83-a20

NOTICES

DEPARTMENT OF COMMERCE

International Trade Administration

[C-274-002]

Carbon Steel Wire Rod From Trinidad and Tobago Preliminary Affirmative
Countervailing Duty Determination

Thursday, October 20, 1983

AGENCY: International Trade Administrastion, Commerce.

ACTION: Notice.

SUMMARY: We preliminarily determined that certain benefits which constitute bounties or
grants within the meaning of the countervailing duty law are being provided to
manufacturers, producers or exporters in Trinidad and Tobago of carbon steel wire rod,
as described in the "Scope of Investigation" section of this notice. Therefore, we are
directing the U.S. Customs Service to suspend liquidation of all entries of the merchandise
subject to this determination which are entered, or withdrawn from warehouse, for
consumption, and to require a cash deposit or bond on this merchandise in an amount
equal to 12.29 percent of the ad valorem value of the subject merchandise. If this
investigation proceeds normally, we will make our final determination by December 27,
1983.

EFFECTIVE DATE: October 20, 1983.

FOR FURTHER INFORMATION CONTACT:Andrew Debicke, Office of Investigations, Import
Administration, International Trade Administration, U.S. Department of Commerce,
14th Street and Constitution Avenue, N.W., Washington, D.C. 20230, telephone (202)
377-5403.

SUPPLEMENTARY INFORMATION:

Preliminary Determination

Based upon our investigation, we preliminarily determine that there is reason to believe
that benefits which constitute bounties or grants within the meaning of section 303 of the
Tariff Act of 1930, as amended (the Act), are being provided to producers or exporters in
Trinidad and Tobago of carbon steel wire rod, as described in the "Scope of Investigation"
section of this notice.
For purposes of this investigation, we preliminarily determine that government guaranteed
loans confer a benefit to manufacturers, producers, or exporters in Trinidad and Tobago
of wire rod. The estimated bounty or grant is 12.29 percent ad valorem.

Case History

On May 16, 1983, we received a petition from counsel for Atlanic Steel Company,
Continental Steel Corporation, Georgetown Steel Corportion, Georgetown Texas Steel
Corporation and Raritan River Steel Company on behalf of the U.S. industry producing
carbon steel wire rod. The petition alleged that producers, manufacturers, or exporters in
Trinidad and Tobago of steel wire rod receive, directly or indirectly, bounties or grants
within the meaning of section 303 of the Tariff Act of 1930, as amended (the Act).
We found the petition to contain sufficient grounds upon which to initiate a
countervailing duty investigation and, on June 6, 1983, we initiated a countervailing
duty investigation (48 FR. 27415). We stated that we would issue a preliminary
determination on or before August 9, 1983. We subsequently determined that the
investigation is "extraordinarily complicated," as defined in section 703(C) or the Act, and
postponed our preliminary determination until October 13, 1983 (48 FR 43206).
Trinidad and Tobago is not a "country under the Agreement" within the meaning of section
701(b) of the Act, and, therefore, section 303 of the Act applies to this investigation. Under
this section, since the merchandise being investigated is dutiable, the domestic industry is
not required to allege that, and the U.S. International Trade Commission is not required to
determine whether, imports of this product cause or threaten material injury to a U.S.
industry.
On April 18, 1983, we presented questionnaires concerning the allegations in the petition to
the

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government of Trinidad and Tobago and to counsel for the Iron and Steel
Company of Trinidad and Tobago (ISCOTT) in Washington, D.C. On August 12, 1983, we
received the responses to our questionnaire from the government of Trinidad and Tobago
and ISCOTT.

Scope of Investigation

The product covered by this investigation is carbon steel wire rod, a coiled semi-finished,
hot-rolled carbon steel product of approximately round solid cross section, not under 0.20
inch nor over 0.74 inch in diameter, not tempered, not treated, not partly manufactured,
and valued over 4 cents per pound. The merchandise is currently classified under item
number 607.17 of the Tariff Schedules of the United States.
ISCOTT is the sole producer and exporter of carbon steel wire rod from Trinidad and
Tobago.
The period for which we are measuring subsidization is January 1, 1982 to April 30, 1983.

