I_
`
`_. . .-
`
`October 13, 1995
`
`By Messenger
`
`(202) 955-8508
`
`66296-000 16
`
`IWFiLIC DIEPECTION VERSION
`
`Husrness Propnetam Information Deleted
`fron P the Enclosed Response to
`Cornmi ssiaixrs' Questions
`
`Secretary
`U.S. International Trade Commission
`500 E. Street, S.W.
`Washington, DC 20436
`
`Re: Circular Welded Carbon Quality Line Ripe
`Inv. No. TA-201-70
`__ . - - - - - -
`
`Dear Secretary Koehnke:
`
`5
`c 7?
`
`f
`C
`CB
`c
`
`On behalf of Kawasaki Steel Corporation, Ntppon Steel :orp<wation, NKK
`Corporation, and Sumitomo Metal Industries, L,td. (colledvelv. "Japamese Respondents")
`and the Korean Iron and Steel Association, Dongbu Steel Co., Ltd., Hyundai Steel Pipe,
`SeAH Steel Corporation, and Shinho Steel Corporation (crdlectbrely , '"Korean Respondents"),
`we hereby submit an original and four copies of the public inspec1 ion vcrsion of the Responses of
`Japanese and Korean Respondents to Questions of Chaimm Bragg and Commissioner Askey.
`We have served all parties on the Commission's public serwce IYST as indicated in the attached
`Certificate of Service.
`
`

`
`October 13, 1999
`Page 2
`
`In accordance with 19 C.F.R. 0 201.8 (19!W), we have deimed pncp~etary business
`information contained in brackets in the attached matmals. Disclt! sure ckf that information,
`which contains business proprietary information of thc Japamese artdl Korean Respondents and
`information released to counsel under administrative protsctive ortfer, would cause substantial
`harm to the parties that supplied the information.
`
`Please contact us if you have any questions.
`
`Very truly yours,
`
`A
`
`,
`J
`
`(p
`
`k p k f ~ . Price
`awasaki Sted Corporation,
`Nippon Steel Corporation, NKK Corporation,
`and Sumitorno Metal Industries, Ltd.
`
`(4 orean Iron and S w l Association,
`
`J lie C. Mencbza
`
`Dongbu Steel, Co., Hyunclai Steel Pipe,
`SekH Steel Corporation, ;md Shinho Steel
`Cc )rpora tron
`
`WA992860.014
`
`

`
`CIRCULAR WELDED cmBor4 QUALITY LME PIPE
`INV. NO. TA-201 70
`
`PUBLIC CERTIFlCATE OF SERWCE
`
`I hereby certify that a copy of the foregoing submission dated October 13, 1999, was
`
`served by messenger on the following parties:
`
`Counsel for Petitioners:
`
`Counsel flor St~lco, Inc. and Steelpipe Inc.:
`
`Roger B. Schagrin, Esq.
`SCHAGRIN ASSOCIATES
`1100 Fifteenth Street, N.W.
`Suite 700
`Washington, D.C. 20005
`
`Counsel for British Steel Plc.; and British
`Steel Inc.:
`
`Sherry I. Gilman, Esq.
`STEPTOE & JOHNSON
`1330 Connecticut Ave., N.W.
`Washington, D.C. 20036-1795
`
`Counsel for Mitsui & Co. (USA), Inc.:
`
`Kenneth G. Weigel, Esq.
`Laura Fraidrich, Esq.
`KIRKLAND & ELLIS
`655 15th Street, N.W.
`Washington, D.C. 20005
`
`Chtistc~phcr Dmm, Eat.
`WILLFCIE, F M R , AND GALLAGHER
`115’5 2lst Street, N.W.
`Washirigtrm, 1I.l:. 2W36-3384
`
`Counsel for Barusan Boru Birlesik
`Fahrikalari; and Mannesmann Boru
`Endus trisi:
`
`Arthur J. Lafave, Esq.
`DI(.’KSTE IN, SHAPIRO, MORIN AND
`OSHDJSE:Y, 1119
`2101 L Street, h.W.
`Washingtrm, D.C. 20037-1526
`
`Counsel for 1\113IP Mannesmann Praezisrohr
`Gmhh and Maninesmiann Pipe and Steel
`C0H.p.::
`
`Guritei von Conrad, Esq.
`BARKES FUC’HARDSON & COLBURN
`1225 €ye Street N.W
`Suite I150
`Washitiglnn, I1.C 20005
`
`

