2952 Federal Register / Vol. 63, No. 12 / Tuesday, January 20, 1998 / Notices

clarity of the information to be

collected; and (d) ways to minimize the

burden of the collection of information

on respondents, including through the

use of automated collection techniques

or other forms of information

technology.

Comments submitted in response to

this notice will be summarized and/or

included in the request for OMB

approval of this information collection;

they also will become a matter of public

record.

Dated: January 13, 1998.

Linda Engelmeier,

Departmental Forms Clearance Officer, Office

of Management and Organization.

[FR Doc. 98–1210 Filed 1–16–98; 8:45 am]

BILLING CODE 3510–07–P

DEPARTMENT OF COMMERCE

[A–405–802]

Certain Cut-to-Length Carbon Steel

Plate From Finland; Final Results of

Antidumping Duty Administrative

Review

AGENCY: Import Administration,

International Trade Administration,

Department of Commerce.

ACTION: Notice of final results of

Antidumping Duty Administrative

Review.

SUMMARY: On July 15, 1997, the

Department of Commerce (the

Department) published the preliminary

results of its administrative review of

the antidumping duty order on certain

cut-to-length carbon steel plate from

Finland (62 F.R. 37866). The review

covers one manufacturer/exporter,

Rautaruukki Oy (Rautaruukki), for the

period August 1, 1995 through July 31,

1996.

EFFECTIVE DATE: January 20, 1998.

FOR FURTHER INFORMATION CONTACT:

Heather Osborne or Linda Ludwig,

Enforcement Group III, Import

Administration, International Trade

Administration, U.S. Department of

Commerce, 14th Street and Constitution

Avenue, NW, Washington, D.C. 20230;

telephone (202) 482–3019 or (202) 482–

3833, respectively.

SUPPLEMENTARY INFORMATION:

Background

On July 15, 1997, the Department of

Commerce (the Department) published

in the Federal Register (62 FR 37866)

the preliminary results of its

administrative review of the

antidumping duty order on certain cutto-length carbon steel plate from

Finland (58 FR 44165, August 19, 1993).

The Department has now completed this

administrative review in accordance

with section 751 of the Tariff Act of

1930, as amended (the Act).

Under section 751(a)(3)(A) of the Act,

the Department may extend the

deadline for completion of an

administrative review if it determines

that it is not practical to complete the

review within the statutory time limit of

365 days. On November 3, 1997, the

Department extended the time limits for

the final results in this case. See

Extension of Time Limit for

Antidumping Duty Administrative

Review, 62 FR 60683 (November 12,

1997).

Applicable Statute and Regulations

Unless otherwise stated, all citations

to the Tariff Act of 1930, as amended

(the Tariff Act) are references to the

provisions effective January 1, 1995, the

effective date of the amendments made

to the Tariff Act by the Uruguay Round

Agreements Act (URAA). In addition,

unless otherwise indicated, all

references to the Department’s

regulation are to 19 CFR part 353 (April

7, 1997).

Scope of the Review

The products covered by this

administrative review constitute one

‘‘class or kind’’ of merchandise: certain

cut-to-length carbon steel plate. These

products include hot-rolled carbon steel

universal mill plates (i.e., flat-rolled

products rolled on four faces or in a

closed box pass, of a width exceeding

150 millimeters but not exceeding 1,250

millimeters and of a thickness of not

less than 4 millimeters, not in coils and

without patterns in relief), of

rectangular shape, neither clad, plated

nor coated with metal, whether or not

painted, varnished, or coated with

plastics or other nonmetallic substances;

and certain hot-rolled carbon steel flatrolled products in straight lengths, of

rectangular shape, hot rolled, neither

clad, plated, nor coated with metal,

whether or not painted, varnished, or

coated with plastics or other

nonmetallic substances, 4.75

millimeters or more in thickness and of

a width which exceeds 150 millimeters

and measures at least twice the

thickness, as currently classifiable in the

Harmonized Tariff Schedule (HTS)

under item numbers 7208.40.3030,

7208.40.3060, 7208.51.0030,

7208.51.0045, 7208.51.0060,

7208.52.0000, 7208.53.0000,

7208.90.0000, 7210.70.3000,

7210.90.9000, 7211.13.0000,

7211.14.0030, 7211.14.0045,

7211.90.0000, 7212.40.1000,

7212.40.5000, and 7212.50.0000.

Included are flat-rolled products of

nonrectangular cross-section where

such cross-section is achieved

subsequent to the rolling process (i.e.,

products which have been ‘‘worked

after rolling’’) for example, products

which have been beveled or rounded at

the edges. Excluded is grade X–70 plate.

These HTS item numbers are provided

for convenience and Customs purposes.

The written description remains

dispostive.

Analysis of Comments Received

We gave interested parties an

opportunity to comment on the

preliminary results. We received briefs

and rebuttal comments from Bethlehem

Steel Corporation, U.S. Steel Group, a

Unit of USX Corporation, Inland Steel

Industries, Inc., LTV Steel Company,

Inc., National Steel Corporation, AK

Steel Corporation, Gulf States Steel Inc.

of Alabama, Sharon Steel Corporation,

and WCI Steel Inc., petitioners, and

from Rautaruukki Oy (Rautaruukki), a

producer/exporter of the subject

merchandise. At the request of

petitioners and respondent, we held a

hearing on October 31, 1997.

Comment 1: Petitioners argue that

Rautaruukki’s interest revenues should

be accounted for and that the

Department should adjust Rautaruukki’s

home market sales prices to account for

unreported late payment charges.

Petitioners contend that Rautaruukki’s

stated policy of charging interest to all

of its customers for late payments

conflicts with Rautaruukki’s assertion

that in practice, its customers rarely pay

interest. Petitioners note that

Rautaruukki enters all interest revenues

into one general account and argue that

charges for late payments constitute

interests revenue.

Petitioners assert that the Department

confirmed at verification that

Rautaruukki’s financial records account

for total interest revenue received in

1996, but that no information was

provided for 1995. Petitioners argue that

neither of the transactions cited by

respondent support Rautaruukki’s claim

that it did not accrue and receive

interest revenue. Petitioners state that

the Department should employ facts

available in calculating Rautaruukki’s

interest revenue due to respondent’s

failure to provide information on

interest revenue earned in 1995 and its

failure to identify the sales for which

late payment charges were assessed.

