Dear Mr. LaRussa:

This letter is filed on behalf of the American Bearings Manufacturers Association ("ABMA") to again reiterate its support of a Commerce Department proposal to clarify the automatic liquidation provisions of its regulations. The ABMA is a trade association representing more than 80% of the domestic bearing industry. A number of the ABMA member companies, both domestic bearing producers and affiliates of major non-domestic bearing producers, are involved in the current antidumping proceedings.

The ABMA first submitted comments on the Department’s proposed clarification of the assessment regulations on May 19, 1999. At that time, the ABMA gave its unanimous support to the Department’s proposal outlined in the Federal Register notice of October 15, 1998 (Antidumping and Countervailing Duty Proceedings: Assessment of Antidumping Duties, 63 Fed. Reg. 55361-64 (Oct. 15, 1998)). We specifically agree with the Department’s conclusion, set forth in the notice, that the producer’s company-specific cash deposit rate would serve as an inappropriate basis upon which to assess final antidumping duties on entries where an intermediary exports the merchandise, and the Department conducts a review of the producer, but not the intermediary.

In the intervening nine months since we have submitted our comments, there has been no apparent movement within the Department to finalize the proposed clarification. Our members are still very much concerned about this issue and about the possible loss of another year’s protection if this clarification is not finalized soon. May is the anniversary month for the anti-friction bearings administrative reviews. As drafted, if the clarification is going to apply to the upcoming reviews, the policy must be finalized before May 31, 2000.

Our association looks forward to providing the Department with whatever assistance may be necessary in order to meet that time frame.

Respectfully submitted,

cc: Richard Moreland

Laurie Parkhill