`
`Counsel for C.A. Conduven:
`
`Julie A. Mendoza, Esq.
`KAYE, SCHOLER, FIERMAN, HAYS, AND
`HANDLER, LLP
`901 Fifteenth Street, N.W.
`Suite 1100
`Washington, D.C. 20005-2327
`
`Counsel for Hylsa, S.A. de C.V.; Tubacero,
`S.A. de C.V.; Tluberias Procarsa, S.A. de
`C.V.; and Tukria Laguna S.A. de C.V.;
`Tubcria Nacimal, 5.-4. de C.V.:
`
`Mit:hael J Chapman. Esq.
`SHE4IWAN & STERLING
`801 I-’emaylvan a Avenue. N.W.
`Suite 900
`Wasllinggm, 11.1 :. 2W04-2604
`
`Behalf of the Government of Canada:
`
`Mr. J.P. Gombay
`Counselor (Economic)
`CANADIAN EMBASSY
`501 Pennsylvania Ave., N.W.
`Washington, D.C. 20001
`
`October 13, 1999
`
`WA992170.0241
`
`

`
`CERTIFICATION
`
`I, Joseph H. Price, of Gibson, Dunn & Crutcher U P certifv that:
`
`(1) I have read the enclosed submission and ated thai to the best of my knowledge
`the facts stated therein are true and accurate;
`
`(2) Business Proprietary Information brackettcd in the enclosed submission is not
`available to the public in substantial form; and
`(3) In accordance with 19 C.F.R. 4 20L6 (2999), we request confidential treatment
`of information contained in brackets in the enclosed submussion. Disclosure of that
`information, which contains business proprietary information of Japanese Respondents and
`information released to counsel under admiiistrative grsaectiw orda ("NO"), would
`cause subsiantial harm to the parties that supplid t~c: anamation. " h e bracketed
`information concerns capacity, production, and sales data, as wdl as infomation provided
`to us under APO, and cannot be meaningfully summarized.
`
`%c>Gsel 'LO Kawasaki Steel Corporation,
`Nippon htecl Zqoration,
`P K K Chpporaticln and
`Sumif omo Metal Industries, Ltd.
`
`DISTRICT OF COLUMBIA ) SS:
`Subscribed and sworn to before me this
`the 12th day of October, 1999.
`
`My Commission Expires: g&d 3 4 2& t-
`My Conznissio~~ wires April 30,2032
`
`WA992850.024
`
`

`
`CERTIFICATION
`
`I, Julie C. Mendoza, of Kaye, Scholer, Fiman, Hays and Handler, LLP, certify
`
`that:
`
`(1) I have read the enclosed submission and a&& that tt the best of my knowledge
`the facts stated therein are true and accurate;
`
`r
`
`(2) Business Proprietary Information bracketed in the enclosed submission is not
`available to the public in substantial form; and
`(3) In accordance with 19 C.F.R. 6 201.6 (1999), we mquest confidential
`treatment of idormation contained in brackets in the endosed submiwion. Disclosure of
`that information, which contains business proprietary infixmation ~f Korean Respondents
`and information released to counsel under administrative prof active order {-'APO"),
`would cause substantial hann to the parties that supplied the information. The bracketed
`information concerns capacity, production, and sales data, as well as iriformation provided
`to us under APO, and cannot be meaningfully summruizbd.
`
`Association, Dongbu Steel Co., Ltd.,
`Myundai Steel Pipe, ScAH Steel
`C'orpmation, and Shinho Steel
`
`DISTRICT OF COLUMBIA ) SST
`
`Subscribed and sworn to before mefis
`the 12th day of October, 1999.
`
`My Commission Expires: @://<, 2/2.1---
`My Commission Expire? April :?2? 2'1172
`
`WA992760.028
`
`3
`
`

`
`PUBLIC VERSION
`Proprietary Information
`leleted from Brackets
`
`Business Proprietary Information
`Deleted from Pages 1,3, 5-8, 10
`and from Exhibit 1
`
`BEFORE THE IJNITELI sr~'r13s
`
`INTERNATIONAL IRAPIE COMMf SSION
`
`In the Matter of:
`
`CIRCULAR WELDED CARBON
`QUALITY LINE PIPE
`
`.- - . __
`
`1
`1
`
`)
`1
`
`In fesiigatiorr Number: TA-20 1-70
`
`RESPONSES OF JAPANESE AND KC IREAV RESPONDENTS
`
`TO QUES'I'IO N S OF
`
`CHAIRMAN BRAGG AND COMiMISSIONEK ASKEY
`
`Joseph H. Price
`Daniel J. Plaine
`Gracia M. Berg
`Merritt R. Blakeslee
`John Christopher Wood
`
`GIBSON, DUNN & CRUTCHER LLP
`1050 Connecticut Avenue, N. W.
`Washington, D.C. 20036
`(202) 955-8500
`
`Counsel for Japanese Respondents
`
`October 13, 1999
`
`1 > 31- ald €3 Cameron
`J u lib: C. Mendoza
`3 d,lv $5'. Mills
`I. IvkGarr, Trade Consultant
`P, 12
`
`K i J E , StYHOLER, FIERMAN,
`! ISLYS &, HANDLER LLP
`9112 Fifteenth Street, N.W.
`M ai hingtm, D.C. 20005
`{2d, 682 -3500
`
`' m nsel ft )r Korean Respondents
`
`

