripping, cutting, finger jointing, moulding, laminating, and coating or vinyl wrapping. At the ripping stage, lumber boards are scanned or evaluated to identify visible characteristics in the wood. These may include knots, pitch pockets, blue stain, or other imperfections that reduce the value of the wood. After identifying these characteristics, an optical scanner or trained personnel will map out the best way to rip the board to maximize the number of clear cuts that are free of imperfections. Generally, all rips will be used to manufacture a downstream product, but visible characteristics may affect the ultimate selling price.

In the cutting process, ripped boards are cut to specific lengths, considering the need to maximize the number of clear cuts while also meeting customer demand for certain lengths and minimizing waste. This is done either by a human cutter or by automated scanners that analyze the characteristics of each board and determines the best cuts based on value and order file. These

7 Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Barcode:3927394-02 C-570-118 INV - Investigation - PUBLIC VERSION cuts can then be finger jointed together by cutting complementary, interlocking profiles into the ends of each piece and gluing them together.

Finger Jointing

Because smaller lengths are less susceptible to warping, finger jointed lengths are generally preferable to longer, solid lengths for structural reasons. Finger jointing also allows mills to minimize waste by manufacturing lengths to customer demand out of smaller pieces that would otherwise be treated as scrap. The adhesive used for finger jointing varies depending on the ultimate application.

These solid or finger jointed "blanks" are then fed through one or more moulders that grind and/or cut the blank to the desired shape, or profile. More sophisticated profiles or products typically require multiple stages of moulding on machines that are connected by transfer belts.

After the moulding process, WMMP may undergo further complex end machining or processing if required by the application. This may include weather stripping or additional cutting and drilling, e.g., for creating lock holes in door frame.

Following the moulding process, the moulded pieces may be coated by painting, priming, lamination, or wrapping with vinyl, veneer, or paper. These processes allow two or more pieces

8 Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Barcode:3927394-02 C-570-118 INV - Investigation - PUBLIC VERSION to be pieced together to form a larger component. Like finger jointing, fitting smaller pieces together into larger components generally results in greater strength and resistance to warping than using a solid piece.

4. Tariff Classification Imports of subject merchandise are classified under Harmonized Tariff Schedule of the

United States ("HTS") statistical numbers 4409.10.4010, 4409.10.4090, 4409.10.4500,

4409.10.5000, 4409.22.4000, 4409.22.5000, 4409.29.4000, 4409.29.4100, 4409.29.5000, and

4409.29.5100.9 Subject merchandise may also enter under 4409.10.6000, 4409.10.6500,

4409.22.6000,4409.22.6500,4409.29.6100, 4409.29.6600, 4418.99.9095 and 4421.99.9780.

Excerpts from the current HTS are attached as Exhibit 1-10. The tariff numbers are provided for the convenience of the U. S. government and do not define the scope of the petition.

The written description of the merchandise under investigation is dispositive.

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

The WMMP covered by these petitions are imported from Brazil and the People's Republic of China. Petitioners do not have any evidence indicating that the subject merchandise is currently produced in a country other than that from which it is exported. However, Petitioners emphasize that subject merchandise also includes WMMP and in-scope components from Brazil and China that have been further processed in a third country, including but not limited to one or more of the following: trimming, cutting, notching, punching, drilling, coating, or any other processing that

9 Note that 4409.29.4000 and 4409.29.5000 no longer appear in the Harmonized Tariff Schedule, as they were changed to HTS numbers 4409.29.4100 and 4409.29.5100, respectively. Because there were subject imports imported under these prior HTS numbers during the period of investigation ("POI"), Petitioners have included these numbers in the scope.

9 Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Barcode:3927394-02 C-570-118 INV - Investigation - ANG D PUBLIC VERSION would not otherwise remove the merchandise from the scope of the investigation if performed in the country of manufacture of the in-scope product.

G. The 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 Brazilian and Chinese entities believed by Petitioners to be producing and exporting the WMMP subject to these petitions are provided in Exhibit 1-11. In

compiling this exhibit, Petitioners relied primarily upon information from foreign producer websites and information procured from [ SouRCE ], as well as

Petitioners' industry knowledge.

Information reasonably available to Petitioners does not allow them 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. Petitioners believe, however, that the companies

listed in Exhibit 1-11 account for the majority of subject imports.

H. 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))

Volume II of these Petitions contains the necessary information concerning the calculation

of the normal value of the foreign like product and the export price for merchandise produced and

exported from Brazil.

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 treated as a non-market economy for antidumping purposes. Volume III of these petitions contains the information necessary to substantiate less than normal value allegations and

factual information relevant to China.

10 Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Barcode:3927394-02 C-570-118 INV - Investigation - PUBLIC VERSION

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 Exports to the United States (19 C.F.R. § 351.202(b)(7)(ii)(A»

The names and addresses of the entities believed by Petitioners to be benefiting from countervailable subsidies and who have exported the WMMP subject to these petitions are provided in Exhibit 1-11. Information reasonably available to Petitioners does not allow them 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. Petitioners believe, however, that the companies listed in Exhibit 1-11 account for the majority of subject imports.

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

Volume IV of these petitions contains information concerning the alleged countervailable subsidies as well as factual information relevant to the alleged countervailable subsidies, the law, regulations, and decrees under which the subsidies were bestowed, the manner in which the subsidies were provided, and Petitioners' estimation - to the extent practicable - of the value of the subsidies to subject producers and exporters of WMMP subject to these petitions.

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

Official import statistics showing the quantity and value of imports under the relevant HTS subheadings during the most recent three-year period are included in Exhibit 1-18. The value of imports from Brazil increased from $265.8 million in 2016 to $316.2 million in 2017, and then declined slightly to $291.8 million in 2018. In January through October 2019, the value of imports from Brazil increased to $267.6 million, from $238.4 million in the same period of2018.

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The value of imports from China increased from $105.3 million in 2016, to $158.4 million in 2017, and to $208.4 million in 2018. In January through October 2019, the value of imports from China was $161.7 million.

M. The Names and Addresses of 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»

The names and addresses of importers of WMMP from Brazil and China that are known to the Petitioners at this time are listed in Exhibit 1-12. Petitioners believe, however, that there may be a number of importers ofWMMP from China and Brazil that they have been unable to identify.

Petitioners respectfully request that the Department and the Commission obtain this information from U.S. Customs and Border Protection, as Petitioners do not have access to this information.

II. DUMPED AND SUBSIDIZED BRAZILIAN AND CHINESE IMPORTS ARE A CAUSE OF MATERIAL INJURY AND THREAT THEREOF TO THE DOMESTIC WOOD MOULDINGS AND MILLWORK PRODUCTS INDUSTRY

A. Introduction

Imports of WMMP from Brazil and China have caused material injury to the domestic industry, both during and prior to the POLIO As subject imports have increased, the domestic industry has lost sales and market share, with devastating impact to its financial performance.

Many domestic producers have simply been unable to compete with dumped and subsidized subject merchandise and have had to shut down facilities leading up to and during the POI. For example,

10 The POI for the preliminary phase of the injury investigation will be 2016-2018 and interim 2019. In order to fully capture the injury to the domestic industry, Petitioners request that the POI for any final phase investigation also begin in 2016.

12 Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Barcode:3927394-02 C-570-118 INV - Investigation - PUBLIC VERSION

• In October 2015, Woodgrain Millwork permanently closed its facility in Prineville, OR and laid off or relocated 55 employees in face of lost sales volumes', 1 1

• In January 2017, Consolidated Pine shut down its third-generation family• run facility in Prineville, OR after 64 years in operation because cheaper imports were "dominat{ing} the market"; 12

• In April 2018, Endura Products shut down its Sparta, TN facility and laid off 83 workers after losing a major contract; 13

• In February 2019, Jeld Wen announced the closure of its Yakima, WA facility, affecting 173 workers. 14

As discussed in greater detail below, these closures are recent manifestations of the devastating impact of unfairly traded subject imports on the industry's trade and financial performance in recent years. If U.S. producers continue losing sales and market share to subject imports, more closures and layoffs like these are inevitable. The Department should therefore initiate investigations into dumped WMMP imports from Brazil and dumped and subsidized WMMP imports from China.

B. The Domestic Like Product Consists of Wood Mouldings and Millwork Products Covered by the Scope

In determining whether an industry in the United States is materially injured or threatened with material injury by reason of imports of the subject merchandise, the Commission first defines the domestic like product.P The "domestic like product" is defined as "a product which is like, or

11 Joseph Ditzler, Woodgrain Millwork Leaving Prineville, The Bulletin (Oct. 28,2015), attached as Exhibit 1- 13.

12 Joseph Ditzler, Bidder, Owner at Odds Over Prineville Facility, The Bulletin (July 11, 2017), attached as Exhibit 1-14.

13 Bobby Lee McCulley, Endura Products Announces Closure of Sparta Facility, Sparta Live (Apr. 13,2018), attached as Exhibit 1-15; Amye Anderson, Sparta Industrial Facility Closes Abruptly, Upper Cumberland Business Journal (Apr. 13,2018), attached as Exhibit 1-16. 14 Mai Hoang, Jeld-Wen to Close Yakima Facility, Yakima Herald (Feb. 4, 2019), attached as Exhibit 1-17. 15 See NEC Corp. v. Dep't of Commerce, 36 F. Supp. 2d 380, 382 (Ct. Int'l Trade 1998).

13 Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Barcode:3927394-02 C-570-118 INV - Investigation - PUBLIC VERSION in the absence of like, most similar in characteristics and uses with, the article subject to an investigation .... ,,16 The like product determination is a factual one made on a case-by-case basis.'? 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." In evaluating these factors, the

Commission looks for clear dividing lines and disregards minor variations. 19

The Commission should define a single like product coextensive with the scope in this investigation. All in-scope WMMP share the same general physical characteristics, including shape and materials. All WMMP are constructed from similar wood inputs and are intended to be used as a covering for floors, walls, doors, and other areas, primarily in residential and non- residential construction. In addition, WMMP produced to the same dimensions are generally interchangeable. All WMMP are sold through the same or similar channels of distribution - (1) distributors; (2) retail, including home centers; or (3) direct to end users

(including builders and homeowners). WMMP are also manufactured in common facilities, using similar production processes and the same production employees.

The Commission should therefore determine that WMMP represent a single domestic like product, coextensive with the scope identified above.

16 19 U.S.C. § 1677(10). 17 See, e.g., NEC, 36 F. Supp. 2d at 383. 18 See Cleo, Inc. v. United States, 501 F.3d 1291, 1295 (Fed. Cir. 2007). 19 Id.

14 Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Barcode:3927394-02 C-570-118 INV - Investigation - PUBLIC VERSION

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

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 maj or proportion of the total domestic production of the product. ,,20 The

Commission should find that there is a single domestic industry manufacturing WMMP in the

United States.

D. SUbject Imports Are Causing Material Injury to the Domestic Industry

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

(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."

An analysis of these factors shows that the domestic WMMP industry is suffering material injury by reason of subject imports.

1. The Volume of Subject Imports Is Significant

In evaluating the volume of imports, the Commission considers whether the absolute and relative volumes of imports, as well as changes in volumes, are significant. 22 The available data show that the volume of subject imports, both in absolute terms and relative to U.S. consumption, is significant within the meaning of the relevant statutory provision.

20 19 U.S.C. § 1677(4)(A). 21 Id. § 1677(7)(B). 22 Id. § 1677(7)(C)(i).

15 Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Barcode:3927394-02 C-570-118 INV - Investigation - PUBLIC VERSION

a. The Volume of Subject Imports Is Significant in Absolute Terms

The volume of subject imports was significant in absolute terms during the POI. The following table shows the quantity and value of imports of WMMP from Brazil and China for

2016-2018 and January through October 2019.23 Official import statistics track import quantities in meters.

TABLE 2 IMPORTS OF WOOD MOULDINGS AND MILLWORK PRODUCTS FROM BRAZIL AND CHINA Quantity (1,000 meters)

Jan.-Oct. Jan.-Oct. 2016 2017 2018 2018 2019

Brazil 372,705 420,298 434,041 357,021 376,176

China 100,543 134,918 190,386 149,238 181,963

Total 473,248 555,216 624,427 506,259 558,139

Value ($1,000)

Brazil $265,788 $316,186 $291,760 $238,355 $267,589

China $105,297 $158,402 $208,288 $168,770 $161,705

Total $371,085 $474,588 $500,048 $407,125 $429,294

HTS numbers: 4409.l0.4010, 4409.l0.4090, 4409.10.4500, 4409.l0.5000, 4409.22.4000,4409.22.5000,4409.29.4000, 4409:29.4100, 4409.29.5000, and 4409.29.5100

As the table shows, imports of WMMP from Brazil and China increased significantly during the POI, whether considered individually or on a cumulated basis. The cumulated subject imports increased by approximately 31.9% from 2016 to 2018, and by another 10.2% in the interim period. Growth in import volumes from each subject country individually was also significant.

Imports from Brazil increased by approximately 16.5% over the three full years of the POI and by

23 See Import Data, attached as Exhibit 1-18.

16 Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Barcode:3927394-02 C-570-118 INV - Investigation - R NGED PUBLIC VERSION

5.4% in the interim period. Imports from China increased by approximately 89.4% over the three full years of the POI and by 21.9% in the interim period. For comparison, Petitioner's total shipments ofWMMP between 2016 and 2018 [..\-Y't,nJ V4

b. Subject Imports Increased Their Market Share During the Period

Petitioners' estimates also show that the volume of subject imports over the POI was significant in relative terms, as increases in subject import volumes over the POI captured U.S. market share at the expense of the domestic industry. Because official import data under the relevant HTS subheadings are reported in lineal meters only, while the industry typically records production volumes in board feet,25 Petitioners relied on an estimated conversion factor for lineal meters to board feet in the market share estimate below. This conversion factor is based on an estimate of 0.65 board feet per lineal meter that [ N ACZf...Al t vE

]. This is the best information available to Petitioners at this time for an estimate of market shares based on volumes. For the purpose of its questionnaires in an investigation, the Commission should ask all responding parties to report data in thousands of board feet to ensure that it can calculate market share on a consistent basis.

Because import volumes and domestic production are not reported on a consistent basis,

Petitioners have also included an analysis of market shares by value.

24 Domestic Producers' Compilation, attached as Exhibit 1-19.

25 Board footage is calculated according to the following formula: (width in inches x length in inches x (thickness in inches) / 144.

17 Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Barcode:3927394-02 C-570-118 INV - Investigation - PUBLIC VERSION

TABLE 3 APPROXIMATE MARKET SHARE BY VOLUME (1,000 board feet) Calendar Year January - Septem ber 2016 2017 2018 2018 2019 Petitioners' Shipments [ JMft.{.b"7a f'lhK3 ] Subject Imports 307,611 360,890 405,877 294,199 326,043 Nonsubject imports 320,651 324,177 314,087 240,574 233,501 Total [ ] i1qtt~('2-. . Petitioners' Share [ ]

Subject Import Share [ ] Nonsubject Import Share [ ]

HTS number for import values: 4409.10.40, 4409.10.45, 4409.10.50, 4409.22.40, 4409.22.50, 4409.29.40,4409.29.41,4409.29.50, and 4409.29.51.

TABLE 4 APPROXIMATE MARKET SHARE BY VALUE Calendar Year January - September Item 2016 2017 2018 2018 2019 Values in $1,000 Petitioners' Shipments [ 3611- ?P9' ] Subject Imports $396,903 $509,129 $547,133 $394,298 $443,018 Nonsubject imports $383,063 $404,794 $399,138 $302,307 $314,710 Total [ q .%,z,~K rJ'~5,~,tt ] .~ . I Petitioners' Share [ ] Subject Import Share [ ] Nonsubject Import Share [ ]

These estimates show that the domestic industry's U.S. market share, both by volume and

value, eroded rapidly under the pressure of dumped and subsidized subject merchandise. During

the three full years of the POI, the domestic industry's approximate market share by volume fell

by nearly [ ] percentage points, from [ ~] of U.S. consumption to [ ~ ] of U.S.

consumption. By value, the domestic industry's loss of market share was even greater, declining

nearly [ ] percentage points from 2016 to 2018. This loss of market share to unfairly traded subject

18 Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Barcode:3927394-02 C-570-118 INV - Investigation - PUBLIC VERSION imports continued during the interim period. In the first three quarters of 2019, the domestic industry lost another [ ] percentage points of market share by volume, and nearly [ ] percentage points by value, compared to the same period in 2018.

SUbjectimport market share, to the contrary, increased rapidly as domestic producers were unable to compete with dumped and subsidized pricing. Specifically, the subject imports captured approximately [ ] additional percentage points of U.S. market share by volume, and

[ ] additional percentage points by value, from 2016 to 2018. In the interim period, subject imports captured another [ ] percentage points of market share by volume, and [# ] percentage points by value. While these gains came primarily at the expense of the domestic industry, non-subject imports also lost market share, confirming that adverse volume effects were primarily the result of price-based competition with Brazilian and Chinese imports, and not because of competition with imports from non-subject sources.

Independent reports corroborate Petitioners' estimates of significantly increasing subject import market shares. As early as October 2016, industry observers noted that "U.S. wood moulding producers continue to struggle to defend their market share against offshore imports," with imports from Brazil "leading the way" and Chinese imports growing rapidly as a slowing

Chinese housing market began "motivating Chinese producers to put even more emphasis on the

U.S. market.v'" As discussed above, these trends have continued throughout the POI, resulting in significant market share losses for the domestic industry over the POI.

Accordingly, during the POI, subject import volumes were significant in absolute terms and relative to domestic production.

26 Us. moulding producers struggle with rising imports, Friday Offcuts (Oct. 28, 2016), attached as Exhibit 1-20.

19 Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Barcode:3927394-02 C-570-118 INV - Investigation - PUBLIC VERSION

2. The Subject Imports Have Had Negative Price Effects on the Domestic Like Product

In evaluating the effect of subject imports on prices, the Commission must consider whether there has been significant underselling by the subject imports, and whether imports significantly suppressed or depressed domestic prices." Subject imports undersold the domestic like product throughout the POI. The dumped prices of Brazilian imports and the dumped and subsidized prices of Chinese imports also suppressed prices by preventing the domestic producers from raising prices in response to growing demand for WMMP. On this basis, the Commission should determine that Chinese imports had significant negative price effects on the domestic like product.

There are no significant distinctions between the subject imports and domestic WMMP with respect to physical characteristics, end uses, or channels of distribution. They thus compete head-to-head on the basis of price, resulting in significant price depression and suppression as a result of subject import underselling. Average unit value ("AUV") data confirm that the subject imports pervasively undersold the domestic like product during the POI. For this analysis,

Petitioners again used the conversion factor of 0.65 board feet per linear foot, described above.

Average Unit Values (U.S. Dollars per 1,000 Board Feet) January - Calendar Year September 2016 2017 2018 2018 2019 Petitioners' Shipments $1,939 $2,001 $2,097 $2,104 $2,204 Subject Imports $1,290 $1,411 $1,348 $1,340 $1,359 % Difference 33% 29% 36% 36% 38%

27 19 U.S.C. § 1677(7)(C)(ii).

20 Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Barcode:3927394-02 C-570-118 INV - Investigation - AN D PUBLIC VERSION

These AUVs confirm that the subject imports were sold in the U.S. market at prices far below the domestic industry's prices throughout the POI. Given this significant underselling, the domestic industry was unable to raise its prices to an extent sufficient to cover increasing costs, which it should have been able to do during a period of growing demand. The domestic industry's unit cost of goods sold ("COGS") increased by approximately [n ... S] from 2016 to 2017, and by another [ ] from 2017 to 2018, for a total of [ ] per 1,000 board feet during the three full years of the POL28 Because of subject imports, however, domestic producers were unable to fully increase prices to recoup these higher costs.

Given the presence of growing volumes of unfairly traded subject imports, domestic producers could only sustain modest price increases without losing even more market share. This price suppression is apparent in the domestic industry's AUV trends, which increased by only

[ ] per 1,000 board feet from 2016 to 2017, and by only [ ] per 1,000 board feet from 2017 to 2018. The domestic industry's COGS to net sales ratio thus increased from ['10 ] in 2016, to

[ ], and finally to [ ] in 2018.29 As a result, the domestic industry was barely able to cover its costs by the last full year of the POI, while the subject imports were able to maintain substantially lower prices and continue capturing market share at the expense of U.S. producers.

As discussed in greater detail below, this price suppression has had disastrous consequences for

U.S. producers' financial performance.

Further evidence of the negative price effects of the subject imports appears in the reports oflost sales and lost revenues. Petitioners have identified lost sales and revenues with an estimated

28 See Domestic Producers' Compilation, attached as Exhibit 1-19. 29 See id.

21 Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Barcode:3927394-02 C-570-118 INV - Investigation - D PUBLIC VERSION total value of ['$

Petitioners submit that these estimates likely understate the true price effects of the subject imports because of product mix issues and the need to convert official import statistics from meters to board feet using an approximate conversion factor. The Commission will need to collect detailed information on a consistent basis regarding the prices of Brazilian and Chinese WMMP in the U.S. market to assess the full extent of underselling, price depression, and price suppression in this investigation. Petitioners recommend that the Commission collect data on the following pricing products:

Product 1. Fingerjointed lineal trim, made of pinel fir, with dimensions of9/16" x 5-114", WM-618, primed or coated (note: price per foot)

Product 2. Fingerjointed lineal trim, made of pinel fir, 5/8" x 2-1/4", LWM- 366, primed or coated (note: price per foot)

Product 3. Fingerjointed lineal trim, made of pinel fir, 11116" x 11116" x 16' WM-I06, primed or coated (note: price per foot)

Product 4. Jamb Product 1. Exterior door frame nominally 1-1/4" thick with a nominal Yz" rabbeted drop for door stop x nominal 4-9/16" width x nominal T long and machined with end dadoes for threshold and head attachment, primed or coated

Product 5. Jamb Product 2. Exterior door frame nominally 1-1/4" thick with a nominal Yz" rabbeted drop for door stop x nominal 6-9/16" width x nominal 7' long and machined with end dadoes for threshold and head attachment, primed or coated

30 See Lost Sales and Lost Revenues, attached as Exhibit 1-21. Pursuant to 19 C.F.R. § 207.11(b)(2)(v), Petitioners have provided information on lost sales and lost revenue that is reasonably available. This information is also being submitted electronically as required by the Commission's regulations.

22 Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Barcode:3927394-02 C-570-118 INV - Investigation - PUBLIC VERSION

Product 6. Brick Moulding. Casing that attaches to exterior edge of door frame nominally 1-114"thick x 2" wide and 7' long with moulded profile on face, primed or coated

3. The Adverse Impact of Subject Imports on the Domestic Industry Is Significant

In examining the impact of subject imports on the domestic industry, the Commission is instructed to "evaluate all relevant economic factors which have a bearing on the state of the industry in the United States.v" These factors include, but are not limited to:

(I) actual and potential decline in output, sales, market share, profits, productivity, return on investments, and utilization of capacity;

(II) factors affecting domestic prices;

(III) actual and potential negative effects on cash flow, inventories, employment, wages, growth, ability to raise capital, and investment;

(IV) actual and potential negative effects on the existing development and production efforts of the domestic industry, including efforts to develop a derivative or more advanced version of the domestic like product; and

(V) the magnitude of the margin of dumping. 32

The Commission is directed to evaluate all factors "within the context of the business cycle and conditions of competition that are distinctive to the affected industry.v'" A review of these factors shows substantial indicators of injury to the domestic industry by reason of the subject imports in this investigation.

3 J 19 U.S.C. § 1677(7)(C)(iii). 32 Id. § 1677(7)(C)(iii)(I)-(V). 33 Id. § 1677(7)(C)(iii).

23 Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Barcode:3927394-02 C-570-118 INV - Investigation - PUBLIC VERSION

a. During a Period of Growing Demand, Subject Imports Adversely Affected the Domestic Industry's Financial Performance

Subject imports had a negative impact on the financial condition of the domestic industry, with the industry's financial indicators declining across the POI. Gross profit, net income, and operating income all plummeted over the three full years of the POI, with corresponding decreases in profit and operating margins, as unfairly traded subject imports suppressed prices and took market share from the domestic industry. From 2016 to 2018, gross profit fell by [1,t? ], from approximately [$1..0\"\ M~\\:~to less than [ ].34 During the same period, the industry'S profit margin fell from [~/) ] in 2016 to a mere [ ] in 2018.

Declines in net income and operating income were even more severe, with the industry

[ ] of the POI. Net income fell from approximately [

] in 2016 to [ ] in 2018, while operating income plummeted from [~ \L~ (V\\\.~ in 2016 to [ ] in 201 7, and finally to a disastrous [

] in 2018.35 As of 2018, the industry's operating margin was [ ], [ percentage points lower than in 2016.36 By the end of the POI, the domestic industry was taking substantial losses on its assets.'? suggesting that many of the producers that remain could be forced to shut down and liquidate their facilities if relief from unfair trade is not granted. The industry continues to operate at an unsustainably low margin of [ '\ e ].

This decline in financial performance occurred while U.S. demand was strong and growing.

Based on Petitioners' shipment data and estimated U.S. import data converted to board feet, U.S.

34 Domestic Producers' Compilation, attached as Exhibit 1-19. 35 Id. 36 Id. 37 Id.

24 Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Barcode:3927394-02 C-570-118 INV - Investigation - PUBLIC VERSION apparent consumption of WMMP increased from approximately [~!\ ~\\;o-d board feet in 2016 to nearly [ ] board feet in 2018, and it continued to increase during the interim period." One major demand driver for WMMP is new residential construction, which can be measured using housing starts data from the U.S. Census Bureau. This data shows that the number of housing units completed in the United States increased by 12.5% from 2016 to 2018.39 Despite this strong growth, as a result of unfair subject import competition, the domestic WMMP industry suffered dramatic declines across key financial indicators. This has forced U.S. WMMP producers to cut high-wage jobs. From 2016 to 2018, the domestic industry lost approximately [ ] workers and

[~.q~\\\.~ hours worked.t" This represents losses of millions of dollars in wages to workers and communities across the country.

b. Domestic Industry Production and Trade Indicators Demonstrate Material Injury Caused by Subject Imports

In addition to declining financial results, the domestic industry's production, capacity, and shipments declined steadily over the POI. From 2016 to 2018, U.S. production capacity fell by approximately [~~.l rt\~\\~o'(\] board feet, with another [ ] board feet of capacity lost during the interim period." Despite significant reduction in overall capacity, capacity utilization rates dropped by more than [ ] from 2016 to 2018, and by [ ] percentage points in the interim period.V By the end of the POI, the industry was operating at only [~.f)]% capacity utilization, as total production plummeted.P Because it was unable to compete against persistent

38 See Section II.D.I.

39 U.S. Census Bureau, Monthly New Residential Construction (Dec. 2017), attached as Exhibit 1-22; U.S. Census Bureau, Monthly New Residential Construction (Dec. 2018), attached as Exhibit 1-23. 40 Domestic Producers' Compilation, attached as Exhibit 1-19. 41 Id 42 Id 43 Id

25 Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Barcode:3927394-02 C-570-118 INV - Investigation - PUBLIC VERSION subject import underselling, the volume and value of the domestic industry's commercial shipments decreased significantly in each full year of the POI and in the interim period."

Both trade and financial data thus reveal material injury by reason of dumped and subsidized imports from Brazil and China.

c. Subject Imports Have Caused Domestic Producers to Lose Sales and Revenues

As noted above, Petitioners have identified lost sales and revenues with an estimated total value of approximately [ ].45 The sales and revenues lost to subject imports would have been [ ] during the period." These lost sales and revenues establish that imports of Brazilian and Chinese WMMP are competing directly with the domestic like product, so that unfairly low AUV s for subject imports have a direct effect on domestic prices and sales.

d. The Estimated Dumping Margins Are Very High

Petitioners estimate dumping margin for the subject merchandise ranging from 268.74% to 361.83%.47 Being forced to compete with imports dumped at this magnitude clearly have a negative effect on the domestic industry's financial situation and overall health.

E. Conclusion

All of the indicators of material injury are present in this case. The volume of subject imports was significant both absolutely and relative to U.S. production, and increased over the

POI. These subject imports undersold the domestic like product substantially and systematically,

44 Id. 45 See Lost Sales and Lost Revenues, attached as Exhibit 1-21. 46 See Domestic Producers' Compilation, attached as Exhibit 1-19. 47 See Petition, Vol. II at 17; Petition, Vol. III at 19.

