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more than 15 per centum of alumina or not more iron than the equivale of one-tenth of 1 per centum of ferric oxide, three-eighths of 1 cent per pound We beg that that portion of the paragraph above mentioned be stricken o and the following substituted:

"Aluminum sulphate, alum, or aluminous cake, containing not less iron the the equivalent of one-tenth per centum of ferric oxide, three-eights of 1 cent p pound; containing less than the equivalent of one-tenth of 1 per centum ferric oxide, three-quarters of 1 cent per pound."

Otherwise than the above, the paragraph to remain as at present.
Our object in making this request is to provide

(a) An increase in duty on one of the articles mentioned.

(b) To simplify their specifications.

Formerly aluminum sulphate of low grade, known as alum cake or alumino cake, was used in considerable quantities, but during the past few year largely as a result of improvements in the process of manufacture, only tv grades of aluminum sulphate are in general use, these being usually known commercial aluminum sulphate and iron free aluminum sulphate, although t term "alum" is often, but incorrectly, applied to both of these products. Wh the tariff act of 1922 was adopted, American manufacturers believed that t rates on aluminum sulphate, as contained therein, would be sufficient to affo them protection from the imported material, which can be produced at low cost abroad than in this country. During the last few years, however, t foreign product has been imported and offered for sale in this country at pric so low as to threaten the existence of the business of American producers, an while the total imports have been small, they have established the price on large tonnage of the domestic product, with disastrous results to the America manufacturers.

The foreign producer has the advantage over the American manufacturer very much lower labor costs, and these low labor costs apply not only to t sulphate of alumina itself, but also to the raw materials that enter into i manufacture.

Respectfully submitted.

MERRIMAC CHEMICAL Co.
SALMON W. WILDER,

Chairman of the Board.

The above brief is concurred in by the following concerns: Charles Lennig Co. (Inc.), Pennsylvania Salt Manufacturing Co., and Grasselli Chemical Co. Mr. COLLIER. Doctor, are aluminum sulphate and chlorine us together in the purification of reservoirs of water for drinking pu poses, or does one take the place of the other?

Mr. WILDER. They are both used.

Mr. COLLIER. Are they used together, or separately? Are the both used in the same preparation?

Mr. WILDER. Aluminum sulphate is used in filter plants to get ri of organic coloring matter and impurities of one kind or another chlorine is used for another purpose, generally.

Mr. COLLIER. I was at a large reservoir for a city some time ag and saw them putting in chlorine. I just wondered if you used bo these at different times.

Mr. WILDER. Sometimes they do.

Mr. HULL. I did not hear, if you stated, what the materials a for this product.

Mr. WILDER. Usually they are hydrate of alumina, which, in itsel is a manufactured product, and sulphuric acid.

AMMONIUM SULPHATE

[Par. 7]

BRIEF OF BY-PRODUCT COKE PRODUCERS

[Including cresylic acid, par. 27, and other coal-tar products, par. 1549]

COMMITTEE ON WAYS AND MEANS,

House of Representatives, Washington, D. C.:

This brief is respectfully submitted to your committee by the undersigned companies interested in the by-product coke industry of the United States. This is a comparatively new industry in this country. Eighty per cent of its growth has occurred within the past 15 years. There are now some 80 byproduct coke plants operating in or near 70 different cities or towns and giving employment to many thousands of men. These plants are owned by 54 separate and unconnected companies. They have capacity to manufacture coke and recover the by-products from 85,000,000 tons of coal per year. The byreduct coke industry has no association or organization for trade or technical Arposes and employs no representative in Washington.

IMPORTANCE OF THE BY-PRODUCT COKE INDUSTRY

In the conservation of natural resources and in the variety of products upon which other industries depend, the by-product coke industry stands as one our most important national assets. Materials manufactured from its byrudnets constitute thousands of every-day necessities. To residents of cities l towns, it is important because it is the largest source of city gas supply ther than natural gas, and because the rapidly increasing consumption of >mestic coke is the most practical remedy for the smoke nuisance. To the griculturist, it is important as a source of sulphate of ammonia, of disintants, preservatives, insecticides, and of other materials for the protection improvement of crops. Finally, from the standpoint of military protection. is essential that the by-product coke industry be maintained and encouraged brause its products are indispensable in every branch of modern warfare.

