Risen Energy Co. v. United States

724 F. Supp. 3d 1356, 2024 CIT 94
United States Court of International Trade·Decided August 16, 2024·No. 23-00153·Published·Cited by 1 cases

Opinion

Slip Op. 24-

UNITED STATES COURT OF INTERNATIONAL TRADE

RISEN ENERGY, CO., LTD.,

Plaintiff,

v.

UNITED STATES, Before: Jane A. Restani, Judge Defendant, Court No. 23-00153 and

AMERICAN ALLIANCE FOR SOLAR MANUFACTURING,

Defendant-Intervenor.

OPINION

[The court remands Commerce’s Ninth Administrative Review for results consistent with this opinion.]

Dated: August 16, 2024

Gregory S. Menegaz, deKieffer & Horgan, PLLC, of Washington, DC, for the plaintiff, Risen Energy, Co., LTD. With him on the brief were Alexandra H. Salzman, Judith L. Holdsworth, and Vivien J. Wang.

Ravi D. Soopramanien, Trial Attorney, Commercial Litigation Branch, Civil Division, U.S. Department of Justice, of Washington, DC, for the defendant. With him on the brief were Brian M. Boynton, Principal Deputy Assistant Attorney General, Patricia M. McCarthy, Director, and Reginald T. Blades, Jr., Assistant Director. Of counsel on the brief was Spencer C. Neff, Office of Chief Counsel for Trade Enforcement & Compliance, U.S. Department of Commerce, of Washington, DC.

Timothy C. Brightbill, Wiley Rein, LLP, of Washington, DC, for the defendant-intervenor, the American Alliance for Solar Manufacturing. With him on the brief was Laura El-Sabaawi.

Court No. 23-00153 Page 2

Restani, Judge: This action is a challenge to the final determination made by the United States Department of Commerce (“Commerce”) in the Ninth 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 (“China”) covering the period from January 1, 2020, to December 31, 2020. Plaintiff Risen Energy, Co., LTD., (“Risen”) requests that the court hold aspects of Commerce’s final determination unsupported by substantial evidence or otherwise not in accordance with law. The United States (“Government”) asks that the court sustain Commerce’s final determination.

BACKGROUND

Commerce published a countervailing duty order on solar cells from China on December 7, 2012. See Crystalline Silicon Photovoltaic Cells, Whether or Not Assembled Into Modules, From the People’s Republic of China: Countervailing Duty Order, 77 Fed. Reg. 73,017 (Dep’t Commerce Dec. 7, 2012). In February 2022, Commerce began its Ninth Administrative Review of this countervailing duty order, covering the period of January 1, 2020, to December 31, 2020. Initiation of Antidumping and Countervailing Duty Administrative Reviews, 87 Fed. Reg. 6,487 (Dep’t Commerce Feb. 4, 2022). On March 22, 2022, the U.S. International Trade Administration selected Risen as one of two mandatory respondents in this review. Dep’t Commerce, Respondent Selection Memorandum, P.R. 47 (Mar. 22, 2022).

Commerce published the preliminary results on January 3, 2023, 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; 2020, 88 Fed. Reg. 1,355 (Dep’t Commerce Jan. 3, 2023), 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,

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Whether or Not Assembled Into Modules, from the People’s Republic of China, C-570-980, POR 01/01/2020-12/31/2020 (Dep’t Commerce Jan. 3, 2023) (“PDM”).

Commerce published its final determination on June 29, 2023. 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; 2020, 88 Fed. Reg. 44,108 (Dep’t Commerce July 11, 2023); 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 01/01/2020-12/31/2020 (Dep’t Commerce June 29, 2023) (“IDM”).

In the final results, Commerce included the Government of China’s (“GOC”) Export Buyer’s Credit Program (“EBCP”) in its calculation of Risen’s countervailing duty (“CVD”) rate. IDM at 15–16. EBCP promotes exports by providing credit at preferential interest rates to qualifying foreign purchasers of Chinese goods. See Clearon Corp. v. United States, 359 F. Supp. 3d 1344, 1347 (CIT 2019). As in prior reviews, during the Ninth Administrative Review, Risen reported that none of its customers used the EBCP during the Period of Review (“POR”) and confirmed that it had never been involved in assisting customers in obtaining loans under the program; it also provided certifications of non-use from all but one of its U.S. customers attesting to this fact. See Risen, Section III Questionnaire Response at 40–41, Ex. 18, P.R. 119–124, C.R. 169–177 (May 27, 2022) (“Risen Questionnaire Response”). The GOC, however, did not provide all of the initially requested information to Commerce, stating that Commerce’s questions about which partner banks were involved in the EBCP program were inapplicable because to the best of the GOC’s knowledge “none of the respondents applied for, used, or benefitted from” the EBCP

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program. GOC, Response to Section II Initial Questionnaire at 147–48, P.R. 125–149, C.R. 205– 242 (May 27, 2022) (“GOC Questionnaire Response”).

In the IDM, Commerce explained that, based on the record before it, it was including the EBCP subsidy in its calculation of the CVD rate it applied to Risen because Risen had failed to supply it with sufficient record evidence to determine non-use and thus fill the gap caused by the GOC’s noncooperation. IDM at 15–16. Risen then sought review of this decision at this court, arguing that Commerce’s decision was not based on substantial evidence and was otherwise not in accord with the law. Compl. at 5–6, ECF No. 8 (Sept. 11, 2023).

JURISDICTION & STANDARD OF REVIEW The court’s jurisdiction is pursuant to 19 U.S.C. § 1516a(a)(2)(B)(iii) (2018) and 28 U.S.C. § 1581(c) (2018). 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(b)(1)(B)(i).

DISCUSSION

Risen argues that Commerce’s decision to include EBCP in Risen’s rate is unsupported by record evidence and is contrary to law. Mot. for J. on the Agency Record at 3, ECF No. 30 (Jan. 31, 2024) (“Risen Br.”). Specifically, Risen argues that the record in this case does not support that a gap exists which would merit a finding that Risen used EBCP, and argues that, if such a gap exists and continues to persist despite Risen’s submissions, Commerce should have notified Risen that its response was deficient and given Risen the opportunity to remedy the deficiency. Risen Br. at 5. Further, Risen argues that, if the record does support a gap, because Risen has supplied non-use certificates for the majority of its customers representing nearly all of its sales, Commerce should pro-rate the EBCP subsidy amount to account for the fact that, for such sales, the gap has

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been filled. Risen Br. at 7, 14–15. Commerce replies that a gap continues to exist, that Risen’s deficient submission was not requested by Commerce and so no notice of deficiency was merited, and that it is not Commerce’s practice to pro-rate the EBCP subsidy in the way that Risen requests and so it should not pro-rate here. Resp. in Opp. to Mot. for J. on the Agency Record at 5–6, 17, ECF No. 33 (Apr. 10, 2024) (“Gov. Br.”). The court addresses each of these arguments below in turn.

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