26 Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Barcode:3927394-02 C-570-118 INV - Investigation - PUBLIC VERSION and they depressed and suppressed U.S. producer prices over the period. As a result, despite strong and growing U.S. demand for WMMP during the POI, U.S. producers' financial performance deteriorated significantly, domestic industry employment stagnated, and domestic producers lost

[$~ ~lkcw1 in sales and revenues to subject imports." Subject imports prevented the domestic industry from reaping any of the benefits of strong and growing U.S. demand and left the U.S.

WMMP industry in a weakened, injured state.

Therefore, the volume, price effects and impact of subject imports on the U.S. WMMP industry have been both significant and harmful. The Commission should find that subject imports have caused material injury to the domestic industry.

F. Subject Imports Threaten Material Injury to the Domestic Industry

The above discussion establishes that the subject imports have caused material injury to the domestic WMMP industry. In addition, the evidence available to Petitioners also demonstrates that subject imports threaten the domestic industry with further material injury.

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

• A significant rate of increase of the volume or market penetration of imports of the subject merchandise; • Price effects of the subject imports; • The nature of any countervailable subsidies; • Existing unused production capacity or potential increases in production capacity in the exporting country;

48 Lost Sales and Lost Revenues, attached as Exhibit 1-21.

27 Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Barcode:3927394-02 C-570-118 INV - Investigation - PUBLIC VERSION

• Inventories of the subject merchandise; and • The potential for product-shifting."

These factors are present in this case and will be demonstrated throughout the investigation:

Increase in imports: The cumulated subject imports increased by approximately 31.9% from 2016 to 2018, and by another 10.2% in the interim period.i" taking substantial market share from the domestic industry.I' Thus, the increase in subject import volume and the increase in subject imports' market share are both significant. The surge of subject imports also affected the profitability of the domestic industry, causing it to decline even during a period of growing demand, rendering U.S. producers vulnerable to injury should subject imports continue to enter the United States at current or increasing rates. Without relief, Brazilian and Chinese WMMP imports will continue to increase in the foreseeable future.

Price effects: The Act provides that, in determining whether the domestic industry is threatened with material injury, the Commission should consider "whether imports of the 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. ,,52 Subject imports had such effects during the POI and, in the absence of relief, will continue to have such effects in the near future.

Subject imports pervasively undersold the domestic like product during the POI, as discussed above. 53 As a result of this underselling, domestic producers were unable to raise prices

49 19 U.S.C. § 1 677(7)(F)(i). 50 Import Data, attached as Exhibit 1-18. 51 See supra section II.D.l. 52 19 U.S.C. § 1 677(7)(F)(i)(IV). 53 See supra section II.D.2.

28 Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Barcode:3927394-02 C-570-118 INV - Investigation - PUBLIC VERSION in accordance with growing demand, and U.S. producers' unit COGS increased further than did their net sales AUVs.54 The price effects of the Chinese imports are also demonstrated by the extensive lost sales reported by the domestic industry.

Nature of the subsidies: As part of its threat analysis, the Commission must consider "if a countervailable subsidy is involved" and, in particular, "whether the countervailable subsidy is a subsidy described in Article 3 or 6.1" of the WTO Agreement on Subsidies and Countervailing

Measures.P Article 3 of the WTO Subsidies Agreement describes subsidies that are prohibited because they are contingent upon export performance or upon the use of domestic over imported goods."

The nature of the countervailable subsidies received by the Chinese and Brazilian hardwood industries encourage both the expansion of capacity and the export of WMMP to the

United States. Examples of the subsidies that benefit WMMP producers in China and Brazil include:

• The provision of inputs at less than adequate remuneration, including timber and veneers;

• Policy loans at preferential rates provided to WMMP producers by Chinese government authorities, as industries favored by the government;

• Grants provided to WMMP producers to assist in the development of export markets or to recognize export performance;

• Preferential land use rights that are granted to promote exports to enterprises and industries located in China's industrial zones; and

• Income tax credits for domestically owned companies, which are contingent upon the use of domestically produced rather than imported equipment.

54 Domestic Producers' Compilation, attached as Exhibit 1-19. 55 19 U.S.C. § 1677(7)(F)(i)(I).

56 Agreement on Subsidies and Countervailing Measures (Apr. 15, 1994), Marrakesh Agreement Establishing the World Trade Organization, Annex 1, 1867 U.N.T.S. 14 at Art. 3.

29 Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Barcode:3927394-02 C-570-118 INV - Investigation - PUBLIC VERSION

Excess capacity and inventories: With respect to capacity in China and Brazil, and inventories held in China and by U.S. importers, Petitioners do not have access to data.

Petitioners believe that the level of excess WMMP capacity in China and Brazil has likely risen in recent years. The wood WMMP industry is one with relatively low barriers to entry and expansion. While WMMP manufacturing can be high-tech, it can also be performed using basic woodworking equipment; some processes can even be performed manually. There are no intrinsic factors limiting the expansion of current Chinese and Brazilian capacity. Moreover, with huge numbers of unoccupied homes in China - now more than 50 million empty homes'? - new housing construction in China is likely to decline.P leading to a drop in domestic demand for Chinese

WMMP and an increase in subject merchandise that needs to be offloaded through export.

Brazil, in turn, is in the midst of a period of economic stagnation following a significant contraction in economic activity in 2015 and 2016.59 Brazil's recovery has been modest at best, with GDP growth of only 1.1 % in 2017 and 2018.60 During this period, the value of the Brazilian real has plummeted to record lows against the dollar that are expected to persist for the foreseeable future.?' giving Brazilian WMMP producers a distinct pricing advantage against the domestic

57 A Fifth of China's Homes Are Empty. That's 50 Million Apartments, Bloomberg News (Nov. 8,2018), attached as Exhibit 1-24.

58 Thomas R. Cook, Jun Nie, and Aaron Smalter Hall, How Much Would China's GDP Respond to a Slowdown in Housing Activity?, Federal Reserve Bank of Kansas City (Sept. 12,2018), attached as Exhibit 1-25 ("year-over• year investment growth in real estate development excluding land purchases-a measure that focuses on real estate construction, installation, and equipment purchases-has dropped by more than 10 percentage points from about 8 percent in the middle of 20 17 to -4 percent in July 2018 .... In addition, housing construction, measured by growth in the floor space of buildings under construction, has dropped from a double-digit pace toa pace close to zero, while growth in the floor space of completed buildings has turned negative").

59 Brazil Overview, World Bank (last updated Oct. 14,2019), attached as Exhibit 1-26. 60 Id. 61 Brazil's Real to Stay Soft, Business Recorder (Jan. 6,2020), attached as Exhibit 1-27.

30 Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Barcode:3927394-02 C-570-118 INV - Investigation - PUBLIC VERSION industry. Along with the relatively robust U.S. housing market, this is likely to drive continued high volumes of Brazilian WMMP,62 which threaten further material injury if relief is not granted.

These factors indicate that, going forward, subject imports will continue to inflict material injury on the domestic WMMP industry, in the absence of relief.

III. CONCLUSION

All statutory factors support a finding that imports of WMMP from China have caused material injury to the domestic industry, and that such imports threaten additional material injury.

Thus, the Commission should make an affirmative determination with respect to subject imports.

Timothy C. Brightbill, Esq. Laura El-Sabaawi, Esq.

WILEY REIN LLP 1776 K Street, NW Washington, DC 20006 (202) 719-7000

Counsel to Petitioner Coalition of American Millwork Producers ECONOMIC CONSULTANTS: Richard F. DiDonna, International Trade Analyst

WR TRADE ANALYTICS GROUP 1 776 K Street, NW Washington, DC 20006 (202) 719-7000

January 8,2020

62 See, e.g., Marcelo Schmid, Brazilian Lumber Exports Increase to Meet North American Demand, Forest2Market (Oct. 11, 2018), attached as Exhibit 1-28.

31 Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Barcode:3927394-02 C-570-118 INV - Investigation - NG D PUBLIC VERSION

EXHIBIT LIST

Exhibit No. Description Security

I-I Petitioners' Contact Information Public

1-2 US Producer Contact Information Public

1-3 Industry Support Calculation Public

1-4 Declaration of Frank DeMott Public

1-5 Declaration of Philip J. Menzner II Public

1-6 Declaration of [ N AlfV\f.. ] Public

1-7 Declaration of [ N AIfV\£. ] Public

1-8 About Us, Architectural Woodwork Institute Public

1-9 Declaration of Doug Hague Public

1-10 Excerpts from the current HTS Public

1-11 Foreign Producer Contact Information Public

1-12 US Importer Contact Information Public

Joseph Ditzler, Woodgrain Millwork Leaving Prineville, The 1-13 Public Bulletin (Oct. 28, 2015), Joseph Ditzler, Bidder, Owner at Odds Over Prineville Facility, 1-14 Public The Bulletin (July 11, 2017) Bobby Lee McCulley, Endura Products Announces Closure of 1-15 Public Sparta Facility, Sparta Live (Apr. 13,2018) Amye Anderson, Sparta Industrial Facility Closes Abruptly, 1-16 Public Upper Cumberland Business Journal (Apr. 13,2018) Mai Hoang, Jeld-Wen to Close Yakima Facility, Yakima Herald 1-17 Public (Feb. 4, 2019)

1-18 Import Data Public

1-19 Domestic Producers' Compilation Public Us. Moulding Producers Struggle with Rising Imports, Friday 1-20 Public Off Cuts (Oct. 28, 2016)

EL-l Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Barcode:3927394-02 C-570-118 INV - Investigation - PUBLIC VERSION

EXHIBIT LIST

Exhibit No. Description Security

1-21 Lost Sales and Lost Revenues Public

U.S. Census Bureau, Monthly New Residential Construction 1-22 Public (Dec. 2017)

U.S. Census Bureau, Monthly New Residential Construction 1-23 Public (Dec. 2018)

A Fifth of China's Homes Are Empty. That's 50 Million 1-24 Public Apartments, Bloomberg News (Nov. 8,2018)

Thomas R. Cook, Jun Nie, and Aaron Smalter Hall, How Much 1-25 Would China's GDP Respond to a Slowdown in Housing Public Activity?, Federal Reserve Bank of Kansas City (Sept. 12,2018)

1-26 Brazil Overview, World Bank (last updated Oct. 14, 2019) Public

1-27 Brazil's Real to Stay Soft, Business Recorder (Jan. 6, 2020) Public

Marcelo Schmid, Brazilian Lumber Exports Increase to Meet 1-28 Public North American Demand, Forest2Market (Oct. 11,2018)

EL-2 Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Barcode:3927394-02 C-570-118 INV - Investigation -

EXHIBIT I-1

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List of Petitioners and Contact Information

1. Bright Wood Corporation 335 NW Hess Rd Madras, OR 97741 Phone: (541) 475-2234 Contact Person: Dallas Stovall Email: [email protected]

2. Cascade Wood Products, Inc. 8399 14th Street White City, Oregon 97503 Phone: 800-423-3311 x216 Contact Person: Gary Trapp Email: [email protected]

3. Endura Products, Inc. 8817 W. Market St. Colfax, NC 27235 Phone: 1-800-334-2006 Contact Person: Kevin MacDonald Email: [email protected]

4. Sierra Pacific Industries 11400 Reading Road Red Bluff, CA 96080 Phone: (530) 529-5108 Contact Person: Jon Gartman Email: [email protected]

5. Sunset Moulding 2231 Paseo Avenue Live Oak, CA 95953 Phone: (530) 790-2727 Contact Person: John Morrison Email: [email protected]

6. Woodgrain Millwork Inc. 300 NW 16th Street Fruitland, ID 83619 Phone: 208-452-3801 Contact Person: Greg Easton Email: [email protected]

7. Yuba River Moulding PO Box 1078 Yuba City, California 95992 Phone: (530) 742-2475 Fax: (530) 742-7140

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Contact Person: Thomas C. Williams, Jr Email: [email protected]

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EXHIBIT I-2

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List of Other Domestic Producers and Contact Information

1. Barnett Millworks Inc 4915 Hamilton Blvd. Theodore, AL 36590 Phone: (251) 443-7710 Email: [email protected]

2. Best Moulding Corporation 100 Alameda RD NW Albuquerque, NM 87184-0259 Phone: (505) 898-6770 Fax: (505) 898-1301 Contact Person: Frank DeMott Email: [email protected]

3. Daiek Woodworks 14981 32 Mile Road Bruce Twp, MI 48065 Phone: (586) 268-1144 Email: [email protected]

4. EastCoast Moulding (ECMD) 2 Grandview Street North Wilkesboro, NC 28659-0130 Phone: (888) 222-3961 Fax: (866) 314-0747 Email: [email protected]

5. Empire Moulding & Millwork 8181 Logistic Drive, PO Box 17 Zeeland, MI 49464 Phone: (800) 253-9000

6. G-M Wood Products 531 Clay St. Newaygo, MI 49337 Phone: (800) 530-9211 Email: [email protected]

7. Innovative Millwork Tec. 11319 Tantor Road, Suite A Dallas, TX 75229 Phone: (972) 869-9892 Fax: (972) 869-1601

8. Menzner 105 Main St. Marathon, WI 54448

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Phone: (800) 257-1284 Fax: (715) 443-6515 Email: [email protected]

9. Metrie Interior Mouldings and Doors 5575 Nordic Way Ferndale, WA 98248 Phone: (360) 384-4774 Fax: (360) 384-494 Email:

10. MJB Wood Group Inc 3100 Olympus Blvd. Suite 480 Dallas, TX 75019 Phone: (972) 401-0005 Email: [email protected]

11. Port-O-Lite 1 Railroad St West Swanzey, NH 03469 Phone: (603) 352-3205 Email: [email protected]

12. Regal Custom Millwork 275 E Santa Ana St Anaheim, CA 92805 Phone: (714) 776-1673

13. Shawnee Woodwork Inc 112 SW Harrison St. Topeka, KS 66603-3015 Phone: (785) 354-1163

14. Smith Millwork Inc 920 Robbins St. Lexington, NC 27292 Phone: (336) 249-8171 Fax: (336) 243-2688

15. Weaber Lumber 1231 Mt Wilson Rd. Lebanon, PA 17042 Phone: (717) 867-2212 Fax: (717) 867-1711

16. Young Manufacturing Company 521 South Main Street Beaver Dam, KY 42320

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Phone: (270) 274-3306 Email: [email protected]

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EXHIBIT I-3

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2018 Wood Moulding and Millwork Products Production

Petitioners 2018 Production (in board feet) Source Bright Wood Corporation Actual data from company (Exhibit 1-19) Cascade Wood Products, Inc. Actual data from company (Exhibit 1-19) Endura Products, Inc. Actual data from company (Exhibit 1-19) Sierra Pacific Industries Actual data from company (Exhibit 1-19) Sunset Moulding Actual data from company (Exhibit 1-19) Woodgrain Millwork Inc. Actual data from company (Exhibit 1-19) Yuba River Moulding Actual data from company (Exhibit 1-19) Petitioners Subtotal [ \ \ 317 ) q q 1) So 0

Other Supporting Domestic Producers 2018 Production (in board feet) Best Moulding Corporation* Declaration of Frank DeMott, attached at Exhibit 1-4 Menzner Hardwoods Declaration of Philip J. Menzner II, attached at Exhibit 1-5 Weaber Lumber I Petitioners + Supporting Domestic Producers Subtotal [ 1); ~0 \ 1»2;2 ... c...t ~ \

Additional MMPA Domestic Producers 2018 Production (in board feet) Alexandria Moulding Barnett Millworks Inc EastCoast Moulding (ECMD)** G-M Wood Products Innovative Millwork Tec. MJB Wood Group Inc Port-OoLite Regal Custom Millwork Shawnee Woodwork Inc Smith Millwork Inc Young Manufacturing Company Additional MMPA Producers Total [ 4 S

See Declaration of [ N AM€.. L attached at Exhibit 1-6, estimating that non-MMPA producers (including AWl and other Estimated Production by Other Domestic Producers [ producers) account for approximately [ j% of the U.S. market

2018 Production (in board feet) Total Estimated U.S. Production [ L.,,,q'Z.) 3

Petitioners & Supporting Companies % of Total U.S. Production 58%

Production by Portion of the Industry Minus Those Taking No Position

Petitioners & Supporting Companies % of U.S. Production Minus Those Taking No Position 67%

**Only [ "l 0 N 1t~~A-"{\ V€, 1 is included in this calculation, as Petitioners understand that [ 1'0 1 of that total in the United States. See Declaration of [ N AMEJ, attached at Exhibit 1-7.

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EXHIBIT I-4

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DECLARATION

Frank DeMott declares and states that:

1. I am the President of Best Moulding Corp. ("Best"). Best produces wood mouldings and millwork products in the United States.

2. Best supports the antidumping and countervailing duty petitions on wood mouldings and millwork products from China and Brazil.

3. In 2018, Best produced [ ] board feet of wood mouldings and millwork products.

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

5. 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 January 2, 2020, in Albuquerque, NM, Bernalillo county USA.

1 Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 11 of 123 Barcode:3927394-02 C-570-118 INV - Investigation -

EXHIBIT I-5

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DECLARATION

Philip J. Menzner II declares and states that:

1. I am the chairman/CEO/president of Menzner Hardwoods ("Menzner"). Menzner produces wood mouldings and rnillworkproducts in the United States.

2. Menzner supports the antidumping and countervailing duty petitions on wood mouldings and millwork products fromChina and Brazil.

3. In 2018, Menzner produced [ ] board feet of wood mouldings and millwork products.

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

5. I declare under penalty of pe1jury under the laws of the United States of America thatto the best of my knowledge, the foregoing is true and correct.

Executed January 6th, 2020, in Marathon, WI.

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EXHIBIT I-6

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DECLARATION

I, [ N A~ ], state as follows:

1. I am the [ t \ -r L~ ]. I have been employed by [ '" 6f\(Z L and I have a total of [ J years of experience in the wood products industry.

2. In my capacity as [ I. I am very familiar with [ and the U.S. market for wood moulding and millwork products.

3. It is my understanding that [ ~ 0 ] of total U.S. production of wood mouldings and millwork products falling within the scope of this investigation, with the remainder produced by other small U.S. producers.

4. A list of[ N AR.RA-n\f6 I is attached to this declaration at Attachment A.

5. NArz~A""lVe.

] .

6. While I believe that they comprise the majority of production [ the [ ] subject to these petitions. The [ ].

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

8. This declaration is made in accordance with 28 U.S.c. § 1746. I declare under penalty of perjury of the laws of the United States of America that the foregoing statements are true and correct to the best of my information and belief.

[ NAME. Date~'2020

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ATTACHMENT A

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REMAINDER OF EXHIBIT NOT CAPABLE OF PUBLIC SUMMARY

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EXHIBIT I-7

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DECLARATION

I, [ N Af'I\.£ ], state as follows: 1. I am the [ -r l -r L E ]. [ ]. I have been employed by [ "t 6A«- ] and I have a total of [ ] years of experience in the wood products industry. 2. In my capacity as [CoM~AN') l \"1 LE.l, I am very familiar with the U.S. market for wood moulding and millwork products, including the operations of other producers of wood moulding and millwork products.

3. Based on my extensive industry knowledge, I am aware that the following Wood Mouldings and Millwork Producers Association ("MMP N') member companies are foreign producers, importers andlor distributors of wood mouldings and millwork products, or otherwise do not manufacture the wood mouldings and millwork products subject to these petitions in the United States:

[ ]; [ ]; [ ]; [ J; [ ]; [: ]; [ ]; [: CO (Y\ (' f\ f'\ '-J NF\yY\E ]; [ ]; [ ]; [ ]; [' ]; [' ]; [ ]; and [ J. 4. In addition, I estimate that [CoMPANi NAMe ] produces in the United States only approximately [ «>1 0 ] or less of the wood mouldings and millwork products it ships or distributes.

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

6. This declaration is made in accordance with 28 U.S.C. § 1746. I declare under penalty of perjury of the laws of the United States of America that the foregoing statements are true and correct to the best of my information and belief.

L [ NAME J Dated: j tvl'w:'{ '3 ~ 2020

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EXHIBIT I-8

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About ArchitecturalI Woodwork Institute

awinet.org/about

About Us

AWI's Vision To be the global leader in architectural woodwork standards, related interior finishes, industry-specific education and networking opportunities.

Mission We fulfill our Vision by: 1. Creating, publishing and continually improving Standards for architectural woodwork and related interior finishes. 2. Providing education and opportunities for industry stakeholders to participate, collaborate, share resources and engage through AWI; 3. Developing, delivering and continually improving AWI's member benefits; 4. Cultivating and strengthening relationships that promote the architectural woodwork and related interior finishes industry.

History of AWI The Architectural Woodwork Institute (AWI) was incorporated in Chicago, Illinois on December 17, 1954. The President was Charles A. Rinehimer and the Board of Directors consisted of 18 members including Mr. Rinehimer.

The AWI was formed by groupa of individuals who were members of the Millwork Cost Bureau, tradea association of custom millwork operators founded in 1914.

The Millwork Cost Bureau's stated purpose was to establish a cost accounting procedure for custom millwork operations and provide estimating training systems for members. Among those individuals who met to plan the formation of an "architectural woodwork association" were Mr. Charles (Chic) Rinehimer, a longtime director and onetime president of the Millwork Cost Bureau and Elmer W. Root, also formera president of the Millwork Cost Bureau.

After several meetings, the Architectural Woodwork Institute was incorporated in Chicago, IL, and its Articles of Incorporation were filed with the Illinois Secretary of State on December 17, 1954.

Past Presidents

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Term Name Location

2018 Bruce Spitz El Paso, TX

2017 Kristine Cox High Point, NC

201 6 Greg Lutz Wylie, TX

2015 Kent Gilchrist Carmel, IN

2014 Randy Jensen Auburn, AL

2013 Michael Bell Davie, FL

2012 Matt Lundahl Phoenix, AZ

2011 Robert Stout Wendell, NC

2010 Doug Carney Fargo, ND

2009 Whitney Coombs Hannover, PA

2007-2008 Richard Ungerbuehler, Sr. Ft. Lauderdale, FL

2006-2007 Ed Brewer Louisville, KY

2005-2006 Rick Kogler Baton Rouge, LA

2004-2005 Kirsten Ingham Arlington, WA

2003-2004 Jay Blankenship Columbus, GA

2002-2003 Scott Nelson Lincoln, NE

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2001-2002 Douglas Mock Granville, OH

2000-2001 Michael Quirk Wayata, MN

1999-2000 Bruce Cody Roanoke, VA

1998-1999 Philip Duvic Potomac Falls, VA

1997-1998 Joseph Bossen Cinnaminson, NJ

1996-1997 Robert Ziegelmeier Somers, NY

1995-1996 Craig Johnson Osceola, WI

1994-1995 Yves DesMarais Hollywood, FL

1993-1994 Joe Sorrelli Brooklyn, NY

1992-1993 Brad Ricketson Tucson, AZ

1991-1992 Lee Biagiotti* Albany, NY

1990-1991 Stan Robuck* Salina, KS

1989-1990 Dave Mengler* Algonquin, IL

1988-1989 Burl Terrill Mertzon, TX

1987-1988 Rudy Scassellati Placitas, NM

1986-1987 James Hamilton, Sr. Winchester, VA

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1985-1986 Charles Pugsley Oklahoma City, OK

1984-1985 Ted BoIle* Springfield, OH

1983-1984 Theodore Petersen St. Louis, MO

1982-1983 Ed Nolen Knoxville, TN

1981-1982 Rick Ohlson Lakewood, WA

1980-1981 Clete Ernster* Cuero, TX

1979-1980 Dick Currie* Hutchinson, KS

1978-1979 Williiam Hanselman Edwardsville, IL

1977-1978 John McDonald* Miami, FL

1976-1977 Albert Morante* Monroe Township, NJ

1975-1976 Marlin Olsen* Eugene, OR

1974-1975 Lloyd Burton* Virginia Beach, VA

1973-1974 Robert Morency* West Dundee, IL

1972-1973 Bud Lundahl Phoenix, AZ

1971-1972 William Otis Pawley's Island, SC

1970-1971 John Mielach* Edison, NJ

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1969-1970 Lou Dietz* Haverford, PA

1968-1969 Eldredge Leeming Vero Beach, FL

1967-1968 Cedric Thompson* Simsbury, CT

1966-1967 James Elliot* Norfolk, VA

1965-1966 James O'Neill, Jr.* Rome, GA

1964-1965 William Winter* Williamsport, PA

1963-1964 Wayne Sandberg* Salt Lake City, UT

1962-1963 Norman Vaughn, Sr.* Warwick, RI

1961-1962 Ralph Harrison* Nashville, TN

1960-1961 Robert Koll* Winnetka, IL

1959-1960 Robert Hoe, Jr.* Poughkeepsie, NY

1958-1959 Elmer Root* Appleton, WI

1957-1958 Claude Twiellenmeier* St. Louis, MO

1955-1957 Albert Carlson* Minneapolis, MN

1953-1955 Charles Rinehinner* Elgin, IL

Honorary Life Members

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Jerry Allen John Leininger

Lee Biagiotti* Bud Lundahl

Michael Bell Teresa McCain

Jay Blankenship Mickey McCoy

Joseph Bossen Dave Mengler*

Ed Brewer John Mielach*

Gerald Brewer Doug Mock

Carl Bullmore* Albert Morante*

Lloyd Burton* William Munyan

Bruce Cody Scott Nelson

Whitney Coombs Ed Nolan

Dick Currie* Rick Ohlson

Yves DesMarais Marlin Olsen*

Lou Dietz* William Otis

Phil Duvic Theodore Petersen

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Wendell Ellsworth Charles Pugsley

Clete Ernster* Michael Quirk

Randy Estabrook Brad Ricketson*

Paul Fetzer Rudy Scassellati

Margaret Fisher Dan Snider*

John Halpin Joe Sorrelli

James Hamilton, Sr. Bruce Spitz

William Hanselman Burl Terrill

Greg Heuer Richard Ungerbuehler, Sr.

Frank Huschitt, Sr. Norman Vaughn*

Kirsten Ingham Norman "Woody" Vaughn, Jr

Craig Johnson Steve Waltman

Rick Kogler Dan Wendell

Ned Kreider Rob Ziegelmeier

Eldredge Leeming

Sponsors

Sustaining Sponsors

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved 7/8 Page 27 of 123 Barcode:3927394-02 C-570-118 INV - Investigation - ‘10 PROTECTING YOUR AMERICAN DREAM, TOGETHER. AW1EF'- P/StRA121 .*

QUALITY Greater Confidence, Better Product, More Business f:)E 1, 2T c ) lF6C (i /41T) 40 11

Level 1

NAVY ISLAND

ACOUSTIC & ARCHITECTURAL WALLS, CEILINGS, DOORS & FRAMES

Level 2

0,0-Nr) PRECISIO N VENEER sTIL..§AGIcotg

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EXHIBIT I-9

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DECLARATION

Doug Hague declares and states that:

1. I am the Executive Vice President of the Architectural Woodwork Institute ("A WI").

2. A WI is comprised of manufacturers of architectural woodwork, including exposed wood andspecial laminates or other materials, as well as businesses that supply raw materials, products or services to architectural woodwork manufacturers, and architects, general contractors and design professionals.

3. The A WI includes a variety of woodworking companies and individuals. Some of our members produce in the United States wood mouldings and millwork products of the type subject to these petitions.

4. I estimate that A WI members produced approximately [ ] board feet of the wood mouldings andmillwork products subject to these petitions in 2018.

5. The AWI and its members take no position on and do not oppose these antidumping and countervailing duty petitions on wood mouldings and millwork products from China and Brazil.

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 trueand correct. � Executed January 2020 in �� (a;µT'1) 2_, 1 yA,.

