DOCUMENT RESUME C S A 00594 - A08916191 Assistance to Nonrubber Shoe Firms. CED-77-51; B-179342. arch 4, 1977. Released March 7, 1977. 49 pp. Report to Rep. James A. Burke; by Robert F. Keller, Acting Comptroller General. Issue Area: Education, Training, and Employment Programs: Programs for Specific Target Groups (1108); Domestic Housing and Community Development (2100). Contact: Community and Economic Development Div. Budget Function: Communit7 and Regional Development: Area and Regional Development (452). Organization Concerned: Economic Development administration; Department of Commerce. congressional Relevance: Rep. James A. Burke. Authority: Trade Act of 1974 (P.L. 93-t618). National Environmental Policy Act of 1969 (42 U.S.C. 4321). Trade Expansion Act of 1962. The Trade Adjustment Assistance Program was set up to provide loans and technical assistance to help firms, hurt by increased imports of their products, to retool to make new or different products and to keep from going out of business. Assistance provided to the nonrubber footwear industry under this program was investigated. Findings/Conclusions: few administrative problems ay herve kept some nnrukber shoe firs from getting loans as quickly as possible. Although the Department of ommserce first thought that more than 200 nonrubber shoe firms ight apply for assistance, only 25 firms petitioned and 16 were certified. About $3.3 million in loans was authorized to four of these firms, and technical assistance costing about $230,000 was provided to one firs and the footwear industries association. The most prevalent reason given by nonpetitioning firms for not applying was that they did not need assistance. The certification and application requirements of the Trade Adjustment Assistance Program, with few exceptions, were reasonable and consonant with the Trade Act of 1974 and other legislation. Recommendations: Administrative delays in processing both petitions and/or applications should be corrected. The Economic Development Administraticn should provide minimal assistance to some firms in preparing their applications for assistance. (Author/SC) ~~~o p/fjS~i 'i REPORT OF THE COMPTROLLER GENERAL ~? " OF THE UNITED STATES Assistance To Nonrubber Shoe Firms Department of Commerce The certification and application require- ments of the T;-ade Adjustment Assistance Program, with few exceptions, were reason- able and in consonance with the Trade Act of 1974 and other legislation. However, two problems could be corrected: administrative delays in processing both peti- tions and/or applications and minimal assist- ance from the Economic Development Ad- ministration to some firms in preparing their applications for assistance. CED-77-51 C X . 6*:~.~ COMPTROLLER GENERAL OF THE UNITED STATE WA*glSqINGYON, D.C. MuDs B-i79342 The Honorable James A. Burke House of Representatives Dear Mr. Burke: Pursuant to your request of April 8, 1976, we have reviewed why the Economic Development Administration has failed to provide the nonrubber footwear industry timely trade adjustment financial assistance under he provisions of the Trade Act of 1974. As agreed,-we orally briefed your office on October 8, 1976, relating the findings of our review to date and provided a written statement of facts on November 23, 1976. As you requested, the Economic Development Admin- istration was given opportunity to present oral comments on the conclusions and recommendations which deal with ways the program's administration can be improved. The Economic Development Administration expressed general agreement with the facts contained in this report. It also expressed agreement with our recom- mendations. As ou know, section 236 of the Legislative Reorganization Act of 1970 requires the head of a Fed- eral agency to submit a written statement on actions taken on our recommendations to the House Committee on Government Operations and the Senate Committee on Gov- ernmental Affairs not later than 60 days after the date of the report and to the House and Senate Committees on Appropriations with the agency's first request for ap- propriations made more than 60 days after the date of the report. We will be in touch with your office in the near future to arrange for release of the report to set in motion the requirements of section 236. B-179342 Copies of this report are being sent to Senators John A. Durkin and Thomas F. McIntyre and Represen- tative Norm D'Amours. Sincerely yours, ACTING Co hellftineral of the United States 2 REPORT OF THE ASSISTANCE TO COMPTROLLER GENERAL NONRUBBER SHOE FIRMS OF THE UNITED STATES Department of Commerce DIGEST The Trade Adjustment Assistance Program, administered by the Economic Development Administration at the Department of Commerce, was set up to provide loans and technical assistance to help firms, hurt by increased imports of their products, to retool to make new or different products and keep from going out of business. A few administrative problems, such as proc- essing delays and the little help given firms in filling out applications for assistance, may have kept some nonrubber shoe firms from getting loans as quickly as possible. The Department of Commerce first thought that more than 200 nonrubber shoe firms might pe- tition for, and that by December 1976 possibly 150 would be eligible for, adjustment assist- ance under the Trade Act of 1974. Only 25 firms petitioned, and 16 were certified. The Economic Development Administration au- thorized about $3.3 million in loans to four of these firms and provided technical assist- ance costing about $230,000 to one firm and the footwear industries association. Why didn't more firms seek assistance? The single prevalent response from 102 firms sur- veyed was that they did not need assistance. Other reasons were -- the Trade Adjustment Assistance program would not solve their problems, -- they did not believe they were eligible, -- they did not know enough about the program, and -- excessive time, money, and paperwork were involved. (See p. 9.) caar sL . Upon moval, the report CED-7751 cov er eshould be noted eror.i CED-77-51 ADMINISTRATION OF THE PROGRAM The Trade Adjustment Assistance Program has two processing stages--certification and ap- plication. With few minor exceptions, Depart- ment of Commerce requirements under these stages were reasonable and in consonance with the Trade Act of 1974 or other applicable leg- islation. Correcting the problems will not greatly affect processing time, although it may help to somewhat reduce the work required to prepare petitions for certification and applications for assistance. (See p. 3.) Administrative delays occurred in 12 cf 18 nonrubber shoe firms either during the cer- tification or application processes or both. Except for the long time taken to screen some applications and, in one case approve an ap- plication, the delays were not extensive and were correctable. (See p. 12.) Some firms need help in preparing their appli- cations for assistance, including economic adjustment proposals. Although entitled to such assistance under the act, few nonrubber shoe firms received any. (See p. 20.) The Economic Development Administration, which was given the opportunity to in- formally comment on the conclusions and recommendations, generally agreed with this report and described actions taken to correct some of the problems noted. (See pp. 5, 19, and 27.) RECOMMENDATIONS The Secretary of Commerce should direct the Assistant Secretary for Economic Development to -- require applicants to submit for the pre- cedirg 2 or 3 years only that financial, production, sales, inventory, and workload information absolutely necessary for de- ciding eligibility for certification; -- reevaluate whether the Economic Development Administration should assess the effects on the environment under the Trade Adjustment ii Assistance Progiam, since the anticipated large volume of trade adjustment assistance never materialized; -- provide nonrubber shoe firms assistance in preparing their application packages, in- cluding development of economic adjustment plans; -- inform such firms of restrictions governing approval of assistance projects when work on the projects has already been done; and --make every effort to advise such firms of alternative Federal programs which could help them adjust to forrt'n competition. To prevent administrative delays, the Secre- tary of Commerce should direct the Assist- ant Secretary for Economic Development to review the Trade Adjustment Assistance in- structions and administrative procedures to determine whether -- regional personnel know about trade adjust- ment assistance, including the 5-working- day screening requirement, and take measures to adjust their work priorities accordingly; -- regional offices have procedures, such as time stamping applications when opening the daily mail, to comply with the screening time requirement; -- regional offices have uniform procedures for processing trade adjustment assistance applications--including the screening of applications before acceptance; and -- regional officials are following the Economic Development Administration headquarters criteria for approving loans. Iuar Sht iii Contents DIGEST i CHAPTER 1 INTRODUCTION 1 Scope of review 2 2 CERTIFICATION AND APPLICATION REQUIREMENTS APPEAR REASONABLE 3 Certification process 3 Application process 4 Agency comments 5 Conclusions and recommendations 5 3 PROGRAM PARTICIPATION NOT AS GREAT AS ANTICIPATED 7 Combl:erce study 7 Extent of participation 7 Results of telephone survey 8 Conclusions 11 4 ADMINISTRATIVE DELAYS IDENTIFIED 12 Time requirements 12 Delays during certification 13 Delays during application 15 Conclusions and recommendations 18 5 NEED TO PROVIDE ASSISTANCE TO FIRMS IN PREPARING APPLICATIONS 20 Legislative requirements 20 Need for assistance in preparing applications 21 Limited assistance provided 23 Need to provide information on other assistance programs 25 Conclusions and recommendations 26 APPENDIX I Certification process 28 II Application process 32 III Form ED-435--Petition by a firm for cer- tification of eligibility to apply for trade adjustment assistance 38 IV Form ED-272--Application requirements and index-trade adjustment assistance for firms 44 APPENDIX Pae V Officials' responses to questions regarding import injury and reasons for not petitioning for trade adjustment assistance 48 VI Status of certified nonrrubber footwear firms as of December 31, 1976 49 ABBREVIATIONS DAS/P Deputy Assistant Secretary for Economic Development Planning DIBA Domestic and International Business Administration EDA Economic Development Administration GAO General Accountina Office OBD Office of Business Development TACD Trade Act Certification Division CHAPTER 1 INTRODUCTION Congress has the constitutional authority to levy duties and in other ways regulate foreign trade. Since 1934, it has periodically delegated the President specific and limited authority to conduct negotiations with other countries for reciprocal tariff and trade concessions. The Trade Act of 1974 (Public Law 93-618) gives the President 5-year authority to engage in multilateral trade negotiations to promote the development of an open, nondis- criminatory and fair world economic system to stimulate the economic growth of the United States. In addition, the act provides procedures to safeguard American industry and labor against unfair or injurious import competition and to assist industries, firms, workers, and communities to adjust to changes in international trade flows. Title II, chapter 3, of the Trade Act of 1974, includes provisions for trade adjustment assistance for firms. The objective of the adjustment assistance program is to help firms injured by increased imports to adjust to changes in international trade flows. Types of assistance include tech- nical assistance to develop an adjustment proposal and direct and/or guaranteed loans to purchase fixed assets or for use as working capital to implement the proposal. The program is administered by the Department of Commerce's Economic Development Administration (EDA). The trade adjustment assistance program for firms under the Trade Act of 1974 differed in several important ways from provisions of a comparable program authorized in the Trade Expansion Act of 1962. Most importantly the eligibi- lity criteria for program assistance are significantly relaxed. The Trade Act of 1974 eliminated the requirement that there be any causal link between tariff concessions and increased imports and that increased imports would not have to be the major factor causing or threatening serious injury to the firm. The Secretary of Commerce (Secretary) deter- mines eligibility (certification) under the new program, and individual firms can directly petition EDA instead of the International Trade commission, formally the Tariff Commis- sion. EDA Headuarters is responsible for certification, whereas the six regional offices are responsible for processing applications for loans and technical assistance. 