‘THE CITY OF SPRINGFIELD, MASSACHUSETTS MAYOR DOMENIC J. SARNO. HOME OF THE BASKETBALL HALL OF FAME September 14, 2018, ‘The Honorable Robert ghthzer, United Trade Representative 60017" street NW ‘Washington, 0¢ 20508, Re: Public Comment Concerning Proposed Action Pursuant to Section 30; China's Acts; Policies, and Practices Related to Technology Transfer, Intelectual Property and Innovation Docket No. USTA-2018-0005 Dear Ambassador Lighthizer | want to comment on the Trump Administration's Section 301 investigation into the acts, policies and practices ofthe Government of China as relates to technology transfer, intellectual property and Fnnovaton. Springfield, Massachusetts is home to the wor’ largest al ear company, CRRC, wich recent invested $85 milion in anew facility that opened in 2018 and isnow producing ral as, employing 250 in ou City with the average salary of $65,000, rts exxts mst north American fact and its success is ental to eur ety and region's economy, bringing back manufacturing and skilled labor to our city. That success sted not only to the production and jobs created by CRRC, but the supply chain of smaller local businesses that ae feeding the facity ‘and creating good paying jobs for our residents \We applaud the President's pledge to addressing unfair rade practices faced by American businesses, However, we are writing today to express our concern that certain tems proposed for tars in response to these practices would increase the cost of CRRC's ral cars which would eventually affect the pully funded projects and penalize the taxpayers. Specifically, we are concemed that a numberof ral cars and City of Springfield + 36 Court Street + Springfield, MA. 01103-1687 + (413) 787-6100bus related goods fom Chapter 86 ofthe Harmonized Tariff Schedule (HTS) wil severely undermine the naton’s plans for expansion and maderation of ts public mass transt [A this time CRRC has contracts withthe Massachusetts Bay Transit Authority (MBTA) and the Los ‘Angeles County Metropolitan Transportation Authority (Metro) These contracts are expected to last for the net five years. The Office ofthe US Trade Representative's(USTR] proposes tariff action will hhave an adverse effect on the cost ofthese railcars and our local economy. tis our understanding that USTR's stated objective in the proposed action I to diminish Chinese sponsored acts that harm and deprive US companies from competing ina fair and open market. The appleation of a tariff on ral cars will not accomplish that goal as thee are no US, manufacturers of light and heavy rll transit vehicles. llTransit Vehicle Manufacturers are foreign owned, Als, the FAST Act requires al federally funded projects to meet "Buy America” requirement that dictate a minimum value of US. manufactured products, components and systems content in each alla. S an example, CRRC has committed to Los Angeles Metro's contract to use 70% of US manufactured components and systems in each railcar. CRRC has also committed to performing the final assembly of Met's vehicles In Massachusetts Springfield's objection based on the potential harm the proposed tarifs wll have to our local economy isnot unique to Western Massachusetts. On behalf of the City of Springfield and a clear appreciation that the taxpayers are funding @ portion of funding ofthe rll cars urge USTR to ernove these rll cars and bus related goods from thelist of products that wl be subject to 302 tart Ifyou have any questions regarding this important topic, please do not hesitate to contact me a (13) 787-6100.