DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-61,957

COMMAND TOOLING SYSTEMS, LLC
RAMSEY, MINNESOTA

Negative Determination Regarding Eligibility
To Apply For Worker Adjustment Assistance and
Alternative Trade Adjustment Assistance

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 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 was initiated on August 9, 2007 in response
to a petition filed by a state agency representative on behalf of
workers of Command Tooling Systems, LLC, Ramsey, Minnesota. Workers
at the subject firm manufacture tool holders for milling machines.
The investigation revealed that criteria (a)(2)(A)(I.C) and
(a)(2)(B)(II.B) have not been met.
The investigation revealed that employment, sales and
production declined during the period of January through July 2007,
when compared to the same time period in 2006.
The subject firm did not shift production of tool holders to a
foreign country in 2005, 2006, or during the period of January
through July 2007.
The subject firm did import a negligible amount of tool
holders during the period under investigation.
The United States Department of Labor surveyed the subject
firm's major declining customers regarding their purchases of tool
holders in 2005, 2006, and January through July 2007. The surveys
revealed no import purchases of tool holders during this 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 in the
investigation, I determine that all workers of Command Tooling
Systems, LLC, Ramsey, Minnesota, 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 23rd day of October 2007.


/s/Linda G. Poole
______________________________
LINDA G. POOLE
Certifying Officer, Division of
Trade Adjustment Assistance