1 In meetings held with your office, we agreed to -- identify EDA requirements for firms from the time of application to actual disbursement of the funds, -- evaluate the need for these requirements, -- evaluate the assistance EDA gives the firms in meeting these requirements, -- identify delays from the time the firms are certified to actual approval for adjustment assistance, and -- identify reasons for these delays. The Office of Management and Budget allotted $20 million for the firm's adjustment assistance program both in fiscal years 1976-77. As of December 1, 1976, EDA had authorized loans amounting to about $13.5 million to 15 firms--including $3.3 million to 4 firms--and technical assistance of $250,000-- including $5,000 to 1 footwear firm and $225,000 to the American Footwear Industries Association. SCOPE OF REVIEW Our review included 18 nonrubber shoe firms which had petitioned EDA for assistance. As of June 30, 1976, 13 firms had been certified by EDA. We reviewed the records of firms at EDA's Washington Headquarters and visited or talked to officials of 11 firms. We interviewed agency officials at EDA's Washington headquarters and the Atlantic Regional Office in Philadelphia. In addition, we telephone surveyed 102 firms in the major footwear producing States to determine why they have not requested assistance. 2 CHAPTER 2 CERTIFICATION AND APPLICATION REQUIREMENTS APPEAR REASONABLE The Trade Adjustment Assistance Program administered by EDA involves two processing stages--certification and appli- cation. During certification EDA makes a determination as to a firm's eligibility to apply for program assistance. Once this decision is reached, the certified firm then may apply for program assistance by submitting required documentation-- including a detailed explanation of the firm's economic re- covery plans. Under provisions of the 1974 Trade Act, the Secretary must make a determination within 60 days of accepting a firm's petition and approve or disapprove the application for assistance within another 60-day period. A detailed explanation of both the certification and applica- tion processes--including flowcharts--are shown in appendixes I and II. Certification and application requirements, with minor exceptions, appear reasonable and in consonance with criteria cited in the 1974 Trade Act and other applicable legislation. The exceptions noted are discussed below. CERTIFICATION PROCESS During certification, a firm submits five copies of the petition and supporting documentation to EDA. Information requested on the petition form includes: -- A description of the article(s)--including the Standard Industrial Classification numbers-- produced by th- firm which have been affected by import competition. --A description--including the Statistical Classification numbers listed in the Tariff Schedules of the United States Annotated---of imported articles like or directly competitive with the article(s) mentioned above. -- Supporting data on the firm's sales, production, inventory, production workers and staff-hours worked, as well as imports of like or directly competitive articles, for the past 5 years. 3 -- Copies of the complete auditor's certified financial reports for the last 5 accounting years, or copies of the firm's own financial statements, together with the firm's Federal income tax returns for the last 5 accounting years. Based on our review of selected investigator reports and discussions with EDA officials, we believe some of the requirements are unnecessary. Specifically we found that -- most nonrubber footwear firms do not know the appropriate standard industrial classification or statistical classification numbers to insert in their petitions, -- EDA generally only needs financial, production, inventory, workload and import information for the preceding 2 or 3 years of a firm's operations, and -- EDA generally only needs two or three copies of the petition and supporting documentation to complete the certification process. APPLICATION PROC.SS In compiling the necessary documentation which comprises the application package, firms are required to provide infor- mation not only for compliance with the 1974 Trade Act but also with other legislation as well. For example, applicants must provide environmental information--current status and expected impact of the proposed project--on the following issue areas. --Air quality -- Water quality -- Land use -- Solid waste management -- Transportation -- Natural environment -- Human population -- Historic and archeological properties -- Construction -- Other factors (as problems/questions arise relative to seismic conditions, fire prone areas, flood prone areas, etc.) -- Energy impacts -- Outside reaction to project -- Cumulative impact -- Adverse impacts 4 Although officials of several nonrubber footwear firms told us they felt the above requirements are unnecessary or troublesome, EDA directives reveal that this information is required to meet objectives of the National Environmental Policy Act (42 U.S.C. 4321) of 1969 and is used to determine whether the firm should submit an environmental impact state- ment. We noted, however, that applicants for assistance under EDA's Business Development Loan Program, although required to include similar environmental information in their applica- tions, are not required to assess "expected" project impact. EDA does the assessment. When we asked an EDA official the reason for the variance in the environmental information requirements imposed on Trade Adjustment Assistance and Business Development Loan Program applicants, we were told that EDA, when initially assuming responsibility for the Trade Adjustment Assistance Program, anticipated a great deal of activity. The then current staffing levels would have - precluded EDA from assessing the expected environmental impact of Trade Adjustment Assistance Program projects as was being done for applicants for regular business development loans. AGENCY COMMENTS We allowed EDA program officials an opportunity to pre- sent oral comments on the findings contained in this chapter. During our review when these matters were addressed, EDA notified several interested firms about certain changes in its procedures. These firms were told that EDA would: -- Provide the appropriate statistical classification numbers needed on Form ED-435. EDA officials said the firms should have known the identifi:ation of the standard industrial classifications numbers since the firms provide this information to the Bureau of the Census. -- Need only three copies of the petition and support- ing documentation o complete the certification process. EDA plans to take action regarding its need for finan- cirl, production, inventory, workload, and import information foi the preceding 2 or 3 years of a firm's operations in the near future. CONCLUSIONS AND RECOMMENDATTONS EDA's requirements and Frocedures for both the certifi- cation and application processes, with few exceptions, appear reasonable and in consonance with provisions of the 1974 5 Trade Act and other applicable legislation. While the problems we noted were mino:, correction may help to some- what reduce the effort of firms in preparing petitions for certification. Accordingly, we recommend that the Secretary of Commerce direct the Assistant Secretary for Economic Development to require applicants to submit for the preceding 2 or 3 years only that financial, production, sales, inven- tory, workload and import information absolutely necessary for deciding eligibility for certification. Additionally, we noted that in EDA's regular business loan program, environmental impact information is gathered by EDA rather than the loan applicants. It is the appli- cant's responsibility to submit this information under the Trade Adjustment Assistance Program and provide their own assessment of the potential environmental impact. Therefore, we recommend also that the Assistant Secretary for Economic Development reevaluate whether EDA should assess the effects on the environment under the Trade Adjustment Assistant Pro- gram, since the anticipated large volume of trade adjustment assistance never materialized. 