`
`PUBLIC VERSION
`Proprietary Information
`r Ieleted from Brackets
`
`This submission is filed jointly on behalf of the Japamse anti Korean Respondents
`
`(hereinafter sometimes collectively referred to as the "Respondents"' 1. It rcsponds to the additional
`
`questions raised by Chairman Bragg and Commissiorler Askey and submitted in writing to the
`
`parties to the Section 201 investigation on circular wclded cx-bon qualitv line pipe ("welded line
`
`pipe") on October 5, 1999. Responses were requested to be filed by October 12, 1999.
`
`QUESTIONS AND RESPONSE&
`
`1.
`
`(A) Question: If a party intends to seek an exrlusim for arctic line pipe from the
`scope of any proposed remedy, please provide a specifics definition of arctic line pipe.
`
`Response: The Japanese Respondents made clear in their prehearing brief that 'I(t}he
`
`domestic industry does not manufacture Arctic grlide wejded line iiipe" itnd that [
`
`j
`
`-:hearing Brief of
`
`Japanese and Korean Respondents at 53 (September 2!4, 1999) (citing [
`I (hereinafter "Joint
`
`Respondents' Prehearing Brief"). As a result, the Japanese P.espaiidents pointed out that their
`
`Arctic grade welded line pipe did not compete with, and the -efore was not a cause of injury to,
`
`the U.S. domestic welded line pipe industry. - See _ . Joint Resrondmts' Prdiearing Brief at 61-63.
`
`At the hearing, Mr. Rusty Fisher of Lone Star Sttel, sperrk-ng on behalf of the Petitioners,
`
`stated that the domestic industry was "familiar with the Ardic grade, and we concede on the
`
`Arctic grade." See Transcript of USITC Hearing, Seliteniber 30, 1 999, at 130 (hereinafter "Tr."). -
`
`Petitioners' counsel, Mr. Schagrin, also advised the Cominirsion that '%e agree with the arctic
`
`claims by the Japanese." - Tr. at 129.
`
`

`
`PUBLIC VERSION
`f roprietary Information
`Meted from Brackets
`
`Following the hearing, Mr. Schagrin submitted a lett'x tc8 the Canmission on behalf of
`
`the Petitioners in which he declared that "we amend the scq)e ot tYie pet,tion as expressed on
`
`pages one and two of the petition" in order to add the Ebllowing laiguagx
`
`Specifically excluded from the scopc is: Line pipe inrported lor use in
`Alaska made to the Arctic grades specified b~ oii and 5 as producers as
`well as pipeline and utility companies operatin; ir Alssl a. Arctic grade
`line pipe is that intended for use in teinpu;ittsirek; of minus 50 degrees
`Fahrenheit and below.
`
`Letter from Roger B. Schagrin to Donna R. Kodinke dat1:d October 9, 1999 at 1 ("Schagrin
`
`Letter"). Mr. Schagrin added that I' {p} etitioners do not belicve F h,it end use certification will be
`
`necessary" and that " {p)roducers and users recoynize thr special t :sting, and uses connoted by
`
`the term 'Arctic grade."' - Id.
`
`The Japanese Respondents believe that nt was appropriate lor MI. Schagrin to amend the
`
`scope of his petition to exclude Arctic grades of welded line pipe. liccordingly, they have nothing
`
`further to add at this time.
`
`1.
`
`(B) Question: If a party intends to seek an ewluslan for m y other type of line
`pipe from the scope of any proposed remedy, plersse provide :I specific definition of
`such product(s).
`
`Response: As the Japanese Respondents made c leas. in I hcir pos t-hearing brief, "imports
`
`of non-Arctic grade line pipe from Japan are concentrated ir high-strenp th grades and sizes that
`
`are rarely produced by the domestic industq." F'ost-lloaring Brie'. of Japanese and Korean
`
`Respondents at 49 (October 6, 1999) (hereinafter "Joint Respondents' Post-Hearing Brief"). The
`
`Japanese Respondents are continuing to develop infomatiai on these specialty welded line pipe
`
`products and, if this case reaches the remedy phase, may well s e d exclusions for one or more of
`
`

