64 FR 14695, March 26, 1999 DEPARTMENT OF COMMERCE International Trade Administration [C-560-804] Final Negative Countervailing Duty Determination: Extruded Rubber Thread From Indonesia AGENCY: Import Administration, International Trade Administration, Department of Commerce. EFFECTIVE DATE: March 26, 1999. FOR FURTHER INFORMATION CONTACT: Robert Copyak or Eric B. Greynolds, Office of CVD/AD Enforcement VI, Import Administration, International Trade Administration, U.S. Department of Commerce, 14th Street and Constitution Avenue, NW, Washington, DC 20230; telephone: (202) 482- 2786. FINAL DETERMINATION: The Department of Commerce (the ``Department'') determines that countervailable subsidies are not being provided to producers or exporters of extruded rubber thread (ERT) in Indonesia. [[Page 14696]] Case History Since the publication of the preliminary negative determination in the Federal Register on September 9, 1998, (63 FR 48191) (Preliminary Determination), the following events have occurred. Between September 23 and October 2, 1998, we conducted verification of the responses of the Government of Indonesia (GOI) and the respondent companies, P.T. Swasthi Parama Mulya (Swasthi) and Bakrie Rubber Industries (Bakrie). Swasthi submitted a case brief on December 1, 1998. No other parties to this investigation filed case briefs or rebuttal briefs. A public hearing was not requested by any interested party. Scope of Investigation For purposes of this investigation, the product covered is extruded rubber thread (ERT) from Indonesia. ERT is defined as vulcanized rubber thread obtained by extrusion of stable or concentrated natural rubber latex of any cross sectional shape, measuring from 0.18 mm, which is 0.007 inches or 140 gauge, to 1.42 mm, which is 0.056 inch or 18 gauge, in diameter. ERT is currently classified under subheadings 4007.00.00 of the Harmonized Tariff Schedule (HTS). Although the HTS subheadings are provided for convenience and customs purposes, the written description of the scope of this investigation is dispositive. The Applicable Statute and Regulations Unless otherwise indicated, all citations to the statute are references to the provisions of the Tariff Act of 1930, as amended by the Uruguay Round Agreements Act effective January 1, 1995 (the Act). In addition, unless otherwise indicated, all citations to the Department's regulations are to the regulations codified at 19 CFR 351 and published in the Federal Register on May 19, 1997 (62 FR 27295). Petitioner The petition in this investigation was filed by North American Rubber Thread Co., Ltd. (the petitioner). Period of Investigation The period for which we are measuring subsidies (the ``POI'') is calendar year 1997. De Minimis Countervailable Subsidy Pursuant to its authority under section 771(36) of the Act, the United States Trade Representative (``USTR'') has designated Indonesia as a ``least developed country.'' See USTR Interim Final Rule: Developing and Least-Developed Country Designations Under the Countervailing Duty Law 15 CFR 2013 (63 FR 29945). Consequently, a net countervailable subsidy rate that does not exceed three percent ad valorem is considered de minimis, in accordance with section 703(b)(4)(B) of the Act, which implements Article 27 of the Agreement on Subsidies and Countervailing Measures (``SCM Agreement''). As discussed below, we determine that the net countervailable subsidy bestowed on extruded rubber thread from Indonesia is less than three percent ad valorem, and therefore, de minimis. Analysis of Programs Based upon our analysis of the petition, the responses to our questionnaires, the information reviewed at verification, and written briefs submitted by interested parties, we determine the following: I. Programs Determined to Be Countervailable A. Bank of Indonesia (BI) Rediscounted Loans Under Decree No. 132/MPP/Kep/1996 of June 4, 1996, the Ministry of Industry and Trade, the Ministry of Finance, and the Bank of Indonesia (BI) provide support for certain exporters with the goal of achieving diversification of the Indonesian export base from oil and gas. Under the program, companies can sell their letters of credit and export drafts at a discount to the BI through participating foreign exchange banks, which are commercial banks that have obtained a license to conduct activities in foreign currencies. In the Preliminary Determination, we determined that this program was countervailable because the sale of the letters of credit and export drafts provided exporters with working capital at lower interest rates than they would otherwise obtain on the market. Our review of the information on the record, our findings at verification, and our analysis of the case brief submitted by Swasthi (see Comment 1) has not led us to change our preliminary determination that this program is countervailable. During the POI, Swasthi obtained rediscounted loans under the BI rediscount loan program, as well as commercial rediscounted loans that were not associated with the BI rediscount loan program. Because Swasthi is a Designated Export Company (PET), it was eligible to obtain BI rediscounted loans at a rate that was lower than the rate available to non-PET companies, specifically, at the Singapore Interbank Offering Rate (SIBOR) rather than SIBOR plus one percentage point. For purposes of the Preliminary Determination, we calculated the benefit to Swasthi under this program as the difference in the interest that Swasthi would have paid at the non-PET rate and interest it paid at the PET rate. However, for purposes of this final determination, we are using a different benchmark. According to section 771(5)(E)(ii) of the Act, the benefit conferred under a loan program is the difference between the amount the recipient of the loan pays on the loan under the government program and the amount the recipient would pay