6 CHAPTER 3 PROGRAM PARTICIPATION NOT AS GREAT AS ANTICPATED Program participation by the nonrubber footwear industry has been minimal in contrast to that initially anticipated. Our telephone survey conducted to explain this lack of pro- gram activity disclosed that the single prevalent response for not petitioning was that the firm was not in need of program assistance. Other reasons cited were: the Trade Adjustment Assistance Program is not the answer, firms do not believe they are eligible, lack of program knowledge, and dissatisfaction with the program. Additionally, 37 of the 74 officials, who believed their firms were injured by imports, were unable to cite decreases in employment, sales and/or production necessary to qualify the firm for program cerfification. COMMERCE STUDY Section 264 of the act sets forth specific action to be taken by Commerce when the International Trade Commission investigates an industry to determine eligibility for import relief. One such action is the initiation of a study to determine "the number of firms in the domestic industry producing like or directly competitive articles which have been or are likely to be certified as eligible for adjustment assistance..." In compliance with the above, Commerce issued a report to the President on March 5, 1976, entitled "Prospects for Adjustment Assistance for Footwear Producing Firms." In the report Commerce concluded that, of the then existing 409 domestic nonrubber footwear firms the International Trade Commission identified, the number that would seek trade adjustment assistance would vary according to the type of remedial measures authorized by the President. Specifically, the report estimated that if the adjustment assistance loan were offered, as did occur, more than 200 firms might peti- tion, of which possibly 150 (75 percent) might be eligible. EXTENT OF PARTICIPATION At the time we initiated our review, the number of firms having petitioned for program assistance was far less than 7 EDA anticipated. Recent program statistics, as shown in the table below, indicate that there has not been any drastic change in the number of nonrubber shoe firms petitioning for assistance. Table I Nonrubber Footwear Firms (oly) Program_Activity As of As of As of 6/30/76 L30/ 7 6 12/31/76 (cumulative) Number of firms which petitioned 19 22 25 (Percentage of the anticipated 200) (10) (11) (12.5) Status: Withdrawn and never resubmitted 3 3 5 In process 3 2 2 Denied - - 1 Rejected (for filing) - 6 1 6 1 9 Number of firms certified 13 16 16 (Percentage of petitioning firms subsequently certified) (68) (73) (64) RESULTS OF TELEPHONE SURVEY During July 29 through October 7, 1976, we telephone officials--presidents, vice-presidents, administrative assist- ants, treasurers, and comptrollers--representing 102 nonrubber footwear firms, to determine their awareness of the Trade Adjustment Assistance Program and why they had not attempted to obtain program benefits. The firms, located in nine states, were selected from listings prov.ded by the American Footwear Industries Association, the International Trade Commission, and EDA. Results of this survey are shown below. 8 Extent of injury To develop information relative to import injury, we asked officials the uestion "Do you feel that you have been injured by imports?" Seventy-three percent (74 officials) responded affirmatively. Firms who replied "yes" to the above were then asked two additional questions which relate to program eligibility criteria: -- "Have you had a decrease in production and/or sales since January 1975?" and -- "Have you had a recent decrease in employment or plan to decrease employment within the next year?" Although affirmative responses to both of the questions do not necessarily mean that the firm would be eligible for certification (this determination can only be made by EDA taking into account other factors as well), it does give a more meaningful indication of the extent of injury. Accord- ingly, we found that of the 74 officials who believe they have been injured by imports -- 37 responded "yes" to the above two questions, -- 10 reported only decreases in production and/or sales, -- 8 incurred only decreases in employment, and -- 19 did not incur decreases in either procuction/ sales or employment. Reasons for not petitioning To determine why firms have not petitioned, we first asked firm officials if they were aware of the program. Thirteen (13 percent) responded negatively. Of the officials who were aware of the program, the following reasons were given for not petitioning. -- Do not know the program specifics (where and how to apply; what it involves) 6 -- Not in need of program assistance 38 -- Do not believe the firm is eligible 10 9 -- Part of another company, conglomerate (entire "firm" may not be injured) 4 --Feel the Trade Adjustment Assistance frogram is not the answer (need quotas, higher tariffs, etc.) 9 -- Too much time and/or paperwork involvedt do not have time or money to prepare a plan 8 -- Do not want a Government loan, object to Government involvement 5 -- Trying on own, waiting to see what happens 4 -- In process of deciding if it shot petition; completing petition 2 -- Other 3 To develop a better understanding of this data, we have summarized the above data according to how each firm responded to the import injury questions in appendix V. In viewing the data in tis manner, certain inconsistencies become apparent. For example, 18 officials, while reporting import injury, also stated that their firms were not in need of assistance. This inconsistency, in our opinion, may be due to the follow- ing reasons: (1) either the injury sustained was not con- sidered serious, (2) the firm took measures to compensate for the injury, or (3) the firm was just beginning to see the effect of injury. Other information obtained Officials learned about the program from various sources. For example, of the 39 officials aware of the program, the following was citeJ as the source of program information. -- Trade associations 63 -- Another shoe firm 11 -- EDA letter a/ 2 -- Various 10 --Do not remember 3 a/In compliance with section 264(c) of the 1974 Trade Act, EDA stated they mailed information about the program to firms in the industry. Although only two officials cited the letter, 92 firms--including 17 which said they were not aware of the program or specifics--were actually on EDA's mailing list. 10 CONCLUSIONS The number of nonrubber footwear firms petitioning for certification is far below that anticipated by Commerce. During oar telephone survey, we found that the single preva- lent response for this lack of activity was the officials' belief that their firms were not in need of program assist- ance. Many other officials indicated they had negative views toward trade adjustment assistance; excessive time, money, and paperwork involved; questionable Government involvement; or feelings that the program is not a solution to their problems. ii CHAPTER 4 ADMINISTRATIVE DELAYS IDENTIFIED The 1974 Trade Act established time constraints for processing petitions and applications, and Commerce pub- lished rules and regulations requiring prompt review of these documents prior to their acceptance for filing. We noted, however, that EDA 1/ did not always comply with the act or regulations in screening and/or processing petitions and trade adjustment assistance applications. Twelve of the 18 nonrubber footwear firms experienced delays either during the certification or application process or both. With the exception of the protracted amount of time taken to screen some applications, and in one case approve an application, the delays were not extensive. TIME REQUIREMENTS Section 251 of the act--with reference to a petition for certification of eligibility--states that "A determination shall be made by the Secretary as soon as possible after the date on which the petition is filed under this section, but in any event not later than 60 days after that date." Similarly, section 252 mandates that the Secretary shall make a determination relative to an application for adjustment assistance as soon as possible after the date on which an application is filed--"but in no event later than 60 days after such date." 2/ In both above passages--although not defined in the act--60 days is construed as meaning calendar days. 1/EDA assumed responsibility for processing applications and petitions from the Domestic and International Business Administration (DIBA) on June 30, 1975, and November 17, 1975, respectfully. 2/Authority for making the approval determination relative to petitions and applications has been delegated to the Deputy Assistant Secretary for Planning and the Deputy Assistant Secretary for Operations. 12 The Department of Commerce has published regulations which established additional timf. constraints. For example, "Rules and Regulations" published in the Federal Register on April 3, 1975, specify that petitions received "shall be stamped with the date on which received. Within five working days of the receipt of said petition the Director shall either accept or reject said petition for filing". Relative to the processing of trade adjustment assist- alice applications, EDA published regulations on September 26, 1975, and December , 1976, stating that "EDA shall have five working days from the date on which it receives the application to determine whether the application has been properly prepared and can be accepted for filing. Immediately after the five working days have elapsed, the Assistant Secretary shall notify the applicant that the application has been received * * *" The regulations further call for the applicant to be advised either that the application has been accepted for filing or that it may be resubmitted when specified deficiencies have been corrected. DELAYS DURING CERTIFICATION We reviewed EDA headquarters files for the 18 nonrubber shoe firms selected for review--4 firms had been recertified by DIBA under the transitional provisions of the act--and noted -- two petitions were not screened within 5 working days; --an eligibility determination was not made within 60 calendar days, in the case of four petitions; and -- DIBA generally took a considerable amount of time to recertify firms previously certified under the Trade Expansion Act of 1962. 13 Delays in screenin petitions for filing we noted in 2 of the 14 cases handled by EDA where the determination as to whether he petition was acceptable for filing took longer than 5 working days--9 and 10 working days, respectively. In one ase, the delay resulted from EDA giving the irm time to provide missing sales and produc- tion information on a subsidiary rather than rejecting the petition. We were unable to document the reason for the other delay. Both delays were, however, minor and it should be noted that, o an average, EDA screened petitions within 4 working days. Delays in making eligibility determination Three petitioning firms withdrew before an eligibility determination was made and prior to elapse of 60 calendar days. Of the remaining 11 firms--excluding the 4 which were recertified under the transitional provisions of the 1974 act--4 were not notified as to eligibility within the required 60 calendar days. The extent of delay was in each case minor--l or 2 days. However, our review disclosed that EDA's processing time has improved. TABLE II Certification Processing Time (note a) Through December 31, 1976 Firm certified Firms certified by DIBA by EDA prior to November 17, 1975 since November 17, 1975 60 days 62 days 60 days 62 days 61 days 33 days 61 days 58 days 26 days 59 days 42 days 36 days a/Does not include four firms recertified by DIBA under the transitional provisions of the 1974 act and discussed below. 14 Time re uired for recertfication While Commerce regulations, as published April 3, 1975, called for the "prompt" recertification of firms previously certified under the Trade Expansion Act of 1962, we found that DIBA generally required a considerable amount of time to complete this process-39 days, 12 days, 36 days, and 67 days. Since the files generally did not document the reasons for the length of time required to recertify these firms, we cannot comment on its reasonableness. DELAYS DURING APPLIAT ION We reviewed Washington EDA files and held discussions with officials to determine if selected nonrubber shoe firm applications had been processed in compliance with requirements. At the time we initiated this aspect of our review, only 6 or 15 certified nonrubber firms had submitted trade adjustment assistance applications. Appendix VI summarizes the status of the 15 certified firms as of December 31, 1976. Based on a review of EDA records of the above six firms submitting applications, we noted -- 3 instances where the applications were not screened within 5 working days nd -- 2 instances where the time reauired for the approval determination exceeded 60 calendar days. Delays in screening aplications for acceptance In three of the six cases where nonrubber footwear firms submitted applications for adjustment assistance, EDA's deter- mination to accept the applications for filing was not made within the stipulated 5 working days. For the remaining three cases, EDA documentation was such that we could not establish the exact time involved in this screening process. The following details the circumstances surrounding the screening delays in the cases noted. Firm A_(23 working days' screening time) In this case the regional legal counsel checklist was signed the same day the application was accepted for filing. 