Analysis of Programs

In their responses, the government of Trinidad and Tobago and ISCOTT provided data for
the applicable period. Based upon our analysis of the petition, the response to our
questionnaire, and legal briefs submitted by counsel for the ISCOTT and the petitioners, we
determine the following:

I. Programs Preliminarily Determined To Confer Bounties or Grants

We preliminarily determine that a bounty or grant is provided to manufactuers, producers,
or exporters in Trinidad and Tobago of carbon steel wire rod under the program listed
below.

A. Government Guarantees of Debt Service

Section 401, article I of the Completion and Cash Deficiency Agreement (CCDA), a financing
contract entered into by the Government of Trinidad and Tobago (GOTT), ISCOTT and
several external private and government-sponsored lenders, states "if, for any reason
whatsoever, ISCOTT shall fail to pay or to pay in full any debt service amount on any debt
service date with respect thereto, the Government, in consideration for the loans made by
the lenders to ISCOTT, shall, and hereby covenants and agrees with each of the lenders to,
pay to the lenders or the lender entitled to such debt service amount the cash deficiency in
respect thereof . . . within 10 days after the applicable debt service date, unless prior
thereto ISCOTT shall have paid such cash deficiency in full."
During the period 1978-1981, ISCOTT obtained several medium-term loans from private
lenders and other government loan agencies in the United States and elsewhere. Petitioners
allege that the guarantees provided for in Article IV of the CCDA enabled ISCOTT to obtain
these loans at interest rates several points below those charged for comparable commercial
loans. They contend that ISCOTT would have had to pay a substantial premium over the
commercial rate charged (estimated by petitioner as 5 percent) if the loan financing had not
been backed by a government guarantee.
Regarding the inclusion of a risk premium in the calculation of the benchmarks for
measuring potential benefits to ISCOTT resulting from the GOTT's guarantees, the
Department generally avoids such adjustments. Without substantial evidence on the record
to support the use of a specific primium amount, we run the risk of substituting speculative
and debatable assumptions as to the value of a guarantee for the recorded, independent
judgment of the financial marketplace. In the absence of a sound basis upon which to fix the
value of a risk premium, we have calculated the benefit to ISCOTT of the GOTT's guarantees
by estimating the value of its not having to pay loan guarantee fees otherwise payable by a
borrower in a comparable commercial transaction.
Similarly, we have made no adjustment in the rates paid by ISCOTT to reflect the company's
payment of withholding taxes on foreign loans. Respondents contend that these tax
liabilities result in a higher effective rate on such loans. The Department's long-standing
administrative practice has been to consider the entire bounty or grant. Under section
771(6) of the Act the tax consequencies of countervailable benefits do not constitute an
allowable offset.
On the basis of our understanding of standard commercial banking practice in comparable
transactions, we have determined the normal guarantee fees payable in this situation. To
calculate the subsidy value we compared the interest rates actually paid by ISCOTT with an
adjusted rate reflecting the additional value of a government guarantee. After calculating
the payment differential in each year of the loan, we then calculated the present value of
this stream of benfits using the risk free rate, the secondary market rate of interest for
long-term government debt in Trinidad and Tobago, as the discount rate. This amount was
then allocated evenly over the life of the appropriate loan to yield the annual subsidy
amount. The estimated net bounty or grant is 12.29 percent ad valorem.

II. Programs Preliminarily Determined Not To Be Used

We preliminarily determine that the following programs have not been used by producers
or exporters in Trinidad and Tobago of carbon steel wire rod.

A. Tax Benefits

Petitioners allege that ISCOTT benefits from preferential tax treatment accorded under the
Fiscal Incentives Act and other provisions of the tax laws of Trinidad and Tobago.
The responses of both ISCOTT and the GOTT indicate that ISCOTT has not received any
benefits or allowances available under the Fiscal Incentives Act or other provisions of the
tax laws of Trinidad and Tobago. We will, however, seek additional information regarding
the possibility that potential tax benefits arising out these provisions may be carried
forward to later years.