Petitioners state that, as facts available,

the Department should calculate an

interest revenue adjustment for all sales

for which, pursuant to their terms of

payment, payment was recorded as late.
Federal Register / Vol. 63, No. 12 / Tuesday, January 20, 1998 / Notices 2953

Respondent claims that it has

reported interest revenue, and no

further adjustment is required.

Respondent states the Department

verified that interest revenue was

properly reported. Respondent contends

that it has provided information on the

total interest revenue which it received

during calender year 1995 and 1996.

Department Position: We partially

agree with both petitioners and

respondent. At verification, the

Department specifically identified one

sale solely for verification of interest

revenue. As noted in the verification

report, the Department verified that for

this sale, no interest revenue was

received. See Sales Verification Report

at 24. We also examined other sales for

which the customer had initially been

billed for late charges (interest revenue)

that were ultimately not paid by the

customer. These sales were also

properly reported. Rautaruukki reported

a negative amount for interest revenue

in 1995, and a positive amount for 1996.

See Respondent’s Rebuttal Brief of

September 15, 1997, at 11. Rautaruukki

did not, however, allocate interest

revenue to 1996 sales in its sales

database.

Section 776(a)(2) of the Act provides

that if an interested party or any other

persons—(A) withholds information

that has been requested by the

administering authority; (B) fails to

provide such information by the

deadlines for the submission of the

information or in the form and manner

requested, subject to subsections (c)(1)

and (e) of section 782; (C) significantly

impedes a proceeding under this title; or

(D) provides such information but the

information cannot be verified as

provided in section 782(i), the

administering authority shall, subject to

section 782(d), use the facts otherwise

available in reaching the applicable

determination under this title.

Because Rautaruukki did not report

any interest revenue in its sales

database, although the interest revenue

was received, the Department must,

pursuant to section 776, use facts

otherwise available in these final

results. We are allocating as facts

available the amount of interest revenue

reported for 1996 to all 1996 sales on a

per-ton basis.

Comment 2: Petitioners argue that

Rautaruukki’s submitted gross unit

prices should be adjusted, because the

Department found a very large

discrepancy with respect to the reported

gross unit price of a pre-selected home

market sale. Petitioners claim

Rautaruukki deducted the full amount

of the credit from the selected sale

rather than applying this credit to all

sales listed on the invoice. Petitioners

contend that since the error was

uncovered pursuant to a small

sampling, this suggests that similar

errors may well exist elsewhere in the

dataset. Petitioners argue that based

upon variation in prices within a given

product control number, the

understatement discovered by the

Department at verification could also

exist in other product control numbers

and, in fact, pervade the dataset.

Petitioners contend that the Department

should make an adjustment to the entire

dataset to account for the errors

uncovered with the sample sales.

Specifically, petitioners suggest that

gross unit prices be increased by the

percentage that the samples sales were

under-reported.

Respondent argues that it has

submitted correct home market gross

unit price data and that no adjustment

is warranted. Respondent claims that

the discrepancy in question was the

result of offsetting a credit to a customer

against a single line item or transaction

which was one of several transactions

on a single invoice. Respondent argues

that this allocation error works both

ways. Although the gross unit price of

the sale in question was artificially

depressed, the gross unit prices of the

remaining transactions on the invoice

were artificially increased. Overall,

according to Rautaruukki, the errors

offset each other. Respondent also

contends that, as noted during the sales

verification, this was a special project

credit involving an end-user (shipyard)

in Finland, and that such special or onetime projects are rare. Moreover,

respondent notes that the Department’s

verification of other home market sales

did not disclose a similar problem.

Department Position: We agree with

respondent. At verification, we found

that, for one sale a credit to a customer

was offset against a single line item,

rather than crediting this amount to all

the items to which it applied. We agree

with respondent that the consequences

of this allocation error serve to

artificially depress the gross unit price

of the sale in question, while artificially

increasing the gross unit prices of the

remaining transactions on the invoice.

We noted that the one sale in question

was found to be below cost, and is

therefore already being excluded from

our calculation of normal value. We

found no evidence at verification of any

other discrepancies in the reporting of

gross unit prices. No further adjustment

of reported gross unit prices is

warranted for these final results.

Comment 3: Petitioners state that

Rautaruukki should be denied any home

market credit expense adjustment

because the Department determined at

verification that the Finnish short-term

interest rate that Rautaruukki used to

calculate the reported home market

credit expense could not be verified.

Petitioners argue that the Department

must use facts available in establishing

the interest rate applicable to the

calculation of the home market credit

expense, and deny Rautaruukki any

home market credit expense adjustment

for the final results.

Respondent argues that it submitted

information on its home market interest

rate and the Department verified

Rautaruukki’s total interest expenses.

Respondent claims that due to time

constraints during the sales verification,

the Department chose to postpone the

verification of Rautaruukki’s home

market interest rate until the cost

verification. Rautaruukki states that

during the cost verification the

Department reviewed Rautaruukki’s

interest expense worksheet and verified

Rautaruukki’s total interest cost.

Additionally, Rautaruukki claims that it

provided the Department with detailed

information regarding borrowings

during the POR. Hence, in respondent’s

view, Rautaruukki’s home market

interest rate was reported to the

Department and is readily verifiable.

Department Position: We agree with

petitioners that we were unable to verify

Rautaruukki’s home market interest rate.

The verification report states that, [w]e

were unable to verify Rautaruukki’s U.S.

or HM interest rates during sales

verification. See Sales Verification

Report at 23. Respondent’s claim that

the Department chose to postpone the

verification of Rautaruukki’s home

market interest rate until the cost

verification is false. We were prepared

to conduct this portion of the

verification during the sales verification;

however, as noted in the verification

report, respondent simply referred us to

prior submissions listing short-term

borrowings. No original loan agreements

or proof of payment relative to these

loans were provided to the sales

verification team. While the cost

verification team examined information

relating to respondent’s overall interest

expense, it was unable to verify the

interest rate claimed by Rautaruukki in

its home market credit calculation. As a

result of the failure on the part of

respondent to support a claimed

adjustment, and thus our inability to

verify that claim, we must use partial

facts available pursuant to Section

776(a) of the Act. Thus, as facts

available we are denying an adjustment

for home market credit expenses for

these final results.
2954 Federal Register / Vol. 63, No. 12 / Tuesday, January 20, 1998 / Notices

Comment 4: Petitioners claim that the

Department should use facts available to

calculate Rautaruukki’s U.S. credit

expense because Rautaruukki used

Finnish interest rates rather than

interest rates related to U.S. borrowing

in its calculation of credit, and that the

Finnish rate submitted by Rautaruukki

could not be verified. Petitioners

contend that the Department should use

an interest rate of nine percent, the

short-term interest rate in effect during

the POR which the U.S. Customs

Service charged on underpayment of

antidumping duties.