15 This checklist--see appendix II page 44--itemizes those regional office assessments, such as the Equal Opportunity Report which must be completed prior to project approval but which are not necessary for application acceptance. We believe that in this case the premature completion of the checklist was responsible, in part, for the screening delay. Firm B (27 working days' screening time) According to EDA officials, the firm submitted an incom- plete application on August 25, 1975. 1/ Rather than reject the application, EDA allowed the firm additional time to provide the required information. According to correspondence from the firm contained in EDA files, certain information which EDA considered "missing" was actually delivered by certified mail in July 1975 and was apparently lost by EDA. Firm C (13 working days' screening time) There were few records for this case in Washington office files as the processing was done almost completely by the western Regional Office in Seattle. The letter of acceptance did make reference to the application being "revised," but it could not be determined if it was done after initial submission or if there was an earlier applica- tion submitted. Of the remaining three cases, EDA files do not document the exact date the application was submitted--only the date it was accepted. In pursuing the matter of compliance with the 5-working day requirement, we found that two officials--the Office of Business Development Deputy Director and the Chief Business Loan Division, Atlantic Regional Office were not aware of these requirements until we brought them to their attention. Additionally, discussion with the 1/ It should be noted that, at the time of submission, EDA regulations governing the screening of applications within 5 working days were not yet published. More recent regulations published December 1, 1976, enable the Assistant Secretary to terminate processing in the event that specified deficiencies have not been corrected within a 30-day period or subsequent to aceptance for filing if it is apparent that "the application contains misrepresentations and/or naccuracies". In either event, the firm must submit a new application. .LU same regional official at a later date disclosed that his region did not have any means of insuring that an application is actually screened within the required period. Specifically, applications are not time-stamped when received and it is conceivable that, an application could sit on a desk for several days before it is opened. 1/ Delays in meeting 60-day processing requirements Of the four nonrubber footwear firms (Firms A, B, C, D) which had loans approved as of December 31, 1976, two were processed within the required 60-calendar day period-- 39 days (Firm A), 60 days (Firm D). (This period reflects the length of time between the acceptance date of the application for filing and the date the Assistant Secretary approves or rejects the application.) As discussed below in the case of Firm B, it appears EDA took 62 days to arrive at the approval determination. Firm C meanwhile withdrew its initial application after 73 days elapsed but had its subsequent application approved within 22 days of acceptance. Firm B The firm's initial application was accepted on October 2, 1975, by the Atlantic Regional Office and final loan approval was made on June 17, 1976--a total of 259 calendar days elapsed time. Although EDA records do not document the withdrawal of the first application, they do show that EDA had problems with the initial adjustment assistance proposal and suggested that the firm first implement, on its own, certain key elements of the proposal relative to market growth and sales trend. The records also show that the firm did submit a new proposal which was accepted on April 16, 1976, and apparently constituted a new application. Based on the April 16, 1976, date, the approval determination was made within 62 calendar days of acceptance. 1/ In one case an application was logged in as received on the same date it was reviewed for acceptance (August 9, 1976). According to a firm official, however, the application was actually submitted on July 20, 1976. 17 Firm C This firm had its initial application accepted on December 12, 1975, and withdrew it on February 23, 1976, a total of 73 calendar days elapsed time. Although EDA records do not indicate why the firm's application was not processed within the 60-calendar day period, we learned that there had been a problem concerning the firm's past unfair labor practices, and this issue had to be resolved. Also, there had been a problem of one partner refusing to meet EDA requirements for a personal guarantee. The latter problem prompted the firm's withdrawal. According to the files two subsequent applications were filed--the last accepted on June 1, 1976, and approved by the Assistant Secretary on June 23, 1976. In addition to above, there was one firm (Firm E) which had its application approved subsequent to December 31, 1976. At the time of approval--January 26, 1977--the application had accumulated 191 days of processing time since initial acceptance on July 19, 1976. Review of EDA records indicated that the regional office had forwarded its recommendations to Washington on July 21, 1976 (2 days after the application was accepted). According to a regional Financial Analyst, the delay in processing was the result of the Washington EDA staff disagreeing with the region's findings--specifically over whether the criteria of "reasonable assurance of repayment" was met. The firm had a $4 million loan out- standing with a finance company and Washington officials agreed to the loan approval after arrangements were made with the finance company to subordinate its claim for repayment to that of EDA. CONCLUSIONS AND RECOMMENDATIONS Although we have identified a number of administrative delays in processing both petitions and applications, for the most part, they were minor. Moreover, in those cases where the delays were lengthy, the restricted scope of our review-- limited to firms in the nonrubber footwear industry which had minimal program activity--precludes our reaching a conclusion as to EDA's overall administration of the Trade Adjustment Assistance Program. Nonetheless, the Secretary of Commerce should direct the Assistant Secretary for Economic Development to review the adequacy of trade adjust- ment assistance instructions and administrative procedures, specifically whether 18 -- regional personnel know about trade adjustment assistance time requirements, including the 5-working-day screening requirement, and take measures to adjust their work priorities accordingly; -- regional offices have procedures, such as time stamping applications when opening the daily mail, to comply with the screening time requirement; -- regional offices have uniform procedures for processing trade adjustment assistance applica- tions--including the screening of applications before acceptance; and --regional officials, are followi EDA head- quarters criteria for approving ans. EDA program officials concurred with our recommendations. 19 CHAPTER 5 NEED TO PROVIDE ASSISTANCE TO FIRMS IN PREPARING APPLICATIONS As a result of the "affirmative finding" of import in- jury by the International Trade Commission, EDA is respon- siole for providing nonrubber footwear firms assistance in the preparation and processing of their trade adjustment assistance applications. This assistance for development and/or implementation of economic adjustment proposals may re provided by gency staff or outside consultants. EDA also is responsible for advising these firms of other Fed- eral assistance programs which may facilitate their orderly adjustment to import competition. Despite the above, we found that the assistance pro- vided nonrubber footwear firms for development of their ad- justment applications or proposals has been minimal. Further, EDA efforts to inform nonrubber firms of the availability of assistance under other Federal programs has been limited. LEGISLATIVE REQUIREMENTS Section 252(c) of the 1974 Trade Act states that: "In order to assist a firm which has been certi- fied as eligible to apply for adjustment assist- ance under this chapter in preparing a viable adjustment proposal, the Secretary may furnish technical assistance to such firm." Tne assistance--consisting possibly of market research or feasibility studies--may be furnished by Federal agencies or througn private individuals, firms, and institutions, in which case not more than 75 percent of the cost of such service may be borne Dy the United States. Additionally, section 264, requires Commerce in the event of an affirmative International Trade Commission finding of import injury--which is applicable in the case of the non- ruboer footwear industry--to make available to the firms in tne industry of Federal programs "which may facilitate the orderly adjustment to import competition of such firms" and to "provide assistance in the reparation and processing of petitions and applica ions of such firms for program bene- fits." 20 NEED FOR ASSISTANCE IN PREPARING APPLICATIONS Of tne 15 certified firms reviewed, we identified 6 which had acquired their own technical assistance from con- sulting firms. The services acquired in five cases in- cluded assistance in the development of the economic adjust- ment proposal, assistance in preparing the application, and in one case, hiring a consulting firm to perform market research. It is difficult to determine the actual cost for these services. In several cases only a portion of the consultant fee has actually been paid--the total amount for technical assistance is anticipated to be paid from the working capital. portion of the loan. The matter is further complicated by the fact that some of the figures--either paid or shown in the proposal also include fees for work performed on the petitions. The following table is intended to give only an indication of the expenses incurred. Table III Cost of Technical Assistance Nonrubber Shoe Firms (note a) Amount Amount as Tye_of services paid shown inpr_2sal Market research b/$15,000 Not available Preparation of proposal finan- cial data, work on petition c/5,783 $65,000 Financial analysis/development of the trade adjustment assistance application 8,060 Not available Preparation of the roposal 5,000 Not available Work n petition and application Not available 25,000 Preparation of application d/900 Not available a/Not included are two firms which acquired assistance exclu- sively for the preparation of petitions. In one case, all the work