B. Worker Training

Petitioners allege ISCOTT has benefitted from worker training subsidies provided through
the Industrial Development Corporation.
The responses of both ISCOTT and the GOTT indicate the company has received no
assistance for employee training under this program during the period of investigation. The
responses do indicate, however, that some ISCOTT employees received training from the
Management Development Centre (MDC). The MDC is a statutory body governed by a board
of directors composed of individuals from both the public and private sectors. Courses
offered and fees charged are approved by the board. Fees for the training of ISCOTT workers
under this program were paid by the company. We will seek additional information
regarding the MDC during verification.

C. Marketing Assistance

Petitioners allege ISCOTT has benefitted from marketing assistance provided by the GOTT
through the International Marketing Organization Fund. The responses of both the GOTT
and ISCOTT indicate ISCOTT has received no assistance under this program.

D. Preferential Export Insurance

Petitioners allege ISCOTT has benefitted from preferential export insurance provided
through the Export Insurance Company, Ltd. The responses

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of both ISCOTT and
the GOTT indicate ISCOTT did not purchase any export credit insurance during the period
for which we are measuring subsidization.

E. Export Shipping Rates

Petitioners allege ISCOTT has benefitted from preferential shipping rates provided at
government direction or with government financial assistance.
The Shipping Corporation of Trinidad and Tobago (SCOTT) acts as a broker for ISCOTT in
locating private vessel owners and negotiating shipping fees. As such, SCOTT is not
responsible for setting rates, nor does it own any vessels. It is reimbursed for its services on
a commission basis.
During the period of investigation, ISCOTT has used both SCOTT and a private concern
based in New York as its agents for locating vessels and negotiating shipping rates. Rates
have varied with each shipment, and ISCOTT has received no direct assistance from the
GOTT for purposes of paying export freight charges. We have no evidence to indicate
ISCOTT has benefitted from preferential shipping rates as the result of direct or indirect
action by the GOTT.

F. Preferential Loans

In our initiation notice, we stated that we would investigate the allegation that ISCOTT
received loans from the GOTT at preferential interest rates. Information now available to
the Department indicates that private lending institutions served as the sources of ISCOTT's
debt financing. Therefore, we preliminarily determine that no countervailable benefit exists
with respect to this allegation. Regarding the GOTT guarantees of ISCOTT's debt financing,
see the section of this notice entitled "Government Guarantees of Debt Service."