Respondent claims that it had no U.S.

borrowings during the POR.

Rautaruukki states that in view of the

Department’s verification of

Rautaruukki’s total interest expense and

in light of the fact that Rautaruukki had

no U.S. borrowings, the Department

should use the Finnish short-term

borrowing rate submitted by

Rautaruukki for the calculation of its

U.S. credit expenses.

Department Position: We partially

agree with petitioners. It is Department

practice to use a U.S. interest rate in the

calculation of U.S. credit expenses. If a

respondent does not have such

borrowing, the questionnaire instructs

the party to use a U.S. published

commercial bank prime short-term

lending rate. Rautaruukki did not do so.

Moreover, as noted in Comment 3

above, the Department was unable to

verify respondent’s home market

interest rate. Therefore, pursuant to

Section 776 of the Act, the Department

must use facts available to calculate

Rautaruukki’s U.S. credit expense.

In Certain Cut-to-Length Carbon Steel

Plate from Sweden; Final Results of

Antidumping Duty Administrative

Review, 61 FR 15772, 15780 (April 9,

1996) and Certain Corrosion-Resistant

Carbon Steel Flat Products from

Australia; Final Results of Antidumping

Duty Administrative Reviews, 61 FR

14049, 14054 (March 29, 1996) the

Department selected the average shortterm lending rates calculated by the

Federal Reserve as surrogate U.S.

interest rates. These rates represent a

reasonable surrogate for respondents’

U.S. dollar borrowing rates because they

are calculated based on a variety of

actual dollar loans to actual U.S.

customers. We have employed this

methodology as facts available in

calculating Rautaruukki’s U.S. credit

expense using the average short-term

dollar lending rate effective during the

POR. See Analysis Memorandum, dated

December 15, 1997.

Comment 5: Petitioners argue that the

Department should adjust Rautaruukki’s

movement expenses related to

international freight charges. Petitioners

note that Rautaruukki’s movement

expenses are based on affiliated party

transactions with JIT-Trans. In this

situation, petitioners note that the

Department tests whether movement

expenses based on affiliated party

transactions reflect arm’s-length

transactions by comparing those

expenses to movement expenses

pertaining to non-affiliated party

transactions. Petitioners reject

Rautaruukki’s claim that JIT-Trans’s

transfer prices reflect an arm’s-length

price merely because JIT-Trans is

profitable overall. In petitioners’ view,

this claim is contradicted by a direct

comparison of JIT-Trans’ charge to

Rautaruukki with its charge to an

unaffiliated party. Petitioners claim that

for the final results, the Department

should revise this expense upwards by

the percentage that the price to the

unaffiliated party exceeded that charged

to respondent.

Respondent alleges no additional

adjustment is required by the

Department to its reported movement

expenses other than the adjustment

already made for affiliated party markup charges. Respondent claims that at

verification, Rautaruukki provided the

Department with documentation to

compare movement expenses from

arm’s length transactions between

Rautaruukki and JIT-Trans and

movement expenses from transactions

between JIT-Trans and non-affiliated

party Outokumpu Oy, a Finnish

producer of stainless steel products.

Rautaruukki cites the explanation for

the higher prices charged Outokumpu in

the sales verification report: ‘‘[t]he rate

charged the unaffiliated party is

somewhat higher * * * because in the

winter it is more expensive to go farther

north (due to the ice) and also because

it is more expensive to make an

additional stop.’’ Respondent contends

that the Department concluded that

transactions between Rautaruukki and

JIT-Trans are at arm’s length and argues

that no additional adjustment by the

Department is required for movement

expenses.

Department Position: We partially

agree with petitioners. Respondent did

not demonstrate that transactions

between Rautaruukki and JIT-Trans are

at arm’s length. In fact the prices

charged to an unaffiliated party are

greater than those charged to

respondent.

Respondent asserted at verification

that ‘‘[t]he rate charged the unaffiliated

party is somewhat higher * * * because

in the winter it is more expensive to go

farther north (due to the ice) and also

because it is more expensive to make an

additional stop.’’ Given the geographic

location of Rautaruukki and Outokumpu

Oy, we find respondent’s explanation

that some price differential is

attributable to the additional expense of

going farther north in the winter to be

reasonable. However the charges to the

affiliated party are higher in summer as

well as in winter. (See Sales Verification

Exhibit 26). For these final results,

therefore, we are increasing

Rautaruukki’s reported U.S. movement

expenses for all shipments by the

absolute value of the amount of the

difference in price charged the

unaffiliated party and Rautaruukki for

the summer. See Analysis Memorandum

dated December 15, 1997.

Comment 6: Respondent claims that

the Department erred in its selection of

a weight conversion factor. Respondent

states that the Department chose to

apply as facts available the lowest

conversion factor submitted by

Rautaruukki, or 0.9059, because the

Department was unable to verify

respondent’s reported weight

conversion factors. Rautaruukki alleges

that this conversion factor is

aberrational and the Department’s use of

this factor distorts the verified

information submitted by Rautaruukki.

Rautaruuki claims that only one product

control number in its database had a

conversion factor of 0.9059, and that

this product control number contains

only one observation, a sale of painted

plate. Respondent argues that this sale

is not an identical or similar match to

its U.S. sales under the Department’s

mode match criteria. Respondent notes

that under the Department’s model

match hierarchy, painted versus not

painted is the first factor to be

considered. The respondent explained

that none of its U.S. sales are of painted

plate and argues that in selecting a

conversion factor of 0.9059, based solely

on painted plate, the Department

selected an aberrant non-representative

factor. Respondent argues that its

submitted data are the most accurate

weight conversion factors. Respondent

contends that its calculation of

theoretical weight was explained in its

submissions and at verification. In the

event the Department continues to

apply a facts available conversion factor,

Rautaruukki urges the Department to

apply an average of its reported factors,

or 0.9870. Respondent argues that

unlike the factor used in the preliminary

results, at least this factor would be

representative of Rautaruukki’s

submitted data.

