Sending Office: Honorable Patrick T. McHenry
This letter is supported by: Strata Solar, Pinegate, O2 Energy, Carolina Solar, EON, Tradewinds, Narenco, Ecoplexus, Coronal, Bird’s Eye Energy, Virginia Solar, Invenergy, Blattner Energy, Patten Energy, NRG, Southern Current,
sPower, EDF, Swinerton Renewables, Recurrent Energy, Minute, Cypress Creek Renewable, RBI Solar, Array Technologies, GameChange Solar, TerraSmart, SunLink Corporation, Solar FlexRack, Schletter, Brilliant Rack, NEXTracker, OMCO Solar, and Attala Steel. The
Solar Energy Industries Association is supportive of ALL exclusion.
Current Signers: McHenry, Hudson, Rouzer, Meadows, Walker, Budd, Knight, Yoder, and Arrington.
Please join Rep. McHenry in sending a letter to the Interagency Group consisting of Trade Ambassador Lighthizer, Sec. Wilbur Ross, and Sec. Rick Perry requesting they exclude 72 cell, 1,500-volt utility-scale solar panels from the safeguard measure
imposed using the Section 201 Trade Case.
“The Procedures to Consider Additional Requests for Exclusion of Particular Products from the Solar Products Safeguard Measure” [Docket No. USTR-2018-0001] provides several factors for which exclusion is acceptable when evaluating requests. We
believe this exclusion is justified based on the benefits of the U.S. solar manufacturing supply chain, the lack of U.S. production, and the findings by the ITC that the utility-scale segment of this industry is “acutely price sensitive”. The exclusion of
this product will preserve tens of thousands of existing solar manufacturing and development jobs, foster market expansion, and allow the U.S. to once again fairly compete in the global marketplace for energy production technologies. Responsible product exclusions
will uphold the integrity of the safeguard measures intended to facilitate positive adjustment to competition from imports of certain crystalline silicon photovoltaic cells.
The deadline to sign will be noon on Friday, May 11th. If you have any questions email firstname.lastname@example.org or call his direct at 28074.
The Honorable Robert Lighthizer
United States Trade Representative
600 17th Street, NW Washington, DC 20006
Dear Ambassador Lighthizer,
We write to express our support for the President’s desire to preserve and increase investment in American solar panel manufacturing capacity. In addition, we appreciate the inclusion in his Proclamation of a process to assess products for exclusion from
the tariff in order to ensure the remedy is targeted to help domestic panel makers while also preventing unintended consequences that could hurt other domestic factories supporting the solar industry and unintentionally harm economic growth.
“The Procedures to Consider Additional Requests for Exclusion of Particular Products from the Solar Products Safeguard Measure” [Docket No. USTR-2018-0001] provides several factors for which exclusion is justified when evaluating requests. We urge the interagency
group to exclude 72 cell, 1,500 volt utility-scale solar panels from this safeguard measure due to this product meeting the following factors stated in the docket:
- Would result in a benefit or advantage to the long-term competitiveness of the solar manufacturing supply chain in the United States;
- Total U.S. production of the particular product for each year from 2014 to 2017;
- Is under development by a U.S. producer who will imminently be able to produce it in marketable quantities.
According to the Solar Energy Industry Association, U.S. solar manufacturing jobs have surged 58% over the last five years, and the growth rate in more than 50 factories throughout the midwest and south has become increasingly associated with the deployment
of a 72 cell, 1500 volt panel, which have never been manufactured in the United States. On the supply chain end, these panels have also created more than 5,700 U.S. manufacturing jobs in the metal racking and tracker industry. Alternative energy markets in
states across the southwest and west present additional opportunities for solar job growth as those states proactively diversify their energy production.
In addition, in 2016, the demand for utility-scale solar panels in the U.S. exceeded 10,000MW, but domestic manufacturing capacity only amounts to 550MW at most, and all of that capacity is currently being used to make higher-margin 1000 volt modules used
in the residential and commercial sectors. No available data indicates there was any production of a 1500 volt module from 2014 to 2017. Furthermore, in the unlikely event that domestic producers would attempt to transition existing operations to lower-margin,
1500 volt modules, production would fall far below marketable quantities.
Other evidence supporting the exclusion of 72 cell, 1500 volt utility-scale solar panels was made public in the International Trade Commission’s investigation No. TA-201-075. This report recognized the utility-scale segment as “acutely price sensitive” because
its pricing is either set at the utilities lowest avoided cost by state Public Service Commissions in regulated markets, or it is the sole base for competition with other integrated forms of generation in deregulated wholesale markets. As such, an increase
of $0.10/MW would significantly reduce private investment for integration of utility-scale solar in electrical grids and utility markets across the country.
We recognize that enforceability is key to the effectiveness of any safeguard measure imposed by the U.S. and to produce the intended result, we must ensure product exclusions do not create loopholes by which importers can circumvent product restrictions.
Customs and Border Protection can easily identify this product by the cell count, wattage (display is currently required on product imports), dimensions, weight, and warrantee.
Based on benefits to the U.S. solar manufacturing supply chain, the lack of U.S. manufacturing of the 72 cell, 1500 volt panel with the inability for U.S. manufacturers to produce marketable quantities, and the finding by the ITC, we urge you to exclude
72 cell, 1500 volt utility-scale solar panels from this safeguard measure. The exclusion of this product will preserve tens of thousands of existing solar manufacturing and development jobs, foster market expansion, and allow the U.S. to once again fairly
compete in the global marketplace for energy production technologies. Responsible product exclusions will uphold the integrity of the safeguard measures intended to facilitate positive adjustment to competition from imports of certain crystalline silicon photovoltaic
We appreciate your consideration of this request, and industry participants in our states stand ready to work with you to support the continued growth of U.S. solar manufacturing.
CC: Secretary Wilbur L. Ross, Jr.
Secretary Rick Perry
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