III. Programs for Which Additional Information Is Needed

A. Government Equity Participation in ISCOTT

The Iron and Steel Company of Trinidad and Tobago was incorporated June 20, 1975 to
serve as the vehicle for a joint venture between the Government of Trinidad and Tobago
and three private investors--Hoogovens Igmuiden, B.V.; Kawasaki Steel Corporation and
Mitsui & Company. As originally conceived, the venture would involve the parties in the
ownership and construction of a greenfield steel mill dedicated primarily to billet
production. In 1976-77, changing market conditions led to reevaluation of the project. The
GOTT purchased the equity interests of its partners and redefined the project to envisage
construction of a scaled down mini-mill oriented primarily towards finished products.
Specifically wire rod. After additional feasibility study, the GOTT determined to proceed
with the redefined project. A financing package put together by a private concern was
proposed and, on December 1, 1978, ISCOTT the GOTT, Barclays Bank, Ltd. (as Trustee) and
several external private and government-sponsored lenders entered into a financing
contract, the Completion and Cash Deficiency Agreement. Under the terms of the CCDA, the
lenders committed to a total of approximately U.S. $243 million in capital financing. For its
part, the GOTT agreed to provide equity investment in ISCOTT at a level which maintained a
60/40 debt to equity ratio for the company. Construction commenced on this basis, and
ISCOTT began commercial wire rod production in August 1981. Completion of construction,
as defined in the CCDA, is now scheduled for November 1983. Throughout this period the
GOTT has made equity contributions to ISCOTT in accordance with its obligations under the
CCDA.
It is well established that government equity participation in a commercial enterprise is not
a subsidy per se. In assessing whether such participation gives rise to subsidies within the
meaning of the countervailing duty law, the Department applies the standard of whether
a government's investment is not inconsistent with commercial considerations. The issue is
whether the investment, analyzed in terms of objective business or investment criteria
operative at the time the investment was made, , may be deemed commercially reasonable
in that, from the perspective of a commercial investor making the same decision in the same
circumstance, there is a reasonable expectation of return within an acceptable period of
time.
The test whether a particular investment is not inconsistent with commercial
considerations is based on a case-by-case analysis of the commercial context in which the
investment decision is made. In the case of ISCOTT, an assessment of commercial
reasonableness must take into account the special circumstances of a start-up project in a
developing country.
Factors ordinarily applied in the case of investment in an established industry or enterprise
in a developed country may require adjustment or prove inappropriate. For example,
investments in developing countries pose a variety of special problems which may include
scarcity of capital, lack of complementary infrastructure, shortages of skilled labor,
insufficient managerial experience and other "learning curve" costs. While these may, in
some senses, increase the element of risk in such investments, the increased risk which may
be present does not of itself become dispositive of the issue of whether a particular
investment in a developing economy may be viewed as inconsistent with commercial
considerations.
On the basis of preliminary analysis, the GOTT's decision to proceed with the ISCOTT project
and its subsequent actions to maintain its commitment to it do not appear to contradict the
requirements of commercial reasonableness. First, as originally conceived and later
redefined, the ISCOTT mill was designed to make use of certain natural advantages.
Trinidad and Tobago has ample natural gas reserves. The direct reduction of iron (DRI)
process employed in ISCOTT's mill is particularly well suited to capitalize on the availability
of natural gas. Trinidad and Tobago also enjoys a strategic geographic location close to
plentiful sources of iron ore and to potential Caribbean, North American and South
American markets. Second, the decision to install state of the art technology such as DRI,
electric arc furnaces, continuous casters and high speed rolling equipment builds upon
natural advantages by providing long-term cost efficiencies and producing consistent
qualities of steel. Third, at the time the ISCOTT venture was initially conceived, the
consensus among steel industry analysts was that projected demand would require
installation of considerable new worldwide capacity by 1985. Moreover, as market
conditions changed, the scope and purpose of the project were altered in response.
GOTT's commitments to the ISCOTT project were undertaken on the basis of at least three
independent feasibility studies prepared by private consultants. The original concept of an
integrated mini-mill emerged from both engineering and economic studies. The subsequent
adaptation of the project to emphasize wire rod production was also based on a study which
assessed the potential viability of the redefined project in a changed market. Finally,
preparation of the financing package which formed the basis of the CCDA entailed a third,
independent assessment of the project's financial prospects. All these studies drew tentative
conclusions that the project was feasible and would be profitable. In our view, the GOTT's
decision to supplement its own evaluation of the commercial viability of the ISCOTT project
with independent