Petitioners claim that the facts

available weight conversion factor

selected by the Department is

appropriate. Petitioners disagree that the
Federal Register / Vol. 63, No. 12 / Tuesday, January 20, 1998 / Notices 2955

conversion factor used by the

Department is aberrational. Further,

petitioners argue that because

Rautaruukki failed to provide sufficient

support for any of its conversion factors

at verification, the Department may

make an adverse inference to ensure

that the respondent does not benefit

from its failure to provide the necessary

information. See Certain Internal

Combustion Industrial Forklift Trucks

from Japan, 62 FR 5592, 5594–95 (Feb.

6, 1997). Petitioners note that the

Department may use as facts available

data that are reported by the respondent

or any other data it deems appropriate.

See Uruguay Round Agreements Act,

Statement of Administrative Action,

A.R. Doc. No. 103–316, 103d cong., 2d

sess. at 869–870. Petitioners claim there

is no requirement that the facts available

selected by the Department reflect the

actual data or be the most recent

information. See e.g., Rhone Poulenc,

Inc., v. United States, 899 F.2d 1185,

1190 (Fed. Cir. 1990); Mitsubishi Belting

Limited and MBL (USA) Corp. v. United

States, Slip Op. No. 97–28, (CIT March

12, 1997) at 5. As the Department could

not verify the conversion factors used by

Rautaruukki, in petitioners’ view, there

is no reason to believe that an average

of these unverified factors would be

more accurate than the factor used by

the Department. Petitioners add that

using an average factor would

essentially reward Rautaruukki for its

failure to provide verifiable conversion

factors. Petitioners conclude that the use

of an average factor would not satisfy

the Department’s need to make an

adverse inference in this instance and

urge the Department to continue to use

the factor employed in the preliminary

results for the final results.

Department’s Position: We agree with

petitioners. By not providing verifiable

weight conversion factors, when

respondent could have done so, we have

determined that respondent failed to

cooperate by not acting to the best of its

ability to comply with a request for

information. See Certain Cut-to-Length

Carbon Steel Plate From South Africa,

62 FR 61731 (November 19, 1997). The

Department first learned that

Rautaruukki had not reported salespecific weight conversion factors at

sales verification. Rather, we were told,

weight conversion factors were

calculated for each product control

number. The verification outline clearly

states: Provide worksheets showing any

conversions from actual to theoretical

weight. Rautaruukki did not prepare any

such worksheets in advance of

verification. When asked at verification

to support the weight conversion

calculation for a specific product

control number, Rautaruukki was

unable to do so in the time available at

the verification. Consequently, pursuant

to section 776(b) of the Act, an adverse

inference is warranted in selecting facts

available. Thus as facts available, we are

continuing to use the weight conversion

factor employed in the preliminary

results of review. See Certain Cut-toLength Carbon Steel Plate from Finland,

62 FR at 37,876.

Comment 7: Respondent alleges that

the Department erred by failing to

consider subject merchandise which is

manufactured to shipbuilding

specification ‘‘A’’ as identical

merchandise. Respondent claims that its

customers sometimes demand that

identical merchandise, such as

shipbuilding plate grade ‘‘A,’’ be

certified by the national classification

society of the country in which the

product will be used. Respondent states

that the Department has treated all of

the grade ‘‘A’’ shipbuilding plate, other

than the grade used in the United States,

as most similar to this grade, and that

the Department assigned a unique

weight to the U.S. specification and a

different but uniform weight to all other

grade ‘‘A’’ shipbuilding plate.

Respondent claims that the Department

is treating identical merchandise

differently based on the identity of the

classification society. Respondent

contends that it demonstrated

repeatedly during this administrative

review that all grade ‘‘A’’ shipbuilding

plate subject merchandise manufactured

to the ‘‘A’’ specification of shipbuilding

plate is the same product, regardless of

the classification society which

provides the certification. Respondent

claims that irrespective of national

classification society, all grade ‘‘A’’

shipbuilding steel has identical

chemistry, delivery condition,

elongation, yield strength and tensile

strength. Respondent claims that it

provided mill certificates, which show

not only that the chemical and physical

properties are the same for all

shipbuilding grade ‘‘A’’ steel, but also

demonstrate that steel from the same

cast or heat was used to meet orders for

grade ‘‘A’’ shipbuilding plate sold to

different classification society

certifications. Respondent states that it

described the procedures that it

underwent in order to qualify as a

supplier of shipbuilding steels, and

notes that in order to be qualified, the

various national certification societies

used common test pieces and test

results. Respondent argues that this

interchangeability of test pieces

supports its claim that this material is

identical and that the various societies

apply the same standard for this

material.

Petitioners did not comment on this

issue.

Department Position: We disagree

with respondent. Respondent’s

argument is based on an examination of

the plate that was produced. As we have

explained to respondent in this

proceeding, the plate specification

variable refers to the physical

characteristics of the specification. See

Analysis Memorandum for the

preliminary results of the third

administrative review of Certain Cut-toLength Carbon Steel Plate From Finland

(July 7, 1997). Thus, while it is possible

to produce plate so that the same plate

meets multiple national standards, this

in no way demonstrates that the

standards themselves are identical. As

noted in the final results of the second

review, prices can vary based on the

specifications to which the product is

sold, even though the product is

physically identical. See Certain Cut-toLength Carbon Steel Plate from Finland;

Final Results of Antidumping Duty

Administrative Review. 62 FR 18468

(April 15, 1997). See also analysis

memo. We continue to find that there

are certain differences between the

various national specifications for grade

A shipbuilding plate and are not

changing the weights assigned to these

products for these final results. We do

note, however, that as there was no

plate sold in the home market that was

made to the same specification as the

shipbuilding steel sold in the United

States, maintaining the weights assigned

to various products will not affect the

home market models that are matched

to U.S. sales.

Comment 8: Respondent argues that

the Department erred by comparing

normal cut-to-length carbon steel plate

sold to the U.S. market with beveled

plate sold in the home market.

Respondent claims that beveled plate is

a structural steel product which requires

separate and additional manufacturing

and handling on a different product

line. Respondent notes that it has

created a special field to identify

beveled plate as well as other

prefabricated plate products, which may

have the same physical characteristics

as basic cut-to-length plate, but are

manufactured by different processes and

have different end uses. Respondent

also notes that it has provided

information about the different and

additional costs associated with the

production of beveled plate. Respondent

contends that the Department has

verified that beveled plate requires

additional processing and the different

nature of the product is reflected in
2956 Federal Register / Vol. 63, No. 12 / Tuesday, January 20, 1998 / Notices

Rautaruukki’s price list which

established an (extra) for beveled plate.