`
`PUBLIC VERSION
`Proprietary Information
`11 Meted from Brackets
`
`such products. At this time, however, they do not haw silfficient infonnation to provide specific
`
`definitions for any such products.
`
`Korean Respondents do not seek any exciusions from thtb scope of this investigation or
`
`from any proposed remedy, should the Commission rcilc5 tE at issue. Kcrean Respondents have
`
`pointed out that a substantial portion of their exDorts ,ire Juel stenciled and, as such, used for
`
`standard pipe applications. In their opinion, such dual stmcil p h ~ r has no effect on the welded
`
`line pipe industry.
`
`1.
`
`(C) Question: If a party intends to seek ari t:xdusim for either arctic line pipe or
`any other type of line pipe from the scope of miy proposed remedy, please provide
`specific data regarding the volume of exports uf such merchandise to the United
`States and/or the volume of imports of such merchandise intu the United States (to
`the extent such data are available to the party).
`
`Response: The volume of Japanese exports of Arctic gricie welded line pipe was
`
`addressed in Joint Respondents' Post-Hearing Brief. Using the da;a supdied in Japanese
`
`Producers' Questionnaire Responses, exports of Arctic gradt: weldzd linc pipe to the United
`
`States during the period of investigation was as follows:
`
`- See Joint Respondents' Post-Hearing Brief at 48. As noted in the Japancse Producers' Question-
`I.
`
`naire Responses, these tonnages were of [
`
`Foreign Producers'/Exporters' Qu. Resp. at 5A. Pursuani to the -equesl of Commission
`
`investigator Valerie Newkirk, the Japanese Respondents will be pr.oviding quantity and value
`
`

`
`PUBLIC VERSION
`Proprietary Information
`leleted from Brackets
`
`data specifically corresponding to the Petitioners' description of A'ctic grade welded line pipe
`
`contained in the Schagrin Letter.
`
`1.
`
`(D) Question: If a party intends to seek ail exdusion for either arctic line pipe or
`any other type of line pipe from the scope of any proposed remedy, please address the
`extent to which it is analytically consistent for the Cornmission to include imports of
`such merchandise in its assessment of serious injmry (ar threat thereof) to the
`domestic industry, but to then exclude such mt:rdiantiiese from the scope of any
`proposed remedy (if the question of remedy is reached). How is the instant
`investigation distinguishable in this regard from the t went safeguard investigation
`of Certain Steel Wire Rod (Inv. No. TA-201-69), if at all'h
`
`Response: Subsequent to the submission of tlm qur stiox counsel for the Petitioners
`
`filed a letter with the Commission amending thc petition to cxclxk Araic grade welded line
`
`See Schagrin I ,etk:r a;l rd discussion under Response to
`pipe from the scope of this investigation. __
`
`Question 1 .(A). Accordingly, imports of Arctic grade wcldrd line pipe should not be considered
`
`by the Commission in its assessment of serious injuq (or threat thereoil The situation in this
`
`case, where the petition has been amended to exclude Arctic grak pipe prior to the
`
`Commission's injury determination is clearly distinguish;tblk: from the situation in the recent
`
`safeguard investigation of Certain Steel Wire Rod ~ . - (Inv No. TA-201-691. In the latter situation,
`
`there was no amendment to the petition and petitioners sought trl have wrtain specialty steel wire
`
`rod items (tire cord quality wire rod, pipe wrap quality u ire rod, and valve spring quality wire
`
`rod) included for injury consideration but excluded for rc medy purposes
`
`1.
`
`(E) Question: If a party intends to seek an exrlusian for either arctic line pipe
`or any other type of line pipe from the scope of any proposed remedy, please
`provide an assessment of whether subject iinporl&-nor -
`
`inchding imports of any
`-
`such "excluded" merchandise-are being imported hito the lJ.S. in such increased
`quantities as to be a substantial cause of serious Bijury. or threat thereof, to the
`domestic industry.
`
`_I
`
`

