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Michigan Automotive Compressor, Inc.
Parma, Michigan 49269
February 7, 2007

Dear Chairman Rangel;

On behalf of MICHIGAN AUTOMOTIVE COMPRESSOR, INC. (MACI), I would like to give input to the matter before the U.S. Department of Commerce regarding investigation of the calculation of weighted average dumping margins.

The purpose of this letter is to introduce you to MACI and to inform you of our challenges in securing capable, quality hot roll sheet steel at affordable cost.

MACI is a Tier one supplier to automotive OEMs in North America.  We are a joint venture of Toyota Industries Corporation and Denso Corporation.  Our core product is the automotive air conditioning compressor with magnetic clutch.  In the manufacture of the clutch, we employ deep draw stamping and slotting operations.  Severe material forming and sidewall ironing (reduction exceeding 50% of nominal material thickness) occurs in the transfer die progression.  This demanding process requires hot strip steel of premium characteristics.  We have conducted numerous trials with hopes of validating a domestic mill source for our requirements, with no success.  Key measureables could not be met, including die tool component life, production efficiency rates, and in-process defect rates.  Meeting acceptable ranges for these measureables is essential for us to remain competitive in our market segment.  In light of recent material cost increases, any reduction accepted in the areas aforementioned could jeopardize our profitability.  In addition, much technical support is afforded to our company from the mill source, Corus of Ijmuiden, Netherlands, that was not previously available when we attempted domestic sourced material.

Please consider our situation in your investigation and determination of dumping margins, specifically in consideration of the demanding requirements of our process/application and the very severe cost pressures of our market segment.

Sincerely,

Joe Shaughnessy
Purchasing Manager


 
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