on a comparable commercial loan that it could actually obtain on the market. We verified that, during the POI, Swasthi obtained comparable commercial rediscounted loans outside of the BI rediscount loan program. Thus, we determine that those company-specific loans provide a more appropriate benchmark than the benchmark used in the Preliminary Determination. Therefore, instead of the using a rate established by the BI, we calculated the benchmark as the weighted-average interest rate of the non-BI rediscounted loans Swasthi obtained during the POI. In order to calculate the benefit under the program, we calculated the difference in the amount of interest Swasthi actually paid on the BI rediscounted loans during the POI and the amount it would have paid at the benchmark interest rate. We then divided the calculated benefit provided from the BI rediscount loan program by Swasthi's total exports of subject merchandise to the United States during the POI. We used export of subject merchandise to the United States because the loans could be segregated by product and destination. On this basis, we determine the benefit to Swasthi under this program to be 0.18 percent ad valorem for Swasthi. No other producers/exporters of the subject merchandise applied for or received loan under this program during the POI. II. Programs Determined To Be Not Used Based on the information provided in the responses and the results of verification, we determine that, during the POI, the producers/ exporters of subject merchandise did not apply for or receive benefits under the following programs: A. Investment Credit for the Expansion of the Rubber Industry. B. Corporate Income Tax Holiday. C. Import Duty Exemption of Capital Equipment. [[Page 14697]] Interest Party Comment Comment 1: Benchmark Used in the Calculation of the Bank of Indonesia (BI) Rediscount Loan Program: Swasthi states that the Department should continue to use the benchmark interest rate employed in the Preliminary Determination, (i.e., the interest rate differential between the BI's PET rate and the non-PET rate). Swasthi further argues that, when calculating the benefit provided by BI rediscounted loans, the Department should take into consideration the opportunity costs that Swasthi incurred as a result of collateral deposits. Swasthi states that collateral deposits are a typical banking practice in Indonesia. Department's Position: We disagree with Swasthi's argument that the Department should continue to calculate the benefit to Swasthi using the BI rate for non-PET companies for comparison purposes. As explained above, section 771(5)(E)(ii) of the Act states that the benefit from a government loan program should be based upon comparable commercial loans that the company could actually obtain on the market. During the POI, Swasthi obtained comparable commercial rediscounted loans which are not associated with the BI rediscount loan program. Therefore, these loans are a more appropriate basis for benchmark purposes than the BI rediscount rate for non-PET companies. Also we disagree that we should factor into our benefit calculations opportunity costs associated with collateral deposits. In determining whether particular loans are comparable for benchmark purposes, the Department normally focuses on the structure of the loans, the maturities of the loans, and the currencies in which the loans are denominated. As explained above, we have determined that Swasthi's commercial rediscounted loans are appropriate for benchmark purposes. They have comparable structures and maturities and are denominated in dollars. As Swasthi acknowledges, collateral requirements are a typical bank practice in Indonesia. Both banks that participate in the BI rediscount loan program and banks that do not participate in the BI rediscount loan program require collateral. Moreover, collateral requirements vary across banks and loan types. Based on these facts, there is no basis for factoring in collateral requirements in determining the effective interest rates, nor is there a basis for finding that Swasthi's commercial rediscounted loans are not an appropriate benchmark. Verification In accordance with section 782(i) of the Act, we verified the information used in making our final determination. We followed our standard verification procedures, including meeting with government and company officials, and examining relevant accounting records and original source documents. Our verification results are outlined in detail in the public versions of the verification reports, which are on file in the Central Records Unit (Room B-099 of the Main Commerce Building). Summary In accordance with section 705(a)(3) of the Act, we determine that the total net countervailable subsidy rate for Bakrie is zero and that the total net countervailable subsidy rate for Swasthi is 0.18 percent ad valorem, which is de minimis. Therefore, we determine that no countervailable subsidies are being provided to the production or exportation of extruded rubber thread from Indonesia. Pursuant to section 705(c)(2) of the Act, this investigation will be terminated upon the publication of the final negative determination in the Federal Register. ITC Notification In accordance with section 705(d) of the Act, we will notify the ITC of our determination. Return or Destruction of Proprietary Information This notice serves as the only reminder to parties subject to Administrative Protective Order (``APO'') of their responsibility concerning the return or destruction of proprietary information disclosed under APO in accordance with 19 CFR 355.34(d). Failure to comply is a violation of the APO. This determination is published pursuant to section 705(d) of the Act. Dated: March 18, 1999. Robert S. LaRussa, Assistant Secretary for Import Administration. [FR Doc. 99-7372 Filed 3-25-99; 8:45 am] BILLING CODE 3510-DS-P