UNITED STATES DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-96,838

CLEVELAND CLIFFS STEEL CORPORATION
DEARBORN WORKS
INCLUDING WORKERS WHOSE WAGES WERE
REPORTED UNDER AK STEEL CORPORATION
DEARBORN, MICHIGAN

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 April 7, 2021 and
filed on April 8, 2021 by a State Workforce Office, on behalf of workers and former workers of
Cleveland Cliffs Steel Corporation, Dearborn Works, Dearborn, Michigan (hereafter referred to as
the "worker group"). The group of workers also consists of workers whose wages were reported
under AK Steel Corporation. 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 carbon slabs, hot-
dipped galvanized and galvannealed steel, and advanced high strength steels and are not separately
identifiable by product.

The petition alleged that worker separations, or threats thereof, foreign competition in the
steel market.

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(a)(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.

Decreased Sales or Production Criterion

(2)(A)(i) The sales or production, or both, of such firm have decreased absolutely;

According to 20 C.F.R. 618.225(a)(2)(ii)(B), "Analysis of sales or production data must
generally consist of a comparison of sales or production data on the petition date to sales or
production data on the date that is 1 year prior to the petition date."

The Department determines that the decreased sales or production criterion has been met.

Increased Imports Criterion

(2)(A)(ii)(I) Imports of articles or services like or directly competitive with articles
produced or services supplied by such firm have increased.

20 C.F.R. 618.110 defines increased imports to mean "that imports have increased either
absolutely or relative to domestic production compared to a representative base period. The
representative base period will be 1 year consisting of the 4 quarters immediately preceding the
date that is 12 months prior to the date of the petition."

The Department determines that the increased imports criterion has been met.

Contributed Importantly Criterion

(2)(A)(iii) The increase in imports described in clause (ii) contributed importantly to such
workers' separation or threat of separation and to the decline in the sales or production
of such 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." In determining
contributed importantly, according to 20 C.F.R. 618.225(a)(2)(iv) "(A) Analysis of the impact of
increased imports on worker separations and declines in sales or production at the workers' firm
must generally consist of determining: (1) Whether there are one or more events, or factors, that
lessen or sever the causal nexus between the increase in imports and worker separations or threat
of separation, and the decline in sales and production at the workers' firm; (2) What percentage
of the workers' firm sales or production declines was attributable to the firm's increased imports;

(3) What percentage of the workers' firm customer(s) sales or production declines was attributable
to the firm's increased imports; and (4) Whether there are other events or factors that mitigate or
amplify the impact of increased imports 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 Cleveland Cliffs Steel Corporation, Dearborn Works, including workers whose wages were
reported under AK Steel Corporation, Dearborn, Michigan, who are engaged in activities related
to the production of carbon slabs, hot-dipped galvanized and galvannealed steel, and advanced
high strength steels 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 Cleveland Cliffs Steel Corporation, Dearborn Works, including workers
whose wages were reported under AK Steel Corporation, Dearborn, Michigan, who became
totally or partially separated from employment on or after April 7, 2020 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 22nd day of June, 2021

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

UNITED STATES DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-96,838A

CLEVELAND-CLIFFS STEEL CORPORATION
MIDDLETOWN WORKS
INCLUDING WORKERS WHOSE WAGES WERE
REPORTED UNDER AK STEEL CORPORATION
MIDDLETOWN, OHIO

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 April 7, 2021 and
filed on April 8, 2021 by a State Workforce Office, on behalf of workers and former workers of
Cleveland-Cliffs Steel Corporation, Middletown Works, Middletown, Ohio (hereafter referred to
as the "worker group"). The group of workers also consists of workers whose wages were reported
under AK Steel Corporation. 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 carbon steel and are
not separately identifiable by product.

The petition alleged that worker separations, or threats thereof, foreign competition in the
steel market.

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(a)(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.

Decreased Sales or Production Criterion

(2)(A)(i) The sales or production, or both, of such firm have decreased absolutely;

According to 20 C.F.R. 618.225(a)(2)(ii)(B), "Analysis of sales or production data must
generally consist of a comparison of sales or production data on the petition date to sales or
production data on the date that is 1 year prior to the petition date."

The Department determines that the decreased sales or production criterion has been met.

Increased Imports Criterion

(2)(A)(ii)(I) Imports of articles or services like or directly competitive with articles
produced or services supplied by such firm have increased.

20 C.F.R. 618.110 defines increased imports to mean "that imports have increased either
absolutely or relative to domestic production compared to a representative base period. The
representative base period will be 1 year consisting of the 4 quarters immediately preceding the
date that is 12 months prior to the date of the petition."

The Department determines that the increased imports criterion has been met.

Contributed Importantly Criterion

(2)(A)(iii) The increase in imports described in clause (ii) contributed importantly to such
workers' separation or threat of separation and to the decline in the sales or production
of such 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." In determining
contributed importantly, according to 20 C.F.R. 618.225(a)(2)(iv) "(A) Analysis of the impact of
increased imports on worker separations and declines in sales or production at the workers' firm
must generally consist of determining: (1) Whether there are one or more events, or factors, that
lessen or sever the causal nexus between the increase in imports and worker separations or threat
of separation, and the decline in sales and production at the workers' firm; (2) What percentage
of the workers' firm sales or production declines was attributable to the firm's increased imports;

(3) What percentage of the workers' firm customer(s) sales or production declines was attributable
to the firm's increased imports; and (4) Whether there are other events or factors that mitigate or
amplify the impact of increased imports 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 Cleveland-Cliffs Steel Corporation, Middletown Works, including workers whose wages were
reported under AK Steel Corporation, Middletown, Ohio, who are engaged in activities related to
the production of carbon steel 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 Cleveland-Cliffs Steel Corporation, Middletown Works, including workers
whose wages were reported under AK Steel Corporation, Middletown, Ohio, who became
totally or partially separated from employment on or after April 7, 2020 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 22nd day of June, 2021

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