BY-PRODUCT VALUES MUST BE PROTECTED

As its name signifies, the by-product coke industry depends for its existence obtaining and maintaining adequate value for its by-products. There primarily only four such by-products, viz, gas, ammonia, tar, and benzols. Dese are sold to numerous other industries to be worked up into a great ariety of products. The values of the ammonia and tar are increasingly Createned by foreign competition and are, therefore, of direct concern to your mittee. It is of vital importance to the by-product coke industry of the United States that these two essential by-products-tar and ammonia-be adeately insured against foreign interference with their values. Any substanal decline in the sum total of the values of these by-products will discourage growth of this industry.

THE AMMONIA SITUATION

In the tariff act of 1922 sulphate of ammonia was given a small margin of rotection by making it dutiable at one-fourth of 1 cent per pound. This protion was requested and obtained not because of any condition of competiwith the foreign by-product coke industry, but on account of the very wis menace of cheap synthetic ammonia produced principally in large German plants built under heavy subsidies for military munition purposes. In de argument submitted in support of the 1922 tariff the following statement was made:

Adequate protection can not have any effect in raising the price of sulphate f ammonia and will not prevent any natural lowering of such price due to Lormal competition, but such protection is directed solely against abnormal petition from what are essentially the products of foreign munition plants."

The accuracy of that statement has been proven by the subsequent behavior the price of sulphate of ammonia. The pre-war price of sulphate of ammon was close to $60 per ton. The present price is about $40 per ton. Bas on the comparative purchasing power of the dollar, the price of sulphate ammonia is about half of what it was before the war. The small rate of du has certainly not prevented a very radical lowering of the price, but it h established a necessary margin of protection against products made by lo cost labor in subsidized foreign plants.

This protection, however, is partly nullified through an evasion of what clearly the intent of the tariff act of 1922. This evasion consists of the impo tation of large amounts of ammonium sulphate-nitrate (Leuna saltpeter) du free. This will be discussed further in connection with our specific recomme dations.

THE TAR SITUATION

It has been absolutely necessary for the by-product coke industry to obtain a increase in the values of other by-products to offset the lowering of the pri of sulphate of ammonia. In most cases the price of tar has increased so to make up a substantial proportion of the difference. The price of ta however, depends upon the value which the tar-distilling companies can obta for their products, of which creosote oil is now the most important, and up the efforts which the tar-distilling companies are making to establish th production of new and more valuable products, such as cresylic acid. T tar-distilling industry of the United States is confronted with the increasin menace of importations of cheap creosote oil and other coal-tar products.

RECOMMENDATIONS

In connection with pending tariff legislation, the undersigned compani respectfully recommend the following:

That the present duty on sulphate of ammonia be retained.

That other ammonia compounds, such as ammonium sulphate-nitrate, su stantially equivalent to sulphate of ammonia, be assessed at a rate of duty a least corresponding to their sulphate of ammonia equivalent.

That the present rate of duty on refined cresylic acid be retained.

That in the event that conditions in the industry so warrant, the Preside be authorized to remove any of the coal-tar products from the free list an apply a suitable duty.

The following brief remarks are offered in amplification of these recor mendations:

SULPHATE OF AMMONIA

The importance of the present tariff to the industry is stated above. Th undersigned companies heartily indorse the constructive efforts now being mac to improve the economic condition of agriculture in this country. In view the fact that agricultural leaders generally are advocating protective dutie on many farm products, it is not believed that these leaders will serious! oppose the very modest duty which stands to protect our home production sulphate of ammonia.

SUBSTITUTES FOR SULPHATE OF AMMONIA

Since the passage of the 1922 tariff act, increasing large quantities of amm nium sulphate-nitrate have been imported duty free. In 1927 about 50.000 tons of this material were imported and it is estimated that in 1928 abou 91,600 net tons entered this country. One ton of ammonium sulphate-nitrate equivalent to 1.26 tons of sulphate of ammonia, so that the 1928 importation were equivalent to 115,400 net tons of sulphate of ammonia. This is nearly on quarter of our annual consumption.