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analyses by private consultants indicates a careful approach
consistent with a prudent investment policy.
Independent confirmation of favorable projections made in the studies noted may be
discerned from the decisions of several private commercial lenders to participate in the
debt financing of the ISCOTT project. Participants include private lenders in the U.S., Japan,
Canada and the Federal Republic of Germany. In addition to reviewing the feasibility studies
commissioned by the GOTT, these lenders were also in a position to draw on their own
internal resources and experience to assess the project's viability. That they chose to lend
to the project is further indication of its commercial reasonableness. Moreover, while we do
not question that guarantees provided by the GOTT served as an inducement to private
lenders to finance the ISCOTT project, it is our understanding of commercial banking
practice that any decision to lend would also have been based on additional consideration
of the underlying project's viability and potential apart from the presence of governmental
guarantees or backing. In these circumstances, the participation of private lenders should
not be discounted as having no bearing on the central issue of whether investment in
ISCOTT is consistent with commercial considerations.
If the GOTT's decision to commence the ISCOTT project appears to have been carried out on
a sound commercial basis, its continued commitment through the period of construction
and beginning of commerical production poses somewhat different questions. In this stage,
fundamental assumptions supporting the commercial reasonableness of the decision to
initiate the project must be measured against actual development and operating
experience. The issue is whether that experience raises fundamental questions about the
commercial reasonableness of the GOTT's maintaining its commitment to the ISCOTT
project.
As noted supra, the terms of the CCDA included a commitment by the GOTT to maintain a
60/40 debt-to-equity ratio for ISCOTT. In addition, under Article III of the CCDA, the GOTT
may provide funds necessary to achieve completion of the project. The GOTT's equity
investments in ISCOTT are triggered by either a report or request by the company. The
amount of capital sought is determined by deducting the cash surplus on hand or projected
and available loan capital from total cash liabilities. The amount of the difference is invested
by the GOTT in either working or fixed asset capital. In return for its payments, the GOTT is
issued stock at the established price of TT $100 per share. Funds received in this manner
are charged against ISCOTT's authorized share capital.
The GOTT has continued to make heavy equity investments in ISCOTT during a period in
which the company has encountered significant difficulties associated with construction,
start-up and initial commercial operation. Unanticipated construction delays have resulted
in substantially higher than projected costs which have been compounded by the effects of
inflation. Breakdowns in key plant components and delays in obtaining replacements have
also hampered the project. Shortages of adequately trained operations, maintenance and
management personnel present continuing problems. The plant has yet to approach full
rated capacity, an engineering performance tests for all production units have not been
completed. As a consequence, ISCOTT has not begun to achieve significant production
levels or earnings on its products. It cash flow per-ton of capactiy figures remain negative.
All of this has occurred against the bankground of a severely deteriorated world market for
steel.
The fact construction delays and other difficulties have occurred during the course of
ISCOTT's start-up phase does not, however, necessarily lead to the conclusion that the
assumptions and expectations which arguably supported to GOTT's decision to embark
upon the project are no longer tenable. First, natural advantages such as reliable and
plentiful sources of basic inputs and location appear to continue to support ISCOTT's
long-term prospects. Second, particularly in a developing country, the learning curve costs
associated with the installation of a technologically advanced industrial facility may
reasonably be expected to be higher than those in a more developed economy. Similarly,
shortages of adequately trained manpower needed for the construction and maintenance of
a major industrial plant make it more likely there will be delays in both construction and the
achievement of fully operational status. In this respect it is significant that the CCDA made
specific allowance for the possibility of delay, and that its final deadline for the certification
of completion has not, as yet, been exceeded. Third, while ISCOTT's cash flow per-ton of
capacity figures are negative, they nevertheless compare favorably with available estimates
of expected per-ton development costs for new steel mills in both developing and
developed countries. Fourth, while ISCOTT is not profitable, it has been conducting limited
commercial operations for a period of only 24 months. Regardless of location in a
developed or developing country, the Department has preliminarily found no indication in
any of the sources available to it that a new industrial facility requiring large capital
investment should be expected to show a positive rate of return within so short a time from
the commencement of production. To the contrary, it appears the reasonable commercial
expectation is that the project would normally be expected to operate at a loss for several
years before beginning to earn a positive return on the initial investment. Fifth, lenders who
participated in ISCOTT's debt financing arrangement do not appear to have withdrawn their
support and have continued to make funds available to the company. Sixth, despite
problems with start-up, ISCOTT has made some shipments to unrelated buyers, thereby
demonstrating the existence of at least a potential market for its products.
In sum, while ISCOTT may not yet have unquestionably proven itself as a viable,
self-sustaining venture, nothing in its experience to date establishes a compelling argument
that the considerations or expectations which led the GOTT to begin the project have, in
light of subsequent developments, lost all measure of commercial reasonableness. Though
difficulties encountered during start-up have led to substantial cost increases not
contemplated in the original projections, the GOTT's continuing commitment to the project,
a commitment seconded by independent lenders, does not at this juncture appear wholly
inconsistent with commerical considerations as we perceive them to operate within the
context of establishing a technologically advanced greenfield industrial facility in a
developing country.
Nevertheless, we are not unmindful of petitioner's contention that the withdrawal of Dutch
and Japanese co-venturers at an early stage of the project raises questions as to its
feasibility. We note, however, that the project underwent a basic alteration in concept
following this withdrawal. The original plan had been for a mill to produce over a million
metric tons of billets annually. A substantial portion of this capacity was to be committed to
"off-take" by the co-venturers. Changing market conditions led to a reorientation of the