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EXHIBIT I-10

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SECTION IX

WOOD AND ARTICLES OF WOOD; WOOD CHARCOAL; CORK AND ARTICLES OF CORK; MANUFACTURES OF STRAW, OF ESPARTO OR OF OTHER PLAITING MATERIALS; BASKETWARE AND WICKER WORK IX-1

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CHAPTER 44

WOOD AND ARTICLES OF WOOD; WOOD CHARCOAL IX 44-1 Notes

1. This chapter does not cover:

(a) Wood, in chips, in shavings, crushed, ground or powdered, of a kind used primarily in perfumery, in pharmacy, or for insecticidal, fungicidal or similar purposes (heading 1211);

(b) Bamboo or other materials of a woody nature of a kind used primarily for plaiting, in the rough, whether or not split, sawn lengthwise or cut to length (heading 1401);

(c) Wood, in chips, in shavings, ground or powdered, of a kind used primarily in dyeing or in tanning (heading 1404);

(d) Activated charcoal (heading 3802);

(e) Articles of heading 4202;

(f) Goods of chapter 46;

(g) Footwear or parts thereof of chapter 64;

(h) Goods of chapter 66 (for example, umbrellas and walking-sticks and parts thereof);

(ij) Goods of heading 6808;

(k) Imitation jewelry of heading 7117;

(I) Goods of section XVI or section XVII (for example, machine parts, cases, covers, cabinets for machines and apparatus and wheelwrights' wares);

(m) Goods of section XVIII (for example, clock cases and musical instruments and parts thereof);

(n) Parts of firearms (heading 9305);

(o) Articles of chapter 94 (for example, furniture, lamps and lighting fittings, prefabricated buildings);

(p) Articles of chapter 95 (for example, toys, games, sports equipment);

(q) Articles of chapter 96 (for example, smoking pipes and parts thereof, buttons, pencils, and monopods, bipods, tripods and similar articles) excluding bodies and handles, of wood, for articles of heading 9603; or

(r) Articles of chapter 97 (for example, works of art).

2. In this chapter, the expression "densified wood" means wood which has been subjected to chemical or physical treatment (being, in the case of layers bonded together, treatment in excess of that needed to insure a good bond), and which has thereby acquired increased density or hardness together with improved mechanical strength or resistance to chemical or electrical agencies.

3. Headings 4414 to 4421 apply to articles of the respective descriptions of particle board or similar board, fiberboard, laminated wood or densified wood as they apply to such articles of wood.

4. Products of heading 4410, 4411 or 4412 may be worked to form the shapes provided for in respect of the articles of heading 4409, curved, corrugated, perforated, cut or formed to shapes other than square or rectangular or submitted to any other operation provided it does not give them the character of articles of other headings.

5. Heading 4417 does not apply to tools in which the blade, working edge, working surface or other working part is formed by any of the materials specified in note 1 to chapter 82.

6. Subject to note 1 above and except where the context otherwise requires, any reference to "wood" in a heading of this chapter applies also to bamboo and other materials of a woody nature. Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 34 of 123 Harmonized Tariff Schedule of the United States (2019) Revision 20 Barcode:3927394-02 C-570-118 INV - Investigation - Annotated for Statistical Reporting Purposes IX 44-2 Subheading Note

1. For the purposes of subheading 4401.31, the expression "wood pellets" means by-products such as cutter shavings, sawdust or chips, of the mechanical wood processing industry, furniture-making industry or other wood transformation activities, which have been agglomerated either directly by compression or by the addition of a binder in a proportion not exceeding 3 percent by weight. Such pellets are cylindrical, with a diameter not exceeding 25 mm and a length not exceeding 100 mm.

Additional U.S. Notes

1. In this chapter:

(a) The term "wood waste" means residual material other than firewood resulting from the processing of wood, including scraps, shavings, sawdust, veneer clippings, chipper rejects and similar small wood residues, as well as larger or coarser solid types of residual wood such as slabs, edgings, cull pieces and veneer log cores;

(b) The term "standard wood moldings" means wood moldings worked to a pattern and having the same profile in cross section throughout their length; and

(c) The term "surface covered," as applied to the articles of headings 4411 and 4412, means that one or more exterior surfaces of a product have been treated with creosote or other wood preservatives, or with fillers, sealers, waxes, oils, stains, varnishes, paints or enamels, or have been overlaid with paper, fabric, plastics, base metal, or other material.

2. The effectiveness of the proviso to section 304(a)(3)(J) of the Tariff Act of 1930 (19 U.S.C. 1304(a)(3)(J)), to the extent permitted by that section and as provided for in schedule XX to the General Agreement on Tariffs and Trade, is suspended, with the result that sawed lumber and sawed timbers however provided for, telephone, trolley, electric light and telegraph poles of wood and bundles of shingles, other than red cedar shingles, shall not be required to be marked to indicate the country of origin.

3. Subheadings 4407.19.05 and 4407.19.06 cover combinations of the named species whose proportions are not readily identifiable.

4. Heading 4409 includes articles having a repeating design worked along any edge or face.

5. Heading 4418 includes--

(a) drilled or notched lumber studs; and

(b) multi-layer assembled flooring panels having a face ply 4 mm or more in thickness.

Statistical Note

1. For the purposes of heading 4407, the term "rough" includes wood that has been edged, resawn, crosscut or trimmed to smaller sizes but it does not include wood that has been dressed or surfaced by planing on one or more edges or faces or has been edge-glued or end-glued.

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 35 of 123 Harmonized Tariff Schedule of the United States (2019) Revision 20 Barcode:3927394-02 C-570-118 INV - Investigation - Annotated for Statistical Reporting Purposes IX 44-15

Heading/ Stat. Unit Rates of Duty Subheading Suf- Article Description of 1 2 fix Quantity General Special 4409 Wood (including strips and friezes for parquet flooring, not assembled) continuously shaped (tongued, grooved, rebated, chamfered, V-jointed, beaded, molded, rounded or the like) along any of its edges, ends or faces, whether or not planed, sanded or end-jointed: 4409.10 Coniferous: 4409.10.05 00 Wood continuously shaped along any of its ends, whether or not also continuously shaped along any of its edges or faces, all the foregoing whether or not . planed, sanded or end-jointed m 3 32%ui Free (A, AU, BH, 33 1/3% CA, CL, CO, D, E, IL, JO, MA, MX, OM, P, PA, PE, SG) 0.6% (KR) Other:

4409.10.10 Wood siding Free 11 2.20/m 2 Resawn bevel siding: m 2 20 Western red cedar

M 3

m 2 40 Other

M 3 Other: m 2 60 Western red cedar

M 3

m 2 80 Other

M 3 m 2 4409.10.20 00 Wood flooring Free 33 1/3%

m3

Wood moldings: Standard wood molding: 5 % 4409.10.40 Pine (Pinus spp.) Free 10 End-jointed m

90 Other m 5 % 4409.10.45 00 Other m Free 4409.10.50 00 Other m Free 40% Wood dowel rods: 5 % 4409.10.60 00 Plain m Free 11 m3

4409.10.65 00 Sanded, grooved, or otherwise advanced in

condition m 4.9% v Free (A+, AU, BH, 33 1/3% m3 CA, CL, CO, D, E, IL, JO, MA, MX, OM, P, PA, PE, SG) 0.9% (KR)

4409.10.90 Other Free 11 $1.70/m 3 m 2 20 Western red cedar

M 3

m 2 40 Other

M 3

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 36 of 123 Harmonized Tariff Schedule of the United States (2019) Revision 20 Barcode:3927394-02 C-570-118 INV - Investigation - Annotated for Statistical Reporting Purposes IX 44-16

Heading/ Stat. Unit Rates of Duty Subheading Suf- Article Description of 1 2 fix Quantity General Special 4409 (con.) Wood (including strips and friezes for parquet flooring, not assembled) continuously shaped (tongued, grooved, rebated, chamfered, V-jointed, beaded, molded, rounded or the like) along any of its edges, ends or faces, whether or not planed, sanded or end-jointed: (con.) Nonconiferous: 4409.21 Of bamboo: 4409.21.05 00 Wood continuously shaped along any of its ends, whether or not also continuously shaped along any of its edges or faces, all the foregoing whether or not planed, sanded or end-jointed m 3 3.2% 11 Free (A, AU, BH, 33 1/3% CA, CL, CO, D, E, IL, JO, MA, MX, OM, P, PA, PE, SG) 0.6% (KR)

4409.21.90 00 Other m 3 Free $1.70/m3

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 37 of 123 Harmonized Tariff Schedule of the United States (2019) Revision 20 Barcode:3927394-02 C-570-118 INV - Investigation - Annotated for Statistical Reporting Purposes IX 44-17

Heading/ Stat. Unit Rates of Duty Subheading Suf- Article Description of 1 2 fix Quantity General Special 4409 (con.) Wood (including strips and friezes for parquet flooring, not assembled) continuously shaped (tongued, grooved, rebated, chamfered, V-jointed, beaded, molded, rounded or the like) along any of its edges, ends or faces, whether or not planed, sanded or end-jointed: (con.) Nonconiferous: (con.) 4409.22 Of tropical wood: 4409.22.05 Wood continuously shaped along any of its ends, whether or not also continuously shaped along any of its edges or faces, all the foregoing whether or

not planed, sanded or end-jointed 3.2% 1' Free (A", AU, BH, 33 1/3% CA, CL, CO, D, E, IL, JO, MA, MX, OM, P, PA, PE, SG) 0.6% (KR) Wood flooring (end-matched): 15 Jatoba (Hymenaea spp.), also known as m 2 Brazilian Cherry

M 3

25 1pe (Tabebuia spp.), also known as Tahibo, LaPacho, Brazilian walnut, and m 2 Patagonian walnut

M 3

35 Santos' mahogany (Myron/Ion balsamum), m 2 also known as Cabreuva

M 3

45 Cumaru (Dipteryx spp.), also known as m 2 Brazilian teak

M 3

m 2 55 Other

M 3 m 2 90 Other

M 3 Other: m 2 4409.22.10 00 Wood siding Free 1' 4.30/m 2

m 2 4409.22.25 00 Wood flooring Free 8%

m3

Wood moldings:

4409.22.40 00 Standard wood moldings m Free 11 59/.

4409.22.50 00 Other m Free 11 40% Wood dowel rods:

4409.22.60 00 Plain m Free 11 59/.

4409.22.65 00 Sanded, grooved or otherwise advanced

in condition m 4.9% 1' Free (A+, AU, BH, 33 1/3% CA, CL, CO, D, E, IL, JO, MA, MX, OM, P, PA, PE, SG) 0.9% (KR) 4409.22.90 00 Other m 3 Free $1.70/m3

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 38 of 123 Harmonized Tariff Schedule of the United States (2019) Revision 20 Barcode:3927394-02 C-570-118 INV - Investigation - Annotated for Statistical Reporting Purposes IX 44-18

Heading/ Stat. Unit Rates of Duty Subheading Suf- Article Description of 1 2 fix Quantity General Special 4409 (con.) Wood (including strips and friezes for parquet flooring, not assembled) continuously shaped (tongued, grooved, rebated, chamfered, V-jointed, beaded, molded, rounded or the like) along any of its edges, ends or faces, whether or not planed, sanded or end-jointed: (con.) Nonconiferous: (con.) 4409.29 Other: 4409.29.06 Wood continuously shaped along any of its ends, whether or not also continuously shaped along any of its edges or faces, all the foregoing whether or

not planed, sanded or end-jointed 3.2% 1' Free (A", AU, BH, 33 1/3% CA, CL, CO, D, E, IL, JO, MA, MX, OM, P, PA, PE, SG) 0.6% (KR) m 2 55 Wood flooring (end-matched)

M 3

m 2 65 Other

M 3 Other: m 2 4409.29.11 00 Wood siding Free 4.30/m 2

4409.29.26 Wood flooring Free 11 8% m 2 30 Maple (Acer spp.)

M 3

50 Birch (Betula spp.) and beech (Fagus m 2 spp.)

M 3

m 2 60 Other

M 3 Wood moldings: 4409.29.41 00 Standard wood moldings 31 m Free 11 5%

4409.29.51 00 Other m Free 40% Wood dowel rods: 4409.29.61 00 Plain m Free 5% 4409.29.66 00 Sanded, grooved or otherwise advanced

in condition m 4.9% 1' Free (A+, AU, BH, 33 1/3% CA, CL, CO, D, E, IL, JO, MA, MX, OM, P, PA, PE, SG) 0.9% (KR) 4409.29.91 00 Other m 3 Free $1.70/m3

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 39 of 123 Harmonized Tariff Schedule of the United States (2019) Revision 20 Barcode:3927394-02 C-570-118 INV - Investigation - Annotated for Statistical Reporting Purposes IX 44-38

Heading/ Stat. Unit Rates of Duty Subheading Suf- Article Description of 1 2 fix Quantity General Special 4418 (con.) Builders' joinery and carpentry of wood, including cellular wood panels and assembled flooring panels; shingles and shakes: (con.) Assembled flooring panels: (con.) 4418.75 Other, multilayer: 4418.75.40 00 Having a face ply more than 6 mm in thickness m 2 3.2% v Free (A", AU, BH, 33 1/3% CA, CL, CO, D, E, IL, JO, MA, MX, OM, P, PA, PE, SG) 0.6% (KR)

m 2 4418.75.70 00 Other 5o/o V Free (A", AU, BH, 40% CA, CL, CO, D, E, IL, JO, MA, MX, OM, P, PA, PE, SG) 1.6% (KR) m 2 4418.79.01 00 Other 3.2% v Free (A", AU, BH, 33 1/3% CA, CL, CO, D, E, IL, JO, MA, MX, OM, P, PA, PE, SG) 0.6% (KR)

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 40 of 123 Harmonized Tariff Schedule of the United States (2019) Revision 20 Barcode:3927394-02 C-570-118 INV - Investigation - Annotated for Statistical Reporting Purposes IX 44-39

Heading/ Stat. Unit Rates of Duty Subheading Suf- Article Description of 1 2 fix Quantity General Special 4418 (con.) Builders' joinery and carpentry of wood, including cellular wood panels and assembled flooring panels; shingles and shakes: (con.) Other: 4418.91 Of bamboo: 4418.91.10 00 Drilled or notched lumber studs m 3 Free -1/ $1.70/m 3

4418.91.90 Other 3.2% 11 Free (A", AU, BH, 33 1/3% CA, CL, CO, D, E, IL, JO, MA, MX, OM, P, PA, PE, SG) 0.6% (KR) m 2 05 Wood flooring

M 3

Other: 10 Arches, laminated kg 20 Roof trusses kg

40 Other fabricated structural wood members kg

50 Prefabricated partitions and panels for buildings kg

95 Other kg 4418.99 Other: 4418.99.10 00 Drilled or notched lumber studs m 3 Free- 1/ $1.70/m 3

4418.99.90 Other 3.2% 11 Free (A", AU, BH, 33 1/3% CA, CL, CO, D, E, IL, JO, MA, MX, OM, P, PA, PE, SG) 0.6% (KR) m 2 05 Wood flooring

M 3

Other: 10 Arches, laminated kg

20 Roof trusses kg

40 Other fabricated structural wood members kg

50 Prefabricated partitions and panels for buildings kg

95 Other kg

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 41 of 123 Harmonized Tariff Schedule of the United States (2019) Revision 20 Barcode:3927394-02 C-570-118 INV - Investigation - Annotated for Statistical Reporting Purposes IX 44-41

Heading/ Stat. Unit Rates of Duty Subheading Suf- Article Description of 1 2 fix Quantity General Special 4421 Other articles of wood: 4421.10.00 00 Clothes hangers Hundreds.. 3.2% Free (A+, AU, BH, 33 1/3% CA, CL, CO, D, E, IL, JO, KR, MA, MX, OM, P, PA, PE, SG) Other: 4421.91 Of bamboo: Wood dowel pins: 5 % 4421.91.10 00 Plain m Free 11

4421.91.20 00 Sanded, grooved or otherwise advanced in condition m 4.9% Free (A+, AU, BH, 33 1/3% CA, CL, CO, D, E, IL, JO, KR, MA, MX, OM, P, PA, PE, SG) Wood blinds, shutters, screens and shades, all the foregoing with or without their hardware: 4421.91.30 00 Consisting of wooden frames in the center of which are fixed louver boards or slats, with or

without their hardware No 10.7% 6' Free (A, AU, BH, 33 1/3% CA, CL, CO, D, E, IL, JO, KR, MA, MX, OM, P, PA, PE, SG)

4421.91.40 00 Other No 5.1 % 5' Free (A+, AU, BH, 50% CA, CL, CO, D, E, IL, JO, KR, MA, MX, OM, P, PA, PE, SG) Toothpicks, skewers, candy sticks, ice cream sticks, tongue depressors, drink mixers and similar small wares: 4421.91.50 00 Toothpicks X Free 25%

4421.91.60 00 Other kg 5.1 % 5' Free (A", AU, BH, 331/3% CA, CL, CO, D, E, IL, JO, KR, MA, MX, OM, P, PA, PE, SG) 4421.91.70 Pickets, palings, posts and rails, the foregoing

which are sawn; assembled fence sections Free 11 Free 20 Assembled fence sections X

40 Other X Clothespins: 4421.91.80 Spring-type 6.5/gross Free (A+, BH, CA, 200/gross CL, CO, D, E, IL, JO, KR, MA, MX, OM, P, PA, PE, SG) 24 Valued not over 800/gross Gross 27 Valued over 800 but not over $1.35/gross Gross 30 Valued over $1.35 but not over $1.70/gross Gross 33 Valued over $1.70/gross Gross

4421.91.85 00 Other Gross 4.8% 61 Free (A+, AU, BH, 35% CA, CL, CO, D, E, IL, JO, KR, MA, MX, OM, P, PA, PE, SG) 35% 4421.91.88 Filed00 By: [email protected],Canoe paddles Filed Date: 1/7/20No 10:23 PM,Free Submission Status: Approved Page 42 of 123 Harmonized Tariff Schedule of the United States (2019) Revision 20 Barcode:3927394-02 C-570-118 INV - Investigation - Annotated for Statistical Reporting Purposes IX 44-42

Heading/ Stat. Unit Rates of Duty Subheading Suf- Article Description of 1 2 fix Quantity General Special 4421 (con.) Other articles of wood: (con.) Other: (con.) 4421.91 Of bamboo: (con.) (con.) Other: 4421.91.93 00 Theatrical, ballet, and operatic scenery and properties, including sets kg Free'' 33 1/3%

4421.91.94 00 Edge-glued lumber m 3 Frees ' 10%

4421.91.97 Other 3.3 % Free (A, AU, B, BH, 33 1/3% CA, CL, CO, D, E, IL, JO, KR, MA, MX, OM, P, PA, PE, SG) 20 Pencil slats Gross 30 Burial caskets No. 70 Gates for confining children or pets No.

80 Other kg 4421.99 Other: Wood dowel pins: Plain: 5 % 4421.99.10 00 Coniferous m Free

5 % 4421.99.15 00 Other m Free 4421.99.20 00 Sanded, grooved or otherwise advanced in condition m 49% u1 Free (A+, AU, BH, 33 1/3% CA, CL, CO, D, E, IL, JO, KR, MA, MX, OM, P, PA, PE, SG) Wood blinds, shutters, screens and shades, all the foregoing with or without their hardware: 4421.99.30 00 Consisting of wooden frames in the center of which are fixed louver boards or slats, with or

without their hardware No 10.7% 5' Free (A, AU, BH, 33 1/3% CA, CL, CO, D, E, IL, JO, KR, MA, MX, OM, P, PA, PE, SG)

4421.99.40 00 Other No 5.1 % Free (A+, AU, BH, 50% CA, CL, CO, D, E, IL, JO, KR, MA, MX, OM, P, PA, PE, SG) Toothpicks, skewers, candy sticks, ice cream sticks, tongue depressors, drink mixers and similar small wares:

4421.99.50 00 Toothpicks X Free 61 25%

4421.99.60 00 Other kg 5.1 % 6' Free (A", AU, BH, 331/3% CA, CL, CO, D, E, IL, JO, KR, MA, MX, OM, P, PA, PE, SG) 4421.99.70 Pickets, palings, posts and rails, the foregoing

which are sawn; assembled fence sections Free ll Free 20 Assembled fence sections X 40 Other X

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 43 of 123 Harmonized Tariff Schedule of the United States (2019) Revision 20 Barcode:3927394-02 C-570-118 INV - Investigation - Annotated for Statistical Reporting Purposes IX 44-43

Heading/ Stat. Unit Rates of Duty Subheading Suf- Article Description of 1 2 fix Quantity General Special 4421 (con.) Other articles of wood: (con.) Other: (con.) 4421.99 Other: (con.) (con.) Clothespins: 4421.99.80 Spring-type 6.5/gross Free (A+, BH, CA, 200/gross CL, CO, D, E, IL, JO, KR, MA, MX, OM, P, PA, PE, SG) 24 Valued not over 800/gross Gross 27 Valued over 800 but not over $1.35/gross Gross 30 Valued over $1.35 but not over $1.70/gross Gross 33 Valued over $1.70/gross Gross

4421.99.85 00 Other Gross 4.8% 61 Free (A+, AU, BH, 35% CA, CL, CO, D, E, IL, JO, KR, MA, MX, OM, P, PA, PE, SG) 35 % 4421.99.88 00 Canoe paddles No Free

Other: 4421.99.93 00 Theatrical, ballet, and operatic scenery and properties, including sets kg Free 33 1/3%

4421.99.94 00 Edge-glued lumber m 3 Free 10%

4421.99.97 Other 3.3 0/ ii Free (A, AU, B, BH, 33 1/3% CA, CL, CO, D, E, IL, JO, KR, MA, MX, OM, P, PA, PE, SG) 20 Pencil slats Gross 30 Burial caskets No. 70 Gates for confining children or pets No.

80 Other kg

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 44 of 123 Harmonized Tariff Schedule of the United States (2019) Revision 20 Barcode:3927394-02 C-570-118 INV - Investigation - Annotated for Statistical Reporting Purposes IX Endnotes--page 44 -44 1/ See 9903.88.03. 2/ See 9903.88.18. 3/ See 9903.88.34. 4/ See 9903.88.18 and 9903.88.34. 5/ See 9903.88.15. 6/ See 9903.88.16.

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 45 of 123 Barcode:3927394-02 C-570-118 INV - Investigation -

EXHIBIT I-11

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 46 of 123 Barcode:3927394-02 C-570-118 INV - Investigation -

Company Name Address E-mail Phone Website

Estrada Municipal - CDR 455, S / N | km 1 Castilian 55 49 3561-3248 and 55- Adami S/A Madeiras Caçador (SC) | Postal Code 89514-899 B [email protected] 49-9184-1887 http://www.adami.com.br/ Rua Distrito Industrial - Quadra 06 - lote 03 - Setor D, Advantage Florestal Ananindeua - PA, 67035-330, Brazil [email protected] 55(91) 3017-5565 https://advantageflorestal.com.br/contact-us/ São Josafat, 1850 Street - Clover - Prudentópolis AFFONSO DITZEL & CIA LTDA Paraná - Brazil - ZIP Code 84400-000 [email protected] 55 42 3446-1440 https://www.affonsoditzel.com/index.php AG Intertrade [email protected] 55 41 3015-5002 http://www.agintertrade.com.br/en/home-2/ General Câmara Street, 243/601 55-51-2217-7344 and Araupel SA 90010-230 - Porto Alegre, RS - Brazil [email protected] 55-51-3254-8900 http://www.araupel.com.br/ Rua Félix da Cunha, 1009 – 8º andar CEP: 90570-001 [email protected] and 55 43 3535-8300 and 55- Braspine Madeiras Ltda. Porto Alegre – RS [email protected] 42-3271-3000 http://www.braspine.com.br/en/home/ R. Mal. Floriano Peixoto, 1811 - 12° andar, Sala 124 - Brazil South Lumber Centro, Guarapuava - PR, 85010-250, Brazil [email protected] 55 42 3622-9185 http://brazilsouthlumber.com.br/?lang=en Curupaitis Street, 701 - Curitiba - Paraná - Brazil - ZIP COMERCIAL EXPORTADORA WK LTDA Code 80.310-180 [email protected] http://wktrading.com.br/ 24 de Outubro Street, 835 Centro - Itararé / SP - Brazil FCC MADEIRAS ZIP Code: 18460-000 [email protected] 55 15 3531-3178 http://fccmadeiras.com.br/index.html#box-portfolio Industries Caxiense De Molduras Ltda 55 54 3221-3951 Dom Pedro II Street, 476 Ipumirim, State of Santa Industries De Madeiras Faqueadas Ipu Catarina, Brazil 89790-000 [email protected] 55 (49) 3438-1210 https://ipumirim.com.br/ Faq Pinus, SN Ipumirim, Santa Catarina, Brazil Postal Code: D-31 [email protected] Ipumirim Portas E Molduras ZIP Code: 89790-000 [email protected] 55-49-3438-1400 http://www.ipumirimmouldings.com/home/ Rua Amazonas, 572 - Agua Verde - 80.610-30 - Curitiba - [email protected] and 55 (41) 3314-5700 and Lavarma S.A. PR - Brasil [email protected] 55-41-9967-1857 https://www.lavrama.com.br/en/pine-moulding

Lavradora Racional de Madeiras Lavrama S/A Rua Amazonas 572 Curitiba, 80610-030 Brazil 55 41 3314-5757 https://www.lavrama.com.br/ Rua Vitorio Girardi 100 CEP 84 220 000 220 000 Senges, Linea PR Brazil [email protected] 55-43-3567-8300 http://www.linea.com.br/ cxp 07 - R. Projetada s/n - Bairro Industrial, Papanduva - Madeireira Beira Rio Ltda. SC, 89370-000, Brazil [email protected] 55 47 3653-2012 http://www.mbeirario.com.br/contact.html

Madesp SC-477, 1725, Benedito Novo - SC, 89124-000, Brazil [email protected] 55-47-3385-0185 http://madesp.ind.br/home/ Rua Caentano Colombo nº157 - Bairro Poco Um Salvaro CEP 88819-138 Criciuma/SC [email protected] 55-48-9974-4840 http://www.salvaro.com.br/ BR-280, 4116 - Industrial Sul, Rio Negrinho - SC, 89295- [email protected] Solida Brasil Madeiras Ltda 000, Brazil [email protected] 55 47 3646-3006 https://www.solidabrasil.com.br/ Rod SC 370, 1868 - Union Side 88750- Sul America Molduras 000 - North Arm - SC [email protected] 55 (48) 3651-1513 https://www.sulamericamolduras.com.br/en-us/ R. Viêira dos Santos, 379 - Centro Cívico, Curitiba - PR, Tebet Lumber Co 80540-310, Brazil [email protected] 55 41 3085.7776 https://www.tebet.com.br/index.html Uniforest Wood Products Inc. [email protected] (302) 450 4541 https://www.uniforestwoodproducts.com/ Av. Ismael Camargo Dos Santos, 539 Bairro sao Randa Indústria e Comércio de Portas Ltda. Cristovao, Bituruna, Brazil, 84640-000 [email protected] +55 (42) 3553-1378 http://randa.com.br/contato/ Av. Mal. Castelo Branco, 813 - S Cristóvão, Lages - SC, JJ Thomazi 88526-600, Brazil 55 49 3223-2186 http://www.jjthomazi.com.br/en/ Carlos Giombelli, s/n Sul Portas Ipumirim/SC, Close 89790-000 [email protected] 55 049 . 3438 1022 http://www.sulportas.com.br/contato/ Rod. BR 282, KM 05, Fazenda Chapada, Lages, Santa https://panjiva.com/Indusflora-Produtos-Florestais- Indusflora Produtos Florestais Ltda. Catarina, Brazil, 88506-600 www.indusflora.com.br Ltda/1501184 RUA AMAZONAS DE SOUZA AZEVEDO, 47 NEIGHBORHOOD BACACHERI CURITIBA | PARANA FV de Araujo ZIP CODE: 82.520-620 55 (41) 3218-9100 http://fvdearaujo.com.br/reflorestamento.php

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 47 of 123 Barcode:3927394-02 C-570-118 INV - Investigation -

Company Name Address Address Line 2 Address Line 3 Address LineE-mail 4 Phone Bel Trade Wood Industrial Co. Ltd. Xibin Xiadun Youxi County, Sanming FUJIAN 365100 P.R. China N/A N/A Binzhou City Meiyijia Industry & Trade Co., Ltd. No. 59, Zhangfu Road, Binzhou Industrial Park Binzhou SHANDONG 256651 P.R. China [email protected] 86-13305430066 Cao County Hengda Wood Products Co., Ltd. Zhuangzhai Town Cao County, Heze City SHANDONG 2774404 P.R. China [email protected] 13355408288 Changchun Daming Wood Industry Co., Ltd. South of Helong Grain Depot Suncaiyuanzi Village, Changchun Jilin P.R. China N/A 86-431-81737544 Changchun WINPROWOOD 4806,north round road Changchun Changchun 130052 P.R. China N/A 86-431-2925833 Changzhou First Laminate Molding Company Zhenbei Industrial Park Henling Town, Changzhou Jiangsu 213000 P.R. China N/A (86 519) 88507159