Petitioners allege respondent has

failed to demonstrate that beveled plate

is not comparable to the plate sold in

the U.S. market. Petitioners contend that

the Department expressly rejected the

arguments raised by respondent in both

the first and second administrative

reviews. See Certain Cut-to-Length

Carbon Steel Plate from Finland, 61 FR

2792, 2795 (January 29, 1996) and

Certain Cut-to-Length Carbon Steel Plate

from Finland 62 FR 18468, 18471 (April

15, 1997). Petitioners argue that the

Department correctly determined in

those prior reviews that Rautaruukki

failed to establish beveling as a productmatching criterion, and that the

Department found that beveled plate

does not possess physical characteristics

which make it unique from non-beveled

plate with regard to applications and

uses. Petitioners claim that the

Department noted that Rautaruukki had

the opportunity to suggest beveling as a

characteristic for use in product

matching, but failed to do so. See

Certain Cut-to-Length Carbon Steel Plate

from Finland, 61 FR at 2795. Petitioners

argue that nothing has changed with

respect to this issue in this review. In

petitioners’ view, respondent has not

established on the record that beveling

is a product matching criterion

considered by the Department.

Petitioners claim that respondent is

simply seeking to create its own

matching hierarchy. Petitioners state

that the support cited by Rautaruukki is

the same information that Rautaruukki

submitted in the second administrative

review information which failed to

convince the Department that beveled

plate should not be compared to the

products sold in the U.S. market.

Petitioners claim that the Department

has correctly determined, and as

Rautaruukki has conceded, beveled

plate products do not possess any

physical characteristics that set them

apart from non-beveled plate products.

Accordingly, petitioners argue that

Rautaruukki’s contentions regarding the

treatment of beveled plate are without

merit and should be rejected by the

Department.

Department Position: We agree with

the petitioners. The Department

correctly determined in those prior

reviews that Rautaruukki failed to

establish beveling as a productmatching criterion, and that the

Department found that beveled plate

does not possess physical characteristics

which make it unique from non-beveled

plate with regard to applications and

uses. See Certain Cut-to-Length Carbon

Steel Plate from Finland, 61 FR 2792,

2795 and Certain Cut-to-Length Carbon

Steel Plate from Finland, 62 FR 18468,

18471. The documentation submitted by

Rautaruukki in the course of this review

does not establish the relevance of

beveling as a product matching

criterion. We have not changed our

treatment of beveled products for these

final results.

Comment 9: Respondent contends

that the Department failed to convert

harbor expenses from Finnish markka to

U.S. dollars in its calculation of margin

expenses. The respondent suggests that

we make an adjustment similar to the

adjustment made for international

freight charges for affiliated party

charges.

Additionally, respondent claims that

the Department did not convert direct

selling expenses and credit expenses for

U.S. sales from Finnish markka to U.S.

dollars in the margin calculation

program. Rautaruukki reported direct

selling and credit expenses in Finnish

markka, but the margin calculation

program applies these figures in U.S.

dollars, resulting in a skewed total for

direct expenses for U.S. sales.

Petitioners did not comment on this

issue.

Department’s Position: We have

converted harbor expenses, U.S. direct

selling expenses, and U.S. credit

expenses from Finnish markka to U.S.

dollars. We note that the affiliated party

charges were in U.S. dollars so no

currency conversion was required for

these expenses.

Comment 10: Rautaruukki claims that

the Department erred in applying the

theoretical weight conversion factor to

its verified COP and CV amounts.

Rautaruukki argues that the Department

should have applied the weight

conversion factor only to the sales

quantities to insure that all sales were

reported on the same (i.e., theoretical

weight) basis and not to reported costs

which reflect actual costs incurred for

delivered or shipped quantities of

subject merchandise. Rautaruukki notes

that its U.S. sales were all reported on

a theoretical weight basis, while some of

its home market sales were reported on

a theoretical weight basis and some

were reported on an actual weight basis.

Consequently, for the sales made on a

theoretical weight basis, Rautaruukki

contends that the costs associated with

these sales were reported on a

theoretical weight basis, not on an

actual weight basis. Therefore,

Rautaruukki argues that if the

Department decides to apply the

conversion factor to costs, it should be

applied only to those products sold on

an actual weight basis. Rautarrukki

suggests that the Department would

need to recalculate costs for only two of

the three products which were matched

in the model match program because

one product’s costs was reported only

on a theoretical weight basis. To

recalculate the costs for the other two

matched products, Rautaruukki

recommends that the Department

calculate the relative distribution or

allocation of costs associated with each

weight basis using the percentage of

sales made on each basis. Then, the

Department could adjust the costs

associated with sales made on an actual

weight basis by applying the conversion

factor and add this figure to the costs

reported on a theoretical weight to

arrive at a figure for the cost for all sales

on a theoretical weight basis.

Petitioners state that Rautaruukki’s

claim that cost data are calculated on

both theoretical and actual weight basis

constitutes new information that the

Department has not verified. Petitioners

cite the Department’s cost verification

report which states that to calculate the

weighted-average cost for all extras,

Rautaruukki used shipped quantities to

determine the per ton cost amounts.

Because Rautaruukki’s case brief dated

September 8, 1997, indicates that

Rautaruukki calculated the average cost

per ton using a combination of costs

based on both theoretical weights and

actual weights, petitioners argue that

Rautaruukki’s cost reporting

methodology is flawed and the reported

amounts are inaccurate and unreliable.

Therefore, petitioners cite Final Results

of Antidumping Duty Administrative

Review: Certain Cut-to-Length Carbon

Steel Plate from Sweden, 62 FR 18396,

18398–99 (April 15, 1997), and

recommend that the Department reject

Rautaruukki’s reported per ton costs and

apply total facts available.