`
`PUBLIC VERSION
`F roprietary Information
`I leleted from Brackets
`
`Response: When Arctic grade and non subjelzt aIlo3, welded line pipe are excluded from
`
`the Japanese import quantities, there clearly is no surge in Japanem impons. In fact, as previously
`
`noted, " {t)hose imports declined by 41 percent from 1094 tu 19OE." Joint Respondents' Post-
`
`Hearing Brief at 43. As a result, increased inipoi-ts from Japan cannot bi: a cause of serious
`
`injury, or threat of serious injury, to the domestic weldcd line pine industry.
`
`2.
`
`Question: Please discuss the extent ta which you belicm average unit values are a
`reliable proxy for price in this investigation, and why.
`
`Response: Average unit values (''AUVs") arc: not a reliable proxy for price in this
`
`investigation for two reasons. First, as explained in Joint Rtspoiu: ents' Post-Hearing Brief, the
`
`primary problem with A W data is that changes in product mix awve a tremendous impact on
`
`A W s . That distortion is inherent in the nature of'thc tlal a base. The pmblem is particularly
`
`acute in this investigation, in which the subject merchandise encannpasscs a wide range of outer
`
`diameters, wall thicknesses, and quality grades. In particular, the lmpon product mix has shifted
`
`significantly over the POI, with increasing quamities of i mports from &)rea entered as line pipe.
`
`- See Joint Respondents' Post-Hearing Brief at 6 1-62.
`
`Second, the Commission has better surrogate price data ;iv iilabk. - Le., __ the average
`
`domestic and import values provided by [
`
`] and Ittac ht:d as 13xhibits 15 and 16 to the
`
`Joint Respondents' Post-Hearing Brief. Contrary to Petitioners' st;itemmts in their Post-Hearing
`
`Brief (pp. 2-3; 36-37), Respondents did not use f
`
`1. Rather,
`
`as explained at pages 62-63 of Joint Respondents' Post -€$ e a ing Brief, 1
`
`ii
`
`

`
`PUBLIC VERSION
`Proprietary Information
`I leleted from Brackets
`
`The [
`
`] data are the most complete and a:cur;itr. pricing information available
`
`to the Commission. They provide complete product i:ovi:rq:e, rdher than being limited to the six
`
`products investigated by the Commission, which only account firr approximately 19.4 percent of
`U.S. producers’ shipments and 8.7 percent of imports in 1995. I N Staft’Report at 1-76.
`3 data provide monthly prices Tot- ths entire period of investigation and
`
`Moreover, [
`
`enable the Commission to compare domestic and import prices in the same size range. The data
`
`also are separated between standard and line pipe. It should i3e not :d thaa the data - consistent
`
`with the pricing data collected by the Commission - show tiat ~n~..rgins of underselling narrowed
`
`in the second half of 1998-early 1999, not widened as Petitioner; ;issen.
`
`3.
`
`Question: I note that on pages 142-143 of the herring $ranscript, counsel for
`Petitioners argues that the Commission should consider. whether imports from
`Mexico pose a threat of serious injury, apart front dererminbg that all other
`imports are a substantial cause of present serious injury to the domestic industry.
`
`For Respondents: If you disagree with this arqumenr, please provide legal authority
`and analysis in support of your position.
`
`Response: Respondents have no comments on his question, which pertains exclusively
`
`to imports from Mexico.
`
`Additional Question from Commissioner Askey:
`
`Commissioner Askey would like to know morc about how the welded line pipe
`market is divided up between naturai gas and p d r o l w n uses. For example, there
`was testimony that because there is little petroleum inaustrv use for welded line pipe
`on the West Coast, Korean dual-stenciled pipe mist he used for standard purposes.
`Conversely, other testimony suggested that such pipe bnn the West Coast would be
`used for natural gas transportation purposes. Cin petcentages be provided
`indicating how much is used for gas vs. petrolmni end uses, both regionally and
`
`

`
`PUBLIC VERSION
`Pfoprietary Information
`I deted from Brackets
`
`nationally? Have usage patterns changed over the POI'? If so, how and why? Any
`data and further discussion of this issue that couh1 be provided would be helpful.
`
`Response: In their Post-Hearing Brief at Exhibit 3, Respondents provided a breakdown
`
`between transmission and distribution (which in fact is v:rtu.dly di transmission) and gathering
`I.
`
`for 2/38" - 16" OD carbon steel welded line pipe prepared b:'
`
`[
`
`Those data are based upon the size, weight and grade of 1)ipt [
`
`] and on imported pipe, I-Jnlike tht: data supnlied hy Petitioners in
`
`Exhibits 6, 7, 9, and 20 of their Post-Hearing Brief, &,e Respondmts' data are confined to carbon
`
`steel welded line pipe under 16" only - they do not include larg,ec diameter pipe, they do not
`
`include seamless pipe or plastic pipe, and they do not include standard ope.
`3 gathers the information from pipz pi odicer:; and importers for [
`1. His percentages are based on the size and grade of the pipe
`
`[
`
`[
`
`.] The welded line pipe was ciasstfiec: as traJEsmission/distribution on
`
`the one hand and gathering on the other according to the foDowiq::
`
`X-65 high strength and above is welded linc pipc used for transmission lines;
`
`5LB, X-42, and X-46 are welded line pipe uscd for gat iering lines
`
`0
`
`0
`
`] states in his Facsimile massap:, virtually all pipe
`0 Finally, as [
`used in distribution is "standard pipc"' hec;msc: distrih ion u ithin City
`Gate does not require high pressure applicatic ns.
`
`The tonnage and the calculation of the percen;agt:s are attached as Exhibit 1.
`
`Transmission and distribution
`
`Primary and secondary gathering
`
`7
`
`