Changzhou Richwood Decorative Material Co., Ltd. No. 8, Mushiwei Road, Qingfeng Village Henglin Town, Changzhou Jiangsu 213103 P.R. China [email protected] 86-519-89189599

Changzhou Xiangrong Decorate Material Co., Ltd. No.20,Cuiheng Road, Henglin Town Changzhou City Jiangsu 213103 P.R. China N/A (86 519) 88721550 Chuzhou Deying International Trading Co., Ltd. No. 314, Building 6, 99 Yulan Road Yuhuatai District, Nanjing JIANGSU 239000 P.R. China [email protected] 86-5503616294 Dalian Pinzhi Hardwood Moulding Co., Ltd. Xi Xing Hai District, Dalian City Liaoning P.R. China [email protected] 86 411 84679971 Dalian Wada International Trading Co., Ltd. 1-202, No.131,Shengli Road Xigang District, Dalian City LIAONING 116000 P.R. China [email protected] 86-41183773730 Deqing Deke Wood Industry Co., Ltd. No. 70, Wulipai Road, Wukang Town Deqing, Huzhou Zhejiang 313200 P.R. China N/A 86-572-8035828 Dezhou Demax Building Decoration Material Co., Ltd. East Zone, 7th Floor, Donghai Plaza, No. 66, Changhe Ave. Dezhou SHANDONG 253000 P.R. China [email protected] 86-534-6026387 Dongguan Hengchang Wood Co., Ltd. Xintang Ind. Zone Houjiezhen Dongguan Guangdong 523949 P.R. China N/A 86 769 5915003 Dongguan Hongfa Woods Co., Ltd. Jiulian Industrial Xianxia, Gaobu, Dongguan GUANGDONG 523000 P.R. China [email protected] 86-15920241961 E&R Wood Co.,Ltd. Room 1106, Block a, Mingfeng Plaza, Kanglenan Road Houjie, Dongguan GUANGDONG 523962 P.R. China [email protected] 86-76981696545 Fujian Hongja Craft Products Co., Ltd. Mowu Industrial Zone Shunchang FUJIAN 353200 P.R. China N/A N/A Fujian Huaan Longda Wood Industries No. 21 Ping Hu Rd HuaAn City FUJIAN 383800 P.R. China [email protected] 13799076666 Fujian Nanping Longhua Wood Industry Co., Ltd. No. 8., Shamen Road HuaAn City FUJIAN 383800 P.R. China N/A N/A Fujian Nanping Yuanqiao Wood Industry Co., Ltd. F Block No. 2 Hongyangxincheng Building No. 118 Qili Industrial Zone, Wangtai Town, NanPing CityFUJIAN 353003 P.R. China [email protected] 13860057998 Fujian PandaProvince Home Youxi Furnishings County Chang Co., ShengLtd Wood Machine Co., NO.1043,Tangbian,Xingtai Development Zone Changtai, Zhangzhou Fujian 363900 P.R. China [email protected] 86-596-8366188 Ltd Industrial Park of Putou Village Chengguan Town, Youxi County FUJIAN 365100 P.R. China N/A N/A Fujian Sanming City Donglai Wood Co., Ltd. Telun Building, No. 639, Erhuang North Road Xinmin Town, Tongan, Xiamen, Samming FUJIAN 361000 P.R. China [email protected] 13950999166 Fujian Youxi Baiying Wood Industry Co., Ltd. Economic Development Zone Xibin Town, Youxi County FUJIAN 365104 P.R. China N/A 0598-8769965 Fujian ZhangpingYouxi County Kimura Hongshulin Merry GardenWood Industry Wooden Co., Structure Ltd. (D.B.A. FujianYouxi ProvinceChengxi EconomicYouxi City DevelopmentMangrovewood Zone Machining Co., Ltd) Youxi City FUJIAN 365100 P.R. China [email protected] 0598-6399536 Design and Installation Co. Ltd. Fushan Industrial Zone ZhangPing FUJIAN 364400 P.R. China [email protected] 13799076666 Fuyang Jinmu Arts And Crafts Co., Ltd. m. A1012,SOHO ZhongShan Plaza, NO.1055 West Zhongshan Rd.Changning District SHANGHAI 200051 P.R. China [email protected] 86-05582395006 Gosspo Industrial Co., Ltd. No. 551 Guangcong Jiu Rd. Zhongluotan Town, Baiyun District, GuangzhouGUANGDONG 510550 P.R. China N/A 86-2031231592 Guangdong CREATEKING New Materials Technology Co., Ltd. No. 3 Mingsha South Road, Xiajiao Industry Zone Danzao Town, Nanhai District, Foshan Guangdong 528241 P.R. China N/A 86-757-85573683

Guangzhou Haider Building Material Co., Ltd. No. B16, Street 11, Shiguang Rd. Panyu, Guangzhou GUANGDONG 511495 P.R. China N/A 86-13316022886 Haining Longtai Decoration Materials Co., Ltd. Mingfeng Industrial Park Shuangfeng Village, Yuanhua Town, Haining CityZHEJIANG 314416 P.R. China N/A 86-15958912696 Room A-103A, 10th Floor, Office Building No. 1, No. 118, Hangzhou Aisen Furniture Co., Ltd. Linping Subdistrict, Yuhang District, Hangzhou Zhejian 311100 P.R. China [email protected] 86-18658823511 Donggang Road, Hangzhou Fuyang Acmey Industrial Co., Ltd. Block 11,Yinhu Innovaon Centre, Fuyang, Hangzhou Zhejiang 311400 P.R. China N/A 86-571-85063308 Hangzhou Huahai Wood Co.,Ltd. Timber Road 555 Wood Industry Zone, Jiashan County Zhejiang P.R. China N/A 86-571-8900-2555 Harbin Hengrun Economic-Trade Co.,Ltd. #106, Zhujiang Road Xiangfang District Heilongjiang 150036 P.R. China N/A 8613654528818 Harbin Xinghua Woodworking Co., Ltd. No.287 Xue Fu Road Harbin Pingfang Dis Haerbin 150066 P.R. China N/A 86045186519807 Hebei Shensui Materials Trading co., Ltd. Rm 1516, Block E, Jinhe Business Building, No. 42 Huaan West RoadZhengding County, Shijiahuang City HEBEI 050800 P.R. China N/A 86-31189199959 Heilongjiang Haojia Wood Co.,ltd 9F Pufa Building No 209 Changjiang Road,Nangang District Harbin Heilongjiang 150090 P.R. China N/A 86-0451-8771-5173

Hengxiang Wood Co., Ltd. Zhuangzhai Town Cao County, Heze City SHANDONG 277400 P.R. China N/A 86-13365305711 Heze Huasheng Wooden Co., Ltd. No. 8 Industry Zone Zhuangzhai Town SHANDONG 274400 P.R. China N/A 86-530-6219566 Homemind Building Material Co., Ltd. No. 888 Tunheng Road Huzhou ZHEJIANG 313009 P.R. China N/A N/A Hongkong Drenthe Limited No. 89, Yushan Rd Suzhou Jiangsu 215000 P.R. China N/A 86-18015425619 Honsoar New Building Material Co., Ltd. 678 Fuji Street 678 Fuji Street Shandong 262705 P.R. China N/A 86-0536-5675882 Jiangsu Chensheng Forestry Development Co., Ltd. East Bldg. No. 2 Beicejingwu Rd Central Av Port Area Dafeng Dis Yancheng City JIANGSU 213103 P.R. China [email protected] 18762383238 Jiangsu Good Wood Industry Co., Ltd. No. 6 Huangpu Dadaotdong Rd Tianhe District, Guangzhou GUANGDONG 550660 P.R. China N/A 86-15918852285 Juyemin Anxiangtai Machinery Manufacturing Co., Ltd. Donghuan Road and Beihuan Road Juye, Heze City FUJIAN 274900 P.R. China [email protected] 5308351700 Liaocheng Queen Eve Import and Export Co., Ltd. 1011 Shunhe Road Zhenxing District, Liaocheng SHANDONG 252100 P.R. China N/A 86-19963593678 Linyi Baiyi Wood Co., Ltd. Yigao Building, Shanghai Street Linyi City SHANDONG 276000 P.R. China [email protected] 13013541966 Linyi Mingsen Wood Co., Ltd. Zaogoutou Industrial park Linyi City SHANDONG 276000 P.R. China [email protected] 86-15265958777 Linyi Yousen Building Material Co., Ltd. East of Fushan Road Dongdiezhuang Village, Machanghu Town, LinyiSHANDONG City 276000 P.R. China [email protected] 13953986708 Longhaida Tongxing Longhai City, Zhangzhou FUJIAN 363105 P.R. China [email protected] 13605018586 Longjian Jiaomei Industrial Comprehensive Development Zone Longhai City FUJIAN 363107 P.R. China N/A 13906959698 Luli Group Co. Ltd. Luli Industrial Park, Houzhen Shouguang Shandong 262724 P.R. China N/A 400-8760-678

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 48 of 123 Barcode:3927394-02 C-570-118 INV - Investigation -

Manzhouli Hongli Wood Co. Ltd Import and Export Processing Zone Hulunbeier Nei Mongol, 21400 P.R. China N/A (86 470) 3989187 Meilin Wood Products Co., Ltd. 116036 Dong Xiao Mo Ying Cheng Zi Town, Ganjinzi District, Dailan LIAONING 118096 P.R. China N/A N/A Ningbo Flying Dragon Art & Craft Product Co., Ltd. Jianshan Industrial Zone, Ditang Street Yuyao Town, Ningbo City ZHEJIANG 315492 P.R. China [email protected] 13805801762 Oppein Home Group Inc. 366 Guanghua 3rd Road Jianggao Town Baiyun District Guangzhou, 510450 P.R. China N/A 86-20-3673-0513 Primewerks Xiamen Industry And Trade Co., Ltd. Room 410 No.1647 Xinglinwan Road Jimei, Xiamen FUJIAN 361002 P.R. China N/A N/A Putian YiHong Wood Industries Co., Ltd. Xiuyu State-Level Wood Trade Demonstration Area Zhangzhou City FUJIAN 363105 P.R. China [email protected] 5945158055 Qimen County Jianxing Bamboo and Wood Products Co., Ltd. Huayang Industrial Park Qimen County Huangshan City ANHUI 245600 P.R. China [email protected] 13956266268 Qingdao Sanhe Dacheng International Trade Co., Ltd. 1501, Fuying Mansion, No. 443, Changjiang East Road Qingdao SHANDONG 266000 P.R. China N/A N/A Samming Shitong Wood Industry Co., Ltd. No. 3 Workshop, C Area, Jingu Metal Processing Zone Sanming City FUJIAN 313300 P.R. China [email protected] 13023923003 Shandong Yigao Building & Decoration Material Co., Ltd. 1619 Iec International Building Linyi SHANDONG 276000 P.R. China N/A 86-15653958899 Shanghai Jiraw Building Materials Co., Ltd. No. 287, Lane 99, Waiqian Road, Waigang Town Jiading District Shanghai P.R. China [email protected] 86-13917165474 Shaxian Hengtong Wood Industry Co., Ltd. Wood and Bamboo Concentrated Processing Zone Qiujianghoudi, Shaxian, Sanming City FUJIAN 365500 P.R. China [email protected] 13507585412 Shaxian Shiyi Wood Bamboo Co., Ltd. Houti Industrial Park Sha County, Sanming City FUJIAN P.R. China [email protected] 0598-5552586 ShengHui Woodware Co., Ltd 161 Beier Road Linyi City SHANDONG P.R. China wechat 15269911111 Shenyang Jinuoer Decoration Material Co., Ltd. No.1-2 Daqing Industrial Zone,Tiexi District, Shenyang City Liaoning Province Shenyang 110142 P.R. China N/A 86-24-89353802 Shenyang Piaoshi Ruilin Decoration Engineering Co., Ltd. No. 66D-2, Qingzhou Street Sujiatun District, Shenyang LIAONING 110108 P.R. China N/A 86-024-31810787 Shouguang Yusen Wood Products Co., Ltd. No. 168, Jinguang Street Shouguang SHANDONG 262700 P.R. China N/A N/A Sino Performer Industrials Co., Ltd. No. 408 Wuyi North Road, Lanling Street Tianning District, Changzhou JINGSU 213000 P.R. China N/A 86-13812195373 South China Timber Industry Ltd. Av.Gongye Dadao,Dist.Xinhui, Jiangmen Guangdong 529100 P.R. China N/A 86-750-6312973 Suzhou Esse Wood Industry Co., Ltd. Room 1801, Guomao Building, No 168 Ease Shanghai Road Taicang City, Suzhou JINGSU 215400 P.R. China [email protected] 86-51253990896 Wuhan Hongda Anxin Decorative Material Co., Ltd. No.68, Yinbai Road East-West Lake District, Wuhan City Hubei 430040 P.R. China admin@nicefloor 86-86-27-83232799 Xiamen Dixin Import & Export Co., Ltd. C-403 Tiandi Garden, 207 Taiwan Street Huli District, Xiamen FUJIAN 361000 P.R. China N/A 86-5925538635 Xiamen Goodwood Industry Co., Ltd. Room 9e No.4 Hexiang West Road Siming, Xiamen FUJIAN 361003 P.R. China [email protected] 86-5922685185 Xiamen Jinxi Builidng Material Co. Ltd. Room 503, 15# of Wanghai Rd Xiamen FUJIAN 361012 P.R. China N/A 86-5150007 Xiamen Reshine Wood Industry Co., Ltd. Rm 504, Building C2, Wanda Plaza, No. 5 Jinzhong Rd. Huli District, Xiamen FUJIAN 361007 P.R. China [email protected] 13950055982 Xuzhou Hexi Wood Co., Ltd. Huangqiao Tongshan District Xuzhou City Jiangsu 221000 P.R. China [email protected] 0516-83148888 Xuzhou Hongtu Wood Industry Co., Ltd. No. 4 Huangpu Dadaotdong Rd Tianhe District, Guangzhou GUANGDONG 510660 P.R. China N/A 86-15918852285 Xuzhou ROC International Trading Co., Ltd TONGCHENG CENTURY SQUARE Pizhou City Jiangsu 221300 P.R. China N/A 86-516-86533386 Xuzhou Sanxing Wood Industry Co., Ltd. No. 8 East Huangpu Rd Tianhe District, Guangzhou GUANGDONG 510660 P.R. China N/A 86-20-82160769 Yanbian Dalifang Wood Products NO.16 CHANGSONG RD DANJIANG ST DUNHUA CITY JILIN P.R. China N/A N/A Yiwu Binhao Decorative Material Co., Ltd No. 3 Xinpan Road Yiwu City, Jinhua ZHEJIANG 322006 P.R. China N/A 86-57985129227 Yongan Yongmind Wood Industry Co., Ltd. Dataokou Industrial Park Xiaotao Town, YongAn City FUJIAN P.R. China [email protected] 0598-3705090 Yuchi Guantong Wood Industry Co., Ltd. Mucai Jiagong Yuanqu (木材加工园区) Lanshan District, Rizhao City SHANDONG 276800 P.R. China [email protected] 18663377000 Zhangping Huaxia Wood Industry Co., Ltd. Fushan Industry Garden Zhangping FUJIAN 364400 P.R. China N/A 86-5962950370 ZhangzhouZhangping Sanchan Green Wood Industrial Co., Ltd & Trade (D.B.A. Co., Zhangzhou Ltd. Lvmu Guilin Street, Gaoming New Village Neighborhood ZhangPing FUJIAN 364400 P.R. China [email protected] 0591 885911809 Industry and Trade Co. Ltd.) 205 #10 Yongxing Zhangzhou City FUJIAN 363105 P.R. China [email protected] 18250593931 Zhangzhou Qunyi Wood Industry Co., Ltd. No. 58, Damiao Dongkeng Village Xiangwei Town, Longhai City, Zhangzhou FUJIAN 363105 P.R. China wechat 13606951714 Zhangzhou Wang Jia Mei Industrial & Trade Co. Ltd. 319 Federal Highway Moxi Villiage, Zhangzhou City FUJIAN 363105 P.R. China wechat 18760683946 Zhejiang Huakai Wood Manufactury Co. Ltd. No. 1 Qianyuan Rd. Huzhou ZHEJIANG 313216 P.R. China wechat 13905300028

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 49 of 123 Barcode:3927394-02 C-570-118 INV - Investigation -

EXHIBIT I-12

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 50 of 123 Barcode:3927394-02 C-570-118 INV - Investigation -

Company Name Address E-mail Phone Website CHEP USA 7501 Greenbriar Parkway, Orlando, FL, 32819 N/A (800) 243-7872 https://www.chep.com/us/en/consumer-goods ORDER N/A N/A N/A N/A COMPOSITE TECHNOLOGY INTERNATIONAL 1730 I Street, Suite 100, Sacramento, CA 95811 [email protected] 916-551-1850 https://cti-web.com/ PO Box 2119, 222 West State Street, Eagle, ID EAGLE FOREST PRODUCTS 83616 [email protected] (800) 309-1845 http://eaglefp.net/ 9325 Snowden River Pkwy # A, Columbia, MD METRIE 21046 [email protected] (410) 423-2440 https://metrie.com/ 162 S Rancho Santa Fe Rd suite b-50, Encinitas, CA MATOS FOREST PRODUCTS 92024 [email protected] (888) 878-8631 https://www.matosforestproducts.com/ COTTONDALE WOOD PRODUCTS 1616 44th Ave, Tuscaloosa, AL 35401 N/A (205) 758-2761 http://www.hintonlumber.com/ DE: (888) 964 8746 PA: (877) 963 6772 107 Park Ave., Seaford, DE 19973; VA: (877) 963 6782 31 Vanguard Dr., Reading, PA 19606; Hagerstown, MD: (866) 3703 Carolina Ave., Richmond, VA 23222; 966 5347 16618 Hunters Green Pkwy., Hagerstown, MD 21740; NJ: (866) 727 0023 45 Mill St., Mays Landing, NJ 08330; Baltimore, MD: (866) WHOLESALE MILLWORK 6300 Erdman Ave., Baltimore, MD 21205 N/A 964 6534 https://wholesalemillwork.net/ ECMD, Inc 2 Grandview Street East Coast Mouldings North Wilkesboro, NC 28659-0130 [email protected] 1 (336) 667-5976 http://ecmd.com/Home/ContactUs 1600 Sparrows Point Blvd, Suite D Atlantic Forest Products Sparrows Point, MD 21219 n/a (800) 551-2374 https://atlanticforest.com/contact/ Woodgrain Millworks 300 NW 16th St, Fruitland, ID 83619 [email protected] 208-452-3801 https://www.woodgrain.com/contact/ 5897 Windward Pkwy CHEP Alpharetta, GA, US n/a (800) 243-7872 https://www.chep.com/us/en/consumer-goods/locations 13100 Northwest Freeway, #450 48forty Solutions LLC Houston, TX 77040 n/a 877-779-8577 https://www.48forty.com/locations? 8020 Arco Corporate Drive Suite 400 https://www.buildwithbmc.com/bmc/store/9901?lat=35.8 BMC Raleigh, NC 27617 [email protected] 919-431-1000 861371&long=-78.6455475&q=27615

BlueLinx 1950 Spectrum Circle Suite 300 Marietta, GA 30067 [email protected] 770-953-7000 http://bluelinxco.com/contact-us/

Agility Logistics 11010 NW 30th St #100, Doral, FL 33172 [email protected] 1.305.716.2900 https://www.agility.com/en/world-wide-directory/ 5285 Meadows Rd. Suite #130 Wood Brokerage International Lake Oswego, OR 97035 n/a (503) 906-2501 http://woodbrokerage.com/contact-us/ 700 103rd Ave N., Millwork Sales Royal Palm Beach, FL 33411 [email protected] 561.472.6497 https://www.millworksales.com/ https://www.uslumber.com/MainSite/Store1/Content/Site U.S. LUMBER 2160 SATELLITE BLVD, STE 450, Duluth, GA 30097 [email protected] (678) 474-4577 Content/1/Home/home.aspx

[email protected], 1-908-304-2346, 1-540- 108 MIFFLIN BLVD. READING PA 19607 MIFFLIN PA [email protected], 692-5370, 1-610-207- The Wood Hub 17058 UNITED STATES [email protected] 5604 http://www.thewoodhub.net/ OrePac Building Products 30170 SW Ore Pac Avenue Wilsonville, OR 97070 [email protected] 503-685-5499 orepac.com D W DISTRIBUTION INC 1200 E. Centre Park Blvd. DeSoto, Texas 75115 214-381-2200 https://www.dwdistribution.com/ PO Box 143 840 Willis Ave TUSON TRADING Albertson, NY 11507 [email protected] 516-746-3661 http://tusontrading.com/home/ 13901 W. 101 Street OLATHE MILLWORK Lenexa, Kansas 66215 913-738-8074 https://www.olathemillwork.com/ Group and Business Credit 440 S. Church Street JELD-WEN Windows & Doors Charlotte, NC 28202, US 1 (800) 535-3936 https://www.jeld-wen.com/en-us https://www.pnc.com/en/corporate-and- 340 MADISON AVE., 11TH FLOOR NEW YORK, NY 10173, institutional/financing/lending-options/business- PNC Business Credit USA 1-888-762-2265 credit/business-credit-us.html 840 Division St. Cobourg, ON Form Solutions K9A 5V2 , Canada 1-888-706-7709 http://formsolutions.ca/ GLOBAL PRODUCT SOLUTIONS 600 Union Street, Ashland, OH 44805 N/A (419) 496-0123 N/A

48FORTY SOLUTIONS 3100 Northwest Freeway, #450, Houston, TX 77040 N/A 877-779-8577 https://www.48forty.com/ DQL GOLD BRIDGE 841 HIGH ST, OAKLAND CA 94601 N/A N/A N/A

BLUE LINX HOUSTON CROSS DOCK 1950 Spectrum Circle Suite 300 Marietta, GA 30067 [email protected] (770)953-7000 https://www.bluelinxco.com 13410 Sutton Park Drive South Jackonsville, FL 32224 LANDSTAR GLOBAL LOGISTICS United States N/A (904)398-9400 https://www.landstar.com

METRIE BALTIMORE DISTRIBUTION 9325A Snowden River Parkway, Columbia, MD 21046 N/A (410)423-2440 https://metrie.com/ AMERICAN RIVIERA 403 E Montecito St, Santa Barbara, CA 93101 N/A (805)883-1155 N/A METRIE DALLAS 3801 S. 20th Avenue, Suite 100, Euless, TX 76039 N/A (972)241-7125 https://metrie.com/ https://www.uslumber.com/MainSite/Store1/Content/Site U S LUMBER GROUP 2160 Satellite Blvd., Suite 450, Duluth, GA 30097 N/A (678) 474-4577 Content/1/Home/home.aspx MIDSTATE LUMBER 200 Industrial Parkway, Branchburg, NJ 08876 N/A (800)-942-7776 https://midstatelumber.com/ PACIFIC WHOLESALE SHUTTERS AND BLINDS 4833 Schaefer Ave. Chino, CA 91710 [email protected] (909) 517-1505 http://www.shutterblindusa.com/shop/index.php PLANO MOLDING 431 East South Street Plano, IL 60545 N/A 1(800)226-9868 https://www.planomolding.com/ SUNCO FLOORS 524 Industrial Dr, Naperville, IL 60563 [email protected] (888)559-9918 http://www.suncofloors.com/ DW DISTRIBUTION 1200 E. Centre Park Blvd, DeSoto, Texas 75115 N/A (214)381-2200 https://www.dwdistribution.com/ MP LUMBER 15685 SW 116th Ave, Portland, OR 97224 [email protected] (503) 747-6887 http://mplumberinc.com/ FERRETERIA MADERAS 3C Cll Bechara, San Juan, 00920, Puerto Rico N/A N/A http://www.maderas3cpr.com/

BLUE LINX 1950 Spectrum Circle Suite 300 Marietta, GA 30067 [email protected] 770-953-7000 https://bluelinxco.com/contact-us/ MEL RAY INDUSTRIES 2167 S Hwy 17, Crescent City, FL 32112 N/A (386) 698-4414 https://www.melray.com/about-us/ MERCADO 4645 N.32ND ST, PHOENIX, AZ 85018 N/A 480-423-8111 N/A https://metrie.com/offices/mouldings-distribution-atlanta- ga?zoom=10¢er=34.0859,-84.6662&marker=38.9208,- METRIE ATLANTA DISTRIBUTION 40 Hopson Dr SE, Acworth, GA 30102 N/A (770) 975-0223 77.0360 SMITH MILLWORK 920 Robbins St, Lexington, NC 27292 N/A (336) 249-8171 http://smithmillwork.com/

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 51 of 123 Barcode:3927394-02 C-570-118 INV - Investigation -

Company Name Address E-mail Phone Website WESTON WOOD SOLUTIONS 300 Orenda Rd, Brampton, ON L6T 1G2, Canada [email protected] (905) 677-9120 http://westonwoodsolutions.com/ OR WOOD PRODUCTS INTERNATIONAL WORLDWIDE DOOR COMPONENTS 5017 N. Coolidge Ave. Tampa, FL 33614 [email protected] 813-870-0003 http://www.wwph.com.cn/ HAMPTON LUMBER SALES 9600 SW Barnes Road - Suite 200 - Portland, OR 97225 N/A 503.203.6517 and 503.203.6547 https://www.hamptonlumber.com/ One Tampa City Center, 201 N. Franklin St., Suite 300 MASONITE INTERNATIONAL Tampa, FL 33602 [email protected] 813-877-2726 https://www.masonite.com/ 17374 DARWIN AVE. HESPERIA CA 92345, Hesperia, CA GLOBAL WOOD SOLUTIONS INVESTMENT 92345 N/A N/A N/A 4002 Ross Ln Affordable Home Products LLC 1-877-733-5883 Chanute KS 66720 [email protected] http://tufbuilt.com/index.php?route=information/contact 1300 North Glenview Place GlobalPointe Milwaukee, Wisconsin 53213 1.877.257.1978 n/a https://global-pointe.com/contact/ 1050 Northbrook Parkway Evermark 1-678-455-5188 Suwanee, GA 30024 [email protected] https://www.evermark-lnl.com/contact/ 1600 Sparrows Point Blvd, Suite D Atlantic Forest Products (800) 551-2374 Sparrows Point, MD 21219 n/a https://atlanticforest.com/contact/ 340 MADISON AVE PNC Bank 1ST FLOOR NEW YORK, NY 10173 n/a (212) 661-1064 https://apps.pnc.com/locator/#/result-details/00235060/340-madison-avenue 55 Jericho Turnpike., Ste. 302 CFFCO USA Inc. Jericho, NY 11753 [email protected] 718-747-1118 http://cffco.com/contactus.html https://www.google.com/search?q=HOME+DEPOT+2455+PACES+FERRY+RD+S E+ATLANTA%2C+GA+30339%2C+UNITED+STATES&rlz=1C1GCEB_enUS876US8 76&oq=HOME+DEPOT%092455+PACES+FERRY+RD+SE%09ATLANTA%2C+GA+ +30339%2C+UNITED+STATES&aqs=chrome..69i57.734j0j4&sourceid=chrome Home Depot Support Center 2455 Paces Ferry Rd SE, Atlanta, GA 30339 n/a (770) 433-8211 &ie=UTF-8 1222 Emmanuel Church Rd #106 Southwood Door Conover, NC 28613 [email protected] (704)-625-2790 https://www.southwooddoors.com/ 707 Skokie Blvd Ste 600 Wexford Home Northbrook, IL 60062 [email protected] (866) 734-3186 http://wexford-home.com/index.html L J Smith 35280 Scio-Bowerston Road, Bowerston, Ohio 44695 [email protected] (740) 269-2221 https://www.ljsmith.com/ 9040 Walnut Cove Lane Prime Hardwood Components Gainesville, GA 30506 [email protected] . (678) 371-9191 225 West Main Street Ideal Stair Parts Little Falls, NY 13365 [email protected] 1-888-823-1124 https://www.idealstairparts.com/ Chung Ik Sang 1111 West Jefferson St. Suite 300 Boise Building Solutions Distribution Boise, Idaho 83702-5389 https://www.bc.com/ 12206 Bell Ranch Drive, Santa Fe Springs, CA 90670, United Larson-Juhl CA States [email protected] https://www.larsonjuhl.com/en-US/ The Shekia Group LLC 1130 King Georges Post Rd, Edison, NJ 08837 (732) 372-7668 https://forevermarkcabinetry.com/ 1359 BROADWAY, 18TH FLOOR NEW YORK NY 10018 Millwork Holdings United States [email protected] (646)-839-7000 11320 S Post Oak Rd Ste 212, Houston, TX 77035 and 7052 Houston Shutters Grand Blvd, Ste 120, Houston, TX 77054 (713) 723-9719, 713-723-7100 http://rockwoodshutters.com/ Brockway-Smith Company 35 Upton Dr Wilmington, MA 01887 [email protected] 978-475-7100 https://www.brosco.com/ Aristree 1060 INDUSTRIAL PARK DRIVE KERNERSVILLE NC. 27284 336-993-5640 SBIC AMERICA 201 S College St, Charlotte, NC 28244 https://www.sbicamerica.com/ Timbergon Trading PO Box 1528, Redmond OR, 97756 [email protected] 1-866-548-9330 https://www.timbergon.com/ 70 West Streetsboro Street, MC Imports Suite 101, Hudson, Ohio 44236 330-748-8460 https://www.mcimportsllc.com/ DEZIGN NORTH AMERICA 3376 Carpet Capital Drive, Dalton, GA 30720 [email protected] 706.370.7673 http://www.dezignnorthamerica.com/ COMPOSITE TECHNOLOGY INTERNATIONAL 1730 I Street, Suite 100 Sacramento, CA 95811 [email protected] 916-551-1850 https://cti-web.com/ 7707 SW 44th St. HOBBY LOBBY STORES Oklahoma City, OK 73179 1-855-329-7060 https://www.hobbylobby.com/

