September 7, 2017 Mail received:

PO Box 283
Southwick MA 01077
Lisa R. Barton PHONE
202.688.5145
Secretary to the Commission
EMAIL
U.S. International Trade Commission cpa@prosperousamerica.org
500 E Street, SW WEB
Daniel DiMicco, Chairman
Fmr CEO, Nucor Corp. Washington, DC 20436 www.prosperousamerica.org
Charlotte, NC

Brian OShaughnessy PUBLIC DOCUMENT

Vice Chairman and
Manufacturing Co-Chair VIA HAND DELIVERY
Revere Copper Products
Rome, NY Re: USITC INV. NO: TA-201-75
Joe Logan
Agriculture Co-Chair Dear Secretary Barton:
Ohio Farmers Union
Ottawa, OH On behalf of the Coalition for a Prosperous America (CPA), we write in
Brad Markell support of the Section 201 petitions filed by SolarWorld and Suniva in the
Labor Co-Chair
AFL-CIO Industrial Union Council International Trade Commissions (Commission) investigation of Crystalline
Washington, DC Silicon Photovoltaic Cells (Whether or Not Partially or Fully Assembled Into
Bill Bullard, Director Other Products).
R-CALF USA
Billings, MT
The CPA is a nonprofit, nonpartisan organization representing the interests of
Bill Parks, Director
NRS 4.1 million households through our agricultural, manufacturing and labor
Moscow, ID
members. We are an unrivaled coalition of manufacturing, agricultural, worker,
Mike Dolan, Director consumer and citizen interests working together to rebuild an America for
Intl Brotherhood of Teamsters
Washington, DC ourselves, our children and our grandchildren. We believe America can provide
Rob Dumont, Director good jobs for workers, affordable goods for consumers, opportunity for farms
TMTA and manufacturers and a clean environment without compromising our national
Farmington Hills, MI
sovereignty and security. Enforcement of trade laws is a priority for our
Marc Fasteau, Director
American Strategic Insurance members.
New York, NY

Burl Finkelstein, Director
Kason Industries
Newnan, GA
Dave Frengel, Director
Penn United Technologies
Saxonburg, PA
John Hansen, Director
National Farmers Union
Lincoln, NE
Kevin Kelley, Director
RTMA
Rochester, NY
Zach Mottl, Director
Atlas Tool & Die Works
Lyons, IL
The CPA is deeply troubled by the recent surge of imports that have all but
devastated the U.S. solar cell and module manufacturing industry. The CPAs
members know all too well the severe impact that destructive import surges can
have on domestic manufacturers, their workers and economic growth. Global
overcapacity is a major challenge across the world as some countries engage in
strategies to overproduce, under consume and excessively rely upon deficit
country consumers (such as the US) for their economic growth. Global
overcapacity caused by persistent surplus countries is a macro economic
problem that effects a large portion of goods production in the US. The steel
and aluminum industries are examples. As the Commissions own data show,
the solar cell and module production industry is also collapsing.

Pam Potthoff, Director Because of large and growing solar overcapacity, largely fueled by China, solar
WIFE
Trenton, NE imports into the U.S. market have more than quadrupled since 2012. The
Stan Sorscher, Director
SPEEA/IFPTE
Seattle, WA
import surge followed the adoption of Chinas 12th Five Year which targeted solar power as a
strategic emerging industry to be developed regardless of market forces.1 The result has been
devastating for the domestic industry. U.S. producers have suffered tremendous financial losses,
declared bankruptcy, and closed facilities. We understand that between 2012 and 2016, nearly 30
U.S. solar manufacturing companies closed their doors. Domestic producer market share
declined. Thousands of workers have lost good paying U.S. manufacturing jobs as a result. That
these severe effects occurred during a period of booming U.S. demand, and despite two
successful solar trade cases, is all the more troubling and simply underscores the urgent need for
trade relief in this case.

We understand that some U.S. installers are concerned that their businesses and US consumers
would lose access to cheap imports. CPAs economic work reveals that excessively ceding
production in exchange for low consumer prices (1) reduces jobs; (2) reduces wages in affected
industries and in affected supply chains and communities; (3) eliminates future innovation; and
(4) forecloses future industries that would otherwise be built from the lost industries. Losing
domestic production also increases the risk of future monopolistic price increases by foreign
producers. Congress recognized, in enacting section 201, that successful economies must balance
production with consumption interests. Excessive reliance upon consumption without sufficient
supply chain production causes economic decline.

America cannot afford to lose another manufacturing industry to imports, particularly one that
combines high-tech and renewable energy like the solar industry. China and other countries have
rightly determined that solar power is a strategic manufacturing and innovation sector. U.S.
producers developed solar technology and have been at the forefront of solar technological
innovation for years. We need to stand up for this industry like we did for semiconductors back
in the 1990s, and keep research and development and critical technological knowhow in the
United States. Indeed, it was trade relief that permitted the U.S. semiconductor industry to stay
on top back then, and it is trade relief that will allow the U.S. solar manufacturing industry to
stay alive and thrive now.

The domestic solar industrys story is one that our members and the Commission have sadly seen
before (severe overcapacity, rising imports, and crushing losses), and one that we will inevitably
see again absent much needed trade relief. An affirmative determination is necessary to prevent
the complete collapse of a critical manufacturing industry, the elimination of future innovation,
wage stagnation and the loss of thousands of good paying U.S. manufacturing jobs.

Sincerely,

Michael Stumo, CEO

1Hearing on Chinas Five-Year Plan, Indigenous Innovation and Technology Transfers, and Outsourcing,
Written Testimony of Willy C. Shih, June 15, 2011.

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