PUBLIC DOCUMENT
REBUTTAL COMMENTS ON THE COMMERCE DEPARTMENT
“ZEROING” PROPOSAL
71 FED. REG. 11189 (MARCH 6, 2006)
SUBMITTED ON BEHALF OF THE
CONSUMING INDUSTRIES TRADE ACTION COALITION
(CITAC)
LEWIS E. LEIBOWITZ
LYNN G. KAMARCK
HOGAN & HARTSON L.L.P.
555 13th Street, N.W.
Washington, D.C. 20004
(202) 637-5600
Counsel for CITAC
May 4, 2006
1/
In particular, these rebuttal comments address comments filed by the Committee to Support U.S.
Trade Laws (“CSUSTL”), Collier Shannon Scott (“CSS”), United States Steel Corporation (“USS”),
Coalition for Fair Lumber Imports (“CFLI”), Committee on Pipe and Tube Imports (“CPTI”), and
Stewart & Stewart (“S&S”). Because of the similar positions taken in many of these comments, we refer
collectively to these comments as “Petitioners” comments.
2/
71 Fed. Reg. 11189 (March 6, 2006) (“Zeroing Notice”).
3/
71 Fed. Reg. 23898 (April 25, 2006).
REBUTTAL COMMENTS ON THE COMMERCE DEPARTMENT
“ZEROING” PROPOSAL
SUBMITTED ON BEHALF OF THE
CONSUMING INDUSTRIES TRADE ACTION COALITION
INTRODUCTION
These rebuttal comments are submitted by the Consuming Industries Trade Action
Coalition (“CITAC”). They respond to comments filed by several parties (collectively referred
to as “Petitioners”) 1/ in the Department’s request for comments on its proposal to eliminate the
practice of “zeroing” in initial antidumping duty investigations employing the “average to
average” comparison methodology. 2/ CITAC timely filed initial comments in this proceeding on
April 5, 2006 (“Initial Comments”).
CITAC requested an extension to submit rebuttal comments to permit a detailed analysis
of the WTO Appellate Body decision in United States – Laws, Regulations and Methodology for
Calculating Dumping Margins (Zeroing), WT/DS294.AB/R (“AB Zeroing Determination”),
which was issued on April 18, 2005. The Department granted this request and extended the
deadline to May 4, 2006. 3/
In our original comments on behalf of consuming industries, we advocated the
abandonment of the zeroing methodology in investigations