ACME FURNITURE INDUSTRY 18895 Arenth Avenue City of Industry, CA 91748 United States N/A 1-626-964-3456 https://www.acmecorp.com/warehouse-locations DESIGNERS CHOICE 126 Fayette St #400, Conshohocken, PA 19428 N/A (610) 828-1875 https://www.designerschoicelp.com/contact-us/ http://info.emser.com/contactus?utm_referrer=http%3A%2F%2Fwww.emser. EMSER TILE 8431 CA-2 Los Angeles, CA 90069-4209 [email protected] 323-650-2000 com%2Findex.php%3Fid0%3Dhome EXPEDITORS INTERNATIONAL 1015 3rd Ave, Seattle, WA 98104 [email protected] (206) 674-3400 https://www.expeditors.com/locations JOHN ROCK 125 Commerce Drive, Raphine, VA 24472 [email protected] (540) 460-8616 https://www.johnrock.com/john-rock-companies/#johnrock KELLEHER 1543 Fifth Avenue – San Rafael, CA 94901 [email protected] https://kelleher.com/contact/ One Tampa City Center 201 North Franklin Street Suite 300 MASONITE Tampa, Florida 33602 [email protected] 813-877-2726 https://www.masonite.com/ MASONITE MESQUITE DFS 970 Us Route 11, Kirkwood, NY 13795 [email protected] (607) 775-2450 https://www.masonite.com/ METROPOLITAN HARDWOOD FLOORS US 8106 S 216th St, Kent WA 98032 USA [email protected] 253 479 3958 http://www.metrofloors.com/contact-us 6361 Sterling Drive North MMI DOOR Sterling Heights, MI 48312 [email protected] 800-686-9218 https://www.mmidoor.com/about-us/locations O K CONTAINER SALES 2707 E. Valley Blvd #305, West Covina ,CA 91792 [email protected] (626) 912-5788 http://okcontainersales.com/contact-us.html OMG IMPORT TRANSIT 140 Huron Street, Brooklyn, New York 11222

SNAVELY INTERNATIONAL 1251 New Windsor Road, Westminster, MD 21158 [email protected] 410-386-0654 http://www.snavelyforestproducts.com/sales-locations/snavely-international UNITED CARGO MANAGEMENT 19401 S. Main Street #202, Gardena, CA 90248 [email protected] 310-225-3099 http://www.ucmcargo.com/contact.html

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EXHIBIT I-13

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 53 of 123 Barcode:3927394-02 C-570-118 INV - Investigation - https://www.bendbulletin.com/business/woodgrain-millwork-leaving-prineville/article_12e60e21-a85f-5a3c- 910e-1d3f035da877.html

Woodgrain Millwork Woodgrain Millwork leaving Prineville Company to close remaining operations, eliminating 55 jobs

By Joseph Ditzler The Bulletin Oct 28, 201 5

Bowman Museum / Submitted photo An aerial view of the COIN Millwork mill in Prineville 1960. The mill eventually became Woodgrain Millwork, which announced Friday that it plans to end operations in Prineville.

Woodgrain Millwork is closing the last of its operations in Prineville, a move that means layoffs or relocation for the remaining 55 employees, a company executive announced today.

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 54 of 123 "Unfortunately, due toBarcode:3927394-02 the recent loss C-570-118 of significant INV - Investigation sales volume,- the operation is no longer financially viable and will be closed in the next few months," wrote Greg Easton, vice president of Woodgrain's millwork division, in an announcement dated Thursday.

Easton wrote that the Idaho-based company provided the employees a 6o-day notice and will offer employment in its other locations, along with relocation assistance.

Easton was not immediately available for further comment. Prineville City Manager Steven Forrester also was unavailable for comment.

Mayor Betty Roppe said, "We've had them quite a while and would have loved to have seen them stay, but they've made the business decision that it's not going to be."

Roppe said Easton told her the plant would be closed by the end of January.

Woodgrain Millwork laid off more than 200 workers from its door and window- frame plant starting in November after a heavy snowfall caused a portion of the factory roof to collapse. The company kept a smaller work force in a pellet mill and interior wood-trim factory, according to The Bulletin archives.

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 55 of 123 Barcode:3927394-02 C-570-118 INV - Investigation -

EXHIBIT I-14

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 56 of 123 Barcode:3927394-02 C-570-118 INV - Investigation - https://www.bendbulletin.com/businessibidder-owner-at-odds-over-prineville-factory/article_966ea777- 249b-5cdf-b71d-4857147de604.html Bidder, owner at odds over Prineville factory Future of Consolidated Pine in the balance

By Joseph Ditzler The Bulletin Jul 11,2017

Everything associated with Consolidated Pine, a wood molding manufacturing plant in Prineville, is for sale. (The Tiger Group photo)

The closing of Consolidated Pine in Prineville earlier this year ended a third- generation family operation that started 64 years ago.

Mark Shirvan, president and CEO of Consolidated Companies, the New Jersey- based parent of Consolidated Pine, said surrendering his family's involvement in Central Oregon is tough to do. Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 57 of 123 "We owned the companyBarcode:3927394-02 for a long C-570-118time, and INV -we're Investigation passionate - about the people that worked for us," Shirvan said June 30. "It was very difficult for us. The focus of our sales was on our own distribution arm. We sold to others, but not to the level that we wanted."

Consolidated Companies attempted to keep the doors of its Prineville operation open by taking on investors from the Tzar Investment Group, of Providence, Rhode Island, and New York City, in May 2016. That deal fell apart, and now the plant, which closed in January, is for sale. The real estate broker, Tiger Group, listed no asking price, but instead is seeking offers.

A prospective buyer could resume operations or dispose of the equipment and 23 acres piecemeal. In addition to forklifts, routers, lathes, band saws and molders, the property comes with rail spurs, phone lines and the company name. Shirvan said he could not guarantee a buyer would keep the operation intact, although he said he hoped a local consortium would step up and take it over. Interest in that option appears to be slim. About 30 jobs went away when the plant, which made decorative, finger-joint molding for home interiors, closed.

Hirak Biswas, CEO and principal at Tzar, at the time said he planned to pump fresh capital into the molding manufacturer on Lamonta Road and expand its reach eventually to overseas markets. Thursday, he said he's still interested in buying not just Consolidated Pine, but its parent company, too.

"We had a strategy on how to turn the company around," he said. "If I acquired the company today, we can turn it around."

The two men said they have not recently spoken to one another. Shirvan said he was misled by Biswas, who, in response, said Consolidated Pine was overvalued by its owners and poorly managed. Biswas said his business partner Ravi Gadiraju is still in touch with Shirvan and a deal may yet be struck.

"My interest is only in the whole company," Biswas said. "I don't have any bad blood."

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 58 of 123 Any attempt to resurrectBarcode:3927394-02 the molding C-570-118 plant INVmust - Investigation reckon with - a regulatory environment meant to protect the nearby national forests from which raw materials come and with competition from overseas wood-product makers. Crook County Commissioner Jerry Brummer, who has 25 years experience running a sawmill, said the time may soon come in which a smaller-scale version of the forest-products economy is revived. Public pressure to establish forest management practices that sustain local jobs is bearing fruit through organizations like the Ochoco Forest Restoration Collaborative.

"I think we're going to see some things happen," he said Thursday. "Now we're working with the Forest Service and other groups to get another mill in. It'll never be like the heyday, when we had five mills running."

Crook County Judge Seth Crawford, in effect the county commission chairman, said that whatever becomes of Consolidated Pine, the bottom line is job creation. The county will work with whoever buys the facility to make it successful. The area is within an Oregon enterprise zone, making businesses there eligible for tax credits in exchange for creating jobs.

"Crook County is open for business," Crawford said Friday. "We'll do whatever we need to do to bring manufacturing jobs (to the area). We're going to get that done. ff

In the past, sawmills provided locally sourced raw material to the makers of wood molding, windows and doors in Prineville, Brummer said. Now that lumber is harvested elsewhere and cut at mills in Gilchrist or John Day, he said, which adds insurmountable costs to companies like Consolidated Pine, which used to run its own sawmill.

Consolidated Pine once served as the sole source of finished products that Consolidated Companies marketed from its East Coast distribution point.

Now, cheaper imports from Chile, China and Brazil dominate the market, Biswas said. But, he said, American-made wood products still command a premium price overseas because of their quality. In India, a new condo, for

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 59 of 123 example, with American-madeBarcode:3927394-02 moldings C-570-118 or INVdoors - Investigation is as much - a status symbol as some American automobiles, he said.

"Marketing is the most critical part," Biswas said. "But the product sells. And we had one leg up because of having a connection in India."

However, the plant needs updated equipment, and its owners overvalued the company, he said. When Biswas visited Prineville 11/2 years ago and met with employees, they were enthusiastic about bringing the plant back to competitive life.

"The overall idea, the company needs to be overhauled," Biswas said.

Shirvan expressed a different view. The real value in Consolidated Pine lies in keeping the operation intact, he said, but his agreement with Biswas ends there. Consolidated Pine "is still a viable business," but not on his companies' budget, he said. He said Biswas had unreasonable expectations.

"Whether his intent was to follow through on the deal, obviously he didn't," Shirvan said. "Mr. Biswas was not earnest. He knew nothing about our business."

— Reporter: 541-617-7815, F,[email protected]

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EXHIBIT I-15

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 61 of 123 Barcode:3927394-02 C-570-118 INV - Investigation -

Endura Products announces closure of Sparta facility

& spartalive.com/endura-products-announces-closure-of-sparta-facility

April 13, 2018

Posted By Bobby Lee McCulley I April 13, 2018 8:19 am

A longtime manufacturing facility Endura Products, formally known as Jeld-Wen Products, has announced that due to the loss of a major contract their Sparta facility will be forced to close its doors and place approximately 83 employees out of work.

"With great sadness, Endura Products is left with no choice but to take immediate steps to shut down its Sparta, Tennessee plant permanently. This development was prompted by a decision by Endura's largest customer to cease its relationship with Endura. That decision was sudden and unexpected," according to a statement released by Endura Products. "Without that customer relationship, it simply is not viable or sustainable for the Sparta plant to continue its operations. Endura Products greatly appreciates the loyalty and hard

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 62 of 123 Barcode:3927394-02 C-570-118 INV - Investigation - work that its White County employees have devoted to the company over the last several years. The company is working with the Tennessee Department of Labor to help these employees transition to other jobs."

According to facility administrators, employees are continuing to work as the plant still has orders to fulfill. However, as soon as those orders have been filled, the remaining employees will be terminated as the plant permanently shuts down.

The future for this facility has yet to be determined, according to Endura Products leaders. Equipment within the facility is expected to be relocated to other Endura plants.

"It's disappointing to hear a local business is leaving White County. In a global economy there are often circumstances that are beyond local control. Endura has been an asset and valuable community partner for many years; we hate to see them close their doors," said White County Executive Denny Wayne Robinson. "The Department of Labor is currently mobilizing resources for our citizens that will be effected by the change. I have been in contact with many local employers and they have already expressed interest in hiring displaced workers."

"White County's economic future is on a positive path of growth. Industrial development can be seen all across the county. From the expansion of local businesses and industries to the recent announcements of Hormann and Fitzgerald, job opportunities are readily available in our community."

The Expositor reached out to numerous manufacturing facilities within White County. The following facilities are currently hiring multiple employees for a variety of positions and shifts.

• Hillsman Modular Molding Inc. (HMMI) • Tri-State Distribution • Seastar Solutions • THK Rhythm

"Many of our best relationships are formed at work. There is no way that a manufacturer can close without causing grief. If there is a bright side to this, it might be that in the last year White County has created over six times as many jobs as will be lost with the closing of Endura," stated Marvin Bullock, president of the Sparta-White County Chamber of Commerce. "If we combine the 500-plus newly-created jobs with the number of long-time employers who are clambering to hire, then perhaps Endura's unfortunate closing could not have happened at a better time for the sake of its employees. My heart reaches out to all those affected."

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 63 of 123 Barcode:3927394-02 C-570-118 INV - Investigation -

EXHIBIT I-16

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 64 of 123 Sparta industrialBarcode:3927394-02 facility C-570-118 closes INV - Investigation abruptly -

April 13, 2018

By Amye Anderson UCBJ Managing Editor

SPARTA - The loss of a major contract has forced Endura Products' Sparta location to close abruptly. Approximately 75 employees will be affected as a result of the closure; which is slated to occur sometime within the next six to eight weeks, once all existing orders are filled.

"It's disappointing," said White County Executive Denny Wayne Robinson. "It's sad. That company, even though it's changed names and ownership - that particular business has been here in White County for a long time; 30-plus years."

The closure, as addressed in a statement released by company president Bruce Procton, was the result of the sudden and unexpected decision by a "significant customer" to drastically reduce its supply relationship with Endura. That loss reportedly accounted for the majority of the plant's business.

"With great disappointment and sadness, Endura Products has had to take immediate steps to shut down its Sparta, Tenn. plant on a permanent basis," a statement from Procton read.

"Endura has been left with no choice but to realign our wood processing and frame production to our other facilities as it simply is not viable or sustainable to continue the operations of the Sparta plant without the aforementioned business," he added.

Meanwhile, those employees affected by the closure are receiving job seeking assistance from Endura. The company has announced it is actively working with the Tennessee Department of Labor to help affected employees find and transition to other jobs. Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 65 of 123 Following the announcement,Barcode:3927394-02 the following C-570-118 local industriesINV - Investigation have indicated - they have open positions available for those affected by the closure of Endura Products:

• HMMI

• Peregrine Steel

• THK Rhythm North America

• Tristate Industries

In addition to assisting newly-displaced workers with their job search, Endura is also providing severance packages that recognize accrued unused vacation, personal and sick leave, as well as offering assistance for health care costs.

"We are very thankful for the loyalty and hard work that our White County employees have devoted to the company over the past six years since its acquisition by Endura," Procton said.

"Our Sparta team worked hard to support the company's com mitment to improving building practices and providing exceptional value to our customers through their devotion to quality and unmatched customer service."

In 2012, Endura Products acquired JELD-WEN, the facility's previous owner and a producer of energy-efficient doors and windows.

Amye Anderson

Amye Anderson is the managing editor of the Upper Cumberland Business Journal and can

be reached via email. Send an email.

Amye Anderson

Amye Anderson is the managing editor of the Upper Cumberland Business Journal and can be reached via

email. Send an email.

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 66 of 123 Barcode:3927394-02 C-570-118 INV - Investigation -

EXHIBIT I-17

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 67 of 123 Barcode:3927394-02 C-570-118 INV - Investigation -

Jeld-Wen to close Yakima facility

tD yakimaherald.cominews/business/localield-wen-to-close-yakinna-facility/article_056ed484-28b1-11e9-9cec-

Mai Hoang February 4, 2019

ELDIVEN JWI N D O WS lk D O O RS

YAKIMA, Wash. - Window and door manufacturer Jeld-Wen will close its Yakima facility in April

The Charlotte, N.C.-based company said in a written statement that it is closing the plant at 1311 N. Sixth Ave. to build efficiencies under a revised business plan. The plant has 179 employees, according to a listing on the state Worker Adjustment and Retraining Notification website.

"The Yakima facility closure will support our value of improving daily by doing everything we can to advance the way we operate and do business," the company wrote in its statement.

The company said it has notified local and state officials of the closure. It has a program in place to move employees to its other facilities or provide outplacement services for those who will transition to new jobs.

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 68 of 123 Barcode:3927394-02 C-570-118 INV - Investigation - Jeld-Wen, which was based in Klamath Falls, Ore., before relocating to its North Carolina headquarters in 2015, has run a plant in Yakima since 1987. It operated out of its former plant at 1015 E. Lincoln Ave. for nearly two decades before relocating to its current facility.

The company also once ran a fiber plant in White Swan that closed in 2010.

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 69 of 123 Barcode:3927394-02 C-570-118 INV - Investigation -

EXHIBIT I-18

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 70 of 123 Barcode:3927394-02 C-570-118 INV - Investigation -

U.S. Consumption Imports of Wood Moulding Products CY 2016 - 2018; Jan. - Oct. 2018, 2019

Source: U.S. International Trade Commission Country Year 2016 Year 2017 Year 2018 Jan - Oct. 2018 Jan. - Oct. 2019 12 Months % Share of Quantity: Meters Imports Brazil 372,705,458 420,297,558 434,040,698 357,020,810 376,176,038 453,195,926 39.36% Chile 278,052,786 271,865,595 267,585,072 229,871,117 221,232,503 258,946,458 22.49% China 100,542,792 134,917,605 190,385,535 149,237,995 181,963,144 223,110,684 19.38% Mexico 143,280,758 148,679,232 144,720,272 123,032,102 118,848,432 140,536,602 12.21% Argentina 24,892,475 30,574,886 28,425,907 22,974,215 31,601,263 37,052,955 3.22% Canada 18,659,150 18,278,939 13,385,762 11,738,750 10,120,250 11,767,262 1.02% Malaysia 10,005,653 9,214,968 8,904,420 7,602,107 7,300,480 8,602,793 0.75% Indonesia 6,551,405 6,746,822 6,108,041 5,029,681 6,189,487 7,267,847 0.63% Italy 4,010,159 4,400,250 4,927,408 4,238,092 4,087,446 4,776,762 0.41% Spain 405,319 568,238 1,521,997 1,167,923 935,641 1,289,715 0.11% Subtotal: 959,105,955 1,045,544,093 1,100,005,112 911,912,792 958,454,684 1,146,547,004 99.58%

All Others 7,451,663 8,404,972 7,632,148 6,970,154 4,186,514 4,848,508 0.42% TOTAL: 966,557,618 1,053,949,065 1,107,637,260 918,882,946 962,641,198 1,151,395,512 100.00% Customs Value: U.S. Dollars Brazil 265,787,640 316,186,057 291,760,096 238,355,494 267,589,335 320,993,937 35.10% Chile 190,164,450 194,570,315 191,927,989 163,630,495 162,852,357 191,149,851 20.90% China 105,296,803 158,402,017 208,388,081 168,769,810 161,705,393 201,323,664 22.01% Mexico 75,666,144 85,036,058 84,869,118 71,820,142 73,269,118 86,318,094 9.44% Argentina 17,835,637 21,164,274 19,663,558 15,661,144 24,098,534 28,100,948 3.07% Canada 32,119,694 37,583,183 32,005,995 27,907,123 26,476,513 30,575,385 3.34% Malaysia 17,294,545 14,061,750 14,629,085 12,556,569 12,108,905 14,181,421 1.55% Indonesia 10,552,565 10,164,554 10,674,257 8,512,054 11,492,029 13,654,232 1.49% Italy 9,735,455 11,608,816 12,965,319 11,116,018 10,828,912 12,678,213 1.39% Spain 1,689,006 2,428,295 4,281,408 3,285,128 4,019,023 5,015,303 0.55% Subtotal: 726,141,939 851,205,319 871,164,906 721,613,977 754,440,119 903,991,048 98.84%

All Others 9,268,162 10,010,675 10,044,572 8,384,864 8,988,110 10,647,818 1.16% TOTAL: 735,410,101 861,215,994 881,209,478 729,998,841 763,428,229 914,638,866 79.44% Customs Value: U.S. Dollars Brazil $ 0.71 $ 0.75 $ 0.67 $ 0.67 $ 0.71 $ 0.71 0.00% Chile $ 0.68 $ 0.72 $ 0.72 $ 0.71 $ 0.74 $ 0.74 0.00% China $ 1.05 $ 1.17 $ 1.09 $ 1.13 $ 0.89 $ 0.90 0.00% Mexico $ 0.53 $ 0.57 $ 0.59 $ 0.58 $ 0.62 $ 0.61 0.00% Argentina $ 0.72 $ 0.69 $ 0.69 $ 0.68 $ 0.76 $ 0.76 0.00% Canada $ 1.72 $ 2.06 $ 2.39 $ 2.38 $ 2.62 $ 2.60 0.00% Malaysia $ 1.73 $ 1.53 $ 1.64 $ 1.65 $ 1.66 $ 1.65 0.00% Indonesia $ 1.61 $ 1.51 $ 1.75 $ 1.69 $ 1.86 $ 1.88 0.00% Italy $ 2.43 $ 2.64 $ 2.63 $ 2.62 $ 2.65 $ 2.65 0.00% Spain $ 4.17 $ 4.27 $ 2.81 $ 2.81 $ 4.30 $ 3.89 0.00% Subtotal: $ 0.76 $ 0.81 $ 0.79 $ 0.79 $ 0.79 $ 0.79 0.00%

All Others $ 1.24 $ 1.19 $ 1.32 $ 1.20 $ 2.15 $ 2.20 0.00% TOTAL: $ 0.76 $ 0.82 $ 0.80 $ 0.79 $ 0.79 $ 0.79 0.00%

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 71 of 123 Barcode:3927394-02 C-570-118 INV - Investigation -

EXHIBIT I-19

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ENTIRE EXHIBIT NOT CAPABLE OF PUBLIC SUMMARY

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EXHIBIT I-20

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U.S. moulding producers struggle with rising imports

& fridayoffcuts.com/dsp_article.cfnn

Friday 28 Oct 2016

Despite consumption trending higher, U.S. wood moulding producers continue to struggle to defend their market share against offshore imports. Between 2012 and 2015, it is estimated that domestic share hovered at around 43%. However, U.S. finger-joint moulding producers have found it increasingly difficult to compete with imported products from South America, due primarily to the sharp devaluation of the Brazilian currency. U.S. MDF moulding producers, on the other hand, have been less affected by the real's devaluation in light of the fact that Brazil does not produce MDF mouldings.

Drawn by the strong U.S. dollar and a recovering U.S. economy, not to mention stagnating/ deteriorating demand in alternative markets, offshore producers have been directing more of their production to the U.S. Furthermore, offshore producers continue to upgrade/expand their capacity, exacerbating the increase in imported mouldings.

Leading the way in 2015 were imports from Brazil that held steady at 1.0 billion lineal feet; Chile was up 5% to 957 million lineal feet, followed by Mexico in third place ( +9% to 443 million lineal feet; figure 3). Although still a relatively small import player, Chinese imports continue to increase rapidly, jumping from 150 million lineal feet in 2014 to 250 million in 2015 (a year-over-year increase of 67%).

Although preliminary, year-to-date import data indicate that China is on pace to achieve 300 million lineal feet for the year. Comments from those travelling in China reveal that the focus of Chinese producers is on supplying the domestic residential home furnishings market first, and then relying on the U.S. as a complementary secondary market. However, in 2015 and into 2016, activity in the Chinese housing market was less robust than in previous years, and it has been speculated that this is motivating Chinese producers to put even more emphasis on the U.S. market.

Prior to the market collapse in 2007, MDF mouldings accounted for some 25% of U.S. consumption. Since then, they have progressively grown their share to 38% in 2015. The majority of MDF gains have come at the expense of finger-joint (the alternative substrate typically used in painted moulding applications). From a high of 62% in 2006, finger-joint saw its share contract to 45% in 2010. Most of this contraction has been at the expense of U.S. producers, and the recent improvement in finger-joint's share (to 48% in 2015) is attributed to the rise in imported product.

Over the last nine years, MDF mouldings have enjoyed increased acceptance by DIY Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved 1/2 Page 75 of 123 Barcode:3927394-02 C-570-118 INV - Investigation - consumer and contractors at the expense of finger-joint mouldings. There are several main reasons for this. For one, MDF moulding prices are generally lower and tend to be more stable than those of finger-joint. In addition, the primer coating on MDF mouldings is typically smoother than on finger-joint mouldings, and there is absolutely no telegraphing of seams. Last, the growing fashion trend toward the craftsman/shaker look of flat boards (replacing traditional shaped profiles) has created a major product category for MDF moulding producers, who estimate that more than 25% of their current moulding production is in primed board product.

For finger-joint moulding producers, the percentage of primed boards is much lower due to the cost advantage MDF moulding producers hold over their finger-joint counterparts. i.e., MDF moulding lines need only rip the panel into blanks, profile the edges and touch-dress the face, while the process and cost of making a finger-joint board is no different from producing a shaped moulding product.

One relative constant over the last nine years has been paint-grade mouldings comprised of both finger-joint and MDF. These have accounted for over 85% of the market; stain-grade solid lineal and plastic mouldings have battled over what is left. In recent years, seemingly thanks to the support of the big box retailers, plastic has made noticeable gains at the expense of solid lineal mouldings.

With our outlook anticipating further growth in U.S. moulding consumption, the questions become where the volume will originate from and whether the market can absorb further price increases. The most likely determinant will be if/when the Brazilian real begins to recover, and how successful Brazilian producers are in pushing through price increases sufficient to cover the rising cost of labour, energy and logs. Until a major shift occurs in the cost structure in Brazil (or in any of the other competing supply countries), prices are likely to continue trending in their current gradual upward trajectory.

Source: International WOOD MARKETS Group, www.woodmarkets.com

Copyright 2004-2020 C) lnnovatek Ltd. All rights reserved.

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved 2/2 Page 76 of 123 Barcode:3927394-02 C-570-118 INV - Investigation -

EXHIBIT I-21

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 77 of 123 Barcode:3927394-02 C-570-118 INV - Investigation -

ENTIRE EXHIBIT NOT CAPABLE OF PUBLIC SUMMARY

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EXHIBIT I-22

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FOR RELEASE AT 8:30 AM EST, THURSDAY, JANUARY 18, 2018 MONTHLY NEW RESIDENTIAL CONSTRUCTION, DECEMBER 2017 Release Number: CB18-10 January 18, 2018 - The U.S. Census Bureau and the U.S. Department of Housing and Urban Development jointly announced the following new residential construction statistics for December 2017:

NEW RESIDENTIAL New Residential Construction (Seasonally Adjusted Annual Rate) CONSTRUCTION 1,500 DECEMBER 2017 1,200 Building Permits: 1,302,000 900 Housing Starts: 1,192,000 Housing Completions: 1,177,000 600 Permits Thousands of Units of Thousands Next Release: February 16, 2018 300 Starts Completions 0 Seasonally Adjusted Annual Rate Dec-12 Dec-13 Dec-14 Dec-15 Dec-16 Dec-17 Source: U.S. Census Bureau, HUD, January 18, 2018 Source: U.S. Census Bureau, HUD, January 18, 2018

Building Permits Privately-owned housing units authorized by building permits in December were at a seasonally adjusted annual rate of 1,302,000. This is 0.1 percent (±1.4 percent)* below the revised November rate of 1,303,000, but is 2.8 percent (±1.9 percent) above the December 2016 rate of 1,266,000. Single-family authorizations in December were at a rate of 881,000; this is 1.8 percent (±1.2 percent) above the revised November figure of 865,000. Authorizations of units in buildings with five units or more were at a rate of 382,000 in December. An estimated 1,263,400 housing units were authorized by building permits in 2017. This is 4.7 percent (±0.6%) above the 2016 figure of 1,206,600. Housing Starts Privately-owned housing starts in December were at a seasonally adjusted annual rate of 1,192,000. This is 8.2 percent (±7.7 percent) below the revised November estimate of 1,299,000 and is 6.0 percent (±11.7 percent)* below the December 2016 rate of 1,268,000. Single-family housing starts in December were at a rate of 836,000; this is 11.8 percent (±6.5 percent) below the revised November figure of 948,000. The December rate for units in buildings with five units or more was 352,000. An estimated 1,202,100 housing units were started in 2017. This is 2.4 percent (±2.3%) above the 2016 figure of 1,173,800.