Ammonium sulphate-nitrate consists of sulphate of ammonia and ammoniu nitrate, on each of which materials there is a duty. Ammonium sulphate nitrate competes directly with sulphate of ammonia and should carry a duf at least equivalent to its sulphate of ammonia value. Its importation, dut free, if not a breach of the 1922 tariff act, is clearly an evasion of this act.

REFINED CRESYLIC ACID

Briefs urging retention of the present rate of duty on refined cresylic acid have been submitted to your committee by several tar-distilling companies. To the by-product coke industry this is extremely important, because it is only through the development of cresylic acid and other tar products that the price of coal tar can be maintained so as to justify the conservation methods of our industry.

OTHER COAL-TAR PRODUCTS

The product on which the tar industry mainly depends for its financial stability is creosote oil, which is now on the free list. The production of this material in the United States has increased very rapidly on recent years and large quantities are being imported from Europe. A continuation of this condition will result in a serious oversupply in the American market. The European creosote oil is produced in low-cost plants with cheap labor and is shipped as ballast, so that it can be brought into this country very cheaply. Importations of other tar products are also liable to jeopardize the industry, particuarly where such products can be easily and cheaply refined in this country and thus greatly undersell refined products, the protection of which is a recognized Lecessity. As conditions may change very rapidly after passage of pending tariff legislation and as any change may be of serious detriment to our home industry, we earnestly recommend that the President be given authority to apply a suitable duty to any coal-tar product now on the free list, in the event That investigation shall prove to his satisfaction that such action is warranted. Respectfully submitted.

Alabama By-Products Corporation. Birmingham, Ala.; By-Products
Coke Corporation, Chicago, Ill.; Camden Coke Co., Newark,
N. J.; The Connecticut Coke Co., New Haven, Conn.; Detroit
City Gas Co., Detroit, Mich.; Domestic Coke Corporation, Fair-
mont, W. Va.; Donner-Hanna Coke Corporation, Buffalo, N. Y.;
Grand Rapids Gas Light Co., Grand Rapids, Mich.; Hamilton
Coke & Iron Co., Hamilton, Ohio; Hudson Valley Coke &
Products Corporation, Troy, N. Y.; Indiana Consumers Gas &
By-Products Co., Terre Haute, Ind.; Jones & Laughlin Steel
Corporation, Pittsburgh, Pa.; The Milwaukee Coke & Gas Co.,
Milwaukee, Wis.; Minnesota By-Products Coke Co., St. Paul,
Minn.; New England Fuel & Transportation Co., Boston, Mass.;
Philadelphia Coke Co.. Philadelphia, Pa.; Public Service Electric
& Gas Co., Newark, N. J.; Rainey-Wood Coke Co.. Swedeland,
Pa.; Republic Iron & Steel Co., Youngstown, Ohio; Seaboard
By-Product Coke Co., Jersey City, N. J.; Toledo Furnace Co.,
Toledo, Ohio; Weirton Steel Co.. Weirton, W. Va.; Wheeling
Steel Corporation, Wheeling, W. Va.; Zenith Furnace Co., West
Duluth, Minn.

BRIEF OF THE AMERICAN IRON AND STEEL INSTITUTE, NEW
YORK CITY

COMMITTEE ON WAYS AND MEANS,

House of Representatives, Washington, D. C.

GENTLEMEN: Paragraph 7 of the tariff act of 1922 imposed a duty of oneth of 1 cent per pound, equivalent to $5 per ton, on ammonium sulphate, te commonly known as sulphate of ammonia. As the domestic production f this article comes almost entirely from the operations of steel making, the aerican Iron and Steel Institute respectfully urges upon your committee the tinuation of the present tariff rate.

