DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-61,559

THUNDER BAY MANUFACTURING CORPORATION
ALPENA, MICHIGAN

Negative Determinations Regarding Eligibility
To Apply for Worker Adjustment Assistance
And Alternative Trade Adjustment Assistance

In accordance with Section 223 of the Trade Act of 1974 (19
USC 2273), as amended, the Department of Labor herein presents the
results of an investigation regarding certification of eligibility
to apply for worker adjustment assistance as an adversely affected
secondary group.
An investigation was conducted in order to determine whether
the petitioning group of workers qualifies as adversely affected
secondary workers as suppliers of component parts to a firm or
subdivision primarily affected by increased imports or a shift of
production abroad.
In order to make an affirmative determination and issue a
certification of eligibility to apply for adjustment assistance,
the following group eligibility requirements under Section 222(b)
must be met:
(1) a significant number or proportion of the workers in the
workers' firm or an appropriate subdivision of the firm
have become totally or partially separated, or are
threatened to become totally or partially separated;

(2) the workers' firm (or subdivision) is a supplier or
downstream producer to a firm (or subdivision) that
employed a group of workers who received a certification
of eligibility to apply for trade adjustment assistance
benefits and such supply or production is related to the
article that was the basis for such certification; and

(3) either-

(A) the workers' firm is a supplier and the component
parts it supplied for the firm (or subdivision) described
in paragraph (2) accounted for at least 20 percent of the
production or sales of the workers' firm; or

(B) a loss of business by the workers' firm with the firm
(or subdivision) described in paragraph (2) contributed
importantly to the workers' separation or threat of
separation.

The investigation was initiated on May 22, 2007 in response to
a petition filed by a company official on behalf of workers of
Thunder Bay Manufacturing Corporation, Alpena, Michigan. Workers at
the subject firm produced gray and ductile cast iron stamping dies
for the automotive industry.
The investigation revealed that criterion 3 has not been met.
Petitioners allege that job losses were due to their firm
losing business as a supplier firm, producing components for trade
certified firms. The investigation revealed the subject firm did
supply component parts utilized in automotive tools and die
production. However the loss of business with a manufacturer of
automotive tools and dies whose workers were certified eligible to
apply for adjustment assistance was very minor and has not
contributed importantly to the separation or threat of separation
of workers at the subject facility. The investigation further
revealed that other customers have not received a primary
certification as eligible to apply for adjustment assistance.
Additionally, in accordance with Section 223 of the Trade Act
of 1974, as amended (19 USC 2273), the Department of Labor herein
presents the results of an investigation regarding primary
certification of eligibility to apply for worker adjustment
assistance. The group eligibility requirements for directly-
impacted (primary) workers under Section 222(a) the Trade Act of
1974, as amended, can be satisfied in either of two ways:
I. Section (a)(2)(A) all of the following must be satisfied:
A. a significant number or proportion of the workers in
such workers' firm, or an appropriate subdivision of the
firm, have become totally or partially separated, or are
threatened to become totally or partially separated;

B. the sales or production, or both, of such firm or
subdivision have decreased absolutely; and

C. increased imports of articles like or directly
competitive with articles produced by such firm or
subdivision have contributed importantly to such workers'
separation or threat of separation and to the decline in
sales or production of such firm or subdivision; or

II. Section (a)(2)(B) both of the following must be satisfied:

A. a significant number or proportion of the workers in such
workers' firm, or an appropriate subdivision of the firm,
have become totally or partially separated, or are
threatened to become totally or partially separated;

B. there has been a shift in production by such workers' firm
or subdivision to a foreign country of articles like or
directly competitive with articles which are produced by
such firm or subdivision; and

C. One of the following must be satisfied:
1. the country to which the workers' firm has shifted
production of the articles is a party to a free trade
agreement with the United States;

2. the country to which the workers' firm has shifted
production of the articles is a beneficiary country
under the Andean Trade Preference Act, African Growth
and Opportunity Act, or the Caribbean Basin Economic
Recovery Act; or

3. there has been or is likely to be an increase in
imports of articles that are like or directly
competitive with articles which are or were produced
by such firm or subdivision.

The investigation revealed that criteria (a)(2)(A)(I.C) and
(a)(2)(B)(II.B) have not been met.
The subject firm did not import or shift production of gray
and ductile cast iron stamping dies abroad in 2005, 2006, or during
January through April 2007.
The Department of Labor surveyed the subject firm's major
declining customers regarding their purchases of gray and ductile
cast iron stamping dies. This survey revealed no imports during the
relevant period.
In addition, in accordance with Section 246 the Trade Act of
1974 (26 USC 2813), as amended, the Department of Labor herein
presents the results of its investigation regarding certification
of eligibility to apply for alternative trade adjustment assistance
(ATAA) for older workers.
In order for the Department to issue a certification of
eligibility to apply for ATAA, the worker group must be certified
eligible to apply for trade adjustment assistance (TAA). Since the
workers are denied eligibility to apply for TAA, the workers cannot
be certified eligible for ATAA.

Conclusion
After careful review of the facts obtained during this
investigation, I determine that workers of Thunder Bay
Manufacturing Corporation, Alpena, Michigan, are denied eligibility
to apply for adjustment assistance under Section 223 of the Trade
Act of 1974, and are also denied eligibility to apply for
alternative trade adjustment assistance under Section 246 of the
Trade Act of 1974.
Signed in Washington, D.C. this 25th day of June 2007


/s/Richard Church
_______________________________
RICHARD CHURCH
Certifying Officer, Division of
Trade Adjustment Assistance