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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 | |