DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-40,610

THE GOODYEAR TIRE & RUBBER COMPANY
EAST GADSEN, ALABAMA

Notice of Negative Determination
Regarding Application for Reconsideration

By application of April 3, 2002, the United Steelworkers of
America, AFL-CIO, CLC, Local Union No. 12L requested
administrative reconsideration of the Department's negative
determination regarding eligibility for workers and former
workers of the subject firm to apply for Trade Adjustment
Assistance (TAA). The denial notice was signed on March 4, 2002
and published in the Federal Register on March 20, 2002 (67 FR
13010).
Pursuant to 29 CFR 90.18(c) reconsideration may be granted
under the following circumstances:
(1) If it appears on the basis of facts not previously
considered that the determination complained of
was erroneous;
(2) if it appears that the determination complained of
was based on a mistake in the determination of facts
not previously considered; or


(3) if in the opinion of the Certifying Officer, a mis-
interpretation of facts or of the law justified
reconsideration of the decision.

The TAA petition, filed on behalf of workers at Goodyear
Tire & Rubber Company, East Gadsden, Alabama engaged in the
production of passenger radial tires and light truck tires, was
denied because criteria (2) was not met. Production of passenger
radial tires and light truck tires at the subject plant increased
from 2000 to 2001.
The request for reconsideration alleges that company wide
sales of tires declined during the relevant period. The
petitioner attached various news articles to illustrate declines
in company sales during the relevant period.
An examination of Goodyear Tire and Rubber's 2001 Annual
Report shows that the company's tire sales declined during the
2001 period over the corresponding 2000 period. Further
examination of the 2001 Annual Report shows that the
preponderance in the declines in company tire sales is related to
lost business in foreign countries, rather than lost domestic
tire sales.
A further review of aggregate U.S. imports of radial tires
shows that imports declined in the year 2001 compared to 2000.
Also, the company did not import articles like or directly
competitive with articles produced at the subject firm.
Thus, on further analysis, criterion (3) group eligibility
requirements of Section 222 of the Trade Act of 1974 also was not
met. Imports of radial tires did not contribute importantly to
the subject plants layoffs. Analysis of information provided
indicates that any fluctuation in corporate wide sales appears
related to a global slowdown, rather than imports impacting the
subject plant.
Conclusion
After review of the application and investigative findings,
I conclude that there has been no error or misinterpretation of
the law or of the facts which would justify reconsideration of
the Department of Labor's prior decision. Accordingly, the
application is denied.

Signed at Washington, D.C., this 3rd day of June 2002
/s/ Edward A. Tomchick
__________________________
EDWARD A. TOMCHICK
Director, Division of
Trade Adjustment Assistance