Department Position: We agree with

petitioners that Rautaruukki’s cost

calculation methodology is flawed in

that it relied on production quantities

based on both theoretical and actual

weights. We disagree with petitioners,

however, that Rautaruukki’s cost

reporting methodology warrants use of

total facts available. Under its

submission methodology, Rautaruukki

first computed a weighted-average cost

of manufacturing for the subject

merchandise based on two broad

product categories, plate and cut-tolength coil. At verification, we

confirmed that each of these weightedaverage cost categories was calculated

by dividing actual costs by total

production quantity on an actual weight

basis (See Production Reports per

February 27, 1997, Submission at

Exhibit 3, calculation 3). Rautaruukki

then computed an average cost for
Federal Register / Vol. 63, No. 12 / Tuesday, January 20, 1998 / Notices 2957

extras by multiplying product-specific

extra amounts by product-specific sales

quantities (some of which were on an

actual weight basis, others on a

theoretical weight basis) and dividing

by the same sales quantities. Because, in

the normal course of business,

Rautaruukki maintains product-specific

sales reports but not product-specific

production reports, it used shipped

quantities of each product to compute

the average cost for extras. Rautaruukki

deducted this average cost for extras

from the weighted-average cost of

manufacturing for each broad product

category in order to compute the average

base cost for the category. To compute

product-specific manufacturing costs,

Rautaruukki added to the average base

cost the same product-specific extra

amounts used to derive the base cost.

By using actual production weights to

compute the average costs for each of

the broad product categories, and by

relying on a mix of theoretical and

actual production weights in

determining the average cost of extras,

Rautaruukki’s submitted costs represent

a mix of weight bases that do not

accurately reflect the per-unit costs

incurred to produce the subject

merchandise. To correct this flaw, we

increased Rautaruukki’s reported COP

and CV amounts by the theoretical-toactual weight conversion factor. See

Comment 6.

Comment 11: Petitioners argue that

the Department should reject

Rautaruukki’s COP and CV data and use

facts available because they contend

that Rautaruukki’s product-specific cost

data are not based on actual costs

incurred during the POR, are not

supported by source documentation,

cannot be reconciled to Rautaruukki’s

audited financial statements, and are

not supported by tests performed by the

Department. Petitioners cite Final

Results of Antidumping Duty

Administrative Review: Certain Cut-toLength Carbon Steel Plate from Finland,

62 FR 18468, 18472–18473 (April 15,

1997), in which the Department rejected

Rautaruukki’s cost data in the second

administrative review, to support its

argument. Petitioners state that the

problems identified in the second

administrative review persist and that

there is insufficient record evidence for

the third administrative review to

support the Department’s reversal of its

previous decision.

Petitioners argue that the submitted

costs be rejected because the

Department verified that productspecific costs are not based on the POR.

Petitioners note that all documentation

provided by Rautaruukki to substantiate

its reported product-specific costs was

from outside the POR. Therefore,

petitioners maintain that the

Department has no reliable basis or

record evidence to determine whether

the submitted data reflect actual costs

for the POR. Petitioners further contend

that the Department cannot rely on

documentation provided during this

review which relates to previous review

periods to support Rautaruukki’s

historical production costs since the

Department previously rejected this

information.

Rautaruukki argues that the

Department’s decision regarding costs

submitted in this third administrative

review must be based on the facts of the

current proceeding and not on alleged

deficiencies or factual errors in previous

administrative proceedings.

Rautaruukki asserts that record evidence

in the current review clearly states that

the Department verified Rautaruukki’s

submitted product-specific information,

reviewed its internal system which

tracks quality and dimensional costs by

product grade, and reconciled these

costs with Rautaruukki’s profit-and-loss

accounts. Rautaruukki contends that the

costs recorded in the quality cost tables

dated July 31, 1995, were the costs in

effect throughout the POR, and

therefore, are a proper basis for

calculating product-specific costs.

Rautaruukki also states that the

Department verified its dimensional

extras costs and reconciled these figures

with Rautaruukki’s financial reports.

Lastly, Rautaruukki argues that the

Department tested and verified costs for

specific products and reconciled these

costs with Rautaruukki’s financial

statements. Therefore, Rautaruukki

maintains that its product-specific cost

data was verified by the Department to

be accurate and reliable.

Department Position: We disagree

with petitioners’ contention that we

must reject totally Rautaruukki’s

submitted COP and CV data for this

review. First, as discussed in Comment

10 above, Rautaruukki relied on actual

costs incurred and actual tonnages

produced during the POR to calculate

weighted-average costs for its broad

categories of plates and cut-to-length

products. In order to derive the total

base cost for each category, Rautaruukki

deducted from the weighted-average

cost, an amount for the average cost of

extras. The company then added back

costs for product-specific extras.

Contrary to petitioners’ assertions, there

is nothing inherently unreliable or

theoretically unsound about

Rautaruukki’s underlying cost allocation

methodology. Rather, much like other

manufacturers that rely on standard

costs as a means to distribute actual

costs among specific products,

Rautaruukki relies on a system of base

and standard extra costs to allocate its

actual production costs among the

company’s plate and cut-to-length

products. We found this methodology

reasonable.

Second, Rautaruukki’s productspecific costs are supported by source

documentation. In its February 27, 1997,

Section D supplemental response,

Rautaruukki provided documentation of

the detailed calculations used to derive

its quality and dimensional extras costs.

Rautaruukki notes that these

calculations are based on engineering

standards and the company’s

production experience. Petitioners

chose not to challenge the validity or

accuracy of Rautaruukki’s calculations.

Instead, the petitioners argue that

because Rautaruukki did not update

these standards during the POR, the cost

of extras as reported by the company are

unreliable. For this review, however, we

have no reason to believe that

Rautaruukki’s extra cost calculations,

which were based on data used by the

company during the POR, do not

reasonably represent the cost differences

incurred to produce individual

products. It is unnecessary for

Rautaruukki to update its standard extra

costs every year so long as these

amounts continue to accurately reflect

costs incurred by the company during

the year.

Third, the reported costs can be

reconciled to Rautaruukki’s audited

financial statements. During the cost

verification, we reconciled

Rautaruukki’s reported product-specific

costs to its audited financial statements

noting only a slight difference. See

Comment 14 below for further

discussion.

Fourth, Rautaruukki’s productspecific costs are supported by tests

performed by the Department during

verification. We tested Rautaruukki’s

calculations of weighted-average costs,

base costs, and extra costs (see cost

verification report at pages 7 through

14). During our verification, we

determined that the standard costs for

extras used by Rautaruukki in the

normal course of business during the

POR were based on actual production

and cost data, engineering standards,

and company experience. As discussed

above in this comment, we do not

believe that it is necessary for

Rautaruukki to update every year the

tables containing these standard extra

costs, where such standard costs

continue to reflect the company’s

production cost experience with

reasonable accuracy. In addition, in

contrast to petitioners’ argument, we
2958 Federal Register / Vol. 63, No. 12 / Tuesday, January 20, 1998 / Notices

found it reasonable that Rautaruukki

reported identical cost of manufacturing

amounts for a small number of

CONNUMs even though these products

had slightly different physical

characteristics. We verified the fact that

these products had the same cost for

various reasons. For example, in some

instances, differences in the costs of

specific extras offset one another,

making the costs of the two products the

same in total. In other instances,

products with differing plate

specifications underwent the same

processing and, as a result, incurred the

same costs under Rautaruukki’s

accounting system. Thus, it was not

unreasonable for certain of

Rautaruukki’s products to have identical

costs.