was performed before the 1974 Trade Act; in the other, thure was no additional charge for the service. b/Also includes some work for preparation of the petition. c/Tnis amount relates to work done on the petition. d/The firm used the services of their regular consultant who was going' to bill $2,500. At the time the firm decided not to submit the application, $900 had already been paid. 21 We found that in two of the above six cases, attempts to obtain EDA technical assistance had proved fruitless. The details are discussed below. Example A This . had already initiated some work through a con- sultant when the request for technical assistance was made. A letter was subsequently received from the Act- ing Deputy Assistant Secretary for Operations denying the request. The letter, citing EDA regulations, stated "technical assistance projects will not be ap- proved to pay for work already done.... You should also be aware that Government contracting regulations require multiple soliciations of contractors, with final choice subject to EDA approval." The firm subsequently told EDA that their request had been made based on interim regulations which make no men- tion of an inability to pay for work already done. EDA, however, again denied the request, stating that their reg- ulations and "the long-standing policy of the Department of Commerce do not permit this Agercy to reimburse for the cost of work already performed ur serv- ices already provided prior to application for assistance." The firm did not pursue the issue further. Example B This firm was recertified--effective January 3, 1975-- under the transitional provisions of the 1974 Trade Act. On April 17, 1975, according to a firm representative, the firm sent a letter to DIBA requesting technical assistance. About a month later, DIBA's Office of Ad- ministrative Support forwarded to the Commerce Office of Administrative Services and Procurement a $25,000 request for technical assistance. The request was subsequently returned "without action" because April 30, 1975, had been established as the deadline for all such requests from DIBA. (As of June 30, 1975, EDA replaced DIBA as the Commerce agency responsible for providing trade adjustment assistance to firms.) In July 1975 the firm contacted EDA to determine the procedures for obtaining financial assistance. About 22 a month later, -n application was submitted--and subse- quently reject because it was incomplete. From Octo- ber 1975 through May 1976, EDA had almost monthly com- munications with the firm, identifying various missing documents or information necessary for the application to be accepted. (In June 1976, after reviewing EDA's files on this firm, we commented to an EDA official that the firm was in dire need of technical assistance. He agreed,and when asked why the firm had not received help, he noted that when the firm had first contacted EDA, the agency was just beginning to become familiar with program operations.) On December 23, 1976, the firm submitted a proposal to EDA's Atlantic Regional Office. Although the regional officials considered the application incomplete, they accepted the proposal in terms of having met the 2-year filing requirement. Nonetheless, as of January 1977, the firm had not yet received assistance and in a tel- ephone discussion with the Chief, Loan Processing Divi- sion Atlantic Regional Office, we were told that the firm needed help in putting their application package together and he was "thinking" of going to EDA's office of Technical Assistance and asking for assistance. LIMITED ASSISTANCE PROVIDED EDA has not been particularly active in providing assist- ance to nonrubber footwear firms for development of trade adjustment applications or proposals. EDA assistance With the exception of one firm--which was in close prox- imity to an EDA Regional Office and took the initiative to constantly seek help during each step of the application proc- ess--EDA has done little to assist in the preparation of ap- plications for trade adjustment assistance. EDA has limited its activities to providing procedural guidance. Use of outside consultants Arrangements for outside consultant assistance, handled by E)A's Office of Technical Assistance, are generally based on referrals by the Office of Business Development (OBD). The office of Technical Assistance also has responsibility for providing technical assistance under the Public Works and Econ,)mic Development Act of 1965, as amended. As of December 31, 1976, only one nonrubber shoe firm had obtained proposal technical assistance. This particular case 23 was referred to the Office of Technical ssistance by the Director, OBD, when it became apparent--based on limited collateral and size of the loan ($1 million)--that an in- dependent feasibility study was necessary. The technical assistance was planned in two phases at an anticipated cost of $5,000 for each: -- Phase I This consisted of work--including a market feasibility study, a production feasibility study, and the develop- ment of an external financing plan--to be performed within a 4-week period. At the end of the 4 weeks, a Trade Act recovery plan and feasibility analysis was due. -- Phase II Phase II--dependent on the results of Phase I being favorable--called for a 4-week assignment to assist in the preparation of the assistance plan and er- fected application. Tne business evaluation project was approved July 7, 1976. The actual contract award was made September 24, 1976, at a cost of $5,000. Based on the results of the consultant's report--initially issued October 19, 1976, 1/ OBD determined that the firm's roposal did not appear feasible, but an offi- cial determination has not been made. Reasons for limited use of outside consutants A Department of Commerce study--performed April 1976-- identified the following reasons of limited use of outside consultant assistance under the program. -- "Contracts are extremely unattractive to firms because they are governed by the stringent con- ditions attached to the Federal procurement process;" and --"Firms with sufficient resources to expect to survive long enough to receive a TAA [Trade Adjustment Assistance Actj loan are usually in a position to procure their own consultants on the assumption that such initiative will hasten the availability of TAAA loan dollars; this 1/A revision was returned to EDA on November 23, 1976. 24 consideration is reinforced by the fact that firms receiving Federal technical assistance funding must pay at least 25 percent of the cost themselves." The attitude of certain EDA officials toward use of tech- nical assistance and--in some cases--toward the Trade Adjust- ment Assistance Program in general is, in our view, also an important factor in explaining the limited amount of assist- ance provided nonrubber shoe firms. For example, one EDA official commented that DIBA, when in charge of trade adjust- ment assistance to firms under the Trade Exoansion Act, forced technical assistance on every firm, regardless of need. He stated that EDA, however, took the position that the shoe firms should know what they want to do and how to do it and that technical assistance is "unnecessary." A similar senti- ment was voiced y a regional EDA official. During a discussion with still another EDA official, we were advised that preproposal technical assistance should be used for market studies and strategies to change styles or production lines out not to pay consultants to assist firms in preparing their applications. He also stated that he is not "sold' on the provision of the act which provides for automatic entitlement to assistance, and consequently EDA has adopted a "passive role" in making firms aware of such assistance. NEED TO PROVIDE INFORMATION ON OTHER ASISTANCE PROGRAMS Many nonrubber shoe firms, though expressing a need for trade adjustment assistance, have been unable to meet cer- tification criteria and accordingly have been denied help. For example, 10 nonrubber shoe firms contacted did not petition for certification under the rogram because they did not believe they would be eligible, while three others withdrew petitions when it was apparent they could not meet certification criteria. It should be noted, however, that it is possible that these firms could obtain assistance under other Federal pro- grams. For example, Commerce, in its study Prosoects For Adjustment Assistance For Footwear Producing -Frms,-ientified several other programs of potential benefit to nonrubber foot- wear firms--including the Business Development Loan Program which is administered by EDA. Other ossible avenues of assistance mentioned in the Commerce study included business loan and management assistance programs administered by the Farmers Home Administration and the Small usiness Adminis- tration. 25 Despite the existence of the foregoing assistance possibilities and the provisions of section 264(c) of the 1974 Trade Act which requires the Secretary of Commerce to make available, to the extent feasible, full information on such assistance programs, EDA has not adequately advised nonrubber footwear firms of these other potential sources of Federal aid. EDA updated the list of nonrubber shoe firms from a current list completed by the Trade Association and mailed letters and brochures to approximately 600 shoe firms publicizing the Trade Adjustment Assistance Program, however, the letters did not identify other programs of po- tential benefit to these firms. Further, while the Assist- ant Chief of EDA's Trade Act Certification Division stated that a summary of Commerce's report identifying the other programs was published in the Federal Register, he agreed that this was not adequate notification. !Applicability of other rograms While we did not evaluate all the programs cited to determine their applicability to nonrubber footwear firms, we did note one instance where a nonrubber footwear manu- facturer received a working capital loan guarantee of $500,000 under EDA's Business Development Loan Program. The decision to process the project under this program in- stead of the trade adjustment assistance program was based on several factors according to a Regional Business Develop- ment Chief. -- it was unlikely the principals could obtain from the previous owners the necessary information for certifi- cation under trade adjustment assistance, -- the firm did meet the requirements of the Business Development Loan Program, and --time considerations. Regarding the latter, EDA's Atlantic Regional OLfice stated that "even a minimal delay could probably cause the demise of this company." In this regard, it took only 96 days from application acceptance to loan agreement signing, a considerably shorter time frame than could be expected under the Trade Adjustment Assistance Program, considering certifi- cation and application requirements. CONCLUSIONS AND RECOMMENDATIONS Several nonrubber footwear firms have identified a need for assistance in preparing their applications for trade 26 adjustment assistance, including development of economic adjustment plans. Despite this, and the fact that firms in the nonrubber footwear industry are entitled to such help under the 1974 Trade Act, little assistance in being pro- vided. Further, EDA has only made limited efforts to advise footwear firms of alternative Federal programs which could serve to assist in their adjustment to foreign competition-- another provision of the 1974 Act. Accordingly, we recommend that the Secretary of Commerce direct his Assistant Secretary for Economic Development to: - rovide nonrubber footwear firms assistance in pre- paring their application packages, including develop- ment of economic adjustment plans; -- inform sih firms of restrictions governing approval of assistance projects when work on the projects has already been done; and -- make every effort to advise such firms of alternative Federal programs which could help them adjust to foreign competition. EDA program officials concurtrd with our recommendations. 