Data Inquiries Media Inquiries Economic Indicators Division, Residential Construction Branch Public Information Office 301‐763‐5160 301‐763‐3030 [email protected] [email protected]

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 80 of 123 Barcode:3927394-02 C-570-118 INV - Investigation -

Housing Completions Privately-owned housing completions in December were at a seasonally adjusted annual rate of 1,177,000. This is 2.2 percent (±17.8 percent)* above the revised November estimate of 1,152,000 and is 7.4 percent (±13.0 percent)* above the December 2016 rate of 1,096,000. Single-family housing completions in December were at a rate of 818,000; this is 4.3 percent (±20.5 percent)* above the revised November rate of 784,000. The December rate for units in buildings with five units or more was 346,000. An estimated 1,152,300 housing units were completed in 2017. This is 8.7 percent (±3.1%) above the 2016 figure of 1,059,700.

The January report is scheduled for release on February 16, 2018. View the full schedule in the Economic Briefing Room: . The full text and tables for this release can be found at . EXPLANATORY NOTES In interpreting changes in the statistics in this release, note that month-to-month changes in seasonally adjusted statistics often show movements which may be irregular. It may take three months to establish an underlying trend for building permit authorizations, six months for total starts, and five months for total completions. The statistics in this release are estimated from sample surveys and are subject to sampling variability as well as nonsampling error including bias and variance from response, nonreporting, and undercoverage. Estimated relative standard errors of the most recent data are shown in the tables. Whenever a statement such as “2.5 percent (±3.2 percent) above” appears in the text, this indicates the range (-0.7 to +5.7 percent) in which the actual percentage change is likely to have occurred. All ranges given for percentage changes are 90 percent confidence intervals and account only for sampling variability. If a range does not contain zero, the change is statistically significant. If it does contain zero, the change is not statistically significant; that is, it is uncertain whether there was an increase or decrease. The same policies apply to the confidence intervals for percentage changes shown in the tables. On average, the preliminary seasonally adjusted estimates of total building permits, housing starts and housing completions are revised 2 percent or less. Explanations of confidence intervals and sampling variability can be found on our website. API The Census Bureau’s application programming interface lets developers create custom apps to reach new users and makes key demographic, socio-economic and housing statistics more accessible than ever before. ###

* The 90 percent confidence interval includes zero. In such cases, there is insufficient statistical evidence to conclude that the actual change is different from zero.

Data Inquiries Media Inquiries Economic Indicators Division, Residential Construction Branch Public Information Office 301‐763‐5160 301‐763‐3030 [email protected] [email protected]

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 81 of 123 New Privately‐Owned Housing Units Authorized in Permit‐Issuing Places (Thousands of Units. Detail may not add to Barcode:3927394-02total because of rounding.) C-570-118 INV - Investigation -

Table 1a ‐ Seasonally adjusted annual rate United States Northeast Midwest South West Period 2 to 4 5 units Total 1 unit units or more Total 1 unit Total 1 unit Total 1 unit Total 1 unit 2016 December ...... 1,266 830 39 397 131 54 187 119 604 452 344 205

2017 January ...... 1,300 806 29 465 153 59 198 124 653 451 296 172 February ...... 1,219 834 45 340 117 54 247 136 585 448 270 196 March ...... 1,260 826 37 397 136 53 192 128 623 456 309 189 April ...... 1,228 794 36 398 120 53 192 124 579 424 337 193 May ...... 1,168 779 32 357 122 52 173 108 579 436 294 183 June ...... 1,275 811 35 429 104 57 207 120 622 445 342 189 July ...... 1,230 812 40 378 123 57 170 117 623 452 314 186 August ...... 1,272 800 36 436 109 58 184 114 620 429 359 199 September ...... 1,225 823 35 367 121 71 185 122 595 428 324 202 October ...... 1,316 850 33 433 122 53 193 127 633 456 368 214 November (r) ...... 1,303 865 39 399 114 55 183 130 651 469 355 211 December (p) ...... 1,302 881 39 382 163 56 199 133 579 462 361 230 . Average RSE (%) 1 ...... 2 2 5 2 3 5 4 4 2 2 2 3 Percent Change2 Dec. 2017 from Nov. 2017 ...... ‐0.1% 1.8% 0.0% ‐4.3% 43.0% 1.8% 8.7% 2.3% ‐11.1% ‐1.5% 1.7% 9.0% . 90 percent confidence interval 3 ...... ± 1.4 ± 1.2 ± 4.8 ± 3.8 ± 3.6 ± 4.6 ± 6.0 ± 6.7 ± 2.8 ± 0.8 ± 1.0 ± 1.1 Dec. 2017 from Dec. 2016 ...... 2.8% 6.1% 0.0% ‐3.8% 24.4% 3.7% 6.4% 11.8% ‐4.1% 2.2% 4.9% 12.2% . 90 percent confidence interval 3 ...... ± 1.9 ± 2.1 ± 6.1 ± 3.5 ± 3.6 ± 5.5 ± 4.1 ± 4.6 ± 3.2 ± 3.3 ± 1.6 ± 3.0

Table 1b ‐ Not seasonally adjusted United States Northeast Midwest South West Period 2 to 4 5 units Total 1 unit units or more Total 1 unit Total 1 unit Total 1 unit Total 1 unit 2016 Annual ...... 1,206.6 750.8 34.8 421.1 116.4 54.3 186.1 112.4 594.5 406.0 309.6 178.1 2017 Annual (p) ...... 1,263.4 817.7 35.4 410.3 126.5 56.8 191.4 122.8 613.0 441.8 332.5 196.4 . RSE (%) ...... 2 2 4 1 2 4 3 4 1 2 1 2 Year to year percent change² ...... 4.7% 8.9% 1.8% ‐2.6% 8.7% 4.7% 2.8% 9.2% 3.1% 8.8% 7.4% 10.3% . 90 percent confidence interval 3 ...... ± 0.6 ± 0.7 ± 6.4 ± 1.0 ± 2.3 ± 3.4 ± 2.1 ± 2.4 ± 0.4 ± 0.4 ± 1.1 ± 2.0 2016 December ...... 94.8 55.5 3.0 36.4 10.5 3.7 11.3 6.5 45.8 31.2 27.2 14.1

2017 January ...... 87.3 53.6 1.9 31.8 9.6 3.5 10.0 5.7 48.6 33.3 19.2 11.2 February ...... 84.8 57.8 3.0 24.0 6.4 3.0 12.7 7.1 45.8 34.0 19.9 13.6 March ...... 112.5 77.1 3.1 32.3 10.8 4.6 15.9 11.2 57.2 43.9 28.7 17.5 April ...... 102.6 69.2 2.6 30.8 9.7 4.6 16.8 11.2 48.2 36.8 28.0 16.7 May ...... 113.0 78.3 3.0 31.6 11.7 5.2 18.0 12.0 54.7 42.2 28.6 18.9 June ...... 127.9 81.8 3.6 42.5 11.0 5.9 21.3 12.8 59.9 42.9 35.6 20.2 July ...... 101.0 69.1 3.2 28.7 10.7 5.0 14.7 10.5 50.4 37.5 25.2 16.1 August ...... 119.6 76.6 3.4 39.6 10.1 5.6 18.8 11.9 57.4 40.3 33.2 18.9 September ...... 101.4 66.6 3.1 31.7 11.0 6.4 17.6 11.0 46.6 33.5 26.2 15.6 October ...... 114.0 70.9 3.0 40.1 10.5 4.8 19.3 12.1 53.9 36.8 30.3 17.2 November (r) ...... 97.0 62.0 3.0 31.9 9.3 4.4 14.3 9.6 46.6 33.0 26.8 15.0 December (p) ...... 93.2 56.5 2.8 33.9 13.0 3.6 11.7 6.9 41.7 30.7 26.8 15.3 . Average RSE (%) 1 ...... 2 2 5 2 3 5 4 4 2 2 2 3 p Preliminary r Revised S Does not meet publication standards because tests for identifiable and stable seasonalilty do not meet reliability standards X Not applicable 1 Average relative standard error for the latest 6‐month period 2 Computed using unrounded data 3 If the 90 percent confidence interval includes zero, there is insufficient evidence to conclude that the actual change is different from zero Note: Year‐to‐date permits estimates reflect revisions not distrubuted to months.

Source: U.S. Census Bureau and U.S. Department of Housing and Urban Development, New Residential Construction, January 18, 2018. Additional information on the survey methodology may be found at .

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 82 of 123 New Privately‐Owned Housing Units Authorized, but Not Started, at End of Period (Thousands of Units. Detail may not add to Barcode:3927394-02total because of rounding.) C-570-118 INV - Investigation -

Table 2a ‐ Seasonally adjusted United States Northeast Midwest South West Period 2 to 4 5 units Total 1 unit units or more Total 1 unit Total 1 unit Total 1 unit Total 1 unit 2016 December ...... 139 70 S66 14 5 20 8 68 39 37 18

2017 January ...... 143 72 S68 15 6 19 8 69 40 40 18 February ...... 135 74 S60 12 5 21 9 66 41 36 19 March ...... 138 77 S59 13 5 19 9 69 44 37 19 April ...... 142 77 S64 15 6 22 10 67 42 38 19 May ...... 146 80 S65 18 6 21 9 71 46 36 19 June ...... 145 78 S65 12 6 20 9 75 44 38 19 July ...... 141 78 S6 1 12 5 20 9 71 45 38 19 August ...... 148 77 S6 9 13 5 20 9 74 43 41 20 September ...... 151 78 S71 14 5 19 10 77 44 41 19 October (r) ...... 154 81 S71 12 5 19 9 77 46 46 21 November (r) ...... 152 79 S71 13 5 20 9 74 44 45 21 December (p) ...... 154 83 S69 15 6 22 9 72 47 45 21 . Average RSE (%) 1 ...... 6 6 X 9 15 16 16 17 8 8 11 13 Percent Change2 Dec. 2017 from Nov. 2017 ...... 1.3% 5.1% S ‐2.8% 15.4% 20.0% 10.0% 0.0% ‐2.7% 6.8% 0.0% 0.0% . 90 percent confidence interval 3 ...... ± 3.7 ± 4.6 X ± 6.5 ± 27.6 ± 18.9 ± 8.6 ± 14.7 ± 5.1 ± 6.5 ± 7.1 ± 8.9 Dec. 2017 from Dec. 2016 ...... 10.8% 18.6% S 4.5% 7.1% 20.0% 10.0% 12.5% 5.9% 20.5% 21.6% 16.7% . 90 percent confidence interval 3 ...... ± 9.8 ± 9.6 X ± 16.4 ± 52.2 ± 30.7 ± 25.0 ± 25.9 ± 14.1 ± 14.0 ± 16.0 ± 18.7

Table 2b ‐ Not seasonally adjusted United States Northeast Midwest South West Period 2 to 4 5 units Total 1 unit units or more Total 1 unit Total 1 unit Total 1 unit Total 1 unit 2016 December ...... 135.9 66.6 2.7 66.6 13.9 5.3 17.7 7.0 67.3 37.0 37.1 17.4

2017 January ...... 137.3 67.9 2.6 66.8 14.4 5.6 17.0 6.7 67.6 38.1 38.3 17.5 February ...... 131.5 69.9 1.4 60.1 12.3 5.2 19.4 7.6 64.7 39.3 35.1 17.8 March ...... 144.6 82.8 1.9 59.9 13.3 5.2 21.6 10.8 70.7 46.5 39.0 20.3 April ...... 143.7 78.3 1.5 64.0 15.1 5.6 21.7 10.4 67.7 43.2 39.3 19.0 May ...... 151.3 83.6 1.2 66.4 18.1 6.6 21.4 9.5 72.1 47.1 39.6 20.5 June ...... 155.9 85.3 2.2 68.4 13.9 6.7 20.3 9.9 78.9 47.3 42.7 21.4 July ...... 140.6 77.8 2.3 60.4 12.7 5.4 18.9 8.9 72.2 44.5 36.8 19.0 August ...... 153.1 81.0 2.5 69.6 12.7 5.3 20.3 10.5 78.2 44.7 41.9 20.5 September ...... 151.3 78.4 1.9 71.0 14.0 5.2 19.7 10.1 78.8 44.8 38.9 18.3 October (r) ...... 149.5 78.0 1.9 69.5 11.0 4.8 19.6 8.8 75.6 44.1 43.3 20.2 November (r) ...... 144.6 74.7 1.7 68.1 11.4 5.1 19.6 7.9 70.7 41.9 42.9 19.9 December (p) ...... 149.7 78.1 1.6 70.0 14.9 5.5 19.1 7.8 71.3 44.3 44.4 20.5 . Average RSE (%) 1 ...... 6 6 57 9 15 16 16 17 8 8 11 13 p Preliminary r Revised S Does not meet publication standards because tests for identifiable and stable seasonalilty do not meet reliability standards X Not applicable 1 Average relative standard error for the latest 6‐month period 2 Computed using unrounded data 3 See the Explanatory Notes in the accompanying text for an explantion of 90 percent confidence intervals Note: These data represent the number of housing units authorized in all months up to and including the last day of the reporting period and not started as of that date without regard to the months of original permit issuance. Cancelled, abandoned, expired, and revoked permits are excluded.

Source: U.S. Census Bureau and U.S. Department of Housing and Urban Development, New Residential Construction, January 18, 2018. Additional information on the survey methodology may be found at .

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 83 of 123 New Privately‐Owned Housing Units Started (Thousands of Units. Detail may not add to Barcode:3927394-02total because of rounding.) C-570-118 INV - Investigation -

Table 3a ‐ Seasonally adjusted annual rate United States Northeast Midwest South West Period 2 to 4 5 units Total 1 unit units or more Total 1 unit Total 1 unit Total 1 unit Total 1 unit 2016 December ...... 1,268 808 S 449 89 58 222 128 566 418 391 204

2017 January ...... 1,236 815 S 418 125 59 202 137 678 453 231 166 February ...... 1,288 877 S 392 111 67 182 163 658 448 337 199 March ...... 1,189 824 S 355 116 65 139 105 633 466 301 188 April ...... 1,154 823 S 314 85 47 200 124 562 449 307 203 May ...... 1,129 795 S 320 85 55 165 140 564 410 315 190 June ...... 1,217 857 S 354 158 62 202 134 529 452 328 209 July ...... 1,185 841 S 333 120 69 161 116 611 463 293 193 August ...... 1,172 871 S 292 108 68 171 117 583 476 310 210 September ...... 1,159 832 S 310 101 75 187 127 543 410 328 220 October (r) ...... 1,261 887 S 356 145 64 200 145 613 472 303 206 November (r) ...... 1,299 948 S 343 92 62 182 142 678 512 347 232 December (p) ...... 1,192 836 S 352 88 47 178 130 582 427 344 232 . Average RSE (%) 1 ...... 4 4 X 12 13 11 14 12 6 6 9 6 Percent Change2 Dec. 2017 from Nov. 2017 ...... ‐8.2% ‐11.8% S 2.6% ‐4.3% ‐24.2% ‐2.2% ‐8.5% ‐14.2% ‐16.6% ‐0.9% 0.0% . 90 percent confidence interval 3 ...... ± 7.7 ± 6.5 X ± 22.4 ± 34.5 ± 23.7 ± 25.9 ± 16.2 ± 12.2 ± 10.7 ± 14.2 ± 15.9 Dec. 2017 from Dec. 2016 ...... ‐6.0% 3.5% S ‐21.6% ‐1.1% ‐19.0% ‐19.8% 1.6% 2.8% 2.2% ‐12.0% 13.7% . 90 percent confidence interval 3 ...... ± 11.7 ± 10.5 X ± 22.9 ± 32.2 ± 24.4 ± 33.3 ± 32.0 ± 14.5 ± 13.1 ± 22.6 ± 21.3

Table 3b ‐ Not seasonally adjusted United States Northeast Midwest South West Period 2 to 4 5 units Total 1 unit units or more Total 1 unit Total 1 unit Total 1 unit Total 1 unit 2016 Annual ...... 1,173.8 781.5 11.5 380.8 116.1 60.1 182.3 120.9 584.6 421.1 290.9 179.4 2017 Annual (p) ...... 1,202.1 848.3 11.4 342.4 111.4 61.8 180.4 130.8 598.2 451.7 312.1 204.0 . RSE (%) ...... 2 1 19 6 4 3 3 2 2 2 3 2 Year to year percent change² ...... 2.4% 8.5% ‐1.0% ‐10.1% ‐4.0% 2.9% ‐1.0% 8.1% 2.3% 7.3% 7.3% 13.7% . 90 percent confidence interval 3 ...... ± 2.3 ± 1.8 ± 30.9 ± 6.3 ± 7.2 ± 6.6 ± 6.4 ± 4.9 ± 3.6 ± 2.8 ± 4.7 ± 4.2 2016 December ...... 86.5 52.9 0.8 32.8 6.4 4.1 13.9 7.0 39.0 28.2 27.2 13.5

2017 January ...... 82.3 53.1 0.2 29.0 8.0 3.4 10.7 6.2 48.0 32.4 15.6 11.1 February ...... 87.8 58.8 1.3 27.7 6.6 3.5 8.9 7.6 48.4 33.6 23.8 14.1 March ...... 97.1 69.5 0.7 27.0 8.8 4.9 9.9 7.3 53.8 41.1 24.7 16.1 April ...... 105.2 76.9 1.4 26.8 7.7 4.4 18.8 12.3 50.3 40.7 28.4 19.5 May ...... 106.0 76.9 1.2 28.0 7.9 5.2 16.8 14.6 52.5 39.1 28.9 18.0 June ...... 116.3 83.8 0.5 31.9 14.8 6.1 20.6 14.5 49.5 42.6 31.4 20.6 July ...... 112.3 79.4 1.1 31.9 11.5 6.7 16.1 11.8 56.3 42.1 28.4 18.8 August ...... 102.6 78.1 0.7 23.8 9.6 6.3 15.4 11.0 50.6 41.9 27.0 18.9 September ...... 104.4 72.5 1.6 30.2 9.3 6.8 18.2 12.4 47.9 35.0 28.8 18.3 October (r) ...... 109.6 75.7 1.6 32.3 13.5 6.2 19.4 14.4 51.7 39.0 25.0 16.2 November (r) ...... 98.1 69.3 0.7 28.1 7.4 4.9 14.9 11.5 49.7 36.1 26.1 16.7 December (p) ...... 80.3 54.3 0.3 25.7 6.2 3.3 10.6 7.1 39.5 28.2 23.9 15.7 . Average RSE (%) 1 ...... 4 4 47 12 13 11 14 12 6 6 9 6 p Preliminary r Revised S Does not meet publication standards because tests for identifiable and stable seasonalilty do not meet reliability standards X Not applicable 1 Average relative standard error for the latest 6‐month period 2 Computed using unrounded data 3 See the Explanatory Notes in the accompanying text for an explantion of 90 percent confidence intervals

Source: U.S. Census Bureau and U.S. Department of Housing and Urban Development, New Residential Construction, January 18, 2018. Additional information on the survey methodology may be found at .

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 84 of 123 New Privately‐Owned Housing Units Under Construction at End of Period (Thousands of Units. Detail may not add to Barcode:3927394-02total because of rounding.) C-570-118 INV - Investigation -

Table 4a ‐ Seasonally adjusted United States Northeast Midwest South West Period 2 to 4 5 units Total 1 unit units or more Total 1 unit Total 1 unit Total 1 unit Total 1 unit 2016 December ...... 1,062 449 S 602 191 53 144 73 448 214 279 109

2017 January ...... 1,071 447 S 613 193 52 147 73 449 212 282 110 February ...... 1,080 455 S 614 194 54 151 76 452 215 283 110 March ...... 1,074 454 S 610 189 52 149 73 452 218 284 111 April ...... 1,074 457 S 607 190 51 151 74 445 219 288 113 May ...... 1,068 459 S 599 184 51 154 76 442 219 288 113 June ...... 1,068 462 S 597 184 50 153 77 442 222 289 113 July ...... 1,067 461 S 597 185 50 151 77 441 221 290 113 August ...... 1,078 472 S 596 186 51 152 77 448 228 292 116 September ...... 1,088 479 S 599 189 53 152 78 445 227 302 121 October (r) ...... 1,098 487 S 599 192 53 154 80 445 231 307 123 November (r) ...... 1,105 495 S 599 188 53 155 82 446 231 316 129 December (p) ...... 1,113 502 S 601 187 53 158 84 447 231 321 134 . Average RSE (%) 1 ...... 3 3 X 5 7 5 4 5 4 4 5 5 Percent Change2 Dec. 2017 from Nov. 2017 ...... 0.7% 1.4% S 0.3% ‐0.5% 0.0% 1.9% 2.4% 0.2% 0.0% 1.6% 3.9% . 90 percent confidence interval 3 ...... ± 1.1 ± 1.7 X ± 1.2 ± 1.6 ± 2.7 ± 1.6 ± 1.9 ± 2.3 ± 3.2 ± 1.3 ± 1.9 Dec. 2017 from Dec. 2016 ...... 4.8% 11.8% S ‐0.2% ‐2.1% 0.0% 9.7% 15.1% ‐0.2% 7.9% 15.1% 22.9% . 90 percent confidence interval 3 ...... ± 3.4 ± 3.4 X ± 5.2 ± 8.6 ± 8.2 ± 7.3 ± 8.4 ± 6.3 ± 6.0 ± 5.0 ± 6.2

Table 4b ‐ Not seasonally adjusted United States Northeast Midwest South West Period 2 to 4 5 units Total 1 unit units or more Total 1 unit Total 1 unit Total 1 unit Total 1 unit 2016 December ...... 1,039.0 427.7 10.6 600.7 189.5 51.9 142.1 71.2 435.5 202.3 271.9 102.3

2017 January ...... 1,045.8 424.4 10.5 610.9 191.0 50.7 142.5 68.6 437.4 201.1 275.0 104.0 February ...... 1,051.1 430.4 11.2 609.5 190.9 51.6 143.7 69.5 441.0 205.9 275.6 103.5 March ...... 1,052.6 435.0 10.4 607.2 187.4 50.7 143.2 67.8 443.1 210.3 278.9 106.1 April ...... 1,071.4 450.9 9.9 610.6 189.9 50.4 147.8 70.1 445.1 217.8 288.7 112.5 May ...... 1,077.5 461.4 10.0 606.1 185.4 50.7 153.9 75.2 447.2 221.7 291.1 113.8 June ...... 1,083.4 473.5 8.9 601.0 185.8 51.0 155.6 79.0 448.0 227.1 294.0 116.5 July ...... 1,092.6 482.8 9.1 600.7 187.5 51.4 156.3 81.4 451.7 230.3 297.1 119.7 August ...... 1,095.9 493.8 9.5 592.6 186.7 52.3 155.5 81.2 456.2 237.3 297.6 122.9 September ...... 1,106.4 498.1 10.3 598.0 189.2 54.0 156.8 82.6 453.4 235.5 306.9 125.9 October (r) ...... 1,110.3 500.0 11.5 598.8 193.5 54.5 158.4 84.3 449.1 235.6 309.3 125.6 November (r) ...... 1,113.2 500.7 11.1 601.4 190.5 54.7 158.2 85.3 447.7 232.0 316.8 128.8 December (p) ...... 1,085.8 478.4 10.0 597.4 185.5 52.3 154.1 81.0 433.6 218.5 312.6 126.7 . Average RSE (%) 1 ...... 3 3 16 5 7 5 4 5 4 4 5 5 p Preliminary r Revised S Does not meet publication standards because tests for identifiable and stable seasonalilty do not meet reliability standards X Not applicable 1 Average relative standard error for the latest 6‐month period 2 Computed using unrounded data 3 See the Explanatory Notes in the accompanying text for an explantion of 90 percent confidence intervals

Source: U.S. Census Bureau and U.S. Department of Housing and Urban Development, New Residential Construction, January 18, 2018. Additional information on the survey methodology may be found at .

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 85 of 123 New Privately‐Owned Housing Units Completed (Thousands of Units. Detail may not add to Barcode:3927394-02total because of rounding.) C-570-118 INV - Investigation -

Table 5a ‐ Seasonally adjusted annual rate United States Northeast Midwest South West Period 2 to 4 5 units Total 1 unit units or more Total 1 unit Total 1 unit Total 1 unit Total 1 unit 2016 December ...... 1,096 765 S 323 102 50 184 120 574 414 236 181

2017 January ...... 1,083 802 S 277 84 67 174 134 611 459 214 142 February ...... 1,161 763 S 382 119 40 123 108 575 402 344 213 March ...... 1,194 810 S 368 111 60 188 134 629 449 266 167 April ...... 1,098 774 S 301 88 60 183 127 591 420 236 167 May ...... 1,180 799 S 369 138 54 146 120 600 426 296 199 June ...... 1,230 815 S 404 134 61 220 128 541 419 335 207 July ...... 1,194 844 S 343 106 75 171 106 637 471 280 192 August ...... 1,091 748 S 340 133 56 178 125 528 395 252 172 September ...... 1,081 771 S 303 79 53 179 112 593 428 230 178 October (r) ...... 1,184 794 S 383 138 60 147 128 628 427 271 179 November (r) ...... 1,152 784 S 353 145 55 176 112 602 464 229 153 December (p) ...... 1,177 818 S 346 112 62 166 119 601 451 298 186 . Average RSE (%) 1 ...... 6 6 X 13 18 16 13 10 8 9 9 9 Percent Change2 Dec. 2017 from Nov. 2017 ...... 2.2% 4.3% S ‐2.0% ‐22.8% 12.7% ‐5.7% 6.3% ‐0.2% ‐2.8% 30.1% 21.6% . 90 percent confidence interval 3 ...... ± 17.8 ± 20.5 X ± 34.5 ± 27.2 ± 41.2 ± 45.2 ± 25.8 ± 25.1 ± 31.1 ± 43.2 ± 38.4 Dec. 2017 from Dec. 2016 ...... 7.4% 6.9% S 7.1% 9.8% 24.0% ‐9.8% ‐0.8% 4.7% 8.9% 26.3% 2.8% . 90 percent confidence interval 3 ...... ± 13.0 ± 15.2 X ± 28.2 ± 51.5 ± 28.8 ± 15.5 ± 11.5 ± 19.6 ± 25.5 ± 23.6 ± 14.7

Table 5b ‐ Not seasonally adjusted United States Northeast Midwest South West Period 2 to 4 5 units Total 1 unit units or more Total 1 unit Total 1 unit Total 1 unit Total 1 unit 2016 Annual ...... 1,059.7 738.4 10.4 311.0 99.5 55.2 164.0 116.8 551.3 402.9 245.0 163.5 2017 Annual (p) ...... 1,152.3 794.0 10.7 347.7 115.8 58.5 171.6 120.6 593.8 434.7 271.1 180.1 . RSE (%) ...... 2 1 17 5 5 5 4 2 2 2 3 2 Year to year percent change² ...... 8.7% 7.5% 2.9% 11.8% 16.5% 6.1% 4.6% 3.3% 7.7% 7.9% 10.6% 10.2% . 90 percent confidence interval 3 ...... ± 3.1 ± 3.1 ± 26.2 ± 8.8 ± 10.4 ± 8.6 ± 7.6 ± 4.2 ± 4.2 ± 4.2 ± 5.2 ± 6.2 2016 December ...... 103.6 75.0 0.6 28.0 9.5 5.0 17.7 12.2 54.0 40.1 22.4 17.7

2017 January ...... 74.6 55.0 0.3 19.4 5.6 4.4 11.3 8.5 43.5 32.9 14.3 9.2 February ...... 78.9 52.7 1.1 25.1 7.5 2.3 7.6 6.6 40.6 29.2 23.1 14.5 March ...... 92.0 62.4 1.3 28.3 8.0 4.0 13.3 9.2 50.0 36.1 20.7 13.0 April ...... 83.4 60.1 1.6 21.7 6.3 4.3 13.9 9.9 45.3 33.0 17.8 12.8 May ...... 98.1 66.9 1.0 30.3 11.6 4.8 11.9 9.8 49.6 35.3 25.0 17.0 June ...... 109.9 71.3 1.1 37.5 12.5 5.7 19.2 10.7 48.2 36.9 30.0 18.1 July ...... 102.2 69.4 0.6 32.1 9.0 6.2 15.1 8.9 54.0 38.4 24.1 15.8 August ...... 102.1 65.6 0.3 36.2 13.1 4.9 16.8 11.2 48.7 34.5 23.6 15.1 September ...... 96.2 68.2 0.7 27.3 8.0 5.6 16.7 10.6 51.1 36.3 20.5 15.7 October (r) ...... 106.9 73.3 0.6 33.1 12.1 5.4 14.5 12.9 55.9 38.5 24.5 16.5 November (r) ...... 96.2 68.5 1.1 26.6 11.7 4.9 15.1 10.3 50.0 39.6 19.4 13.7 December (p) ...... 111.7 80.6 1.1 30.0 10.4 6.0 16.2 12.1 56.9 43.9 28.2 18.5 . Average RSE (%) 1 ...... 6 6 47 13 18 16 13 10 8 9 9 9 p Preliminary r Revised S Does not meet publication standards because tests for identifiable and stable seasonalilty do not meet reliability standards X Not applicable 1 Average relative standard error for the latest 6‐month period 2 Computed using unrounded data 3 See the Explanatory Notes in the accompanying text for an explantion of 90 percent confidence intervals

Source: U.S. Census Bureau and U.S. Department of Housing and Urban Development, New Residential Construction, January 18, 2018. Additional information on the survey methodology may be found at .