Last, to support their argument that

the cost data submitted in this review

should be rejected, the petitioners cite

Final Results of Antidumping Duty

Administrative Review: Certain Cut-toLength Carbon Steel Plate from Finland,

62 FR 18468, 18472–18473 (April 15,

1997), in which the Department rejected

Rautaruukki’s cost data in the second

administrative review. We note that any

decision in a specific review must be

made on the facts of the record for that

review. In this review, as explained

above, we were able to verify

Rautaruukki’s cost extras and found

their reporting methodology to be

reasonable. As the Department has

stated, we review each period

independently and may determine that

a change in analysis is appropriate.

* * * Thus, the Department is not

bound in a current administrative

review to strictly adhere to the

methodology or practice used in a

previous review. See Certain Dried

Heavy Salted Codfish from Canada, 54

FR 13211, 13213 (March 31, 1989).

Comment 12: Petitioners state that

Rautaruukki’s variable cost of

manufacturing data reported for its

home market and U.S. sales differs

substantially from the amounts derived

from the COP and CV datasets.

Petitioners argue that the Department’s

calculation of variable costs as used for

the preliminary determination, which

were computed by subtracting the fixed

overhead amount reported in the COP

dataset from the total cost of

manufacturing amount reported in the

COP dataset, fails to accurately calculate

product-specific costs. Petitioners

reason that this methdology is

unacceptable because Rautaruukki

reported the same fixed overhead

amount for every product produced,

thereby disregarding fixed-cost

differences between products.

As the Department cannot derive

accurate product-specific variable costs

from Rautaruukki’s COP dataset,

petitioners recommend that the

Department use an adverse facts

available percentage of 24.95 percent,

the margin from the last administrative

review, for calculating the difference in

merchandise (difmer) adjustment. As

alternative adverse facts available,

petitioners suggest that the Department

use Rautaruukki’s lowest reported home

market variable cost and its highest

reported U.S. variable cost to calculate

the difmer adjustment for all nonidentical comparisons. Petitioners assert

that use of adverse facts available is

appropriate since Rautaruukki failed to

submit revised data in response to

several requests made by the

Department that Rautaruukki ensure

that its home market and U.S. sales files

reflect the same variable cost of

manufacturing amounts as reported in

its COP and CV datasets. petitioners cite

Final Results of Antidumping Duty

Administrative Review: Porcelain-onSteel Cookware from Mexico, 61 FR

54616, 54618 (October 21, 1996);

Preliminary Determination of Sales at

Less than Fair Value: Class 150 Stainless

Steel Threaded Pipe Fittings from

Taiwan, 59 FR 10784, 10785 (March 8,

1994); and Final Determination of Sales

at Less than Fair Value: Class 150

Stainless Steel Threaded Pipe Fittings

from Taiwan, 59 FR 28432 (July 28,

1994) to support the use of adverse facts

available.

Petitioners further contend that if the

Department does not use adverse facts

available, the Department should at

least apply neutral facts available for the

difmer adjustment. As neutral facts

available, petitioners suggest that the

Department apply an amount equal to

the twenty percent cap as the difmer

adjustment. Petitioners cite Notice of

Final Results and Partial Termination of

Antidumping Duty Administrative

Reviews: Tapered Rolled Bearings, Four

Inches or Less in Diameter, and

Components Thereof, from Japan, 59 FR

56035, 56048, which was upheld in

NTN Bearing Corp. of America v. United

States, 924 F. Supp. 200 (Ct. Int’l Trade

1996), to show that the Department’s

practice has been to apply an amount

equal to the twenty percent cap in those

instances where a respondent fails to

provide variable cost data in the

requisite form for the difmer test.

Rautaruukki disagrees with the

petitioners’ claim that the Department

erred in calculating Rautaruukki’s

variable costs by subtracting fixed

overhead costs from the total cost of

manufacture reported in the COP and

CV datasets. Rautaruukki maintains that

the Department’s calculation is

acceptable because the Department

verified that the cost data are in

accordance with its practice and

generally accepted accounting

principles.

Department Position: We agree with

petitioners that Rautaruukki incorrectly

reported its fixed manufacturing costs

by reporting only amounts related to

producing base products (i.e., all

products were assigned the same

amount of fixed manufacturing costs).

As a result, the methodology used by

the Department for the preliminary

determination (determining productspecific variable cost of manufacturing

by subtracting the reported productspecific fixed cost of manufacturing

from the product-specific total cost of

manufacturing) failed to account for

fixed-cost differences arising from

processing route differences. This flaw

in methodology, however, has no

impact on the similar product matches

for Rautaruukki in this review. The only

difference between home market sales

and the U.S. sales to which they are

matched is the specification of the steel.

All other model match criteria,

including width and thickness, and

identical. With respect to specification,

all U.S. sales and the home market sales

that are matched to those U.S. sales are

shipbuilding grade A material. As

respondent has argued throughout this

proceeding (See Comment 7), all

shipbuilding grade A material is

manufactured the same regardless of the

national classification standard to

which it is ultimately certified.

Petitioners have not disputed these

claims. Thus, with respect to these

sales, there are essentially no

differences in the total cost of

manufacturing for the matched

products, and no differences in the

processing routes or machines used in

production. Accordingly, we consider

the methodology used by the

Department for the preliminary results

reasonable and non-distortive for

purposes of this review. We are

continuing to use this methodology for

these final results.

Comment 13: Petitioners claim that

Rautaruukki improperly reduced its

costs associated with the production of

subject merchandise by including

revenue from sales of slab in the amount

it reported for scrap and sales of byproducts. Petitioners note that slabs are

semi-finished, non-subject merchandise

and that the income from sales of slab

should not be deducted from costs.

Petitioners recommend that the

Department exclude Rautaruukki’s

reported scrap amount from the

calculation of total costs because the
Federal Register / Vol. 63, No. 12 / Tuesday, January 20, 1998 / Notices 2959

Department has no way of knowing

what percentage of Rautaruukki’s scrap

amount is from sales of slab.

