| Superior Production
Partnership
Cleveland, Ohio 44117
February 7, 2007
Charles B. Rangel,
Chairman
Committee on Ways and Means
Dear Ladies and Gentlemen,
In regards to
the U.S. Dept. of Commerce’s proposed modification of the calculation of
weighted average dumping margins in anti-dumping investigations (71 FR 77722) ,
our company would like to weigh in with the following opposition point of view,
and wish to make a case for the U.S to comply with the W.T.O. rulings and
eliminate zeroing.
We are a
medium sized company, still family owned after 90 plus years in business,
employing over 300 people with two manufacturing plants, two warehouses here in
Columbus, and five distribution warehouses from Allentown PA. to Seattle WA. We have been in and are currently trying to compete in the sheet metals forming
business as it pertains to after-market collision repair parts. Pick-Up Trucks
and Vans, front and rear bumpers, specifically. These parts are visible to the
naked eye and get painted or chrome plated and are then placed on the front or
rear of the vehicles as needed. Our products come to market through
distributors and collision repair facilities and are underwrote as preferred
replacement parts by several current U.S. Auto insurance agencies.
The sheet metal
used in the making of our products comes to us from our distributor
(Chesterfield Steel, Cleveland Ohio), through The CORUS Group, Strip Products
Division, located in The Netherlands Europe. This business partnership has been
in place for over ten years now, and is a partnership that has been mutually
beneficial to all three parties. Increasingly, however, it is becoming more and
more difficult to compete due to this and the other actions taken over the last
several years.
This material
is of a special surface critical blend, type, and quality (i.e. the industry
term is Bumper Quality) that is so well quality controlled by The CORUS Group;
it is NOT equaled by any of our domestic mills here in the United States. We’ve had our own Metallurgist on staff here at Superior Production
Partnership for 20 years, and have used Chesterfield Steels’ resources as well.
Both our materials groups have procured whole master lots in the past of
material from multiple domestic sources over the years. None were able to match
the quality such as critical conditions of surface (no strain or luder lines),
draw-or-formability of the metal, and thickness tolerances. The domestic mills
that come before your committee will argue they can produce the same material,
when in fact through years of trials and testing this is just not the case.
That being
said, this action puts undue cost pressure on Corus, our supplier’s mill source,
which in turn could ultimately affect our ability to secure this material in
the future. We use approximately 4,000 to 5,000 tons of this special grade
sheet steel per year to support our business and its customers. We never want
to be at risk of having our supplier one day determine that the United States does not have a “level playing field” and decide to sell this critical
material elsewhere, thus affecting future employment within my Company.
On behalf of
my Company and all our employees, I urge you to drop these unfair trade
policies and practices.
Thanks to the committee for
this opportunity for us to be heard.
Best Regards,
Richard Holstein
Owner/President
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