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 86 of 123 Barcode:3927394-02 C-570-118 INV - Investigation -

EXHIBIT I-23

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 87 of 123 Barcode:3927394-02 C-570-118 INV - Investigation -

FOR RELEASE AT 8:30 AM EST, TUESDAY, FEBRUARY 26, 2019 MONTHLY NEW RESIDENTIAL CONSTRUCTION, DECEMBER 2018 Release Number: CB19‐17

Data collection and processing were delayed for this indicator release due to the lapse in federal funding from December 22, 2018 through January 25, 2019. Although released for the first time this month, the December 2018 estimates of housing units authorized by building permits include late reports and corrections normally associated with the first revision to the estimates. While response rates were consistent with normal levels, delays in data collection could make it more difficult to determine exact start and completion dates. However, processing and data quality were monitored and no significant issues were identified.

February 26, 2019 ‐ The U.S. Census Bureau and the U.S. Department of Housing and Urban Development jointly announced the following new residential construction statistics for December 2018:

NEW RESIDENTIAL New Residential Construction (Seasonally Adjusted Annual Rate) CONSTRUCTION 1,500 DECEMBER 2018 1,200 Building Permits: 1,326,000 Units of 900 Housing Starts: 1,078,000 Housing Completions: 1,097,000 600 Permits Next Release: TBD Thousands 300 Starts Completions Seasonally Adjusted Annual Rate 0 Source: U.S. Census Bureau, HUD, February 26, 2019 Dec‐13 Dec‐14 Dec‐15 Dec‐16 Dec‐17 Dec‐18 Source: U.S. Census Bureau, HUD, February 26, 2019

Building Permits Privately‐owned housing units authorized by building permits in December were at a seasonally adjusted annual rate of 1,326,000. This is 0.3 percent (±1.2 percent)* above the revised November rate of 1,322,000 and is 0.5 percent (±1.1 percent)* above the December 2017 rate of 1,320,000. Single‐family authorizations in December were at a rate of 829,000; this is 2.2 percent (±0.7 percent) below the revised November figure of 848,000. Authorizations of units in buildings with five units or more were at a rate of 460,000 in December.

An estimated 1,310,700 housing units were authorized by building permits in 2018. This is 2.2 percent (±0.6%) above the 2017 figure of 1,282,000.

Housing Starts Privately‐owned housing starts in December were at a seasonally adjusted annual rate of 1,078,000. This is 11.2 percent (±14.0 percent)* below the revised November estimate of 1,214,000 and is 10.9 percent (±16.1 percent)* below the December 2017 rate of 1,210,000. Single‐family housing starts in December were at a rate of 758,000; this is 6.7 percent (±15.3 percent)* below the revised November figure of 812,000. The December rate for units in buildings with five units or more was 302,000.

An estimated 1,246,600 housing units were started in 2018. This is 3.6 percent (±2.1%) above the 2017 figure of 1,203,000.

Data Inquiries Media Inquiries Economic Indicators Division, Residential Construction Branch Public Information Office 301‐763‐5160 301‐763‐3030 [email protected] [email protected]

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 88 of 123 Barcode:3927394-02 C-570-118 INV - Investigation -

Housing Completions Privately‐owned housing completions in December were at a seasonally adjusted annual rate of 1,097,000. This is 2.7 percent (±10.0 percent)* below the revised November estimate of 1,128,000 and is 8.4 percent (±12.2 percent)* below the December 2017 rate of 1,197,000. Single‐family housing completions in December were at a rate of 790,000; this is 0.1 percent (±14.0 percent)* above the revised November rate of 789,000. The December rate for units in buildings with five units or more was 296,000. An estimated 1,191,700 housing units were completed in 2018. This is 3.4 percent (±3.8%) above the 2017 figure of 1,152,900.

The U.S. Census Bureau is updating its 2019 economic indicator release calendar in coordination with other agencies and the Office of Management and Budget to address the impacts of the recent lapse in federal funding. Please refer to for the latest information on the rescheduled release dates.

EXPLANATORY NOTES In interpreting changes in the statistics in this release, note that month‐to‐month changes in seasonally adjusted statistics often show movements which may be irregular. It may take three months to establish an underlying trend for building permit authorizations, six months for total starts, and six months for total completions. The statistics in this release are estimated from sample surveys and are subject to sampling variability as well as nonsampling error including bias and variance from response, nonreporting, and undercoverage. Estimated relative standard errors of the most recent data are shown in the tables. Whenever a statement such as “2.5 percent (±3.2 percent) above” appears in the text, this indicates the range (‐0.7 to +5.7 percent) in which the actual percentage change is likely to have occurred. All ranges given for percentage changes are 90 percent confidence intervals and account only for sampling variability. If a range does not contain zero, the change is statistically significant. If it does contain zero, the change is not statistically significant; that is, it is uncertain whether there was an increase or decrease. The same policies apply to the confidence intervals for percentage changes shown in the tables. On average, the preliminary seasonally adjusted estimates of total building permits, housing starts and housing completions are revised 2.4 percent or less. Explanations of confidence intervals and sampling variability can be found on our website.

API The Census Bureau’s application programming interface lets developers create custom apps to reach new users and makes key demographic, socio‐economic and housing statistics more accessible than ever before. FRED Mobile App Receive the latest updates on the nation’s key economic indicators by downloading the FRED App for both Apple and Android devices. FRED, the signature database of the Federal Reserve Bank of St. Louis, now incorporates the Census Bureau’s 13 economic indicators.

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* The 90 percent confidence interval includes zero. In such cases, there is insufficient statistical evidence to conclude that the actual change is different from zero.

Data Inquiries Media Inquiries Economic Indicators Division, Residential Construction Branch Public Information Office 301‐763‐5160 301‐763‐3030 [email protected] [email protected]

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 89 of 123 New Privately‐Owned Housing Units Authorized in Permit‐Issuing Places (Thousands of Units. Detail may not add to Barcode:3927394-02total because of rounding.) C-570-118 INV - Investigation -

Table 1a ‐ Seasonally adjusted annual rate United States Northeast Midwest South West Period 2 to 4 5 units Total 1 unit units or more Total 1 unit Total 1 unit Total 1 unit Total 1 unit 2017 December ...... 1,320 877 38 405 144 53 220 133 589 463 367 228

2018 January ...... 1,366 870 45 451 115 48 176 124 697 470 378 228 February ...... 1,323 886 46 391 145 63 192 127 617 471 369 225 March ...... 1,377 851 40 486 135 51 203 119 652 456 387 225 April ...... 1,364 863 41 460 95 51 195 123 727 479 347 210 May ...... 1,301 843 34 424 134 57 209 122 625 458 333 206 June ...... 1,292 853 36 403 119 56 173 117 670 475 330 205 July ...... 1,303 873 28 402 125 56 181 118 665 483 332 216 August ...... 1,249 827 35 387 102 51 190 119 650 450 307 207 September ...... 1,270 854 40 376 95 57 171 119 664 459 340 219 October ...... 1,265 847 36 382 120 62 186 117 641 461 318 207 November (r) ...... 1,322 848 39 435 117 53 176 115 702 474 327 206 December (p+) ...... 1,326 829 37 460 110 57 145 110 688 455 383 207 . Average RSE (%) 1 ...... 2 2 6 2 4 5 3 4 1 2 2 3 Percent Change2 Dec. 2018 from Nov. 2018 ...... 0.3% ‐2.2% ‐5.1% 5.7% ‐6.0% 7.5% ‐17.6% ‐4.3% ‐2.0% ‐4.0% 17.1% 0.5% . 90 percent confidence interval 3 ...... ± 1.2 ± 0.7 ± 4.3 ± 3.1 ± 4.1 ± 9.6 ± 2.7 ± 2.5 ± 0.5 ± 1.2 ± 4.8 ± 1.4 Dec. 2018 from Dec. 2017 ...... 0.5% ‐5.5% ‐2.6% 13.6% ‐23.6% 7.5% ‐34.1% ‐17.3% 16.8% ‐1.7% 4.4% ‐9.2% . 90 percent confidence interval 3 ...... ± 1.1 ± 1.8 ± 5.1 ± 2.2 ± 3.8 ± 13.4 ± 1.9 ± 3.3 ± 2.1 ± 1.9 ± 1.9 ± 2.0

Table 1b ‐ Not seasonally adjusted United States Northeast Midwest South West Period 2 to 4 5 units Total 1 unit units or more Total 1 unit Total 1 unit Total 1 unit Total 1 unit 2017 Annual ...... 1,282.0 820.0 37.2 424.8 123.6 54.2 195.1 121.5 626.9 447.6 336.4 196.7 2018 Annual (p) ...... 1,310.7 852.7 37.6 420.4 117.0 55.2 184.7 118.8 663.4 466.2 345.5 212.4 . RSE (%) ...... 1 2 3 1 2 4 3 4 1 2 2 3 Year to year percent change² ...... 2.2% 4.0% 1.1% ‐1.0% ‐5.3% 1.8% ‐5.3% ‐2.2% 5.8% 4.2% 2.7% 8.0% . 90 percent confidence interval 3 ...... ± 0.6 ± 0.5 ± 3.5 ± 1.1 ± 2.2 ± 3.5 ± 2.3 ± 1.5 ± 0.4 ± 0.4 ± 1.9 ± 2.0 2017 December ...... 94.8 56.5 2.8 35.5 11.7 3.5 13.0 7.0 42.6 30.7 27.4 15.4

2018 January ...... 96.7 61.8 3.2 31.7 7.5 3.0 9.2 6.0 53.7 36.9 26.3 15.9 February ...... 92.1 62.2 3.2 26.7 8.2 3.4 9.7 6.9 47.7 35.9 26.4 15.9 March ...... 117.6 75.8 3.3 38.4 10.5 4.2 15.9 10.1 57.3 41.7 33.9 19.8 April ...... 119.9 79.1 3.3 37.4 7.8 4.6 18.2 11.9 64.0 43.4 29.9 19.2 May ...... 125.0 84.4 3.0 37.6 13.5 5.7 21.6 13.3 58.4 44.3 31.5 20.9 June ...... 121.6 81.7 3.4 36.6 11.5 5.5 16.5 11.8 61.1 43.8 32.6 20.5 July ...... 113.0 77.8 2.4 32.8 11.1 5.1 16.5 11.1 57.9 42.2 27.5 19.4 August ...... 116.9 78.5 3.5 35.0 9.0 4.8 19.7 12.1 59.8 42.1 28.5 19.5 September ...... 99.4 65.0 3.3 31.1 8.2 4.9 15.2 10.0 50.2 34.0 25.7 16.1 October ...... 112.6 73.9 3.2 35.4 10.8 6.0 19.5 11.6 54.7 38.8 27.6 17.5 November (r) ...... 101.0 60.9 3.1 37.0 9.5 4.2 13.9 8.5 52.2 33.7 25.5 14.5 December (p+) ...... 95.4 53.4 2.6 39.4 9.1 3.7 8.3 5.8 49.3 29.9 28.6 13.9 . Average RSE (%) 1 ...... 2 2 6 2 4 5 3 4 1 2 2 3 p Preliminary p+ Although released for the first time this month, data for December 2018 include late reports and corrections normally associated with the first revision. r Revised S Does not meet publication standards because tests for identifiable and stable seasonalilty do not meet reliability standards X Not applicable 1 Average relative standard error for the latest 6‐month period 2 Computed using unrounded data 3 If the 90 percent confidence interval includes zero, there is insufficient evidence to conclude that the actual change is different from zero Note: Year‐to‐date permits estimates reflect revisions not distrubuted to months.

Source: U.S. Census Bureau and U.S. Department of Housing and Urban Development, New Residential Construction, February 26, 2019. Additional information on the survey methodology may be found at .

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 90 of 123 New Privately‐Owned Housing Units Authorized, but Not Started, at End of Period (Thousands of Units. Detail may not add to Barcode:3927394-02total because of rounding.) C-570-118 INV - Investigation -

Table 2a ‐ Seasonally adjusted United States Northeast Midwest South West Period 2 to 4 5 units Total 1 unit units or more Total 1 unit Total 1 unit Total 1 unit Total 1 unit 2017 December ...... 159 87 S70 15 6 23 10 76 49 45 22

2018 January ...... 163 90 S70 14 6 23 10 80 51 46 23 February ...... 160 89 S69 13 6 23 11 79 50 45 22 March ...... 160 89 S68 14 7 22 10 81 51 43 21 April ...... 164 91 S71 12 7 26 13 85 50 41 21 May ...... 160 87 S71 14 7 25 12 79 47 42 21 June ...... 163 89 S72 14 7 25 12 83 49 41 21 July ...... 170 94 S7 4 16 8 25 12 84 52 45 22 August ...... 167 92 S7 3 15 8 25 11 85 51 42 22 September ...... 168 91 S75 13 7 24 10 89 53 42 21 October (r) ...... 168 91 S75 14 7 23 10 91 57 40 17 November (r) ...... 175 97 S76 13 6 25 11 95 60 42 20 December (p) ...... 187 101 S84 12 6 28 12 97 61 50 22 . Average RSE (%) 1 ...... 6 6 X 10 13 17 18 16 7 7 10 12 Percent Change2 Dec. 2018 from Nov. 2018 ...... 6.9% 4.1% S 10.5% ‐7.7% 0.0% 12.0% 9.1% 2.1% 1.7% 19.0% 10.0% . 90 percent confidence interval 3 ...... ± 6.6 ± 7.2 X ± 8.4 ± 11.3 ± 11.7 ± 8.3 ± 14.9 ± 10.6 ± 10.6 ± 9.6 ± 9.4 Dec. 2018 from Dec. 2017 ...... 17.6% 16.1% S 20.0% ‐20.0% 0.0% 21.7% 20.0% 27.6% 24.5% 11.1% 0.0% . 90 percent confidence interval 3 ...... ± 9.3 ± 9.3 X ± 15.1 ± 17.2 ± 32.3 ± 32.6 ± 21.8 ± 16.3 ± 13.6 ± 9.0 ± 14.2

Table 2b ‐ Not seasonally adjusted United States Northeast Midwest South West Period 2 to 4 5 units Total 1 unit units or more Total 1 unit Total 1 unit Total 1 unit Total 1 unit 2017 December ...... 153.4 80.1 1.9 71.4 15.2 5.2 20.1 8.0 73.8 45.9 44.2 21.0

2018 January ...... 157.5 85.8 2.9 68.7 13.6 5.6 21.5 8.5 77.9 48.9 44.4 22.8 February ...... 157.9 86.9 2.4 68.6 13.6 6.5 22.9 10.3 78.0 48.8 43.4 21.3 March ...... 164.9 93.9 2.8 68.1 14.0 7.0 24.7 11.8 82.0 53.9 44.2 21.2 April ...... 164.7 91.1 2.1 71.4 11.6 6.8 26.9 13.8 83.8 50.0 42.5 20.5 May ...... 165.7 92.8 1.9 71.0 14.4 7.5 25.4 12.8 81.8 49.7 44.1 22.8 June ...... 173.6 95.4 1.6 76.6 15.0 8.0 26.0 13.2 88.1 51.8 44.5 22.4 July ...... 171.2 94.4 2.1 74.8 16.2 8.2 24.0 11.2 86.3 52.9 44.7 22.1 August ...... 171.7 95.4 2.2 74.1 15.5 7.6 25.6 12.8 87.2 52.5 43.4 22.6 September ...... 165.9 89.2 2.2 74.5 12.4 7.3 24.5 10.4 89.6 52.1 39.4 19.4 October (r) ...... 162.4 88.4 1.8 72.2 12.4 6.4 23.8 10.2 90.1 55.0 36.1 16.8 November (r) ...... 166.7 92.5 2.0 72.2 11.4 5.9 24.3 9.6 90.7 58.2 40.2 18.8 December (p) ...... 183.1 94.5 2.1 86.5 12.5 5.9 24.8 10.0 95.6 57.2 50.2 21.4 . Average RSE (%) 1 ...... 6 6 26 10 13 17 18 16 7 7 10 12 p Preliminary r Revised S Does not meet publication standards because tests for identifiable and stable seasonalilty do not meet reliability standards X Not applicable 1 Average relative standard error for the latest 6‐month period 2 Computed using unrounded data 3 See the Explanatory Notes in the accompanying text for an explantion of 90 percent confidence intervals Note: These data represent the number of housing units authorized in all months up to and including the last day of the reporting period and not started as of that date without regard to the months of original permit issuance. Cancelled, abandoned, expired, and revoked permits are excluded.

Source: U.S. Census Bureau and U.S. Department of Housing and Urban Development, New Residential Construction, February 26, 2019. Additional information on the survey methodology may be found at .

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 91 of 123 New Privately‐Owned Housing Units Started (Thousands of Units. Detail may not add to Barcode:3927394-02total because of rounding.) C-570-118 INV - Investigation -

Table 3a ‐ Seasonally adjusted annual rate United States Northeast Midwest South West Period 2 to 4 5 units Total 1 unit units or more Total 1 unit Total 1 unit Total 1 unit Total 1 unit 2017 December ...... 1,210 847 S 359 88 49 170 124 594 443 358 231

2018 January ...... 1,334 886 S 435 116 62 145 122 684 474 389 228 February ...... 1,290 900 S 372 132 65 154 109 615 476 389 250 March ...... 1,327 882 S 431 120 61 182 140 630 440 395 241 April ...... 1,276 898 S 357 96 57 160 105 669 516 351 220 May ...... 1,329 938 S 379 106 65 239 157 652 496 332 220 June ...... 1,177 851 S 316 104 70 164 113 564 446 345 222 July ...... 1,184 861 S 317 103 67 178 135 624 456 279 203 August ...... 1,280 890 S 373 99 66 187 118 657 477 337 229 September ...... 1,237 879 S 349 141 60 171 129 568 444 357 246 October (r) ...... 1,209 863 S 327 91 73 186 121 592 426 340 243 November (r) ...... 1,214 812 S 387 107 64 144 113 670 446 293 189 December (p) ...... 1,078 758 S 302 107 51 125 97 630 456 216 154 . Average RSE (%) 1 ...... 6 5 X 13 17 16 12 10 8 7 10 9 Percent Change2 Dec. 2018 from Nov. 2018 ...... ‐11.2% ‐6.7% S ‐22.0% 0.0% ‐20.3% ‐13.2% ‐14.2% ‐6.0% 2.2% ‐26.3% ‐18.5% . 90 percent confidence interval 3 ...... ± 14.0 ± 15.3 X ± 18.9 ± 28.1 ± 23.0 ± 26.8 ± 22.8 ± 23.4 ± 26.3 ± 15.7 ± 14.7 Dec. 2018 from Dec. 2017 ...... ‐10.9% ‐10.5% S ‐15.9% 21.6% 4.1% ‐26.5% ‐21.8% 6.1% 2.9% ‐39.7% ‐33.3% . 90 percent confidence interval 3 ...... ± 16.1 ± 14.7 X ± 25.3 ± 45.8 ± 32.5 ± 31.8 ± 25.0 ± 29.8 ± 26.4 ± 13.3 ± 10.7

Table 3b ‐ Not seasonally adjusted United States Northeast Midwest South West Period 2 to 4 5 units Total 1 unit units or more Total 1 unit Total 1 unit Total 1 unit Total 1 unit 2017 Annual ...... 1,203.0 848.9 11.4 342.7 111.4 62.0 179.6 130.2 598.7 453.0 313.2 203.8 2018 Annual (p) ...... 1,246.6 872.8 14.0 359.7 110.4 64.1 171.8 123.1 628.9 463.9 335.4 221.8 . RSE (%) ...... 2 1 22 6 5 6 3 2 2 2 3 2 Year to year percent change² ...... 3.6% 2.8% 23.5% 5.0% ‐0.9% 3.4% ‐4.3% ‐5.5% 5.0% 2.4% 7.1% 8.8% . 90 percent confidence interval 3 ...... ± 2.1 ± 1.8 ± 31.5 ± 6.2 ± 6.8 ± 9.2 ± 4.9 ± 4.4 ± 2.8 ± 2.3 ± 4.4 ± 3.8 2017 December ...... 81.4 55.1 0.3 26.1 6.2 3.4 10.1 6.8 40.4 29.4 24.7 15.5

2018 January ...... 91.6 59.9 0.9 30.8 7.5 3.6 7.2 5.5 50.8 36.0 26.1 14.8 February ...... 89.7 62.4 1.2 26.1 8.1 3.4 8.1 5.0 45.6 35.9 27.9 18.1 March ...... 107.2 72.5 1.1 33.5 9.2 4.6 12.9 9.6 52.4 37.6 32.7 20.8 April ...... 117.5 85.1 1.8 30.6 8.7 5.3 15.1 10.3 61.4 48.3 32.4 21.1 May ...... 123.7 88.7 1.0 33.9 9.9 6.2 24.0 16.6 59.0 45.0 30.9 20.9 June ...... 112.0 83.5 0.8 27.7 10.2 7.2 16.4 11.9 52.8 42.5 32.6 21.8 July ...... 111.9 81.8 0.6 29.5 10.1 6.7 17.9 14.0 57.2 41.5 26.6 19.6 August ...... 113.8 80.8 1.4 31.6 8.9 6.1 16.7 10.9 58.4 43.2 29.7 20.5 September ...... 109.7 75.0 0.9 33.8 13.2 5.3 16.7 12.7 48.3 36.3 31.5 20.8 October (r) ...... 105.7 74.9 1.7 29.1 8.7 7.2 17.9 12.2 50.6 35.8 28.4 19.8 November (r) ...... 92.2 59.1 1.3 31.8 8.6 5.0 11.8 9.2 49.8 31.4 22.0 13.4 December (p) ...... 71.7 49.0 1.3 21.4 7.4 3.4 7.1 5.0 42.7 30.4 14.6 10.2 . Average RSE (%) 1 ...... 6 5 45 13 17 16 12 10 8 7 10 9 p Preliminary r Revised S Does not meet publication standards because tests for identifiable and stable seasonalilty do not meet reliability standards X Not applicable 1 Average relative standard error for the latest 6‐month period 2 Computed using unrounded data 3 See the Explanatory Notes in the accompanying text for an explantion of 90 percent confidence intervals

Source: U.S. Census Bureau and U.S. Department of Housing and Urban Development, New Residential Construction, February 26, 2019. Additional information on the survey methodology may be found at .

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 92 of 123 New Privately‐Owned Housing Units Under Construction at End of Period (Thousands of Units. Detail may not add to Barcode:3927394-02total because of rounding.) C-570-118 INV - Investigation -

Table 4a ‐ Seasonally adjusted United States Northeast Midwest South West Period 2 to 4 5 units Total 1 unit units or more Total 1 unit Total 1 unit Total 1 unit Total 1 unit 2017 December ...... 1,105 497 S 598 185 52 154 82 445 230 321 133

2018 January ...... 1,117 502 S 604 189 53 152 82 452 233 324 134 February ...... 1,119 503 S 605 189 52 152 80 451 234 327 137 March ...... 1,125 508 S 606 185 53 156 83 450 231 334 141 April ...... 1,123 515 S 596 181 53 153 82 454 240 335 140 May ...... 1,126 519 S 595 182 54 156 83 453 242 335 140 June ...... 1,120 518 S 590 187 57 154 82 448 241 331 138 July ...... 1,118 522 S 584 187 59 154 83 450 242 327 138 August ...... 1,125 520 S 592 188 60 154 82 450 238 333 140 September ...... 1,132 524 S 596 190 60 154 82 451 239 337 143 October (r) ...... 1,137 529 S 595 187 61 153 81 458 242 339 145 November (r) ...... 1,141 529 S 599 186 62 151 80 465 241 339 146 December (p) ...... 1,144 534 S 597 187 63 152 81 473 246 332 144 . Average RSE (%) 1 ...... 3 3 X 6 8 7 6 6 3 4 6 6 Percent Change2 Dec. 2018 from Nov. 2018 ...... 0.3% 0.9% S ‐0.3% 0.5% 1.6% 0.7% 1.3% 1.7% 2.1% ‐2.1% ‐1.4% . 90 percent confidence interval 3 ...... ± 1.0 ± 1.2 X ± 1.6 ± 1.2 ± 1.7 ± 2.1 ± 2.8 ± 2.0 ± 1.9 ± 1.2 ± 2.2 Dec. 2018 from Dec. 2017 ...... 3.5% 7.4% S ‐0.2% 1.1% 21.2% ‐1.3% ‐1.2% 6.3% 7.0% 3.4% 8.3% . 90 percent confidence interval 3 ...... ± 3.5 ± 3.9 X ± 5.2 ± 9.8 ± 14.6 ± 7.6 ± 7.8 ± 5.8 ± 5.4 ± 5.5 ± 6.0

Table 4b ‐ Not seasonally adjusted United States Northeast Midwest South West Period 2 to 4 5 units Total 1 unit units or more Total 1 unit Total 1 unit Total 1 unit Total 1 unit 2017 December ...... 1,080.5 476.5 10.4 593.7 184.6 52.1 151.8 80.6 431.0 217.5 313.1 126.3

2018 January ...... 1,088.5 476.2 10.5 601.9 186.8 51.4 146.6 77.3 438.9 220.8 316.3 126.7 February ...... 1,090.7 477.5 11.2 602.0 186.2 50.3 146.6 74.7 439.0 223.0 318.9 129.5 March ...... 1,102.4 486.6 11.3 604.5 182.5 50.9 150.6 77.4 441.6 223.2 327.6 135.2 April ...... 1,119.2 508.3 12.0 598.8 180.5 52.2 148.7 77.6 454.8 239.1 335.1 139.4 May ...... 1,135.5 522.9 11.9 600.6 183.1 53.9 156.6 82.4 457.7 244.7 338.1 141.9 June ...... 1,135.8 531.2 11.8 592.8 187.7 57.2 157.2 84.7 455.3 247.7 335.7 141.6 July ...... 1,143.3 545.7 11.7 585.9 189.3 60.5 158.1 87.5 461.6 253.0 334.3 144.7 August ...... 1,141.4 542.6 12.4 586.4 189.3 62.2 156.5 85.2 457.7 248.0 337.9 147.2 September ...... 1,150.5 544.9 11.9 593.7 191.5 61.9 156.3 84.9 460.2 248.7 342.5 149.4 October (r) ...... 1,151.9 544.1 12.6 595.2 189.5 63.4 157.0 84.7 462.6 247.3 342.8 148.7 November (r) ...... 1,149.7 534.1 12.9 602.7 188.0 62.9 155.9 84.1 465.3 240.5 340.5 146.6 December (p) ...... 1,117.7 510.2 13.2 594.2 185.8 62.1 150.2 79.3 457.7 232.2 323.9 136.6 . Average RSE (%) 1 ...... 3 3 16 6 8 7 6 6 3 4 6 6 p Preliminary r Revised S Does not meet publication standards because tests for identifiable and stable seasonalilty do not meet reliability standards X Not applicable 1 Average relative standard error for the latest 6‐month period 2 Computed using unrounded data 3 See the Explanatory Notes in the accompanying text for an explantion of 90 percent confidence intervals

Source: U.S. Census Bureau and U.S. Department of Housing and Urban Development, New Residential Construction, February 26, 2019. Additional information on the survey methodology may be found at .