`
`PUBLIC VERSION
`Proprietary Information
`I :rileted from Brackets
`
`Respondents have used the information horn I
`
`] Obtaining the exac-. bred.outs requested by
`
`Commissioner Askey is impossible within the tirnefranie The fd.owinsr is a brief summary of
`
`the information we received as part of our attempt to obtain ;Ihe I eciuested data.
`
`Leon Smith (regarding oil) and Rick Hofhan (resarhg gas) of the Federal Energy
`
`Regulatory Commission confirmed that their agency cioea; m t compile si atistics for the breakouts
`
`of the data requested by Commissioner Askey. Regal ding oil, Lam Sm th confirmed that almost
`
`all of the welded line pipe under 16" would be used for pathcrim: iiear the wells.1 He explained
`
`oil is not distributed by pipe; it is generally distributed by tnick or in certain limited
`
`circumstances by barge. The transmission (also called mainlina 01 trunk line) of oil generally
`
`requires 16" or larger pipe, and the gathering of oil near the wellhead uscs pipe of under 16".
`
`There are exceptions to this principal, but he thoiight the exceptims were very uncommon. He
`
`pointed out that in the 1970's, the trunkline used smaller ip:, but this has changed since that
`
`time and now the pipe used for transmission is much larger.
`
`Roger Little, Data Analyst, Office of Pipeline Safety, Depxtmert of Transportation,
`
`confirms that their agency does not have the data and "to thc beEt of his knowledge there is no
`
`source for the data." DOT collects statistics on pipelines bur the data inr:ludes seamless pipe and
`
`excludes petroleum products and data on natural gas rn rilrd are i s
`
`1 These government employees of course cannot speak far- the Crovemment. Mr. Smith's
`opinion regarding the use of welded line pipe is his own opiidr)n, based on his experience.
`
`

`
`PUBLIC VERSION
`Piroprietary Information
`X >eleted from Brackets
`
`Warren R. True, Chief Technology Editor, Pipeline/Gas Pr xessing Editor, Oil and Gas
`
`Journal, stated that the Journal does not collect infomiation nm p1.p :s tha1 would allow the
`
`breakouts requested by the Commission. Jeff Share, Ediior, Pipcli
`ne & Gas Journal, confirms
`
`-
`
`I
`
`-
`
`-
`
`I
`
`-
`
`
`
`the Pipeline & Gas Journal does not have the available statistics. Ile did explain that: (1) pipe
`
`used for distribution of natural gas is generally made dplasiic aim (2) mainline transmission is
`
`of pipe 24" or larger. Larry Engles, Engineering Sen ice:; Direct 01, American Gas Association,
`
`confirmed that his association does not collect the requested data. Ann Roland, Vice President of
`
`Communications, Interstate Natural Gas Association ~dlmcrica. I he association dealing with
`
`transmission pipes between states, confirmed that her associatioai does nut have the data. She
`
`further confirmed that gas transmission pipes are "generally ab0 &'e 1 h inches."
`
`The primary problem is that no one break.s o u usi: ir form tion solely for subject
`
`merchandise. This is the problem with Petitioners' data as nrell. While Petitioners purport to
`
`have presented the data requested regarding the sources of demami, Petitioners' data, in fact, do
`
`not break down the sources of demand for subjcct merchmdise.
`
`Distribution: According to Petitioners' Post-€[easing Bri 2J Exhibits 6, 7, and 9, natural
`
`gas distribution constitutes a significant end use for welded line pipe. 'fhis is incorrect. While a
`
`significant portion of total pipe is for distribution, mc'st c f it is nai-subicct pipe. The second
`
`& (31s Journal
`page of the 1998 Planning Guide from the Ppeline
`-
`
`_ _ I
`
`~
`
`(Exhibit 9 of Petitioners' Post-
`
`Hearing Brief) states as follows concerning Gas Disb ihuiiori Utili ies:
`
`"Industry estimates indicate the U.S. gas distrihitiort system contains
`1.6 million miles of piping, of which 900,000 milesq ii ma& of steel,
`70,000 miles of cast iron and about 500,000 aiilee c f mostly poly-
`ethylene (PE) pipe."
`
`

