Risen Energy Co. v. United States

2023 CIT 48
CourtUnited States Court of International Trade
DecidedApril 11, 2023
DocketConsol. 20-03912
StatusPublished

This text of 2023 CIT 48 (Risen Energy Co. v. United States) is published on Counsel Stack Legal Research, covering United States Court of International Trade primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Risen Energy Co. v. United States, 2023 CIT 48 (cit 2023).

Opinion

Slip Op. 23-

UNITED STATES COURT OF INTERNATIONAL TRADE

RISEN ENERGY CO., LTD.,

Plaintiff,

JINGAO SOLAR CO., LTD., ET AL.,

Consolidated Plaintiffs, Before: Jane A. Restani, Judge SHANGHAI BYD CO., LTD., TRINA SOLAR CO., LTD., ET AL., Consol. Court No. 20-03912 Intervenor Plaintiffs,

v.

UNITED STATES,

Defendant.

OPINION AND ORDER

[Commerce’s Remand Results in the Sixth Administrative Review of Commerce’s Countervailing Duty order on crystalline silicon photovoltaic cells from the People’s Republic of China are remanded for reconsideration consistent with this opinion.]

Dated: April 11, 2023

Gregory S. Menegaz and Alexandra H. Salzman, deKieffer & Horgan, PLLC, of Washington, DC, argued for Plaintiffs. With them on the brief was James K. Horgan.

Sarah M. Wyss, Mowry & Grimson, PLLC, of Washington, DC, argued for Consolidated Plaintiffs. With her on brief were Jeffrey S. Grimson, Bryant P. Cenko, Jill A. Cramer, Kristin H. Mowry, Yixin (Cleo) Li.

Craig A. Lewis and Jonathan T. Stoel, Hogan Lovells US LLP, of Washington, DC, for Intervenor Plaintiffs Shanghai BYD Co., Ltd.

Jonathan M. Freed, Kenneth N. Hammer, MacKensie R. Sugama, and Robert G. Gosselink, Trade Pacific PLLC, of Washington, DC, for Intervenor Plaintiffs Trina Solar Co., Ltd. Consol. Court No. 20-03912 Page 2

Joshua E. Kurland, Commercial Litigation Branch, U.S. Department of Justice, of Washington, DC, argued for Defendant. With him on the brief were Brian M. Boynton, Patricia M. McCarthy, and Reginald T. Blades, Jr. Of counsel on the brief was Spencer Neff, Office of Chief Counsel for Trade Enforcement & Compliance, U.S. Department of Commerce, of Washington, DC.

Restani, Judge: Before the court are the remand results of the U.S. Department of

Commerce (“Commerce”) pursuant to the court’s order in Risen Energy Co. v. United States, 46

CIT __, __, 570 F. Supp. 3d 1369, 1382 (2022), in the Sixth Administrative Review of the

countervailing duty order on crystalline silicon photovoltaic cells, whether or not assembled into

modules (“solar cells”), from the People’s Republic of China, covering the period from January 1,

2017, to December 31, 2017. See Redetermination Pursuant to Court Remand Order, ECF Nos.

93–94 (“Remand Results”). Plaintiff Risen Energy Co., Ltd. (“Risen Energy”) and Consolidated

Plaintiff Jingao Solar Co, Ltd. (“JA Solar”) (collectively, “Plaintiffs”)1 challenge the Remand

Results as unsupported by substantial evidence or otherwise not in accordance with law.

BACKGROUND

While the court presumes familiarity with the facts as set out in Risen, the court briefly

summarizes the relevant record evidence for ease of reference. In March 2019, Commerce began

the Sixth Administrative Review of the countervailing duty order on solar cells from the People’s

Republic of China. Initiation of Antidumping and Countervailing Duty Administrative Reviews,

84 Fed. Reg. 9,297, 9303–04 (Dep’t Commerce Mar. 14, 2019). On November 5, 2019, the U.S.

International Trade Administration selected JA Solar and Risen Energy as mandatory respondents

(“Mandatory Respondents”) in this review. See Dep’t Commerce, Resp’t Selection Mem. at 1–2,

1 Intervenor Plaintiffs Shanghai BYD Co., Ltd. (“Shanghai BYD”) and Trina Solar Co., Ltd. (“Trina”) are non-examined parties who seek the benefits of whatever relief the court grants. See Remand Results at 4; Trina Comments on Remand Results, ECF No. 99 (Nov. 7, 2022); Shanghai BYD Comments on Remand Results, ECF No. 100 (Nov. 7, 2022) (“Shanghai BYD Brief”). Consol. Court No. 20-03912 Page 3

P.R. 98 (Nov. 5, 2019).

