James Bovard's June 23 editorial page article "Steel Rulings Dump
on America," focusing on the Commerce Department's decisions to
impose duties on steel imports from 20 countries, shows a lack of
understanding of the purpose and implementation of U.S. trade law.

The decisions involved imports of steel that were subsidized or
sold in the U.S. at less than fair value ("dumping"). Commerce's
investigations, as are all such probes, are highly technical and
transparent, and follow strict legal procedures. The
administration's trade policy lies in the laws themselves and a
commitment to enforce them. Mr. Bovard's charge that appropriate
actions that follow the facts reflect career employees being
"captured" by domestic interests simply reflects his own bias and
misunderstanding of the issues.

Protection from unfair trade practices is a right granted to all
domestic industries, and Commerce is not allowed any discretion in
implementing these laws. If a domestic industry provides us with
reasonable evidence that a foreign manufacturer has received
subsidies or that dumping is occurring, as it did with steel, we
must conduct an investigation according to law, departmental
regulations and administrative precedent. And all our actions are
subject to judicial review, which grants importers and foreign
producers the right to challenge our actions in court.

Mr. Bovard has challenged Commerce Secretary Ronald H. Brown's
statement that "information used in making our final determinations
was verified." Mr. Bovard is wrong. All information supplied by
foreign firms was painstakingly verified. Only when foreign
producers could not or would not provide us with the necessary input
did we rely on material from other sources ("best information
available"). Data was supported by sworn cifications and affidavits;
it was not "make believe," as Mr. Bovard claimed. Failure to use the
best information available would be contrary to law and deny U.S.
industry the remedy to which it is entitled. Also, in calculating
constructed value, the use of 8% for profit and 10% for
administrative overhead, which Mr. Bovard criticizes, is also
required by law.

Jill A. Schuker

Director, Office of Public Affairs

Department of Commerce

Washington