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`PUBLIC VERSION
`Proprietary Information
`iwleted from Brackets
`
`As [
`
`] states in his mcmo, distr buthi systems require low
`
`rather than high pressure applications. (See - Joint Respondents' I'bst-Hearing Brief, Exhibit 3).
`
`Hence, plastic and cast iron are substitutes for pipe used in the dstributicm system precisely
`
`because that pipe is for low rather than high pressure app tications Moreover, because the
`
`systems are under low pressure, almost all of the steel pipe within [he "City Gate" is standard
`
`PlPe.
`
`Transmission: According to Petitionersa Post-He,tring BI it f Exhibits 6, 7, and 20, pipe
`
`for transmission represents 20 percent of the installed ba.*e of natural giE* pipelines. While
`
`Petitioners' data does distinguish between under 16" and ovc'r 1 C
`I' oipe in the aggregate, these
`
`data do not distinguish between under and over 16" pipe used in tritmnission. In fact, the bulk
`
`of the miles included in "transmission" is over 10'* OD. 111 addition. virtually all of the "offshorett
`
`transmission is seamless - not welded - line pipe and as such is not subject merchandise.
`
`

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`PUBLIC VERSION
`Pwprietary Information
`1; ieleted from Brackets
`
`Kt SPE ctfull'r submitted,
`
`,ti' ie (2. hlendoza
`%ad3 W. hlills
`': ul J . McCrarr, Trade Consultant
`LYE, SC H( ILER, b'IERMAN, HAYS
`L. HANELJ~,R U P
`Ct 8un.fel f ~ i y Koredin Respondents
`
`_-
`
`Gracia M. Berg
`Merritt R. Blakeslee
`John Christopher Wood
`GIBSON, DUNN & CRUTCHER LLP
`Counsel for Japanese Respondents
`
`

`
`Public Version
`Proprietary Information
`Deleted from Brackets
`
`Exhibit 1
`
`

`
`Puolic Version
`Proprietary Information
`Deleted from Brackets
`
`

`
`P lsolic Version
`Proprietary information
`Deleted from Brackets
`
`

`
`Public Version
`Froprietary Information
`Deleted from Brackets
`
`

`
`Public Version
`Proprietary Information
`Deleted from Brackets
`
`1
`
`Servica Centers, North America
`I A I B I ,C I I! I P I E I 9 I E I I I I I W I h I 241 I! I 0 I
`A
`A & P Allow, Inc.
`Ace_Steel. Inc*
`
`I Q I 1s I T I U I v I W I Y I2 I
`
`F C - 0 Metals. Inc.
`
`Art h a Inc.
`A3A Allow hc.. CANADA
`Ashley Metals, h.
`A h Ideal Mctalr. CANAD&
`Atlas Steel Products Co.
`Aveat. Sheffield Inc.. CA&4DD
`AZCO Steel Company - Aetec $tc_l corp.
`B
`
`Page 1 of 9
`
`Baldwin Steel Company
`Banner Service Corporarion
`
`

`
`Public Version
`Proprietary Information
`Deleted from Brackets
`
`Bannu Service Corporation
`Basstt Indu&cs,&.
`Ben-co
`Bellesteel
`-.
`hduslrics,.Ipc.
`.St.&ff...
`Bcnedict-Miller. he.
`Bcnjqnin S-1 C a any, Tne.
`Bernscn lncomo rata!
`Berlin Metals Inc.
`B h c k Steel Company
`Sing StteI,,LLC
`Th.e Bisrctt Stcel Company
`Bloch Steel 1nduSaic-s
`. Block iron 0 Suuu1y,Co
`Bl*k Steel CorPoraLlan
`Bobco Merals, LLG
`Bomnann Steel &n~anv
`Bridftmort Steel com a=
`Bnnsb !&d-fiO~-&A.DA
`B r ~ ~ n - C a m bell ComDPny
`~ * * u l o n
`Brown-Straust Steel
`The Bl~nalrrm Cpmpan~
`Burnon Tool Stccl Co. inc.
`C
`
`:Division_ --
`
`'sft
`
`of - .-
`
`

