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steadily declining financial conditions and prospects. All this amounts to time and money, two sorely lacking commodities in a business about to go under.” Just how burdensome and discouraging all this is to any firm pursuing adjustment assistance is easily apparent in the list of material required by the Economic Development Administration to evaluate applications for financial assistance in phase 2, that is after a firm has been certified as eligible for assistance. The inventory is contained in EDA's form ED–272, a copy of which is appended hereto. The complexity of program procedures is also readily evident in two flow charts which the Government Accounting Office prepared to illustrate separately the certification process and the follow-up process of actual applications for financial assistance. These two flow charts are reproduced and also appended hereto. Clearly, receiving assistance under the Trade Adjustment Assistance Program involves many hurdles which are often overwhelming to both firm and worker applicants. Equally clearly, the record of specific accomplishments to date proves this program is not the appropriate tool to provide an effective remedy for the serious injury which the International Trade Commission, on two successive occasions, found the U.S. nonrubber footwear industry to be suffering as a result of increased import competition. There should be no dispute over the most recent ITC finding of injury on non-rubber footwear last month : From 1968 to 1976, imports rose from 182 to 370 million pairs. Import penetration increased from 21.5 percent to 45.7 percent. Production fell from 642 to 444 million pairs. Employment declined from 233,000 to 170,000 workers. The unemployment rate was 11.7 percent in the last half of 1976, 50 percent higher than the national average. Idle capacity in the industry is about 200 million pairs, 30 percent of the industry's capacity. The number of firms declined from 597 in 1969 to 376 in 1975, and probably less than 350 today. Levels of profitability are unreasonably low for a significant number of firms in the industry. Yet in the face of such indisputable evidence, one lone ITC Commissioner repeated his previous recommendation of adjustment assistance as a remedy, even though he tempered his decision by voicing concern again over the insufficiency of funding of the program. In this respect, the Commissioner stated in his latest decision: “As I noted in my opinion in the previous footwear investigation, I believe that insufficient funds have been made available to the Department of Commerce's Trade Adjustment Assistance Program. In fiscal year 1976, the Department of Commerce budgeted $17 million for financial assistance for firms and $3 million for technical assistance for firms. The same amounts have been budgeted for financial and technical assistance for fiscal year 1977 and for the proposed fiscal year 1978 budget. I consider these amounts insufficient to effectively deal with the problems of the footwear industry alone, not to mention the requirements of firms in other industries.” This Commissioner would have us believe that adjustment assistance has not been tested sufficiently to date because the number of shoe firms applying for assistance has been small and the number of actual recipients to date even smaller. At the same time he admits that if all injured firms in the industry were to seek assistance, they would overwhelm the program. What a classic “Catch–22” situation 1 To get loans, a shoe firm must be able to prove that the loan will be repaid and at the same time it must also prove it is going out of business. All this in a program which is inadequately funded and fraught with expensive, timeconsuming and almost insurmountable operational hurdles for applicants both firms and workers. We in the nonrubber footwear industry say to those who recommend adjustment assistance as a remedy for the shoe industry's import injury, that adjustment assistance has been tested and tested adequately by any measures. It has failed. Only effective import relief will save the domestic footwear industry. President Carter has the authority to do so as a result of the ITC's recommendations of last month. The footwear industry and its workers are confident that he will.

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OAM ID 372

OMB Approval Not Requerd

VS DEPARTMENT OF COMMERCE
ECONOMIC DEVELOPMENT ADMINISTRATION

APPLICATION REQUIREMENTS AND INDEX-TRADE ADJUSTMENT ASSISTANCE FOR FIRMS

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INSTRUCTIONS FOR COMPLETION AND USE OF FORM ED-272 This form identified the documentary material needed by EDA to mulusue applicauons for financini ausistance to businesses under ius trade adjustment acistance prognumas. Many items are ncluded in this list, but only thone items checked in Column (B) will be required to perfect an applicauon. Exch project is unique; the specific documentary requiremena for it we determined in a pretppicauen conference with the prospective applicant, a which time un EDA representsure shall: 1. Place a check mark in Column (B) to the left of exch requued item, except for those with pre-printed check marks

which are required from all applicants 2 Place the letren NR, instead of a check muk, next to each unneeded item; 3. Idenuty additional documentary requiremenu on the numbered, but other blank, linet, 4. Execute the frent endorsement to this form, and

S. Give the prospective applicant a copy of the endorsed for us the index of the application. Bring a copy of the checked form u in index (which shall be included in the application package), the applicant shall assemble in the order indented the documenury material ind mark euch item for identication wich an appropruse number/letter from this form. When the application is received an EDA reprezenuove stall check ench item to ensure that a provides the necewary informacon and shall indicate its accepublity by instining the approprute space in Column (A) and thall execute the second

endonement.

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AC RE CEPTEDI QUIRED

A

1.