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 93 of 123 New Privately‐Owned Housing Units Completed (Thousands of Units. Detail may not add to Barcode:3927394-02total because of rounding.) C-570-118 INV - Investigation -

Table 5a ‐ Seasonally adjusted annual rate United States Northeast Midwest South West Period 2 to 4 5 units Total 1 unit units or more Total 1 unit Total 1 unit Total 1 unit Total 1 unit 2017 December ...... 1,197 837 S 347 115 65 175 120 614 461 293 191

2018 January ...... 1,218 859 S 348 114 60 169 132 596 445 339 222 February ...... 1,289 882 S 400 138 69 160 129 655 462 336 222 March ...... 1,229 862 S 356 150 65 154 108 595 467 330 222 April ...... 1,257 797 S 447 144 53 196 126 613 408 304 210 May ...... 1,251 875 S 364 90 49 169 140 673 472 319 214 June ...... 1,216 867 S 342 76 47 170 119 610 452 360 249 July ...... 1,195 829 S 360 108 49 183 129 594 452 310 199 August ...... 1,230 939 S 286 90 48 205 148 649 534 286 209 September ...... 1,148 835 S 304 117 59 175 127 560 436 296 213 October (r) ...... 1,111 820 S 282 90 53 178 124 542 419 301 224 November (r) ...... 1,128 789 S 327 133 62 138 110 545 441 312 176 December (p) ...... 1,097 790 S 296 81 49 131 107 555 412 330 222 . Average RSE (%) 1 ...... 5 5 X 15 20 15 10 9 7 8 9 9 Percent Change2 Dec. 2018 from Nov. 2018 ...... ‐2.7% 0.1% S ‐9.5% ‐39.1% ‐21.0% ‐5.1% ‐2.7% 1.8% ‐6.6% 5.8% 26.1% . 90 percent confidence interval 3 ...... ± 10.0 ± 14.0 X ± 25.6 ± 20.5 ± 22.7 ± 22.8 ± 16.8 ± 17.7 ± 20.3 ± 23.4 ± 32.0 Dec. 2018 from Dec. 2017 ...... ‐8.4% ‐5.6% S ‐14.7% ‐29.6% ‐24.6% ‐25.1% ‐10.8% ‐9.6% ‐10.6% 12.6% 16.2% . 90 percent confidence interval 3 ...... ± 12.2 ± 14.1 X ± 23.0 ± 22.1 ± 16.2 ± 18.7 ± 17.7 ± 19.9 ± 23.2 ± 20.9 ± 22.9

Table 5b ‐ Not seasonally adjusted United States Northeast Midwest South West Period 2 to 4 5 units Total 1 unit units or more Total 1 unit Total 1 unit Total 1 unit Total 1 unit 2017 Annual ...... 1,152.9 795.3 10.7 346.9 115.7 59.0 172.3 120.5 594.7 435.5 270.3 180.4 2018 Annual (p) ...... 1,191.7 844.3 9.1 338.3 108.7 54.5 169.2 124.8 596.7 449.9 317.2 215.1 . RSE (%) ...... 2 1 24 7 6 4 4 3 3 2 4 2 Year to year percent change² ...... 3.4% 6.2% ‐14.9% ‐2.5% ‐6.1% ‐7.5% ‐1.8% 3.6% 0.3% 3.3% 17.4% 19.3% . 90 percent confidence interval 3 ...... ± 3.8 ± 2.5 ± 25.3 ± 11.5 ± 12.9 ± 7.8 ± 6.1 ± 4.5 ± 5.1 ± 3.6 ± 7.2 ± 5.5 2017 December ...... 113.4 82.4 1.2 29.8 10.5 6.2 16.9 12.2 58.5 45.3 27.6 18.7

2018 January ...... 84.0 59.8 0.7 23.5 8.0 4.4 11.1 8.6 42.3 32.1 22.6 14.7 February ...... 88.6 61.3 0.4 26.9 8.7 4.1 10.0 8.0 46.8 33.8 23.0 15.4 March ...... 94.9 67.1 0.8 27.0 11.0 4.6 10.8 7.3 47.6 37.9 25.5 17.3 April ...... 94.7 61.0 0.9 32.8 10.2 3.5 15.0 9.9 46.6 31.6 22.9 16.0 May ...... 105.7 74.1 1.0 30.6 7.7 4.2 14.2 11.7 56.7 39.9 27.1 18.3 June ...... 108.6 75.6 0.7 32.2 7.5 4.8 14.7 9.9 53.6 38.7 32.7 22.2 July ...... 101.9 67.6 0.5 33.7 9.5 3.9 15.9 10.8 49.9 36.6 26.7 16.3 August ...... 113.9 83.6 0.5 29.9 8.5 4.1 19.5 13.6 59.8 47.8 26.2 18.1 September ...... 100.9 72.7 0.8 27.3 11.0 5.8 16.4 12.0 47.3 36.1 26.2 18.7 October (r) ...... 100.2 75.5 0.8 23.9 8.4 5.3 17.1 12.5 47.7 37.2 27.1 20.5 November (r) ...... 94.7 68.7 1.0 25.0 11.0 5.5 12.0 9.8 46.0 38.0 25.8 15.4 December (p) ...... 103.7 77.2 1.0 25.5 7.2 4.5 12.7 10.6 52.4 40.0 31.4 22.1 . Average RSE (%) 1 ...... 5 5 39 15 20 15 10 9 7 8 9 9 p Preliminary r Revised S Does not meet publication standards because tests for identifiable and stable seasonalilty do not meet reliability standards X Not applicable 1 Average relative standard error for the latest 6‐month period 2 Computed using unrounded data 3 See the Explanatory Notes in the accompanying text for an explantion of 90 percent confidence intervals

Source: U.S. Census Bureau and U.S. Department of Housing and Urban Development, New Residential Construction, February 26, 2019. Additional information on the survey methodology may be found at .

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 94 of 123 Barcode:3927394-02 C-570-118 INV - Investigation -

EXHIBIT I-24

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 95 of 123 Barcode:3927394-02 C-570-118 INV - Investigation -

A Fifth of China's Homes Are Empty. That's 50 Million Apartments

B bloomberg.com/news/articles/2018-11-08/a-fifth-of-china-s-homes-are-empty-that-s-50-million-apartments economics

Bloomberg News

November 8, 2018, 4:00 PM EST Updated on November 8, 2018, 8:37 PM EST

• Risk is potential for flood of sales during any property slump

• Xi has said homes are for living in, not for speculation

0:14

Property Policy Is Most Important for China, Nomura's Lu Says

Lu Ting, chief China economist at Nomura International, discusses China's economy and policies.

Chinese President Xi Jinping's mantra that homes should be for living in is falling on deaf ears, with tens of millions of apartments and houses standing empty across the country.

Soon-to-be-published research will show roughly 22 percent of China's urban housing stock is unoccupied, according to Professor Gan Li, who runs the main nationwide study. That adds up to more than 50 million empty homes, he said.

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 96 of 123 Barcode:3927394-02 C-570-118 INV - Investigation -

EXHIBIT I-25

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 97 of 123 Barcode:3927394-02 C-570-118 INV - Investigation -

FEDERAL RESERVE BANK OF KANSAS CITY | SEPTEMBER 12, 2018

How Much Would China’s GDP Respond to a Slowdown in Housing Activity?

, Data Scientist, , Senior Economist, and , Senior Data Scientist

We analyze China’s interindustry connections and show that China’s housing activity has become increasingly important to its GDP growth. Our results suggest that a 10 percent decline in nal demand for real estate and housing-related construction would lead to a decline in total output of 2.2 percent, an eect more than two times larger than it would have been 10 years ago.

China’s real estate sector has undergone rapid growth over the last two decades. Real estate investment grew at about a 20 percent average annual rate from 1999 to 2018, more than twice the rate of GDP growth over the same period. The strong growth in housing activity was driven by two sources of strong demand. The rst source was the housing reform in China in the late 1990s, which gradually moved Chinese households from public housing to private housing, generating huge housing demand (called “rigid demand” or “gang xu” in Chinese). The second source was fast growth in house prices combined with a lack of other nancial investment opportunities, which spurred enormous speculative demand in the Chinese housing market.

However, demand from both sources has weakened recently. By 2013, about 20 percent of Chinese households already owned multiple houses.1 Additionally, the share of Chinese young people age 20 to 29, the main source of new demand for housing, started to decline in 2014. Furthermore, the Chinese government has tightened control on speculative investment in the housing market since 2017 amid growing concerns that high house prices are pushing up the costs of doing business and restricting consumer spending. The recent intense debate in China on introducing a property tax has put further downward pressure on the Chinese housing market.

In response to this weakening demand, year-over-year investment growth in real estate development excluding land purchases—a measure that focuses on real estate construction, installation, and equipment purchases—has dropped by more than 10 percentage points from about 8 percent in the middle of 2017 to −4 percent in July 2018 (Chart 1). In addition, housing construction, measured by growth in the oor space of buildings under construction, has dropped from a double-digit pace to a pace close to zero, while growth in the oor space of

completedFiled By: buildings [email protected], has turned negative Filed (Chart Date: 2). 1/7/20 10:23 PM, Submission Status: Approved Page 98 of 123 / Chart 1: Growth in Real Estate Investment (Excluding Land Purchases) Barcode:3927394-02 C-570-118 INV - Investigation - Year-over-year percent change Year-over-year percent change 40 40

30 30

20 20

10 10

0 0

-10 -10 2013 2014 2015 2016 2017 2018

Investment in real estate development (excluding land purchases), YTD Source: Wind Information Company, Ltd. Chart 2: Growth in Construction Activity Year-over-year percent change Year-over-year percent change 40 40

30 30

20 20

10 10

0 0

-10 -10

-20 -20 2005 2008 2011 2014 2017

Floor space of buildings under construction, YTD Floor space of buildings complete, YTD (six-month moving average) Source: Wind Information Company, Ltd.

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 99 of 123 / With shrinking demand and an oversupply of houses, housing activity is likely to slow further Barcode:3927394-02 C-570-118 INV - Investigation - in the longer run. How, then, will China’s GDP respond? To answer this question, we examine how dierent industries are connected to housing activity using an input-output (IO) table, which reports a given industry’s total output as well as how much of other industries’ output it uses.

Chart 3 illustrates connections between industries based on a simplied version of China’s IO table in 2012 (the latest version available). For the purpose of illustration, we group 139 industries into ve sectors: construction, real estate, manufacturing, nancial and professional, and other. Housing activity is reected in both the real estate sector and the construction sector.2 The relative size of each node (green dot) shows the relative size of total output in each sector. The arrows on the blue lines indicate the direction of the ow of output from one sector to another, and the width of the lines shows the relative size of that output. For example, the thin line connecting the manufacturing sector to the construction sector shows that the construction sector used 8.3 percent of the manufacturing sector’s output in 2012. In comparison, the thick line connecting the “other” sector to the manufacturing sector shows that the manufacturing sector used 34.6 percent of output in other sectors. Together, these connections suggest that an exogenous decline in construction activity, for example, may lower demand for the manufacturing sector, which, in turn, may cause demand for other sectors to decline. Chart 3: A Simplied Version of China’s Input-Output Table in 2012

8.3%

Construcon

34.6% Manufacturing Real estate

14.4%

6.3% Other 25.8%

Financial and professional

Sources: National Bureau of Statistics of China and authors’ calculations.

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 100 of 123 / To estimate the eect of a decline in housing activity on total output, we follow Cook, Nie, and Barcode:3927394-02 C-570-118 INV - Investigation - Smalter Hall (forthcoming) and estimate the response of all industries using IO tables. In particular, we map values from an IO table into a system of linear equations and use them to compute the dynamics in all variables due to changes to variables related to housing activity.3 Chart 4 shows the eect of a 10 percent decline in housing activity on China’s total output over a 10-year horizon.4 The blue line is calculated using the most recent IO table in 2012, and the green and gray lines are calculated using IO tables in 2007 and 2002, respectively. The chart reveals two major ndings. First, the negative eect on China’s total output is quite persistent and dissipates gradually after 10 years. Second, the eect has become much larger in more recent years, suggesting that the housing market has become more important to China’s economic growth over time. Chart 4: Response of Total Output Following a 10 Percent Decline in Housing Activity Decline in total output(percent) Decline in total output(percent) 0.6 0.6

0.5 0.5

0.4 0.4

0.3 0.3

0.2 0.2

0.1 0.1

0.0 0.0 1 2 3 4 5 6 7 8 9 10 Year 2002 2007 2012 Sources: National Bureau of Statistics of China and authors’ calculations.

Chart 5 shows the growing eect of the housing sector by summing the yearly estimates from the three IO tables in Chart 4. Each green circle in the chart shows the total eect of a 10 percent decline in housing activity on China’s total output based on interindustry relationships within a given year. For example, the green circle for 2012 shows the total eect as 1.33 percent, suggesting the accumulated decline in China’s total output over the next 10 years would be around 1.33 percent of the current year’s output. A polynomial function that ts all three estimates suggests that by 2018, the total eect could increase to 2.2 percent. In other words, our analysis suggests that if current housing activity declines by 10 percent, the total decline in China’s output over the next few years could be around 2.2 percent of 2018 GDP.

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 101 of 123 / Chart 5: Total Eects of a 10 Percent Decline in Housing Activity Barcode:3927394-02 C-570-118 INV - Investigation - Decline in total output (percent) Decline in total output (percent) 2.5 2.5

2.0 2.0

1.5 1.5

1.0 1.0

0.5 0.5

0.0 0.0 2002 2007 2012 2017 Year Sources: National Bureau of Statistics of China and authors’ calculations.

Finally, it is important to note that the above estimate assumes a 10 percent decline in housing activity. In reality, the size of the decline will depend on the extent to which the Chinese government acts to stabilize the housing market. Historically, the government has often intervened in the housing market. For example, in response to declines in house prices in 2014, local governments loosened restrictions on home purchases, and the central bank lowered mortgage rates for second-home buyers. In addition, the government-sponsored Shantytown Renovation Program, which oered cash compensation to residents whose homes were demolished, supported home prices in small cities in the last two years, largely explaining why the growth of house prices in these cities has not slowed as much as in big cities in China. Although Chinese authorities have recently attempted to cool the housing market, they are likely to reverse these policies and institute new interventions if the housing market becomes a signicant drag on the Chinese economy.

1According to the Survey and Research Center for China Household Finance, the vacancy rate of sold residential homes in urban areas reached 22.4 percent in 2013. 2In a typical IO table for China, the construction sector includes real estate construction. However, the IO table does not explicitly separate real estate construction from other types of construction. In the analysis, we assume all investment in real estate development excluding land purchases turns into xed capital, and thus use the share of xed capital formation related to the real estate sector in total xed capital formation in the construction sector to approximate for the share of housing-related construction in total construction. 3Miller and Blair (2009) provide an excellent review of input-output models. 4In general, we can write an IO table in the form of x = Z*i + f, where x (a vector) refers to output from different industries, Z shows the input from one industry to other industries, i refers to the total intermediate input from different industries, and f is the nal demand representing demand from consumers, governments, and foreign investors. In this exercise, we assume nal demand (the components in f related to real estate and part of construction) declines by 10 percent. The shares of construction we estimate to be related to real estate constructionFiled By: are [email protected], 46.3 percent, 34.7 percent, and Filed 23.3 Date: percent 1/7/20 in 2012, 10:23 2007, PM, andSubmission 2002, respectively. Status: Approved Page 102 of 123 / References Barcode:3927394-02 C-570-118 INV - Investigation - Cook, Thomas, Jun Nie, and Aaron Smalter Hall. Forthcoming. “An Inter-industry Analysis of China's Housing Market and the Macroeconomy.” Federal Reserve Bank of Kansas City, Research Working Paper. Miller, Ronald E., and Peter D. Blair. 2009. Input-Output Analysis: Foundations and Extensions, second edition. Cambridge: Cambridge University Press.

Thomas Cook is a data scientist, Jun Nie is a senior economist, and Aaron Smalter Hall is a senior data scientist at the Federal Reserve Bank of Kansas City. The views expressed are those of the authors and do not necessarily reect the positions of the Federal Reserve Bank of Kansas City or the Federal Reserve System.

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 103 of 123 / Barcode:3927394-02 C-570-118 INV - Investigation -

EXHIBIT I-26

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 104 of 123 Barcode:3927394-02 C-570-118 INV - Investigation - THE WORLD BANK IBRD • IDA

Where We Work This page in: EN v

The World Bank In Bra5il

Bra5il's economic and social progress between 2003 and 2014 lifted 29 million people out of poverty and inequality dropped significantly. Restoring fiscal sustainability is the most pressing economic challenge for Bra5il.

BRAZIL HOME OVERVIEW

Overview

CONTEXT STRATEGY RESULTS

Brazil experienced a period of economic and social progress between 2003 and 2014, when more than 29 million people left poverty and inequality declined significantly. The Gini coefficient dropped 6.6% (from 58.1 to 51.5) during that time. The income level of the poorest 40% of the population increased by an average of 7.1% (in real terms) between 2003 and 2014, compared to a 4.4% increase in income for the population as a whole. Since 2015, however, the pace of poverty and inequality reduction seems to have stagnated.

In the wake of a strong recession, Brazil has been going through a phase of highly depressed economic activity. The country's growth rate has been slowing since the beginning of the decade, from an annual growth rate of 4.5% (between 2006 and 2010) to 2.1%

(between 2011 and 2014). FiledThere By: was [email protected], a significant contraction Filed in economicDate: 1/7/20 activity 10:23 PM,in 201 Submission 5 and 2016, Status: with Approved the GDP dropping by 3.6% Page 105 of 123 and 3.4% (respectively). The economic crisis Barcode:3927394-02was a result of falling C-570-118 commodity INV - Investigation prices and the- country's limited ability to carry out necessary fiscal reforms at all levels of government, thus undermining consumer and investor confidence. 2017 saw the beginning of a slow recovery in Brazil's economic activity, with 1.1% of GDP growth in 2017 and 2018 - largely because of a weak labor market, investments deferred by uncertainties about the elections and the truckers' general strike, which brought economic activities to a halt in May of 2018.

Restoring fiscal sustainability is the most pressing economic challenge for Brazil. To address the dynamics of unsustainable debt, the government has enacted Constitutional Amendment 95/2016, which limits the rise of public spending. This amendment imposes a fiscal adjustment of 4.1% of GDP through 2026 and stabilizes the debt at about 81.7% of GDP in 2023. Implementing this fiscal adjustment requires reducing the rigidity of public spending and revenue-earmarking mechanisms, which make more than 90% of the federal government's primary spending mandatory.

A comprehensive social security reform was sent to the Congress in February and has been approved by the lower house in August. The reform is expected to generate accumulated savings of 9 percent of GDP until 2030 and, combined with the spending rule, it would stabilize the general government gross debt at around 81.7 percent of GDP by 2023. This large-scale fiscal imbalance also affects subnational governments, whose inclusion in the reform is still on discussion. Their capacity to handle increasing wage and pension payments will be limited in the absence of reforms.

Brazil also needs to accelerate productivity growth and infrastructure development. The average income of Brazilian citizens has increased only 0.7% per year since the mid-1990s, which is one tenth of the rate in China and half the OECD average. This can be explained by a lack of Total Factor Productivity (TFP) growth between 1996 and 2015. Brazil's productivity problem can be attributed to the absence of an adequate business environment, distortions created by market fragmentation, several support programs for companies that have yet to yield any results, a market that is relatively closed to foreign trade and little domestic competition.

Brazil also features one of the lowest levels of infrastructure investment (2.1% of GDP) in comparison to its peers, and the quality of these investments is low. Accelerating productivity growth remains one of the country's top priorities, as the demographic transition comes to an end and the fiscal space for expansionary policies remains severely limited. Higher investments in infrastructure will also be required to ensure proper maintenance of existing infrastructure, by eliminating bottlenecks and expanding access to social services. This will require improving the government's planning capacity, improving the regulatory framework and leveraging private resources to finance investments.

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 106 of 123 A comprehensive diagnosis was produced byBarcode:3927394-02 the Bank's technical C-570-118 team INVin -July Investigation 2018, containing - a summary of Brazil's primary challenges in economic and social development and pointing to a possible course of action to overcome them. This material is entitled Public Policy Notes and is available for consultation on the World Bank website. It covers the following topics: stabilization and fiscal adjustment, the tax system, intergovernmental fiscal issues, the pension reform, the State reform, productivity, credit markets, infrastructure, education, logistics & transportation, the labor market, ways to address the violence epidemic, climate change (NDC) and water resources management.

Last Updated: Oct 14, 2019

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EXHIBIT I-27

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 110 of 123 Barcode:3927394-02 C-570-118 INV - Investigation - BUSINESS RECORDER Foundcti. M Brazil's real to stay soft

By RECORDER REPORT on January 6,2020

Brazil's real will trade not far off record lows into the new year, receiving eventual support from a tentative economic recovery after months of unconvincing macro performance that has dragged the currency down, a Reuters poll showed.

The real was seen at 3.97 per dollar in 1 year, implying a 5.5% appreciation from Wednesday but a 1.8% drop compared to the forecast in November's survey, according to the median view of 27 strategists polled Dec. 2-4.

Brazil's currency fell to a record low of 4.26 against the US dollar in late November and is trading not far above that rate now. Economists in the survey pegged it at 4.195 per dollar in one month and 4.10 in three months. "Our models still suggest a fair value for the BRL around 4.00/4.10," said Flavio Serrano, chief economist at Haitong Brasil. "Faster growth should boost investment", he added, which would aid the battered currency "somewhat."

The real rose slightly this week following the announcement of the strongest quarterly gross domestic product (GDP) growth since early last year, driven by a solid performance in agriculture and a sharp rebound in industry.

However, an overall slow economy has hurt the currency as President Jair Bolsonaro's reforms, focused on macroeconomic goals, have so far failed to materialize big capital spending plans, notably in the oil sector.

Tensions over welfare spending cuts and the environment have also weighed. Still, Latin America's top economy looks safe from the ructions that are rippling through other markets in the region.

Policy easing to boost growth has been another source of foreign exchange weakness. Brazil's central bank stands ready to lower its interest rate by another 50 basis points to a fresh record low of 4.50%, its president said this week.

The currency has lost almost 8% in 2019 and is set to close its 8th year in the red since the decade started,

a persistentFiled depreciationBy: [email protected], that aroused USFiled President Date: 1/7/20 Donald 10:23 Trump'sPM, Submission anger Status:this week. Approved Page 111 of 123 Brazil's real to stay soft I Business Recorder BUSINESS With protectionist worriesBarcode:3927394-02 centered in other C-570-118 places INV for - Investigationthe time being, - the survey reflected a relatively RECORDER stable prospect for the Mexican peso. The currency's 1-year median forecast was 19.73 per dollar, inside recent ranges.

Lately it has been falling slowly towards 20 per dollar after two months of gains in September-October, amid growing caution about the chances of ratifying a continental trade deal this year due to resistance by some US Democrats.

And, as in Brazil, lower "carry trade" rate differentials are a factor too. "The peso will maintain a weak performance mainly due to erosion of carry and volatility associated with external premiums," Banorte wrote in a report this week.

In line with many emerging market countries, Mexico's central bank is leaving the door open to future rate cuts, resulting from weaker than anticipated economic activity and cooling inflation.

But contrary to the pesos of Argentina, Chile, and Colombia, Mexico's currency is finishing 2019 basically at the same level where it started, the 4th year in a row it will close near 20 per dollar despite some episodes of volatility.

A similar narrative could have applied for Chile's currency, but an outbreak of mass protests in October changed everything and now the peso is forecast to trade at 750 per dollar in 12 months, very close to today's depressed levels.

As Chile descended into chaos, Argentina was enacting strict capital controls to avoid further international reserve losses over political fears. In practice, these emergency steps froze the interbank value of the peso, halting months of depreciation.

Estimates for the currency showed an unusually calm trajectory at the start of 2020. The peso has also kept its composure in parallel markets, where it could be more reactive once a newly-elected Peronist government announces its plans.

Copyright Reuters, 2020

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EXHIBIT I-28

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Blog Brazilian Lumber Exports Increase to Meet North American Demand

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October 11,2018 Lumber Prices

Author: Marcelo Schmid

Share f V. in

Brazilian lumber exports have followed a similar trend as exports from other countries over the last

decade, which is to say they have slowly crept back up after tanking in the wake of 2008. The US housing

market is the primary driver of global lumber flows, and the Great Recession of 2008 had a lingering,

widespread effect on these flows, as well as the local markets where lumber is produced in volume. In

many areas, current production remains far below pre-recession levels. In the case of Brazil, however,

production has been steadily rising and is on course to return to pre-2008 levels.

Since the Filedworst By:of [email protected],the international financial Filedcrisis Date:began 1/7/20 to abate 10:23 in PM,2011, Submission Brazilian Status:sawmills Approved increased Page 114 of 123 capacity and exports have Barcode:3927394-02increased 63 percent C-570-118 (8.5 percentINV - Investigation annually) in -value, and 108 percent (13 percent annually) in volume. The Brazilian lumber sector closed 2017 with shipments of $665 million, which is still below pre-recession levels.

Figure 1 - Brazilian lumber exports, 2007 - 2017

2.0

•_ E 05 200

0.0 0 , f\;) ro, (0 G, ,

Ton - USD FOB

Source: Secretariat of Foreign Trade (SECEX), adapted by Forest2Market do Brasil

The states of Parana and Santa Catarina are the primary exporters of Brazilian lumber (Figure 2). These states both contain large areas of planted pine and are thus home to a number of sawmills that rely on these dense stands of pine logs as a raw material.

Figure 2 - Main exporting states of Brazilian lumber

Rio Grande do Sul 8.8%

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved 1\ Page 115 of 123 Barcode:3927394-02 C-570-118 INV - Investigation - Grosso r ----Ot -mato 5.7%

Parani 32.1% Ot her 16.4%

Santa Catarina 37.0%

Source: Secretariat of Foreign Trade (SECEX)

The primary single destination for Brazilian lumber in 2017 was the United States, which imported more than 419,000 tons—just over 500 million board feet (MMBF). Unlike the domestic Brazilian market, lumber and other sawn wood products are highly valued by the US construction and homebuilding sectors. For the purposes of comparison, it's worth noting that this Brazilian volume is roughly the same as two modern, high-capacity southern yellow pine (SYP) sawmills, which are capable of producing 250-350

MMBF annually. The overall size and scale of the US market is tremendous; it is on pace to consume nearly 50 billion board feet in 2018.

Figure 3 - Main export markets for Brazilian lumber

Filed By: [email protected], Filed Date: 1/7/20 10:23 PM, Submission Status: Approved Page 116 of 123 Barcode:3927394-02 C-570-118 INV - Investigation -

Vietnam 7.2%

Source: Secretariat of Foreign Trade (SECEX)

The primary drivers of the continued surge in Brazilian lumber exports include:

. Increased foreign demand primarily from North American and Europe directly linked to the construction and homebuilding industries. • A favorable exchange rate for exporters; current rates as of this writing are RS4.20/USS1. . North American trade policies: The US's imposition of tariffs on Canadian lumber imports (as well as some Chinese wood products, i.e. plywood and panels) has opened up the market to other global suppliers.

With the slow, steady upward performance of both the US and European housing markets and the continuing evolution of global trade disputes, the Brazilian lumber industry is poised to grow by filling gaps in supply. Economists predict that the exchange rate should remain high (above R$3.8/US$1), which favors Brazilian exporters. However, Brazil is in an election year and if recent history is to be a guide, it would be wise to maintain a certain level of caution; political discord has a way of impacting everything from economic development to exchange rates.

Continued demand for the pine resource in Parana and Santa Catarina will cause log prices to increase in the near term, especially with the contentious trade negotiations taking place in North America.

Brazilian lumber producers in these regions must monitor the political situations both at home and abroad in order to properly time their exports and maximize their profit margins.

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