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project towards the production of a specific finished product, wire rod. In addition
to raising the possibility of direct competition with the co-venturers, this reorientation
substantially removed their interest indications that, in at least one case, the co-venturers'
own financial difficulties may have been an element in the decision to withdraw.
Finally, we also note the Mitsui resurfaced as a lender to the project.
As evidenced by its continuing and expanding equity commitment to ISCOTT, the GOTT has
chosen to stay with the project in the apparent belief that, start-up problems
notwithstanding, the company's long-term prospects justify continued support which will
eventually pay off. On the basis of the information currently available to us, we are not in a
position to preliminarily determine that assessment is not consistent with commercial
considerations. We will, however, seek additional information regarding this program.

B. Loss Coverage or Absorption

Petitioners allege that at least a portion of the funds which the GOTT has committed to the
ISCOTT project since the commencement of commercial operations should be treated as
loss coverage or absorption. In effect, they maintain that ISCOTT has been the beneficiary
of sublstantial operating studies without which the company could not remain viable.
As discussed in the section of this notice titled "Equity Participation by the Government",
the GOTT's continued commitment to getting ISCOTT off the ground does not appear to
represent an investment inconsistent with commercial considerations as we view then
within the context of the start-up of a new industry in a developing country. While ISCOTT
has begun to market its products on an intermittent basis, it is not yet a fully operational
enterprise. From this perspective, equity infusions by the GOTT which may in some
instances serve to offset initial operating losses may still be viewed primarily as
investsments in the capitalization and establishment of ISCOTT rather than as operating
subsidies. As such, they remain within the realm of commercial reasonableness which
governs with respect to investment in the start-up of an enterprise. We will seek additional
information regarding this issue during verification.

C. Point Lisas Development Zone

Petitioners allege the Point Lisas Development Zone, in which ISCOTT's steel mill is located,
represents the GOTT's effort to establish an infrastruture specifically designed to support
the company's operations. They allege that ISCOTT is the beneficiary of preferential rental
or lease terms, that the Zone's Marine Bulk and Export Terminal was specially designed for
use by ISCOTT and that roads, power lines and a natural gas pipeline have been provided to
ISCOTT on terms which do not reflect their true cost.
The responses state that services similar to those provided in the zone do not exist in any
other part of Trinidad and Tobago. Information currently available indicates rates paid by
ISCOTT for the use of developed land within the Point Lisas Development Zone are paid
according to a formula applied to all lessees in the area. The presence of other lessees within
the Zone is also an indication that its facilities are not dedicated to sole use by ISCOTT. We
will seek additional information regarding the Point Lisas Development Zone during
verification to determine whether a specific or regional bounty or grant is being provided.