APPLICATION REQUIREMENTS AND INDEX
Bases ADO Canon

Form ED 271, Application for Trade Adjustment Auistance for Fums", or equivalent form 08-326P 2. Letter of transmitul by Appbcant fum etting forth its propoul for Trade Adjustment

Asusunce and including narrative hustory of the fimm
The history of the form must include a discussion of the basis of iu cenificauon u being
clipble for Trade Adjustment Axulance, lu financial position in yein pnor to being
affected by foreign competition and in recent yean must be idenufied by reference to actual
wales, profiu, net worth, etc. The propoul for Trade Adjustment Assistance must not only
discuss the results expected from the Project for which the application is being made, but
must also discus in detail how the propoul will:
1. materially contribute to the economic adjustment of the firm,
2. sive adequale considerzuon to the interest of the lum's workers, and
3. demonstrate that the firm wl make all reasonable efforts to use its gun resources for

wonomic development.
3. Form ED-436 or Form DIB 346, "Cenificate of Elipduity"

Form ED-272. Application Requiremenu and Index - Trade Adjustment Assurance for
Firms

General Roovirerend

3. Form ED-220. “Marketing and Capacity Information Report"
6. Form ED :23. "Employment Schedule and Assurances
7. Form ED SO3, “Amurances of Compliance with the Department of Commerce and the

Economic Development Administra uon Regulations under Tide VI of the Civil Righu Act

of 1964 and Public Law 92-65"
8. Form ED-524. "Certification of Compliance wich the Clean Ave Act and the Federal Water

Pollution Control ActTM

Affirmative Action Plan (businesses so or more employees)
10. Form CD-227. "Request for Nume Check or Identification Record Check" for ownen and/or

officers (EDA representa nove shall list required persons bdow]:

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Applicant's Finand Position
11. Most recent (not over 90 days old) aged interim financial sustement of applicant

dated
12. Most recent audited or signed fiscal yeu end financial statement (supported

by copy of tu return) for FY 13. Pro forma income and cash now projections (by quarters from the date of the most recent

interen financual statement, submulted in accordance with 11 above, through the first year of operations subsequent to completion of the project and yearly for the second and third years of opera uon ) showing cash requirements and demonstrating applicant's ability to

wervice all debt principal payments from net income after taxes rather than from cash flow 14. Assumptions underlying pro forma projections 15. Pro forma bolance sheets for the last date of each of the periods covered by the pro forma

projections submitted pursuant to 13 above 16. Apane of accounts payable 17. Apng of accounts recemble not factored 18. Statement of the fum's position with the factor 19.

Letren of financial comsrulment from the below listed lendens involved in the project llerten of commonent or intent must include amount of loen, interest rate, repayment term, collateral and lien pourion reqused:

C. d.

JOAM 0-272 (Aur. 10-71)

USCOMM-OC 1019176

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32. Schedule for construction of faalives, and acquistion and installation of M de E
33. Schemauic layouu of buüdings including iayout and work now of key machinery and equip.

ment (i... production lines) (Reduce lo u nes legal size (8-1/2 = 14) w practical)
4. Capability of machinery and eqwpment to produce the anticipated quality of quanuity of

goods at maximum production rate per bour anticipated

1. Independent appraisal of production capacity
b. Manufacturer's warranties (EDA representative shall lust required items below):

1. 2. 3.

35. Form ED-267, Tabulation of Toual Incurred Costs to Date" - Applicant should use this us

1 detailed projected listing of specific sub element of project cost. (For M & E, indicate

model. apacity, and whether new or used) 36. Evidence of oor Option for purchase of land including descripdon of land and

purchase price 37. Map of local area (city or county) showing precise location of the project relevant porrior

thereof not peater than 8-1/2 2 14) 38. Site plat (Reduced to u neur legal size (8-1/2 x 14) us practical 39. Independent bid by contractor or coat estimate by architectengineer for project buldings.

including description of type of construction, square foouage and special features and sure.

ment asuring that Davis Bacon Wages will be pud 40. Cost estimates by machinery and equipment supplien and installen (including Davis Bacon

statement on costs associated with myor installations)

41. Other Project Costs:

1. Architectural and opineering services
b. Leul and/or administrative expenses
c. Commitment of interim lender supporting the projected cost of interest expenses during

construction indicated on Forms ED-267 and ED-271
d. Preliminary expenses
c. Evidence in support of continguency reserve

Other Documentadon Reovired

43. 44. 45. 46.

47.

49.
SO.

on

Fint EDA Endonament
A pre-application conference was held at
at which time the undersiped EDA repreknu tive explained the items on this form to
or

(firm), the underugned indicated the forme, documentation and other items of information required to support an application for business development Lesistance by place

ing his inities in the appropriate boxes. TY NAME AND TITLE OF CDA NCPCSENTATIVE

SIGNATURE

DATE

Fine EDA Endorsement. The underugned hus renewed the application and has determined that the applicant has submitted al required items of information, that each item is completed, that all documents requnnt appixunt's signature or certificadon are properly executed, that the cause application is or pauzed us required by this form and that all problems involving required items have been resolved.

It is therefore recommended that the Regonal Director asign this application a project number and that procesang commence. RECOMMENDED TY NAME AND TITLE OF

SIGNATURE EDA REPRESENTATIVE

DATE

FORM CD-273 (A. 10-73)

USCOMMOC 181716

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