DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-56,082

COOPER TIRE & RUBBER COMPANY
INNER TUBE ASSOCIATES
CLARKSDALE, MISSISSIPPI

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

In accordance with Section 223 of the Trade Act of 1974 (19
USC 2273), as amended, the Department of Labor herein presents the
results of its investigation regarding certification of eligibility
to apply for worker adjustment assistance.
In order to make an affirmative determination and issue a
certification of eligibility to apply for Trade Adjustment
Assistance, the group eligibility requirements in either paragraph
(a)(2)(A) or (a)(2)(B) of Section 222 of the Trade Act must be met.
It is determined in this case that the requirements of (a)(2)(A) of
Section 222 have been met.
The investigation was initiated on November 24, 2004 in
response to a petition filed by the United Steelworkers of America,
Local 556L on behalf of workers producing inner tubes at Cooper
Tire & Rubber Company, Clarksdale, Mississippi. Workers producing
inner tubes are separately identifiable from others at the
facility.


The investigation revealed that sales and employment at the
subject facility decreased in 2003 compared with 2002 and during
January though November of 2004. Production of inner tubes at the
subject facility ceased in November, 2004.
The United States Department of labor surveyed the subject
firm's major customer regarding their purchases of inner tubes
during 2002, 2003 and January through November 2003-2004.
Respondents reported that imports increased, and reliance on
imports continued to increase through November of 2004.
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.
The group eligibility criteria for the ATAA program

that the Department must consider under Section 246 of the

Trade Act are:
1. Whether a significant number of workers in the
workers' firm are 50 years of age or older.
2. Whether the workers in the workers' firm possess skills
that are not easily transferable.
3. The competitive conditions within the workers' industry
(i.e., conditions within the industry are adverse).
The Department has determined that criterion 2 has not been
met.
The investigation revealed that the skills of the worker
group are easily transferable to other positions in the local
commuting area.



Conclusion
After careful review of the facts obtained in the
investigation, I conclude that increases of imports of inner tubes
produced at Cooper Tire & Rubber Company, Clarksdale, Mississippi
contributed importantly to the total or partial separation of
workers and to the decline in sales or production at that firm or
subdivision. In accordance with the provisions of the Act, I make
the following certification:
"All workers of Cooper Tire & Rubber Company, Inner Tube
Associates, Clarksdale, Mississippi, became totally or partially
separated from employment on or after November 23, 2003, through
two years from the date of certification are eligible to apply
for adjustment assistance under Section 223 of the Trade Act of
1974."
I further determine that all workers of Cooper Tire & Rubber
Company, Inner Tube Associates, Clarksdale, Mississippi are
denied eligibility to apply for alternative trade adjustment
assistance under Section 246 of the Trade Act of 1974.
Signed in Washington, D. C., this 13th day of January, 2005.

/s/ Richard Church
______________________________
RICHARD CHURCH
Certifying Officer, Division of
Trade Adjustment Assistance