Wind Tower Foundations Not Covered by AD/CVD on Spanish Wind Towers
Monopiles, the foundations of large offshore structures such as wind towers, are not subject to AD/CVD orders on wind towers from Spain, the Commerce Department said in a Feb. 6 scope ruling.
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The department said that the ruling should be applied to all monopiles from Spain.
The Feb. 6 scope ruling was sought by domestic trade group Wind Tower Trade Coalition, which also supplied comments, Commerce said.
Monopiles are “steel cylindrical foundations that are embedded into the seabed as a base for offshore wind turbines,” Commerce said. It said wind turbines are then placed either directly onto the monopile or onto an intermediary piece. Each monopile is custom-designed for where it will be located, and each includes a “cathodic” system to protect it from seawater corrosion, it said.
Merchandise covered by the scope of the orders on wind towers from Spain, meanwhile, “consists of certain wind towers, whether or not tapered, and sections thereof” that are made of “multiple steel plates rolled into cylindrical or conical shapes and welded together … to form a steel shell,” Commerce said. They are included even if they are joined, internally or externally, to other non-subject merchandise such as nacelles or rotor blades, it said.
The scope, Commerce said, doesn't describe monopiles, nor indicate “where a wind tower ends and the foundation (upon which it must be installed) begins.” Therefore, the department considered the characteristics of the products and sought evidence from other sources to make its determination.
The monopiles’ characteristics differ significantly from wind towers’, the department said. Monopiles are designed to hold the weight of the towers, while towers must only withstand the force of their rotating rotors, so the fact that both have strength requirements is not a defining characteristic, it said. It also said wind towers have doors at their bases, while monopiles “are filled with water or concrete and pile driven into the seabed and, therefore, cannot have a door at their base.”
“The presence or absence of a door is not a determinative factor in scope classification; however, the clear statements that a door would be located at the ‘base of the tower,’ according to the description provided in the Petition filed by the [Wind Tower Trade Coalition], demonstrates that the foundation (located beneath the base/door) does not comprise part of the wind tower,” it said.
As for information from other sources, the International Trade Commission “not only differentiated between wind towers and monopolies, but also made that distinction in multiple instances,” Commerce said. The petition from the Wind Tower Trade Coalition likewise included several descriptions that “differ from the descriptions of monopiles,” including two exhibits showing manufacturers describing the products as separate entities, it said.
“These sources demonstrate that wind towers and foundations are considered distinct products within the industry,” Commerce said.