D. Import Duty Exemptions

Under the laws of Trinidad & Tobago imports may or may not be subject to duties under
any one of three tariff schedules. Products on the First Schedule are assigned duties ranging
from zero to some precentage of value. Those on the Second Schedule benefit from a general
exemption. The Third Schedule establishes conditional exemptions for approved industries.
The First and Second Schedules are general enactments apparently applicable to all
industries in Trinidad and Tobago. Section 49A of the Customs Act of 1973 empowers the
Government to grant duty exemptions on any merchandise imported by a company which
is within the approved industry list of the Third Schedule. ISCOTT has applied for and
received exemptions under this provision.
On its face, the grant of duty exemptions to "approved industries" listed in the Third
Schedule appears to establish a countervailable element of preferentiality. Examination of
the Third Schedule, however, shows that approximately 76 industries in Trinidad and
Tobago are apparently able to qualify for a Third Schedule exemption. In addition, a
substantial portion of the items subject to a conditional exemption under the Third
Schedule already qualify for a general Second Schedule exemption. Other items are assessed
a duty free rate under the First Schedule. Finally, in a number of instances, individual
construction contractors on the ISCOTT project have sought Third Schedule exemptions on
their own behalf, and the direct or indirect benefit to ISCOTT cannot be calculated with any
reasonable degree of certitude. Consequently, we will seek additional information regarding
this program during verification.

E. Preferential Prices for Natural Gas

The petitioners allege that ISCOTT benefits from the provision of natural gas through
government owned entities at preferential prices.
On the basis of information currently available, it appears that the price paid by ISCOTT for
natural gas is established through negotiations between ISCOTT and the National Gas
Company and/or the National Energy Company. There is no evidence on the record to
indicate that these negotiations are not conducted at arm's length. Typical contracts
between ISCOTT and its suppliers provide for a base price MMBTU with per annum escalator
clauses and pass-through provisions to cover increases in the prices charged ISCOTT's
suppliers by the AMCO Trinidad Oil Company, and independent, non-government owned
entity. Since the prices ISCOTT pays for natural gas are negotiated at arm's length and
ultimately based on the prices paid by its suppliers to an independent producer, we
preliminarily determine ISCOTT receives no benefits from the provision of natural gas at
perferential prices. We will, however, seek additional information regarding this program
during verification.

F. Short Term Loans

ISCOTT indicates the receipt of several short-term loans from private sources during the
period of investigation. Some of these loans have been repaid and others have been
rolled-over. At this time, we have no evidence to indicate that these loans were made on a
preferential basis, nor whether a guarantee fee was levied. We will seek additional
information on these short-term loans.

Verification

In accordance with section 776(a) of the Act, we will verify all the information used in
reaching our final determination.

Suspension of Liquidation

In accordance with section 703 of the Act, we are directing the U.S. Customs Service to
suspend liquidation on all entries of Carbon steel wire rod from Trinidad and Tobago
which are entered, or withdrawn from warehouse, for consumption on or after the date of
publication of this notice in the Federal

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Register, and to require a cash deposit or
the posting of a bond for each such entry of the merchandise in an amount equal to 12.29
percent of the ad valorem value of the subject merchandise.

Public Comment

In accordance with � 355.35 of the Commerce Department Regulations, if requested, we will
hold a public hearing to afford interested parties an opportunity to comment on this
preliminary determination at 10:00 a.m. on November 14, 1983, Room 3078 at the U.S.
Department of Commerce, 14th Street and Constitution Avenue, N.W., Washington, D.C.
20230. Individuals who wish to participate in the hearing must submit a request to the
Deputy Assistant Secretary for Import Administration, Room 3099B, at the above address
within 10 days of this notice's publication. Requests should contain: (1) The party's name,
address, and telephone number; (2) the number of participants; (3) the reason for
attending; and (4) a list of the issues to be discussed. In addition, prehearing briefs must be
submitted to the Deputy Assistant Secretary by November 7, 1983. Oral presentations will
be limited to issues raised in the briefs. All written views should be filed in accordance with
19 CFR 355.46 within 30 days of this notice's publication, at the above address and in at
least 10 copies.

Alan F. Holmer,

Deputy Assistant Secretary for Import Administration.

October 13, 1983.

[FR Doc. 83-28563 Filed 10-19-83; 8:45 am]

BILLING CODE 3510-DS-M