Rautaruukki responds that it did not

report slab as a by-product and offset its

COP and CV data by revenues from the

sale of slabs. Rautaruukki notes that the

Department verified that by-products

reported include burnt lime, coke, coal

tar, sulfur, benzene, nut coke, and

utilities. Rautaruukki maintains that

slab is not included as a by-product

offset in its submitted costs.

Department Position: We agree with

Rautaruukki. Although Rautaruukki

officials stated that in their management

accounting monthly reports, they

included sales of slabs with by-product

turnovers (See Sales Verification Report

at 5), we found no evidence to show that

Rautaruukki had improperly offset

reported production costs with revenue

from the sale of slab. As discussed in

our cost verification report at page 7, byproduct revenues offset to the cost of

subject merchandise included burnt

lime, coke, coal tar, sulfur, benzene, nut

coke, and utilities. Because we have no

evidence that Rautaruukki included

sales of slab in the by-product offset, we

made no adjustment. Comment 14: Petitioners argue that if

the Department accepts Rautaruukki’s

product-specific cost data, the

Department should make an adjustment

to account for the difference between

Rautaruukki’s May 5, 1997 COP dataset,

which was submitted after verification,

and its audited financial statements.

Petitioners note that the reconciliation

reviewed by the Department was based

on data submitted prior to verification

and that the May 5, 1997 dataset no

longer reconciles to Rautaruukki’s

financial statements. As Rautaruukki

did not explain whether the discrepancy

between its revised COP dataset and its

financial statements relates to subject or

non-subject merchandise, petitioners

recommend that the Department adjust

the submitted data by the amount of the

discrepancy. Rautaruukki replies that the slight

discrepancy between its costs submitted

on May 5, 1997, and its audited

financial statements represents omitted

costs of products sold to third countries

that were outside the scope of this

administrative review. Rautaruukki

further contends that the Department

verified the accuracy and validity of its

cost reconciliation and its production

costs for plate. Therefore, Rautaruukki

concludes that an adjustment to its

reported costs is unwarranted. Department Position: We agree with

practitioners. The reconciliation

reviewed by the Department did not

include the correction of errors

identified at the beginning of

verification (See Cost Verification

Report at 3, 6, and 7). Based on our

revised reconciliation, it appears that

the COP and CV data submitted by

Rautaruukki in its May 5, 1997,

response did not capture all costs as

recorded under the company’s financial

accounting system. As we have no

evidence to support Rautaruukki’s

contention that the difference relates to

third country sales that were outside the

scope of this administrative review, we

adjusted Rautaruukki’s submitted costs

for this small difference. See Analysis

Memorandum dated December 15, 1997.

Final Results of Review

As a result of our review, we have

determined that no margin exists for

Rautaruukki Oy for the period of August

1, 1995 through July 31, 1996. The

Department will issue appraisement

instructions directly to the Customs

Service.

Furthermore, the following deposit

requirements will be effective upon

publication of this notice of final results

of review for all shipments of plate from

Finland entered, or withdrawn from

warehouse, for consumption on or after

the publication date, as provided for by

section 751(a)(1) of the Act: (1) The cash

deposit rates for the reviewed company

will be zero; (2) for previously reviewed

or investigated companies not listed

above, the cash deposit rate will

continue to be the company-specific rate

published for the most recent period; (3)

if the exporter is not a firm covered in

this review, or the original less than fair

value (LTFV) investigation, but the

manufacturer is, the cash deposit rate

will be the rate established for the most

recent period for the manufacturer of

the merchandise, and (4) if neither the

exporter nor the manufacturer is a firm

covered in this review, the cash deposit

rate will be 40.36 percent. This is the all

others rate from the amended final

determination in the LTFV

investigation. See Amended Final

Determination Pursuant To CIT

Decision: Certain Cut-To-Length Carbon

Steel Plate from Finland, 62 FR 55782

(October 28, 1997). These deposit

requirements when imposed, shall

remain in effect until publication of the

final results of the next administrative

review.

This notice serves as a final reminder

to importers of their responsibility

under Section 351.402(f) of the

Department’s regulations to file a

certificate regarding the reimbursement

of antidumping duties prior to

liquidation of the relevant entries

during this review period. Failure to

comply with this requirement could

result in the Secretary’s presumption

that reimbursement of antidumping

duties occurred and the subsequent

assessment of double antidumping

duties.

This notice also serves as a reminder

to parties subject to administrative

protective order (APO) of their

responsibility concerning the

disposition of proprietary information

disclosed under APO in accordance

with Sections 351.305 of the

Department’s regulations. Timely

notification of return/destruction of

APO materials or conversion to judicial

protective order is hereby requested.

Failure to comply with the regulations

and the terms of an APO is a

sanctionable violation.

This administrative review and this

notice are in accordance with section

751 (a)(1) of the Act (19 U.S.C.

1675(a)(1)) and Sec. 351.213 and

351.221 of the Department’s regulations.

Dated: January 12, 1998.

Robert S. LaRussa,

Assistant Secretary for Import

Administration.

[FR Doc. 98–1277 Filed 1–16–98; 8:45 am]

BILLING CODE 3510–DS–M

DEPARTMENT OF COMMERCE

International Trade Administration

[A–423–805]

Certain Cut-to-Length Carbon Steel

Plate From Belgium; Final Results of

Antidumping Duty Administrative

Review

AGENCY: Import Administration,

International Trade Administration,

Department of Commerce.

ACTION: Notice of Final Results of

Antidumping Duty Administrative

Review.

SUMMARY: On September 15, 1997, the

Department of Commerce (the

Department) published the preliminary

results of its 1995–96 administrative

review of the antidumping duty order

on cut-to-length carbon steel plate from

Belgium (62 FR 48213). This review

covers one manufacturer/exporter of the

subject merchandise, Fabrique de Fer de

Charleroi, S.A. (FAFER), and its

subsidiary, Charleroi (USA) for the

period August 1, 1995 through July 31,

1996.

EFFECTIVE DATE: January 20, 1998.

FOR FURTHER INFORMATION CONTACT:

Maureen McPhillips or Linda Ludwig,

Office of AD/CVD Enforcement, Group

III, Import Administration, International

Trade Administration, U.S. Department

of Commerce, 14th Street and

Constitution Avenue, NW., Washington,