United States Steel Corp. v. United States

925 F. Supp. 2d 1328, 2013 CIT 97, 2013 WL 3942964, 35 I.T.R.D. (BNA) 1832, 2013 Ct. Intl. Trade LEXIS 101
CourtUnited States Court of International Trade
DecidedJuly 31, 2013
DocketSlip Op. 13-97; Court 12-00070
StatusPublished

This text of 925 F. Supp. 2d 1328 (United States Steel Corp. 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.

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United States Steel Corp. v. United States, 925 F. Supp. 2d 1328, 2013 CIT 97, 2013 WL 3942964, 35 I.T.R.D. (BNA) 1832, 2013 Ct. Intl. Trade LEXIS 101 (cit 2013).

Opinion

OPINION

MUSGRAVE, Senior Judge:

Plaintiff United States Steel Corp. (“Plaintiff’) challenges the Department of Commerce’s (“Commerce”) final results in the 2009 countervailing duty administrative review of Certain Corrosion-Resistant Carbon Steel Flat Products from the Republic of Korea, 77 Fed.Reg. 13093 (Dept. Commerce, Mar. 5, 2012) Public Record Part 1 Doc. '(“PR1”) 49 (“Final Results”). Plaintiff challenges the benchmark interest rate used by Commerce to determine whether and to what extent sales in the U.S. of Defendant-Intervenor Hyundai Hysco Ltd.’s (“Hysco”) products were affected by a cohntervailable subsidy.

JURISDICTION AND STANDARD OF REYIEW

The -court has jurisdiction pursuant to 28 U.S.C.,§ 1581(c). Commerce’s final determination will be upheld unless it is found “to be unsupported - by substantial evidence on the record, or otherwise not in accordance with law.” 19 U.S.C. § 1516a(b)(l)(B)(i). More specifically, *1330 when reviewing agency determinations, findings or conclusions for substantial evidence the court assesses whether the agency action is reasonable given the record as a whole. Nippon Steel Corp. v. United States, 458 F.3d 1345, 1350-51 (Fed.Cir.2006).

Separately, the two-step framework provided in Chevron, U.S.A., Inc. v. Natural Res. Def. Council, Inc., 467 U.S. 837, 842-45, 104 S.Ct. 2778, 81 L.Ed.2d 694 (1984), governs judicial review of Commerce’s interpretation of the antidumping statute. See United States v. Eurodif S.A., 555 U.S. 305, 316, 129 S.Ct. 878, 172 L.Ed.2d 679 (2009) (Commerce’s “interpre-: tation governs in the absence of unambiguous statutory language to the contrary or unreasonable resolution of language that is ambiguous”). Commerce’s interpretation will not be set aside unless it is “arbitrary, capricious, or manifestly contrary to the statute.” Chevron, 467 U.S. at 844, 104 S.Ct. 2778.

FACTS

Commerce reviewed loans that Hysco received from the government-owned Export-Import Bank of Korea (KEXIM), for the period of calendar year 2009. Commerce had previously determined that the KEXIM program loans were countervailable. Issues and Decision Memorandum in Corrosion-Resistant Carbon Steel Flat Products from the Republic of Korea, 77 Fed.Reg. 13093 (Dept. Commerce Mar. 5, 2012) (“I & D Memo”) at 2-3.

The KEXIM loans were short-term, variable rate loans, whose interest rate changed monthly. I & D Memo at 3. Hysco received the KEXIM loans in 2008 and by their terms they extended into 2009. Commerce initially determined that the KEXIM loans should be benchmarked against all 2008 commercial loans received by Hysco. Corrosion-Resistant Carbon Steel Flat Products from the Republic of Korea, 76 Fed.Reg. 54208 (Dept. Commerce Aug. 31, 2011) (“Preliminary Results”). Hysco pointed out that the 2008 interest rates were much higher than the rates charged in 2009 and argued that the 2009 KEXIM loan payments should be judged against annual average 2009 interest rates. In response, Commerce decided that only Hysco’s short term variable interest rate loans were comparable to the KEXIM loans and requested further information from Hysco. Commerce removed Hysco loans taken out in 2009 from the benchmark, because the KEXIM loans were taken out in 2008. Final Results, 77 Fed.Reg. at 13093.

Commerce then determined how the commercial loans’ variable interest rates were calculated. It identified the commercial loans’ monthly base CD rate regularly reported by the Korean Financial Investment Association, and their specific fees and interest rate spreads. I & D Memo at 10-11. Commerce then applied a weighted average calculation to determine monthly rates for the 2009 review period. Plaintiffs Memorandum In Support of Motion for Judgment on the Agency Record under Rule 56.2 (“PI. Br.”) at 11, and sources cited therein. Commerce concluded that the resulting rates reflected the interest rates that Hysco would have paid had the commercial loans extended into 2009 and been paid on the same date as Hysco’s KEXIM loan payments. I & D Memo at 10-11. Commerce thus determined what the short-term commercial loan rates would have been had Hysco made payments under the 2008 loans in 2009. I & D Memo at 11; see 19 C.F.R. § 351.505. Commerce stated:

HYSCO took out comparable, variable rate, short-term financing in 2008, which is the year in which the KEXIM short-term financing was taken out. Therefore, we used the variable rate loans provided by commercial banks during *1331 2008 to determine our weighted-average commercial benchmark and compared the benchmark rate to the interest rate charged on the KEXIM loans. To determine the benefit from the KEXIM loan, we then compared the amount of actual interest paid on the KEXIM loan to the amount HYSCO should have paid at the commercial benchmark.

I & D Memo at 11. Commerce found that the ad valorem subsidy rate fell from a preliminary finding of 0.09% to the final determination of only 0.03% subsidy. I & D Memo at 3. Commerce determined for this review period that the benefit enjoyed by Hysco under the program was a de minimis rate of 0.46% and thus not countervailable. Final Results, 77 Fed.Reg. at 13094.

ANALYSIS

The relevant statute provides:

(E) Benefit conferred A benefit shall normally be treated as conferred where there is a benefit to the recipient, including — * * *
(ii) in the case of a loan, if there is a difference between the amount the recipient of the loan pays on the loan and the amount the recipient would pay on a comparable commercial loan that the recipient could actually obtain on the market....

19 U.S.C. § 1677(5)(E)(ii). Commerce determines a loan benchmark by looking at loans the company received from commercial lenders, 19 C.F.R. § 351.505(a)(3)(i), provided those loans are comparable to the government loan involved. 19 C.F.R. § 351.505(a)(2)(i). Commerce “normally will rely on the actual experience of the firm in question in obtaining comparable commercial loans.” 19 C.F.R. § 351.505(a)(3)(i).

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925 F. Supp. 2d 1328, 2013 CIT 97, 2013 WL 3942964, 35 I.T.R.D. (BNA) 1832, 2013 Ct. Intl. Trade LEXIS 101, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-steel-corp-v-united-states-cit-2013.