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|Fair Trade: Section 232 Hearing|
Fair Trade: Section 232 Hearing Preparation
||Webinar to review the data collection worksheet at 12:00 p.m. EDT (11:00 a.m. CDT; 9:00 a.m. PDT)|
|June 9||All AEC members' data must be received|
|June 15||Request to appear at hearing will be filed|
|June 22||Section 232 Hearing in Washington, DC|
|June23||Post-hearing submission due (AEC comments that will contain information that we gather now to address the key elements identified in the BIS investigation)|
A data template has been created for quickly collecting information from AEC members regarding the 232 investigation that we can use to fashion relief comments. Please note that the definition of “critical infrastructure” we used comes directly from the Department of Homeland Security and Presidential Policy Directive 21 (PPD-21): Critical Infrastructure Security and Resilience. This definition is quite broad and likely covers much of what AEC members produce. What we do not have a good handle on is the amount of extrusions produced for defense-specific applications that this template will help provide.
The data and information will be gathered by our Fair Trade counsel, which will be kept confidential. We can then use the broad aggregated data as part of the submission.
We will also want anecdotal examples of projects lost to imports that we can point to. To help with that, the International Trade Commission (ITC) standard lost sale/lost revenue template is available to download. You can either use this template to provide specific examples, or just send Wiley Rein bullet points on the transaction, but try to include as much of this information as possible that would be helpful. They do not need a comprehensive list, but just a few key examples to help tell the story.
You may contact Jeff Henderson with questions but remember that AEC staff cannot be a data collector nor should we be your source to answer questions pertaining to your data submission.
DO NOT send your data to AEC! Send your data to our new attorney for the 232 Investigation:
Mayer Brown LLP