27 APPENDIX I APPENDIX I CERTIFICATION PROCESS A firm is reguired to return three completed petitions-- including copies of supporting documentation--to EDA's Trade Act Certification Division (TACD) in Washington. A copy of the petition form is shown on Appendix III. ACCEPTANCE FOR FILING Before accepting a petition for filing, TACD reviews the provided information for completeness and adequacy. Items to be addressed on the petition include: -- ! brief narrative on the firm's economic history. --A description of the article(s)--including the Standard Industrial Classification numbers-- produced by the firm which have been affected by import competition. -- A description--including the Statistical Classifica- tion Numbers listed in the Tariff Schedules of the United States Annotated--of imported articles like or directly competitive with the article(s) mentioned above. --A description of the extent of the actual separation or threat of separation of workers. -- A description of how increased imports contributed importantly to the decline in sales and/or production and worker separation. -- Information on previous firm petitions under the Trade Expansion Act of 1962. -- Supporting data on the firm's sales, production, inventory, production workers and staff-hours worked, as well as imports of like or directly competitive articles, for the past 5 years. -- Copies of the complete auditor's certified financial reports for the last 5 accounting years, or copies of the firm's own financial statements, together with the firm's Federal income tax returns for the last 5 accounting years. 28 APPENDIX I APPENDIX I Prior to rejecting a deficient petition, EDA gives the firm the opportunity of either providing necessary information or withdrawing the petition. Once the petition is determined.. acceptable for filing, TACD notifies the petitioner and initiates an eligibility investigation. Notice of the peti- tion filing is published in the Federal Register, after which the petitioner or any other interested party has 10 days to request a public hearing. INVESTIGATION AND DETERMINATION A TACD investigator reviews the petition and supporting documentation to determine if the certification criteria have been met. The documentation must establish -- that a significant number or proportion 1/ of the workers in such firm have become totally or partially separated or are threatened to become totally or partially separated; -- that sales or production, or both, of such firm have decreased absolutely; and -- that increases of imports of articles like or directly competitive with articles produced by such firm contributes importantly 2/ to such total or partial separation, or threat-thereof, and to such decline in sales or production. Much of the investigator's time is spent analyzing the documentation to assess its validity and to determine whether it establishes that the legislative criteria have been met. During this process, the investigator also contacts the firm to clarify any questionable information, performs calculations 1/ "Significant number or proportion of the workers is construed as meaning a total unemploymnent of 5 percent of the workers or 50 workers, whichever is less, but with as few as 3 workers in cases of a firm employing fewer than 50 workers". 2/ "Contributed importantly" is defined as a cause which is important but not necessarily more important than another cause. 29 APPENDIX I APPENDIX I to verify that absolute decreases in sales and/or production have occurred, and contacts past customers of the firm to determine reasons for decreases in their purchases. After the investigation is complete, the report findings, or other documents are submitted to the TACD Division Chief. A summary of factual data and the Chief's recommendations are processed through appropriate channels up to the Deputy Assistant Secretary for Economic Development Planning (DAS/P) who signs off on the project and sends a letter of approval/ denial to the petitioner. Notification of approval action is also sent to the congressional delegation and to the State Governor wherever the firm is located and to the press. The certification determination by the DAS/P must be made within 60 calendar days of petition acceptance. 1/ In cases where the petition is denied by agency regulation, the petitioner is not allowed to reapply for 1 year. There is one exception to the procedures as outlined above. Firms requesting certification under the Trade Expansion Act of 1962 do not have to submit new petitions. This is in consonance with provisions of the 1974 Trade Act which stipulate that: "A certification of eligibility of a firm under action 302(c) of the Trade Expansion Act of 1962 made before the effective date of this chapter shall be treated as a certification of eligibility made under section 251 of this act * * *". A flow chart of the certification process follows on the next page. 1/ A firm's application must be made within 2 years of the date of certification. 30 APPENDIX I APPENDIX I CERTIFICATION PROCESS FIRM CONTACTS TACD TO INQUIRE ABOUT PROGRAM TACD (WASHINGTON) SENDSLITERATURE AND SIX COPIES ED.435 FIRM SENDS PETITION TO TACO TACD RECORDS AS RECEIVED REQUIRED WITHIN 5 WORKING DAYS (EDA REQUIREMENT - NOT SPECIFIED IN ACT) TACD SCREENS PETITION PETITION NOT NO YE 5I INVESTIGATION INITIATED ACCEPTED (DETERMINE IF FIRM IINCOMPLETE _MEETS CRITERIA).I FINDINGS OR OTHER nCVUMENTS SUBMITTED REQUIRED INFORMATION cMENT SUMTTED TACODIVISION CHIEF SUMMARYOF FACTUAL DATA NFOtAfO MAND CHIEF'S RECOMMENDATION PRovlDED FORWARD TO DIRECTOR OF OFFICE OF PLANNING AND PROGRAM SUPPORT IOP.'SOD) FIRM ENCOURAGED TO WITHDRAWPETITION -- DIRECTOR fOPP'SD) REVIEWS IF FIRM DOES NOT WITHDR~W~~ IT~PETITION"PACKAGCE" 5I~ REJCCTED Y1 CONCURS. AND INITIALS ( END1 I OFFICE OF CHIEF COUNSE REVIEWSPACKAGE AND CONCURS REQUIRED WITHIN 60 CALENDAR DAYS CITED 'IN THE ACT) i PACKAGE SUBMITTED TO DEPUTY ASSISTANT SECRETARY FOR ECONOMIC DEVELOPMENT PLANNING IFirm may withdraw petition at any 'P SIGNSLETTER time during the process. OF DENIL FIR TO D P GN ED 2 Firm is notified by letter; also a (NOTIFICATON CERTIFIED (NOTIFICA TIN L OTINPV notice is published in the Federal TO FIRM TO FIRM Register - petitioner, rersons, organizations, or groups demonstrating substantial interest in the proceedings have 10 days after notice is published NOTlFICATION TO to tequaaheaoing. n nMEMBERS OF CONGRESS, 30nce the investigation begin, a firm must provide any additional GOVERNOR, information requested as necessary to make on eligibility deter- PRESS RELEASE mination. If a firm does not comply, the firm can either withdraw 'Criteria (eligibility): a) decrease in product;on or soles. b) decrease in employment. c) increase in imports (absolute or relative to domestic production). d) causation -- imports contributed impwtantly." 31 APPENDIX II APPENDIX II APPLICATION PROCESS Certified firms are referred to EDA's Office of Business Development (OBD) in Washington, where they are in-ited to send a representative for preapplication counselin . 1/ During this session the firm is provided with a Trade-Adjust- ment Assistance index form (see app. IV) which identi- fies the documentary material required by EDA to evaluate the application. 2/ SCREENING THE APPLICATION Once the firm has compiled the necessary documentation, the application "package" is submitted to the appropriate regional office for processing. Before the application can be processed, however, it must first be screened to determine that all the required documentation as identified on the index form is included and is complete. EDA regulations as published in the Federal Register (September 26, 1975) call for the applicant to be notified within 5 rking days of receipt that the application was received and that either (1) it has been accepted or (2) it may be resubmitted when specified deficiencies are corrected. ACCEPTANCE FOR FILING AND PROCESSING Once the application is accepted for filing, the project is assigned a case number, logged on control sheets, and the Washington Trade Assistance Coordinator notified that the application is in process. 1/ In the past, OBD/Washington was responsible for the processing of Trade Act cases--including all preapplica- tion counseling. Although EDA Directive No. 13.01-17, effective April 13, 1976, now gives the region authority to handle the loan processing and servicing functions, EDA officials still encourage firms to meet in Washington for preapplication counseling. 2/ Applicants are also required to provide information-- current status and expected impact of the proposed project--on 14 environmental issue areas. This require- ment, while not shown on the index, is contained in the environmental package provided to the applicant. 32 APPENDIX II APPENDIX II Review by regional loan development officias The entire application package, and especially the economic adjustment proposal is reviewed and evaluated by regional loan development officials to insure compliance with 1974 Trade Act legislative criteria. Specifically, as mandated by section 252 of the act, approval of an applica- tion is dependent, in part, that the firm's proposal contains the following elements -- be reasonably calculated materially to contribute to the economic adjustment of the firm; -- give adequate consideration to the interests of the workers of such firm; and -- demonstrates that the firm will make all reasonable efforts to use its own resources for economic development. Additionally, the application documentation must establish that the funds requested are not available from the firm's own resources, that there is "reasonable assurance of repayment" of the loans, and that agency policy requirements have been met. Pursuant to the above, the firm's documentation is analyzed with respect to the following factors: -- Management The firm's management team is evaluated as to their efficiency and capabilities relative to the size of the firm and the industry. -- Marketing Information such as the firm's current share of the market, project share, current product lines and plans to penetrate new product lines is evaluated. -- Raw materials The availability of raw materials, energy source and unit price of each is considered. 