Schneider Electric Statement to the USTR

Edward Gresser
Chair, Trade Policy Staff Committee
Office of the United States Trade Representative
1724 F Street, N.W.
Washington, DC 20258

RE: Potential Action: CSPV Cells (Docket Number: USTR - 2017 - 0020)

Dear Mr. Gresser,
We are writing on behalf of Schneider Electric to oppose institution of high tariffs on imported  solar panels.  Schneider Electric is leading the Digital Transformation of Energy Management and Automation in Homes, Buildings, Data Centers, Infrastructure and Industries, with $27 billion in revenues.

With global presence in over 100 countries, Schneider is a leader in Power Management – Medium Voltage, Low Voltage and Secure Power, and in Automation Systems. We provide integrated efficiency solutions, combining energy, automation and software.

We have 22 manufacturing facilities in the United States and employees in every state. Schneider Electric produces a wide variety of solar energy-based products from battery inverters, charge controllers, and quality balance of systems solutions, including a manufacturing facility in California.  Schneider Electric recognizes that the energy landscape in the US is changing, and to that effect we have over 1GW of installed solar capacity, and are leading the technological transition into energy storage and microgrids, investing tens of millions of dollars in product development on a yearly basis.  Just recently we completed an installation of 1,379 solar PV panels and associated inverters at our North America headquarters in Andover, Massachusetts, to convert 448 kW of direct current to alternating current.  Finally, the company incorporates solar in Energy Savings Performance Contracts for schools, hospitals, state, local and federal government facilities. 

We also advise customers on solar projects and incorporate solar into our energy efficiency and microgrid customer projects.   We currently support clients in the pursuit of utility-scale solar projects in all deregulated US states—including California, Virginia, and Texas.   Solar is also an integral part of microgrid installations in the US –an increasingly important market for national security and resilience purposes.  Schneider Electric is currently considered #1 microgrid installer of microgrids in the United States.

We don’t ask for appropriations funding from the government, and don’t seek special protections for our business, and we expect that our suppliers in the solar industry do the same.  The key to widespread solar adoption and growth in the US—and the associated economic activity and job creation—is having modules that are priced on par with conventional fuel sources such as gas and coal.

Imposition of tariffs on solar modules to protect only two companies will drive costs up for us and our clients, leading to project loss and lack of growth in the US.  The relative expense of domestic panels, even when supported by Federal subsidization, has been cost-prohibitive for US developers responding to the unprecedented demand for solar expansion.  Reliance on domestic panels would have significantly slowed solar growth at a time when consumers have clamored for it due to the falling cost and clean energy generation it produces.

The result will be a loss of economic activity and jobs—very detrimental to one of the fastest growing employment sectors, putting thousands of Americans to work.  SEIA estimates that 88,000 US jobs could be lost in the next year alone.

We hope that you consider a free market approach in your decision.