Sulphate of ammonia is produced in the operation of coking in by-product rens. Not so long ago, the coke required in steel production was made in the -called beehive ovens, which were very wasteful in their operation. In the byProduct ovens not only is coke produced but the gases arising from the distillaion of the coal are cooled and the tar is condensed and removed. The gases are 1 conducted to a vessel containing a weak solution of sulphuric acid in which The ammonia present combines with the sulphuric acid to form ammonium phate (NH):SO.. A subsequent operation removes the light oil. In other ords, the production of ammonium sulphate is a necessary incident in the production of coke and is therefore incidental to the production of steel. idental, but inevitable, products are tar, gas, benzol, toluol, xylol, etc.

Other

Beehive ovens are simple to construct and are easy of operation, but they are extremely wasteful. By-product ovens are costly to construct and operate, but they effect great economies, for they save the oil, gas, and tar that were previously destroyed.

Exhibit A appended to this brief shows the production of ammonium sulphate in the United States for the years 1918 to 1928, inclusive, as reported by the United States Department of Commerce. All of this has been produced at by-product coke plants. In European countries and in Japan ammonium sulphate is also produced by the air-nitrogen industry, but as yet no sulphate is so produced in the United States. The large increase in production is due to the discontinuance of the wasteful beehive ovens and the substitution therefor of the by-product ovens.

Exhibit A also shows the imports, exports, and amount available for consumption. The tabulation shows that the United States produces more ammonium sulphate than it needs and therefore it must seek outlets for its surplus in foreign markets.

The vast quantity of ammonium sulphate produced and imported is used as a fertilizer. The other uses are decidedly minor. It is from sulphate of ammonia that nitrogen, one of the three essential chemical elements used in fertilizer, is obtained. Therefore, the true comparison is between the domestic ammonium sulphate and the world production of pure fixed nitrogen in whatever form it appears.

Exhibit B shows the European production and consumption of fixed nitrogen in the years 1913 and 1925, and its production in 1926 and 1927. It is apparent therefrom that, whereas in 1913 European consumption greatly exceeded its production, in the later years the situation was reversed and the production now vastly exceeds the consumption. Between 1913 and 1927 European production increased by 232 per cent, while the world consumption increased by but 90 per cent. The great increase in production both in Europe and in the United States, together with the efforts of the Chilean nitrate industry to retain its markets, has led to severe competition and the lowering of price levels throughout the world. Furthermore, the capacity of the European countries to produce greatly exceeds their actual production. Germany alone is generally credited by trade sources with an annual capacity of 1,000.000 tons of nitrogen and is reported to be still building. England, France, and Italy are known to be increasing their air-nitrogen industry on an extensive scale. Since 1914 the German Government has been closely identified with developments in, and the success of, the German nitrogen industry. At least three of the German plants, including the great Haber plant at Merseburg. were built with Government funds. The Government agreed to assume the total first cost of the Merseburg plant in return for certain privileges in the disposal of the product. (See United States Department of Commerce Trade Information Bulletin No. 270, Nitrogen Survey, Pt. IV, pp. 5 and 6.)

In view of the situation as created by the world nitrogen production and the production in the United States of ammonium sulphate, and of the importance of encouraging the production in this country of coal-tar crudes, so necessary in times of peace and in times of war, we urgently request that the slight duty now imposed on ammonium sulphate be retained. The following reasons are suggested for the committee's consideration:

1. To conserve national resources. There are many wasteful beehive ovens still in operation. The by-product coke oven is very expensive in comparison with the beehive oven that it displaces. Some inducement must be offered in the way of return from the recovery of by-products in order that steel and gas manufacturers may be willing to invest the money required for the erection of costly plants.

2. To foster the domestic nitrogen industry as a measure of national defense. Domestic supplies of nitrogen are indispensable in times of war.

3. To foster the domestic nitrogen industry, to make American agriculture and industry more nearly independent of foreign supplies in times of both peace and war.

4. If consumers are to pay less for sulphate of ammonia because of the denial of protection for this commodity, consumers must pay an increased price for steel, tar, benzols, etc., since the production of both steel and sulphate of ammonia are, in a sense. merged in one operation.

5. Every ton of nitrogenous fertilizer material imported into the United States will foster foreign conservation and preparedness, to the detriment of American conservation and preparedness.

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