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“Buy America” and the Hubbell Power Systems Response S. W. E. D. E Conference May 8, 2014 Doug Kirk Business Unit Manager, Construction Products
Agenda Ø Overview of Hubbell actions Ø What can Hubbell provide Ø Guidelines for making inquires to Hubbell ®
Overview of Hubbell Actions Ø Created a Buy America team and appointed customer service Buy America coordinators Ø Reviewed relevant statutes, regulations and agency guidance Ø Created a decision matrix for several domestic content restrictions (by statute and agency) for common requests – includes restrictions, test criteria, and qualifying scenarios Ø For Centralia, Missouri location, converted to US sourced steel for most Chance® products and included domestic steel requirement and certification in purchase orders to steel suppliers Ø Continued coordinated effort to monitor Buy America requirements, state DOT clarifications/interpretations and respond to customer requests. ®
HPS On-Going Buy America Team HCC BU Point Person Sourcing Buy America Team Customer Service Legal Material Managers Page 4 ®
HPS Internal Process Flow for Buy America HPS receives request Preparation of Response • CS emails customer to confirm receipt • CS seeks clarification, if necessary (e. g. FHWA versus FTA) • CS begins tracking request • CS routes internally to each BU Page 5 • BU prepares analysis of products • CS reviews consolidated response Coordinated Reply • CS sends full reply • certificate or spreadsheet • Copy of reply kept by HPS for future reference ®
The Hubbell Response to Buy America FHWA Requirements? Ø In General, YES! Hubbell can offer products certified for FHWA Buy America! Ø Response will be SKU specific for Hubbell product For Constructions Products (Anchors and Pole Line Hardware) Ø Anchors = Made in Centralia, Missouri with US sourced steel Ø Pole Line Hardware = Largely Exempt due to misc component Ø The default Hubbell response will be based on the July 12, 2013 letter from California Office of US Department of Transportation -Federal Highway Administration Ø If specific state DOTs have other interpretations, Hubbell can review and respond accordingly ®
Buy America Spreadsheets for General Inquires If a Customer requests FHWA or FTA Buy America data, customer service will provide information in approved HPS spreadsheet. This is NOT a certificate, but is used by recipients to determine ability of HPS to supply Buy America compliant products in the future. Spreadsheets answer thencurrent status of products. HPS also provides a include guidance memo, sample form certificate, and DOT letters with reply.
Buy America Certification for Orders Sample of FHWA and FTA Buy America certificate that shows compliance. An Appendix is attached with a list of part numbers covered by the certificate and the basis for compliance for each part.
How to Proceed with Buy America Inquires for Hubbell Power Systems, Inc. Ø Send all inquires through your normal HPS contact person, sales person, customer service representative, channel partner, etc. Ø Be specific about what state DOT you are working with for FHWA Buy America or what other statute you need compliance with Ø Each compliance request will be individually evaluated on a SKU by SKU basis Ø Please allow time to process and review these requests Ø All Purchase Orders must include the specific type of Buy America Certification being requested. If your legal department wants to speak directly with Hubbell legal about compliance and certification paperwork that can be arranged. ®