Emma L. David v. Honorable Raymond J. Donovan, Secretary of Labor, United States Department of Labor

EUGENE A. WRIGHT, Circuit Judge:

This is a challenge to the Assistant Secretary of Labor’s decision that appellant David is ineligible for benefits as an adversely affected woods employee, under the Redwood National Park Expansion Act of 1978, Pub.L. No. 95-250, 92 Stat. 163 [Redwood Act], The parties disagreed in their interpretation of Labor Regulation 92.15, 29 C.F.R. § 92.15 (1980), under which appellant seeks benefits. We must decide which interpretation of that regulation should be applied.

FACTS

Emma David worked for Simpson Timber until her layoff on April 30, 1981. Her job involved…