The U.S. solar manufacturing sector is not monolithic. It comprises a diverse set of companies -- several of which spoke out this week against pending solar trade protection measures.

Twenty-seven solar mounting equipment manufacturers and their domestic suppliers wrote a letter to the U.S. International Trade Commission on Tuesday to express their opposition to the Section 201 trade case brought by Suniva and joined by SolarWorld, which seeks to impose tariffs and a floor price on imported crystalline silicon photovoltaic cells and modules. The opposed companies said they have experienced strong growth as a result of the American solar industry's upward trajectory. But now, they say their companies and the jobs they support are at risk.

"The tariffs requested by Suniva would more than double the price of solar panels in the U.S., undercutting the cost-competitiveness of solar and reversing its high growth trajectory," the manufacturers wrote. "We would be forced to cut our operations, seriously endangering manufacturing jobs at our factories."

"We have been building our companies to meet demand from a large and growing domestic solar market. That market is now under threat," the letter continues. "As true U.S. solar manufacturers, and on behalf of our 5,700 workers, we ask that you not grant Suniva’s request for global safeguard measures."

The opposition letter was spearheaded by PanelClaw, a 10-year-old Boston-based company that claims to hold over 30 percent market share of all flat-roof racking in the country. Suniva and SolarWorld have positioned themselves as representatives of the solar manufacturing sector, even though they collectively employ fewer than 500 workers, the company wrote in a separate letter. More than 38,000 people work in U.S. solar manufacturing, according to the latest survey data. That number is up 26 percent from 2015. 

Suniva's and SolarWorld's claims that U.S.-based solar manufacturing will grow as a result of the tariffs "defies the laws of economics," PanelClaw wrote, referring to a recent analysis by Suniva's law firm Mayer Brown that found imposing new tariffs on imported solar products will produce a net increase of at least 114,800 new jobs.

“The notion by the petitioners that increasing the cost of modules will lead to job creation is not only unconscionable, but also counter to all we have seen since the industry was born,” said Constantino Nicolaou, CEO of PanelClaw. 

In a highly competitive energy resource market, trade-case opponents argue higher prices for solar products will cause demand to fall drastically. If the ITC approves Suniva's requested remedy of 40 cents per watt on imported cells and a floor price of 78 cents per watt on modules, it's expected to trigger the loss of some 88,000 solar jobs -- thousands of them in manufacturing. 

There are more than 600 facilities in the U.S. that build supplies for the solar industry, including steel and polysilicon, inverters and trackers, cells and panels, and racking and mounting systems. Looking at the broader ecosystem, tariffs on imported cells and modules could have knock-on effects for related businesses.

“If you overlap our jobs, with the processing plant and steel mill jobs related to our industry, and those jobs can circle out in the supply chain [across] layers and layers, the jobs affected by our industry are even greater than the jobs we are counting at our respective companies,” said Russell Schmit, CEO of Schletter, commenting in the PanelClaw letter. “It’s hard to quantify exactly what this trade case could do, but I could see this cutting our business by half at least, so that would cost us 100 jobs or more."

Dissent from solar mounting equipment companies follows the ITC’s first public hearing on the Suniva/SolarWorld petition on August 15, where more than 40 witnesses spoke in front of trade commissioners in Washington, D.C.

In defense of the petition, Suniva’s attorney Matthew McConkey referenced findings in an ITC staff prehearing report, which includes a list of U.S. companies that have closed their production facilities since 2012. The report also notes that total U.S. imports of certain crystalline silicon photovoltaic cells, whether or not partially or fully assembled into other products, were more than five times higher in 2016 than in 2012.

"The data set forth in the commission’s staff report reveals a domestic industry that is literally on the precipice of being extinguished. U.S. module manufacturers suffered net losses exceeding a billion dollars over a five-year period,” he said. “If this isn’t serious injury, then that concept has no meaning.”

The ITC staff report also notes, however, that Tesla and Mission Solar claim not to have been injured by imports, adding uncertainty to the case. Hundreds of solar workers, elected officials and U.S. trading partners attended the hearing to support the case against Suniva and SolarWorld's request for tariffs on imported solar parts.

The 26 other signatories to the letter released on Tuesday are Advanced Solar Products, Aerocompact, Anchor Products, Array Technologies, EcoFasten Solar, Ecolibrium Solar, DCE Solar, GameChange Solar, IronRidge, NEXTracker, OMCO, Pegasus Solar, Quick Mount PV, RBI Solar, S-5!, Schletter, SMASHsolar, SnapNrack, Solar FlexRack, Sollega, Sunfolding, SunModo, SunLink, TerraSmart, Tessolar and Unirac.

On September 22, the trade commission is scheduled to vote on whether or not the petitioners have in fact sustained injury. On October 3, the ITC has set a hearing on the remedy to be imposed on importers, should a severe injury be identified. A vote on the remedy itself is scheduled for October 31.

Findings and recommendations must be sent to President Trump by November 13. The president has the authority to accept, modify or reject the proposed tariffs. His decision could come by the end of the year.