33 APPENDIX II APPENDIX II -- Sales, profits, and debt service EDA examines data on past sales as well as evaluates the soundness of projection figures. Pro-forma financial statements and projections are used to determine whether the firm will have the ability to repay the loan from profits. Officials also assess whether the firm can pay short- term and/or long-term debt. -- Collateral EDA looks to secure as much of the loan as possible in the event the company goes bankrupt. In this regard, EDA tries to get first lien on all fixed assets, accounts receivables, and inventories. Approval of assistance is also dependent on the applicant's compliance with EDA requirements mandated by legislation other than Trade Act. Such legislation includes: -- Title VI of the Civil Rights Act of 1964, as amended Applicants are required to summarize their present work force according to job category, sex, and minority classifications. They are also required to sign a statement stating they agree to comply with Civil Rights Act regulations. -- Clean Air Act, as amended and Federal Water Pollution Control Act, as amended An applicant signs a form attesting that the facility is not on EPA's list of violating facilities. -- National Environmental Policy Act of 1969, as amended In keeping with the objectives of the above, an applicant must provide information--current status and expected impact by the project--on 14 issue areas. 34 APPENDIX II APPENDIX II -- Public Works and Economic Development Act of 1965, as amended In compliance with established EDA policy ard the above legislation, name checks are normally done on the firm's owners and/or officers, and in some cases, are also required on certain stockholders. The name check investigations are processed by EDA's Investi- gations and Inspections (I&I) staff who, in turn, checks the names through the Federal Bureau of Investigation. Legal counsel review and action memorandum Before regional office recommendations are formalized, the application "package" is submitted to regional legal counsel for review through the use of "legal checklists." The checklists are used as a control for insuring that EDA requirements as mandated by the 1974 Trade Act and other legislation have been met. Upon completion of the legal checklist, an "Action Memorandum" is formulated and forwarded to OBD in Washington. This document summarizes the proposed project, noting all the pertinent specifics, includ- ing the regional office recommendations. Approval determination OBD reviews the Action Memorandum, including approval or rejection recommendations, 1/ and forwards it to the Deputy Assistant Secretary for Operations (DAS/O). The DAS/O signs off on the memorandum and either notifies the firm of rejection or--in case of favorable recommendation--forwards the memorandum to the Assistant Secretary for Economic Development for his approval and signature. According to the act, this determina- tion by the Assistant Secretary--as delegated from the Secretary of Commerce--must be made within 60 calendar days of appli- cation acceptance. Subsequent to application approval, the firm is made an assistance offer to which it must respond within 10 days. 1/ In some cases, OBD might restructure the project and would rewrite the Action Memorandum. 35 APPENDIX II APPENDIX II Following the firm's acceptance of the assistance offer, the firm and EDA enter into legal proceedings surrounding the loan closing. A flow chart detailing the application process follows. 36 APPENDIX II APPENDIX II APPiCATIOW IROCESS llIrl RIceI1vEs NOilltCA tO OF RLIGII6LITY ._ RIttIRLO TO IOW PIM*INVITE T EN 144RISlENTTYVI TO WlHINOTON FOR lPRIAPPLCATION IN THE PAST THE PRIA0PLICATION COUNSELING SESSION VWAUIINGTON. ALTHOUGNNOT MANDA. TOVT. l)i ILL STILL R AO ToIR#S LAN Is SOUND .. 0titUSSION S SOUND_. OISCUA&E r"IRNllREO TO OT TODISCUSS TIIR CASEWITH0R0 ' OOINROMAL AGIENT IR TCNNIICANCL AUISTANCE INCLrUS PROPOSAL CLo RIS DTVLOEIT*ET OI N.ILIRNTATION lPi GPIVElCPPLICATION OIIAD -- APPROPRIATE REGIONALOFFICE NOTIFIED NEOOTIATIOf TAILS OF LOA 0C LOANoUAiATEa --.FRlM PREP, S APPLICATION *RIODAL STAFF REClRlS Ai. ICTION lREIEt OOCUMIITTION J0ECAY A PAN IOI tDNS FORWA COUPLEENETS S OULD WITHIN I DOATS IICLUDI CIVL DNIAN'GIOAL STAF =NALYSIaICIT P 0 A OSTAo* L TO OCIRE3CaTT ROEICAI CNDS SI CM 1135ec.lPe. IC"' "AL lLIOL __*io CNIwbI !(It A To WAIIITONiOR RW -- CONTA I 3 I RJIi NAALOFFCC RICO1eNDAETIO$ PROJlCT AND rovA i_ ANI /PdO O PtCOMNDO rorrI A PR7OVAL I . 42WRITIV (us) SW AND P |A AUST &#T T SECRETAy OERATTLONSISIGNl P S OF OF DINI ANDA CRETARIA 'ON ACCOUNT | DEVELOPMENT | tOnOR PERIOD NCOMIC REAOSl THEREFOE RIlRIe FUNDS AND MAKESLOANOFFER TO llRM ~~i~~~~~a ~~i I ,IONAS #tbf^;l ~ I OA TO ACCEPT OlPi | * Feel-l El Nv Iill FridAb5t RZAilVl 2 1 EDA shlf have wrrHing days aet af tiO TH e I nti1n iu mif to dmiml wherthr i hle poperly preprtnd a soteoinsoil nceswory RElOIONALOI C PoR inii"n Im mANedI phe the 5 veking r mThAsiflnt Sertory shell neify th4 applicnt tkot CLOSING _ d,1 opllatrion h c *ceived en fi: OWanIILOINt AT CLOSINO (I) a licaloin hs been accelaM lf Illil, r (2) N plicRtl myr reslltl he n limir nie l are Coflctoed. h 'tDA ht heW *v-LnNlicPrilr to eeenHtllsotlon of not cuntin the Rimol tim go *otof hu .404l; I*lptlf li fl . Thi i Libstii in st dIy pffe y Dtmnt of CIrbnemo 37 APPENDIX III APPENDIX III OMB No. 41-R2261; Approval Expires December 31, I978 FORM ED-435 U.S. DEPARTMENT OF COMMERCE ,12.7S) ECONOMIC DEVELOPMENT ADMINISTRATION PETITION BY A FIRM FOR CERTIFICATION OF ELIGIBILITY TO APPLY FOR TRADE ADJUSTMENT ASSISTANCE (Under Certification Trode Adjustment Assistance for Firms and Communities, 15 C.F.R., Port 315, U.S. Deportment of Commerce, pursuant to Section 251 of the Trade Act of 1974, Public Laow 93-.618) RETURN TO: For Government U1 Only Attention. Wfice of Planning and Program Support Project Number Dte Accepted for Economic Development Administation Filng 6113 Main Commerce Building Washington, D.C. 20230 'nerral Instructions: This petition required for filing by a frm requesting the Secreary or Commerce to certify the firm's dibility to apply for Trade Adjustment Asistance. For purposes of this petition, a '"fin" include an individual proprietor- ship, partnership, joint venture, association, corporation (including a development corporation), busine trust, cooperative, trustee in bankruptcy, and receiver under decree of any court. Statutory criteria for certification include I ) a signifcant number or proportion of the firm's workers have become totally or partially searpated, or re threatened with separation, (2) sales or production, or both, of the firm have decreed absolutely, and (3) increases of imports of articles like or directly competitive with articles produced by the firm contributed importantly to uch total or partial separation, or threat thereof, and to such decline in les or production. This Petition subject to the Freedom of Information Act and all information submitted herewith is available to the public, except that waich is exempt under 5 U.S.C. 552 8(4) s confidential busine information, including trade secrets and com- mercial and financial information. Any information which the petitioner desires to be teated as onfidentid should be attached on separte sheets identified with the appropriate item number and bearing at the top of each such sheet the clear leind "Confidential Busines Information." Submnut five executed copies of this petition form and any attachments. Acceptance of this petition will be delayed if the form and appropriate attachments are not properly completed in accordance with instructions hereon. Name and Address of Petitioning lirm Strret Otv. (County Staft, and Z/P CodeJ Telephone Number Iclude Area Cbde Legai Form of Orpnization: (Indicte hy an "X' O Single Proprietorship 0 Partnership O ( orporation 0 Other (Ptearespecify Name, Address, and Nature of Business of any parent company, subsidiary, ffiliate, predeoeor or succeaor firm, co-venturer or of any other ftrm comrolled or substantially beneficially owned by the petitioning firm or by its principl shareholders. (If the untwer i "None': so tindicate.) USCOMMDC 1B2-f.p7R 38 APPENDIX III APPENDIX III Itm 1 - HNSTORY OF FIRM Attach a reparate sheet dentified at the top u "Item I - Hbtory of Firm" td provide brief wrrtive of the fim's conomic history, inudin (a)the year founded; (b) type(s) of business menped in; (c) a precise dciption of a ll ods ad services produced; (d) number, losation and nature of business of all manufacturing, production and sales facilltis; (e) markets srved; ( names and titles of offerns, directors and manage- ment of the firum; (g mjor ownership intereats now In the firm; (h) significant ownershlp of mnanaemnt chages In put S years; and (1)any other important events in the recent history of the firm. Itm 2 - ARTICLEISI PPIODUCED Describe precisely the artie(s) produced by the firm which have been affected by import competition, includingtheStadard Industrial Clsiification number(s) for each such article. ii. iv. V. vii. viii. Itam 3- IMPORTED COMPETITIVE ARTICLEISI) Describe precisely the importeJ article(s) which are like or directly competitive with the article(s) described in Item 2, including tite Statistical Clasification Number listed in the Taruiff Schedules of the Uniteo States Annotated (TSUSA). (Attach sepelte ert if needed) i. iv. vii, viii. Item 4 - SEPARATION OF WORKERS Attach a seplate sheet identified at the top a "Item 4 - Separation of Workers" and desribe the extent of the actual separation, or theat of separation whether total or partial, or the workers of the firm. Include data on the number and proportion of workers affected, and any chanes in average weekly hoursn worked. Ira thret of worker sepration exists explain the nature of the threat and the antidpted cone- quences thereof, Including the number and proportion of workers threatened with total or prtial separation. If any group of the firm's employee has petitioned the Secretary of Labor for crtification ofeligibility to apply for Trade Adjustment Aitance in an effort to obtin benefits for workers, give the date of such petition and a brief summry of the status of the worker cas. (If the answetr is "none," so indicat.) 2 FORM ED-436CO-C 27 USCM39DC IS0o6 39 APPENDIX III APPENDIX III Item S - ASIS OF PTTION Attach a separate gheet identified at the top as "Item 5 - Bias of Petition" and wucltethe declie I total ie or productiont 'or both) of the firm and relate the Increase in imports to the firm's decline in seles or production and worker eupration, and explaIn how the Increled Imports contributed importantly to the Nu or production decline and actual or threatened worker paration. Itam el - PREVIOUS FIRM PETITION Did the fini previously petition the Tariff Commission of the United States for a finding of import njury under provilokn of the Trade Expansion Act o 1962? If so. give the date of such petition and a brief ummary of the results of the petition. (If the answer b "No", o indicate.) Item 7 - SUPPORTING DATA Provide data on the firm's ales, production. inventory, production workers and man hours worked, as wet as imports of like or directly comn- petiive articles, for the past five years on the attached tabular form. Item - CERTIFIED FINANCIAL REPORTS Atta.h copies of the complte auditor's certified financial reports for the petitioning firm and its subsidiaries for the last five accountiUs yoas If such reports by certified public accountants arecnot available. furnish copies of the complete profit and loss statements. blance sheets, and supporting statements prepared by the petitioning firm's own a'counlants, togiether with copies of the firm's Federal income tax retur for the last live accounting years. NAME AD TITLE OF PERSON TO CONTACT FOR ADDITIONAL INFORMATION Name Title Address Tele-phone Nu mber Are ode CrntiIsn - The undersigned officer of the firm execuing this certification in behalf of the petitionig firm hereby certifis that the tnfor- mation contained in or submitted with thi- petition is correct and complete to the best of his knowledge and belief. Nome of firm Sinature of Authontred Official of the Finn Title Dte This form must be certified by ans vorn to before a Notary Public CERTIFICATION Y NOTARY: (Coiplete) Subscribed and sworn to before me this - of __ (dey) (month; (yeav, Notuary PubliUc (SEAL) Expiration Date The U.S. Code. Titk 18 (Crimes and Criminal Procedure), Section 1001, makes it criminal offense to make a wiufuly false Statemst or representation to any department or agency of the United States as to any matter within its jurisdiction. FORM ED-435 t 2- 76 U40C 182 40 APPENDIX III APPENDIX III ~ Ii. -. i l lb Ii .'' i - ·iI ', p -. 