UNITED STATES DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-96,310

VALENT AEROSTRUCTURES

MANUFACTURING & WAREHOUSE FACILITIES

A DIVISION OF LMI AEROSPACE, INC.

WICHITA, KANSAS

Certification Regarding Eligibility

To Apply for Trade Adjustment Assistance for Workers

In accordance with Section 223 of the Trade Act of 1974, as amended ("the Act"), 19 U.S.C.§
2273, the Department of Labor ("Department") herein presents the results of an investigation
regarding certification of eligibility to apply for Trade Adjustment Assistance ("TAA") for workers.

The investigation was initiated in response to a TAA petition dated September 24, 2020 and
filed on September 25, 2020 by a State Workforce Office, on behalf of workers and former workers
of Valent Aerostructures, Manufacturing & Warehouse facilities, a division of LMI Aerospace,
Inc., Wichita, Kansas (hereafter referred to as the "worker group"). In accordance with 20 C.F.R.
618.110 a worker group is defined as, ""¦inclusive of teleworkers and staffed workers."

The worker group is engaged in activities related to the production and warehousing of
aerospace parts, such as assembled structures and component parts and are not separately
identifiable by product.

The petition alleged that worker separations, or threats thereof, were due to foreign trade
because, "company supplies/supports operations for certified petition TA-W-95,556, Spirit
Aerosystems."

During the course of the investigation, the Department collected information from the
petitioner(s), the workers' firm, and other relevant sources.

The group eligibility requirements for workers of a firm under Section 222(b) of the Act, 19
U.S.C. § 2272(b), are satisfied if the following criteria are met:

Employment Criterion

(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.

20 C.F.R. 618.225(d)(1)(ii) states that an "Analysis of separation data must generally
consist of a: "(A) Comparison of employment on the petition date to employment on the date that
is 1 year prior to the petition date; (B) Review of employment activity during the 1-year period
prior to the petition date; and (C) Review of evidence provided by the workers' firm regarding
actual and threatened separations that occur, or are scheduled to occur, after the petition date."

The Department determines that the employment criterion has been met.

Supplier/Downstream Producer Criterion

(2) the workers' firm is a supplier or downstream producer to a firm that employed a group
of workers who received a certification of eligibility under subsection (a), and such supply
or production is related to the article or service that was the basis for such certification
(as defined in subsection (c) (3)and (4)); and

Section 222(c)(4) of the Trade Act, 19 U.S.C. § 2272(c), defines the term "Supplier" to
mean "a firm that produces and supplies directly to another firm component parts for articles, or
services, used in the production of articles or in the supply of services, as the case may be, that
were the basis for a certification of eligibility under subsection (a) of a group of workers
employed by such other firm."

The Department determines that the Supplier criterion has been met.

Contributed Importantly Criterion

(3) either
(A) the workers firm is a supplier and the component parts it supplied to the firm
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 described in paragraph

(2) contributed importantly to the workers' separation or threat of separation
determined under paragraph (I).

20 C.F.R. 618.225(d)(5) states that the component parts supplied represented at least 20
percent of the supplier's production or sales during the 1-year period prior to the petition date, or
loss of business with the firm, during the 1-year period prior to the petition date, contributed
importantly to separations or threat of separation at the workers' firm." Sec. 222(c) of the Trade

Act and 20 C.F.R. 618.110 defines contributed importantly as, "a cause that is important but not
necessarily more important than any other cause."

The Department determines that the 20% criterion has been met.

Conclusion

After careful review of the facts obtained in the investigation, I determine that workers of
Valent Aerostructures, Manufacturing & Warehouse facilities, a division of LMI Aerospace, Inc.,
Wichita, Kansas, who are engaged in activities related to the production and warehousing of
aerospace parts, such as assembled structures and component parts meet the worker group
certification criteria under Section 222(b) of the Act, 19 U.S.C. § 2272(b). In accordance with
Section 223 of the Act, 19 U.S.C. § 2273, I make the following certification:

"All workers of Valent Aerostructures, Manufacturing & Warehouse facilities, a division
of LMI Aerospace, Inc., Wichita, Kansas, who became totally or partially separated from
employment on or after September 24, 2019 through two years from the date of
certification, and all workers in the group threatened with total or partial separation from
employment on the date of certification through two years from the date of certification,
are eligible to apply for adjustment assistance under Chapter 2 of Title II of the Trade Act
of 1974, as amended."

Signed in Washington, D.C. this 28th day of January, 2021.

/s/ Hope D. Kinglock
_______________________
HOPE D. KINGLOCK

Certifying Officer, Office of

Trade Adjustment Assistance