`
`Public Version
`Proprietary Information
`Deleted from Brackets
`
`D
`
`F
`
`F z q t Staj Co oration
`Jpsah P. Pazzio.%c.
`Ftdenl Pi c &.Steel Corparatinn
`F d E O l d i i O l l
`F_erallov Nonh Amaican Steel CQ
`F e r p n Metals
`Ferro Union, Inc. A Macstcr! Service Cmkn LiSA G .
`Fidelity Stainless Ltd.. CANADA
`A. F M & SonsBppany
`Fust Metals IJIC.
`Fisher Bros. Stnl Cornoration
`k 1. ForsVth & Co. Ltd.. CA”
`2.5
`Fox Metals and Allo&I&
`mcncks-. GlE- -.2
`Friendswoad Metals & Specialty
`Stl COT.
`&*.-
`F StetlCo am
`G
`
`Cdvmct, Inc.
`General Pur~ose Steel, Inc.
`General Steel Co.
`Galzink steel.”
`Fermnj Steel & Tube
`Glazcr Steel & Aluminum Division of Triple-S Steel
`
`

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`Public Version
`Proprietary Information
`Deleted from Brackets
`
`!
`
`~. M ,.*de & c o
`
`Cioldm Industncs. Inc.
`
`H
`
`H_asEih-Stal G.. ID~,
`-= - - -
`Hc3-Division of ESCO
`Hipb Steel Suvice Center, Inc.
`Huntco Steel, Inc.
`
`I
`
`J A F Steel Como~P_n
`Jodc-StdkR steel CO.. be.
`Jemison Steel Comoanv. L.L.C_,
`Josmh T. Rverson & Sog.lnc.-Eg
`Joseph T. Ryerson & SQQ, h e -West
`K
`K ~ I K Steel Comuanv
`Rm-Mz Metals
`
`Glazer S m 9 & Aluminum Division oPTWple S SW
`
`

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`Public Version
`Proprietary Information
`Deleted from Brackets
`
`-
`
`h & m k b L k
`McNichols Cornany
`m l s Steel C0rnDan.y
`Metal Enterunscs
`Metal Sewices International. Inc
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`

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`Public Version
`Proprietary Information
`Deleted from Brackets
`
`0
`
`Pacesetter Steel ScFrice. Inc.
`Pacific M-
`& Tool Steel Co.
`
`.
`
`Quality Flame Curting hc.
`
`

`
`Public Version
`Proprietary information
`Deleted from Brackets
`
`3. hbin'h &mspe.uy
`Russel Metals Inc., CANADA
`Ruse1 Mclllls-Bahcall %up
`Rvmon Tu& Inc.
`PYEF!?&&3--
`Ryerson Co i7 Processing Compgy
`RyersonTh in
`S
`Sabel stwl S&&C
`Sampson Steel Carp.
`Samson Metal ScMcc. Lnc.
`Samuel, Son and Company Ltb, CANADA
`S d t e c l Service Center. hc2
`Schultz Metal Y nnce, b.
`ScheuStm~S 1 c - o s " l v
`Sion Steel
`Scnnon Steel Camoration
`s ~ ~ k s - @ E L ~ s p a e c
`Carp.
`Service Steel Division
`Siozal Steel Comuany
`Slmcoc Steel Lmj?t&C@@~
`Siuncr Steel Company
`Siskin Stctl B; Supgly Co.,
`SkOrr-%! C.Qs.k!C:
`SkYllnt Steel COrD.
`
`

`
`Public Version
`Proprietary information
`Deleted from Brackets
`
`col-Dom_og
`V
`
`Stan)ev Steel S-ce
`tatc Line SUDD~V
`tate Stel s?mplv=y
`SkelInC.
`g-1 Warehouse Comoanv, hi&
`lnc.
`Steel SCIV~CM.
`e Steel S m l v c omp+Y
`- steelca
`ShlinR Steel Orow
`Stewart Staid+ Supply Inc.
`&hb.q Inc.
`Sugu Steel Corporation
`Sullivan Steel& Aluminum
`sun Steel Comumy
`-or
`Steel Supply
`T
`
`rision of Thyssn
`
`Ine.
`UI.
`
`U
`
`V
`
`

`
`,
`
`Public Version
`Proprietary Information
`Deleted from Brackets
`
`W
`
`Y
`. .-..-. Yarde Metals
`Y a k Stscl. Comuanv, In,c..
`
`Zecco Metals lnc.
`
`-
`- hi..
`(216) 694-3636
`Steel Service
`Key Center
`(216) 694-3941CYFax
`Center Institute Suite 2400
`127 Public Square .@n@=,org
`Cleveland Ohio
`M114-1216
`
`..*.
`
`-
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`- I -