To Whom It May Concern:

SATIC USA attests that the “Manufactured Products” listed herein, as the “Product Line” are (BABA)
compliant and provides accurate and up-to-date information regarding the Build America Buy America
(BABA) provisions within the Infrastructure Investments and Jobs Act of 2021 (IIJA). The IIJA requires that “the
head of each Federal agency must ensure that none of the funds made available for a federal award for an
infrastructure project may be obligated unless all of the iron, steel, manufactured products, and construction
materials incorporated into the project are produced in the United States.”1

Specifically, in the case of manufactured products, the product must be both (a) manufactured in the
United States and (b) the cost of components of the manufactured product that are mined, produced, or
manufactured in the United States must be greater than 55 percent of the total costs of all the components
of the manufactured product.2

 

In determining whether the cost of components for manufactured products meets that threshold, SATIC USA has used the following: 3

(a) For components purchased by the manufacturer, the acquisition cost, including transportation costs
to the place of incorporation into the manufactured product (whether or not such costs are paid to
a domestic firm), and any applicable duty (whether or not a duty-free entry certificate is issued); or
(b) For components manufactured by the manufacturer, all costs associated with the manufacture of the
component, including transportation costs as described in paragraph (a) above, plus allocable
overhead costs, excluding profit, and does not include any costs associated with the manufacture of
the manufactured product.

Following these criteria, SATIC USA attests that it manufactures an electricity optimizing power
conditioner product in the United States that satisfies BABA’s greater than 55 percent requirement and
that this product line is available for purchase during all required qualifying dates.
SATIC USA attests that the “Product Line” is to be installed as an integral component of a solar electricity-
generating system and must be either physically or electrically integrated into the solar photovoltaic inverter
circuitry to qualify.

SATIC USA attests that the direct domestic labor costs of the Product Line is 100% SATIC USA’s labor cost and
the direct material costs exceed 55% of the component costs.4 

SATIC USA attests that the form, fit and function of raw materials to manufacture the Product Line are
transformed at SATIC USA’s U.S. facility.

Kindly note that the cost of the SATIC PPB Product Line portion of the inverter-based solar photovoltaic
system counts only as a portion of the total solar photovoltaic system, i.e. solar modules, racking, etc., and
cannot carry the weight of an entire solar photovoltaic system.5

Specifically, SATIC USA attests that the following Product Line numbers can be made available within 90
days upon receipt of a request for BABA-compliant products:

SATIC Power Perfect & Pure Power Models PPB, PPBHD, PPBSD (each a Manufactured Product).

SATIC USA certifies under penalty of law that all the information contained in this attestation is true, correct and
correct. Any material misrepresentation may result criminal or civil penalties. See 18 U.S.C. Sec. 1001 et. seq.6

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1 eCFR :: 2 CFR 184.1 -- Purpose and policy. See also § 70914(a) of the IIJA.
2 eCFR :: 2 CFR Part 184 -- Buy America Preferences for Infrastructure Projects
3 eCFR :: 2 CFR 184.5 -- Determining the cost of components for manufactured products.
4 A VerificaSon LeUer issued by a CPA under NDA is available upon request.
5 The IRS pre-assigned percentage is 4.5%. B.D. Erickson II, C.E.O.
6 18 USC 1001: Statements or entries generally

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