Suniva Calls on GTM to Retract Inaccurate Report

Suniva has called on GTM Research (“GTM”) to retract and amend the portions of GTM’s recently released report, titled “U.S. Solar Outlook Under Section 201: The Trade Case’s Impact on U.S. Solar Demand,” that are based on the false assertion that the trade petition requests a floor price of $1.18 per watt. This assertion is a completely incorrect reading of the remedies requested in the petition – no where in the petition does it request the floor price and tariff interact in this manner. GTM negligently published this assertion without ever contacting the co-petitioners of the trade petition or their counsel. Had GTM followed standard norms of journalistic procedure and asked for comment from the co-petitioners, they would have happily assisted GTM and GTM could have prevented the foreseeable harm caused to the co-petitioners. In fact, Suniva understood that GTM would contact Suniva once GTM had developed their report. Instead, GTM chose to run harmful headlines based on its decision to not seek comment from the co-petitioners. The trade petition never calls for a cumulative remedy of a $1.18, based on a $.78 minimum import price for modules PLUS a $.40 cell tariff. Suniva would have been happy to help GTM with their model based on a $.78 minimum import price for modules that is INCLUSIVE of the $.40 cell tariff as provided in the trade petition. This is why Suniva has called upon GTM to retract their report while there still may be time to minimize the harm caused to the co-petitioners. Suniva does not understand why GTM would publish faulty assertions without contacting the co-petitioners.

GTM DOES NOT DISPUTE INJURY: In addition, the GTM analysis makes no attempt to dispute the fact that the entire U.S. solar cell and module manufacturing industry has been seriously injured by imports. Indeed, GTM previously acknowledged that the U.S. industry has been seriously injured. Prior GTM analysis noted that 2016 was “the brutal year for many businesses: Public solar companies are getting thrashed, module oversupply is causing severe financial pain for manufacturers, and even downstream companies who’ve benefited from cheaper equipment and growing demand have struggled.”1

EVEN GTM’S FLAWED ANALYSIS SHOWS STRONG GROWTH IN US SOLAR DEMAND

• GTM’s analysis shows that under every scenario analyzed solar installations increase in every single year. Thus there is no decline in installed solar capacity in the US.
• GTM’s alternative scenario projections show that installed capacity would increase by at least 36 GW between 2018-2022.2 This is an 80 percent increase over current installed capacity.

OTHER ASSUMPTIONS IN GTM ANALYSIS ARE UNSUPPORTED, NON-TRANSPARENT AND CONTRADICT PRIOR GTM ANALYSIS:

• The growth in US solar installations would likely be higher than the 80 percent forecast by GTM as GTM’s new analysis includes price effects that are contradicted by its own prior research.
• GTM’s analysis is completely non-transparent in explaining how it arrived at the price impacts under its new alternative scenario. Prior GTM analysis projected that installed prices would at worst return to 2015 levels given the remedies proposed.3 Thus, even GTM’s alternative scenario projections should be dismissed as unsupported, non-transparent analysis that conflicts with its own research.
• Actual price levels in 2015 were higher than the alternative scenario projected by GTM in its new analysis. In its new analysis GTM forecasts residential prices under $3 per watt.4 Actual residential prices in 2015 were over $4 per watt.5 In its new analysis, GTM forecasts utility prices at well below $1.50 per watt.6 Actual price levels in 2015 were approximately $2 per watt.7
• GTM’s own analysis shows that in 2015 installed solar capacity increased by 7.5 GW.8 GTM’s new analysis makes no attempt to explain why it projects annual installations would ever fall below the 7.5 GW installed at 2015 prices when it concludes that prices would be at 2015 levels. Thus, if price levels were to stabilize at 2015 levels then solar installations would increase by at least 37.5 GW between 2018 and 2022, the same pace as in 2015 and which would almost double current installed capacity.

CONCLUSION: GTM’s analysis suffers from a fatal flaw in its core assumption and even its other assumptions are based on unsupported, non-transparent analysis and should be dismissed. GTM’s analysis fails to include any benefit from the restoration of US solar cell and module manufacturing and employment. However, even if GTM’s analysis is given any credibility it shows that US solar installations would continue to grow at significant rates under the remedies requested in the 201 petition. It further shows that prices would stabilize giving US manufacturers the opportunity reopen shuttered production facilities and rehire the thousands of American workers who have lost their jobs to the surge in low priced imports.

Further, GTM has consistently acknowledged the fact that the US CSPV cell and module manufacturing industry has been seriously injured due to the influx of foreign imports, including in this report, by focusing solely on remedies to this injury to the industry.

About Suniva

Suniva® is the leading U.S.-born, U.S.-operated manufacturer of high-efficiency crystalline silicon photovoltaic (PV) solar cells and high-power solar modules. The company is known for its high-quality products, industry-leading technology, reliable performance, and high power density. suniva.com

1 A Journey to the Center of the Solar Industry, Podcast by Stephen Lacey, June 7, 2017, GTM, available at https://www.greentechmedia.com/articles/read/a-journey-through-the-solar-industry.

2 U.S. Solar Outlook Under Section 201: The Trade Case’s Impact on US. Solar Demand, GTM Research, June 2017, Figure 1.2 at 5.

3 Suniva Trade Case: A Doomsday Scenario for US Solar?, Podcast by Stephen Lacey, June 1, 2017, GTM, available at https://www.greentechmedia.com/articles/read/the-suniva-trade-case-a-doomsday-scenario-for-americas-solar-industry.

4 U.S. Solar Outlook Under Section 201: The Trade Case’s Impact on US. Solar Demand, GTM Research, June 2017, Figure 1.1 at 9.

5 2015 National Solar Jobs Census, The Solar Foundation, p. 14, available at http://www.thesolarfoundation.org/wp-content/uploads/2016/10/TSF-2015-National-Solar-Jobs-Census.pdf.

6 U.S. Solar Outlook Under Section 201: The Trade Case’s Impact on US. Solar Demand, GTM Research, June 2017, Figures 1.3 and 1.4 at 9.

7 2015 National Solar Jobs Census, The Solar Foundation, p. 14, available at http://www.thesolarfoundation.org/wp-content/uploads/2016/10/TSF-2015-National-Solar-Jobs-Census.pdf.

8 U.S. Solar Outlook Under Section 201: The Trade Case’s Impact on US. Solar Demand, GTM Research, June 2017, Figure 1.2 at 5.

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