UNITED STATES DEPARTMENT OF LABOR
Employment and Training Administration
TA-W-96,618
BCS ACCESS SYSTEMS US LLC

MANAGEMENT

AUBURN, NEW YORK
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 November 17, 2020
and filed on November 18, 2020 by a Company Official, on behalf of workers and former workers
of BCS Access Systems US LLC, Management, Auburn, New York (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 of remote access, passive
entry components, tire pressure modules and keyless entry electronic components and are not
separately identifiable by product.

The petition alleged that worker separations, or threats thereof, were due to foreign trade
because, BCS-AIS North America conducted a manufacturing footprint study and concluded
that there is excess manufacturing capacity in North America. A financial study concluded that
the optimized footprint would consist of closing the Auburn, New York manufacturing site and
transferring products/production lines to the Winona, Minnesota facility and Reynosa, Mexico
facility.

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(a) of the Act,
19 U.S.C. § 2272(a), are satisfied if the following criteria are met:

Employment Criterion

(1) A significant number or proportion of the workers in such workers' firm have become
totally or partially separated, or are threatened to become totally or partially separated.

20 C.F.R. 618.225(b)(2)(i)(B) states that an "analysis of separation data must generally
consist of a: "(1) Comparison of employment on the petition date to employment on the date that is
1 year prior to the petition date; (2) Review of employment activity during the 1-year period prior
to the petition date; and (3) 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.

Shift/Acquisition Criterion

(2)(B)(i)(I) there has been a shift by the workers' firm to a foreign country in the production
of articles or the supply of services like or directly competitive with articles which
are produced or services which are supplied by such firm; or

(II) such workers' firm has acquired from a foreign country articles or services that
are like or directly competitive with articles which are produced or services which
are supplied by such firm;
According to 20 C.F.R. 618.225(b)(2)(ii)(B), "Analysis of shift data must generally consist
of a: (1) Comparison of shift/acquisition data on the petition date to shift/acquisition data that is
1 year prior to the petition date; (2) Review of shift/acquisition activity during the 1-year period
prior to the petition date; and (3) Review of evidence provided by the workers' firm regarding shift/
acquisition activity scheduled to occur after the petition date."

The Department determines that the shift criterion has been met.

Contributed Importantly Criterion

(ii) the shift described in clause (i)(I) or the acquisition of articles or services described
in clause (i)(II) contributed importantly to such workers' separation or threat of
separation.
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."

According to 20 C.F.R. 618.225(b)(2)(iii), "(A) Analysis of impact of shift activity on
worker separations must generally consist of determining: (1) Whether there are one or more events
or factors that sever or lessen the causal nexus between the shift activity and worker separations
or threat of separation; (2) What percentage of the workers' firm sales or production declines was
attributable to the firm's shift activity; (3) Whether operations at the workers' firm domestic facility
or facilities decreased at the same or at a greater rate than operations at the foreign facility or
facilities; and (4) Whether there are other events or factors that mitigate or amplify the impact
of shift activity on the workers' firm. (B) The impact may be determined using a quantitative or
qualitative analysis."
The Department determines that the contributed importantly criterion has been met.
Conclusion

After careful review of the facts obtained in the investigation, I determine that workers of
BCS Access Systems US LLC, Management, Auburn, New York, who are engaged in activities
related to the production of remote access, passive entry components, tire pressure modules and
keyless entry electronic components meet the worker group certification criteria under Section
222(a) of the Act, 19 U.S.C. § 2272(a). In accordance with Section 223 of the Act, 19 U.S.C. §
2273, I make the following certification:

"All workers of BCS Access Systems US LLC, Management, Auburn, New York, who
became totally or partially separated from employment on or after November 17, 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 19th day of January, 2021.

/s/ Hope D. Kinglock
_______________________
HOPE D. KINGLOCK
Certifying Officer, Office of
Trade Adjustment Assistance