Recently, the U.S. Department of Commerce has decided to initiate an anti-circumvention investigation against modules made in four Southeast Asian countries: Malaysia, Thailand, Vietnam and Cambodia, and imported to the US from the four countries. These productions are alleged to have been set up in order to evade U.S. anti-dumping duty (AD) and countervailing duty (CVD), despite of the fact that through years of litigation at CIT, the production process from wafer to cells has been determined to be substantial and not minor. We are deeply disappointed at this course of action taken by the U.S. Department of Commerce. It would inevitably

1 increase the cost for U.S solar industry downstream players which makes up majority of the solar industry job opportunities in the U.S, and subsequently increase the cost of green energy for millions of Americans.

2. The imposition of high duties on Chinese enterprises in Southeast Asia and especially its potential retroactive nature of this sky high duty leads to extreme uncertainty to solar producers and therefore U.S buyers. It is also unfair for those American companies who have entered into agreement to bear additional duties to have to face this unbearably high cost.

We look forward to and urge a prompt closure of the investigation in order to restore U.S solar market supply and to realize America’s clean energy target.