DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-54,375

INTERNATIONAL PAPER COMPANY
ATLANTIC REGION FOREST DIVISION
GEORGETOWN, SOUTH CAROLINA

Notice of Negative Determination
Regarding Application for Reconsideration

By application of June 3, 2004, a petitioner requested
administrative reconsideration of the Department's negative
determination regarding eligibility for workers and former
workers of the subject firm to apply for Trade Adjustment
Assistance (TAA). The denial notice applicable to workers of
International Paper Company, Atlantic Region Forest Division,
Georgetown, South Carolina was signed on May 12, 2004, and
published in the Federal Register on June 2, 2004 (69 FR 31135).
Pursuant to 29 CFR 90.18(c) reconsideration may be granted
under the following circumstances:
(1) If it appears on the basis of facts not previously
considered that the determination complained of
was erroneous;
(2) if it appears that the determination complained of
was based on a mistake in the determination of facts
not previously considered; or
(3) if in the opinion of the Certifying Officer, a mis-
interpretation of facts or of the law justified
reconsideration of the decision.
The TAA petition was filed on behalf of workers at
International Paper Company, Atlantic Region Forest Division,
Georgetown, South Carolina engaged in administrative and staff
support functions associated with the management of forest lands.
The petition was denied because the petitioning workers did not
produce an article within the meaning of Section 222 of the Act.
In the request for reconsideration a petitioner contends
that the Department erred in its interpretation of work performed
at the subject facility and alleges that the petitioning workers
performed administrative and procurement activities for several
mills in North Carolina and Georgia, which were impacted by the
Canadian and European imports.
A company official was contacted in regards to these
allegations. It was revealed upon further investigation that the
petitioning workers were engaged in land sales, environmental
activities and GIS development for the Forest Resources Division
of the International Paper Company. Furthermore, the nature of
work that the workers performed had no direct relationship with
the production within the Forest Resources Division, nor did they
support production at any of the International Paper Company
mills. The official further stated that the establishment of a
new business strategy to lower operating cost through the
elimination, consolidation and reorganization of a number of
managerial and administrative job functions within the Forest
Resources Division caused the workers separations at the subject
firm during the relevant time period.
The petitioner further alleges that because workers of the
International Paper, Augusta, Maine were granted certification in
December of 2003, workers of the subject firm should be also
eligible for TAA.
A review of the case concerning International Paper, Augusta
Maine (TA-W-53,534) revealed that the displaced workers of the
Augusta facility were engaged in activities directly related to
the production of light-weight coated paper for the publishing
industry insofar as they procured logs from company woodlands and
provided them to an affiliated TAA certified International Paper,
Bucksport, Maine (TA-W-53,533).
The current investigation did not establish any relationship
between the production facilities and dislocated workers of the
International Paper Company, Atlantic Region Forest Division,
Georgetown, South Carolina.
Conclusion
After review of the application and investigative findings,
I conclude that there has been no error or misinterpretation of
the law or of the facts which would justify reconsideration of
the Department of Labor's prior decision. Accordingly, the
application is denied.

Signed at Washington, D.C., this 13th day of July, 2004.
/s/ Elliott S. Kushner

___________________________
ELLIOTT S. KUSHNER
Certifying Officer, Division of
Trade Adjustment Assistance