1 I iB 111ii i .. . fu .Z~~ .. 8·I 1, - .1 3~~ j- I.C i i ii i il . liii il iigI~ ii1 U, a _ _ _ _ _ _ 4-_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ 84 g rl] if g~~~~~~~~~~~~~~~~ .sa j 41 APPENDIX III APPENDIX III rI L jsr . C: j · ;', . : :f': 4 JI II l . Ii 'T I _.., i 42 APPENDIX III APPENDIX III l'as A d-r- XlX ( I XIX 0, I SI~~~~~~~~~~~~~~~~~~; t i4i, i I! I )| *1' .: %I " ii f ii!a,·' .31.1 1 1.I i.ri '1~~~~~~~i! ____________________________ I IDU ~ ~ I a ~ ~ a jj ~~ _ _ _ _ _ _ _ _ _ _ _ _ _ i _ _ _ _ _ 43 43 APPENDIX IV APPENDIX IV Vomes1141_ tin. ItO-t OlMA Itl teql UI. NPA#T NTOPOOIIRC 000WItc OIILCOtt6IT ADO1IaYLllATiO APPLICATION IQUIIIIMNTS AND INDEX-TRADE ADJUITMENT AIIETANCE FOR FIRMI MNO ANOAo1lwN OPr FICAIG T ft0N. OmP, PNOJc? No o. PoJiCcT LCAT OMr vat -." I DATE,- INTUCTIONiS Or COPLITION AND UL OF OWl ED4?2 This fonnrm identfis th documntrmy maerWal needed by EDA to vlluate pplication for financial a atnce to busin under its tradn ut4junmt swestn prtgran. Many items are included in thi ist, but only thoe Items cacked in Column (B) will be rqued to perfect an Aplaton. Eachproject ts i; the specific docmeny rements for it are deterined in pe-application conferenc with the prpethe pplicant, at which tuie n EDA reprsmntatL sallJ: I. acea hk markt In Coluan () to the bft of ach requrd item, except f thoe with pr-prted chck marks which onerquird fIomnjapplicanta; 2. Place the blttn NR. in d of chck mark. nt to each unnmdd item; 3. Identify additonal documntry rquiremets on the numbered, but othrwse blank, ltm; 4. Execute the fi endmmesnt to thI form; nd . Giw the prospecti applicant copy of the end d fo m asthe ndx of the applIcation. 'Jsinl a copy of the checked form ats naind (which hall b included in the pplication pck4t). the applicant hal uaemble in :he order indicated the documntay maril nd mrk ech Itnnm for idetiicon with its ppprite number/letter fro th form. Wen the pplticaon i ra . n EDA reprehntUtiw sil chck ac ite m to mure tlut it providn thee ncry information andshll indicate its acceptability by initaliq the ppropriate pace in Column (A) and shll execute the second endorsement. COdUkQ-OC11I) 44 APPENDIX IV APPENDIX IV Al. A^I.SATIIi IM RUBMIDM AI N I A eI ~,em, V I Foem D27. "Applletlao for Trade Adjuamnet Ar for FW, r equit rtmte Prm PA46-3P' 2. Lett of tramImttal by Applicont firm ttirn forth preposl for T Adjuatm AituMe and ncluding narrative hitory of the finn The hIltory of the fim mut Include discuiob of the be of ts certifcation es binl deibla for Tid. Adjuetent Atoetanm. Its finencl poition in yemrprio to bei affcted by foreign competition and in recent years mt be Identified by rferen to atual , profits. worth. etc. The propal for Te Adjutment Assisan mrut not oeny dicu th rmult expectd from the Proec f which the application Is bein made, but mwit lo dise In dtaill how the propol wtl: I. matsdally coatribute to the economic aunnt o th finn. 2. ove adqut coideratlb n to the Intert of the firm worern, ad 3. demonstra that the firm will m all reasonabl efforts to Ue its ow re urce for economic development. 3. Fom ED-436 or Form DID 346, "'rtfiietsof E bilbty" - 4 Form ED-272 "Application Requitonu and Index - Ttt Adjustment A tance fort Pirm" S. Form ED-220,'*arketing end Capacity Information Report" 6. Form ED223, "Employnent Schedule and Asurances" 7. Form ED503. "Aurnces o Complnce with the Depertnt Commerce ad the Ecoaomic Development Administration Replatiotu under Tide VI of the Civil Right Act of 1964 end Public Law 92.65" 8. Fornm ED-24. "Certification of Complince with the Clean Air Act and th Federal Water Pollution Control Act" 9 Affirmative Action Pan (busnes5O or more employees) 10. Foram CD-227. "Request for NUne Check or Identlfication Rortd Check" for ownern and/or officen ('DA rpemen'aie abe lis r qisad persons bow): a. b. d. *. h. 11. Mot rcent (not er 9 daysiold) lttd nt.rim fnca statemnt do tppint 12. t4t rcnt  audited ] sfned flsci yeuend inanciad statement (uppoted by copy of tax rturn) fo FY 13 Pro forms tncon ad rash now projectio (by qtrnr from the dte of the most recent interimn firncial statement, ubmitted in ccordmtne with I I bove. throh the first yusr od operations ubequent : completion the jropct ind yedrly the coed ad third yerm o opettlion )thowing cluh requiremmu td dnonttin&applicant's bility to entrc ill debt pinciptl piyMmnt ro nt incoe ater tes flthr ha from ctth flow 14. Asumption udrlyifi pro formt projections / 15. Pro forNt bnce d hfor u rhesrt dtt f lh of th piod covad by the po form pojctions ubmitrd pursuant to 13 bove 16. A oo rccount pyible .Ain of ccounuts rceable not fctored d. Stat t o( t _fto potion with the_ rm's 19k. lat of fbmd omnunmnint fram th blow wd lenders nvond the project rcomensI (kIfrtn t Itntrmr Iintindtermount ofn . Inat rat, rapqimnt bymm chlefe ta rurn ostion rqu_ _ ): 16.A~g o acoutspaybl OON I",l tpam inac ) b tdi Ouar:llm[4 45 APPENDIX IV APPENDIX IV A I Afp1me PI P -. 20. LIte dofquly emlm t from the below tised sou re for fla id m atdum w hq ptal requrtmmt. a appropria mfitm o/f cmnm e r mdu woei nMWof Atd a m or ta,,t): b. d. _b. __ 21. Financl tatent (nol nt 90 drys old) of below bated pathll; of a patit corpori- Iti. or ownel. pi tnr o n of a i hld applicant, or both (Individs u Form ED-273 "P'eronil Fintncil Statement. as of - .") AEDA ,omart itS w Nott behw ta ril, regu to af64t jlnM*i tnmmum,).' 22. Litte of cnrmrint of luaranton EDA ta It l t rw mtam blow: R~SWrfd ntm Rp,td A mt b. C d. e- 23. Lett fa two bdi ktitutios d _histo fi e the pojet eithr dictly,.in participation with EDA o wilh an EDA pematy: b. 24. roped La Documnt (Not and LoAn Agrment) dentifynll trtan mtaet rat. cokterl to be taken and other key tm and coiltior of ny lon to be gurantld by EDA 25. Copih of L()! volved b prOct: a. From _ to b. From tu uoma and OpWiM 26. Certificate of pood tandint for corporate applicant 27. Copy of prtnship _ureemnt 23 OrlmniLlton clru ihowlg Coroporu nd manaelment (persol) strIctures 29. RItd of the flowg named propict admnistlretlve and opralioul peonnel. a. Chief excute offker b. Chief fir_ officer c. COef lm and mnritl offlme d. lcr i charge of poducion Other: (Titc and Ne) 30. Ltten of comnitmcnt fom blow lited pplrtn of Cer t and am nuterials, nd frotm critical nars broker. etc. (EDLA I it nselhe fY nlst urd eann fnr Iae of Suppler or Ctor Iturm 31. Inde pednt FeaMbility Study by rooam I-I in". trI u Lca oc tll1'll 46 APPENDIX IV APPENDIX IV A- .. A IB ww aY I 32. Schedul for contrution of raetltit, and acqui tion ad ustalation of M · E 33. Schematic layout of buildin including layout and work flow of bay machinery and eqU- mnt (ie. prodaction ine) (Reduncto a near iO mie (8-1/2 x 14) rs practicl) 34. Capabiity of machinery anadequipm t to produce the ntpeted quality of quantity of goods at maxinumn production rat per hour anticipted a. Independent ppraisal of production apacity b. Manufacturer's warrantin (EDA rprmentfire Jikll dlr mequtrad Itemt bebw, 3. Fom ED-267. Tabulation of Total Incurred Coatsto Date" - Applicant ahuld un ths an a detaild projected litifig of specificub-lement of project coat. (For & . , indicate model, capacity, and whether new or ued) 36. Evridence of Q or Option for [ purchase of land ncluding decription of land and purchse prce 37. Map of ocal area (city or county) howing precise loction of the project (reler pertlon thereof not gmater than 8-1/2 14) 38. Site plt (Reduced to u near legal in (8-1/2 x 14)as practical 39. Indepndent bid by contractor or coat estimate by rchitect/enginer for project building. elcludin I description of type of coatructlon, square foot ae nd special feature ad state- mant asaurin that Dres Bacon We will be paid 40. Cot timates by machinery nd equipment supplien and instalen (incluln Davis Bacon statement on cots asocated with major instaliatorr) 41. Other Project Cost: a. Architectural and uginri nrvices b. Lali and/or administrtive expenes c. Commitment of interim lender supporting the projected coat of nterest expenss during construction indicated on Form ED-267 ar ED-271 d. Preliminar expenes . Evidence in support of continluency reaerve Oter Doeabualn Required 42. 43. 44. 45. 46. 47. 48. 49. Flet EG Elsmant A pre-ppication conference washed t on _ I _ I at which time the undrigned EDA repeentive explained the item on this form to of · (firm); the underained indicated the fortes, documentation and other items of information quired to aupport an pplication for bu e delopment asistance by pioc- n hi nitialtin the ppropriate boxes. TYVIEAE A"O TITLE or IDA 06rl"15,Av- SIGATUE H | Fin IDA ledem t Th undersigd has reviewed the ppication and hasdetermined that the applicant hassubmitted ll nrquired item of infonartion. that each item is completed, that ill document requiring applicant's aIsture or certification ar prnpriy executed, that the mnti pplicaion is orgapnted asrequired by thit form anC that aII problem inrvolvin required items hae beenrsovd. It is therefort recommended that the Regional Director in thi pplication a project number tndthat pcreimn commmoa. NICOMMaNoEO, TYst NlAME sI TITL O 5LIOUIATUft |AtO Ito RIpagamNTATIVZ PoAl 1o-1 tlll.N 10'-1. ucoMQ litattsel 47 APPENDIX V APPENDIX V i! F1X1 - . 0 -m ai * a n O _ " 0. 101 . . ! II i iI I. 0 nH 4 ( 0 0 0 fi.4 I4~~~~4 ,, % f Il48 a4 llj f II 4i It Y APPENDIX VI APPENDIX VI STATUS OF CERTIFIED NONRUBBER FOOTWEAR FIRMS AS OF DECEMBER 31, 1976 (note a) Number which have received financial assistance b/4 Number which have received proposal technical assistance 1 Number with applications in process 1 6 Other: Have no plans to submit an application 2 Have submitted a proposal but not the entire application 2 Have met with EDA officials but have not submitted application c/2 Have sold operations to another company 1 No contact with OBD; (status unknown) 2 9 Total 15 a/ With the exception of one firm in Puerto Rico which we omitted from the review because of anticipated difficulty in contacting firm officials. b/ Type of assistance and amount includes: Fixed asset Working capital loan $250,000 loan $1,000,000 Working capital loan 630,000 Working capital loan 700,000 Working capital loan 750,000 c/ According to an OBD official, the parent company ceased the shoe operations. 49
Assistance to Nonrubber Shoe Firms
Published by the Government Accountability Office on 1977-03-04.
Below is a raw (and likely hideous) rendition of the original report. (PDF)