Commerce published its preliminary results on February 11, 2020, see Crystalline Silicon

Photovoltaic Cells, Whether or Not Assembled Into Modules, From the People’s Republic of

China: Preliminary Results of Countervailing Duty Administrative Review and Rescission of

Review, in Part; 2017, 85 Fed. Reg. 7,727 (Dep’t Commerce Feb. 11, 2020), along with the

accompanying Preliminary Issues and Decision Memorandum, Decision Memorandum for the

Preliminary Results of the Countervailing Duty Order on Crystalline Silicon Photovoltaic Cells,

Whether or Not Assembled Into Modules, from the People’s Republic of China, C-570-980, POR

01/01/2017–12/31/2017 (Dep’t Commerce Jan. 31, 2020) (“PDM”).

Commerce published its final determination on December 9, 2020. See Crystalline Silicon

Photovoltaic Cells, Whether or Not Assembled Into Modules, From the People’s Republic of

China: Final Results of Countervailing Duty Administrative Review; 2017, 85 Fed. Reg. 79,163

(Dep’t Commerce Dec. 9, 2020); see also Issues and Decision Memorandum for Final Results of

the Administrative Review of the Countervailing Duty Order on Crystalline Silicon Photovoltaic

Cells, Whether or Not Assembled Into Modules, from the People’s Republic of China, C-570-980,

POR 01/01/2017-12/31/2017 (Dep’t Commerce Nov. 27, 2020) (“I&D Memo”).

In Risen, the court upheld Commerce’s determination that Plaintiffs received regionally

specific electricity subsidies subject to countervailing duties. See 570 F. Supp. 3d at 1382. The

court remanded to Commerce to reconsider (1) the benchmark for land prices in China and (2) the

benchmark for determining the cost of ocean freight for subsidy calculations involving provisions

of raw materials for less than adequate remuneration. Id. at 1376, 1379. Additionally, the court

granted the United States’ (“Government”) request for remand on the Government of China’s

(“GOC”) Export Buyer’s Credit Program (“EBCP”) but instructed Commerce to attempt to verify Consol. Court No. 20-03912 Page 4

or to explain the reason that the court “should not provide some form of equitable relief.” Id. at

1373.

Following remand, Commerce recalculated (1) the land benchmark by averaging the prior

dataset with new data placed on the remand record and (2) the ocean freight benchmark by

adjusting the previous average to correct the overreliance on data related to United States to China

routes. See Remand Results at 1–2. Finally, Commerce attempted to verify nonuse of the EBCP

by the Mandatory Respondents, finding that JA Solar did not use the program but concluding that

Risen could not show nonuse. Remand Results at 1.

The Remand Results do not adequately address all of the court’s concerns in Risen and

they are not supported by substantial evidence. Accordingly, the court once again remands with

further instructions.

JURISDICTION & STANDARD OF REVIEW

The court’s jurisdiction continues pursuant to 19 U.S.C. § 1516a(a)(2)(B)(i) and 28 U.S.C.

§ 1581(c). The court sustains Commerce’s final redetermination results unless they are

“unsupported by substantial evidence on the record, or otherwise not in accordance with law[.]”

19 U.S.C. § 1516a(a)(2)(B)(i). “The results of a redetermination pursuant to court remand are also

reviewed for compliance with the court’s remand order.” U.S. Steel Corp. v. United States, 41

CIT __. __, 219 F. Supp. 3d 1300, 1307 (2017) (internal quotations and citations omitted).

DISCUSSION

I. Export Buyer’s Credit Program

The GOC’s EBCP promotes exports by providing credit at preferential interest rates to

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