# STATE OF CONNECTICUT DEPARTMENT OF ENVIRONMENTAL PROTECTION

State ofConnecticut & 

### Hamilton Sundstrand Corporation 

### ) ) ) 

### ) 

### Trading Agreement & 

### OrderNo. 8291

WHEREAS, the Commissioner ofEnviromnental Protection ("Commissioner") and Hamilton Snndstrand Corporation ("Respondent") agree that the Commissionermay issue a permit or orderto allow emissions trading in accordance with Section 22a-174-220) ofthe Regulations ofConnecticut State Agencies ("Regulations") as a method ofcompliance with Section 22a-174-22 ofthe Regulations: A. At the request and with the agreement ofthe Respondent, the Commissioner finds the following: 1. 

### This Trading Agreement and Order supercedes Trading Agreement and OrderNo. 8109 and all subsequentmodifications thereto. 2. Respondent is a corporation that owns and operates a facility involved in the manufacturing and assembly ofaerospace components at One Hamilton Road, Windsor Locks ("facility"). 3. At the facility, Respondent operates the emission units described in Table 1 below, which are subjectto Section 22a-174-22 ofthe Regulations ofCOlmecticut State Agencies ("RegUlations") pertaining to the control ofNitrogen Oxide (NOx) emissions. 4. Forthe purposes ofthis Trading Agreement and Order, the following definitions shall apply:

a. Allowable Emission Limit (AEL): the applicable NOx emission limit set forth in Section 22a-174-22(e) or Section 22a-174-22(f) ofthe Regulations corresponding to each emission nnit described in Table 1 ofthis Trading Agreement and Order. b. Allowance: CArRNOx Ozone Season allowance originally allocated to a CArRNOx Ozone Season nnit located in the State ofConnecticut, as defined in Section 22a-174-22c ofthe Regulations or a NOx allowance designated specifically for compliance during Ozone Season control periods and allocated to a CArRNOx Ozone Season nnit located in the State ofCOimecticut after the date ofissuance ofthis Trading Agreement and Order.

(Printed on Recycled Paper) 79 Elm Street

_ Hartford. CT 06106-5127 www.ct.gov/dep An Equal Opportunity EmployerHamilton Sundstrand Corporation 

### 2 Trading Agreement & OrderNo. 8291

c. Discrete Emission Reduction Credit (DERC): a unit that was generated and approved by the Commissionerin accordance with a Trading Agreement and Order issued by the Commissioner, orgenerated and approved by the Commissioner in accordance with a protocol submitted and approved pursuant to Section 22a-174-38 ofthe Regulations. Such unit is equivalent to I ton of NOx emissions and may be used for emissions trading in accordance with Section 22a-174-220) ofthe Regulations, subjectto the provisions ofPart B of this Trading Agreement and Order. d. Non-Attainment Area: means the geographic area which has been designated as nonattainmentpursuant to 40 CFR 81 in accordance with the provisions of 42 USC 7407 (Section 107 ofthe Act). pursuant to 40 CFR 81.307, the designated ozone non-attainment areas in the State ofConnecticut are: the Greater Connecticut, CT area and the New York-NorthernNew Jersey-Long Island, NY-NJ-CT area.

e. Full Load Emission Rate ("FLER"): Nitrogen Oxide ("NOx") emission rate corresponding to each emission unit described in Table I ofthis Trading Agreement and Order that the Respondent shall not cause or allow the emissions ofNOx from that emission unitto exceed; and that the Respondent agrees such FLER shall serve as the basis fordetermining Estimated DERCs Required, Estimated Allowances Required, Actual DERCs required, and Actual Allowances Required in accordance with this Trading Agreement and Order. f. CAlRNATS: means "CAIRNOx Ozone Season Allowance Tracking System" as defined in 40 CFR 96.302. g. Ozone Season: May I through September 30 ofeach calendaryear or such period as defined by the U.S. Environmental Protection Agency, subsequent to the issuance ofthis Trading Agreement and Order.

Table 1 Respondent

- NOx Emission Rates, FLERs and Allowable Limits (lbs/MMBtn)**n~II~'f$]i~'f:ijjj'il~j'll'[rl1~** UNIT- Heat Stack FLER Allowable Date of Date of reg. or Input Test Rate (Ib/mmbtll) Emission LastStack Next Stack Limit permit no. Fnel (mmbtu) (AEL) Test Test BoilerNo. I No.6 oil 61 0.35 0.425 0.25 1115/2008 11/612013 (Riley) Nat. Gas 0.14 N/A 0.20 11/3/2008 111412013 R#213-0052 BoilerNo. 2 No.6 oil 61 0.36 0.434 0.25 1114/2008 111512013 (Riley) Nat. Gas 0.14 N/A 0.20 11/3/2008 111412013 R#2I3-0053 BoilerNo. 3 No.6 oil 61 0.37 0.445 0.25 Jl/4/2008 1115/2013 (Riley) Nat. Gas 0.11 N/A 0.20 1lI3/2008 1lI4/2013 R#213-0054

.- ..Hamilton Sundstrand Corporation 3 Trading Agreement & OrderNo. 8291 5. The Respondent agrees thatthe actual NOxemissions rate from the emission units described inTable 1, when burning the corresponding fuels, exceeds the corresponding AELs. 6. Pursuantto Section 22a-174-22G) ofthe Regulations, the Respondentproposes to comply with Section 22a-174-22(e) ofthe Regulations, when operating the emission units described in Table 

### I, and burning the corresponding fuels, by means ofemissions trading in accordancewith the provisions ofthis Trading Agreement and Order. 7. Respondent proposes to use a full load emission rate ("FLER") identified in Table 

### I for the purposes ofcalculating DERCs and allowances required. The Commissioner, in accordance with Section 22a-174-22G) ofthe Regulations hereby allows Respondent to comply with Section 22a-174-22 ofthe Regulations at the facility through use of emissions trading, subject to the provisions ofthis Trading Agreement and Order.

B. With the agreementofRespondent, the Commissioner, acting under Sections 22a-6, 22a-174, 22a176, and 22a-l77 ofthe Connecticut General Statutes, hereby orders Respondent as follows: 

### 1. Expiration ofthis Trading Agreement and Order: The Respondent may only use emissions trading, subject to the provisions ofthis Trading Agreement and Order, until the date of expiration ofthis Trading Agreement and Order. The date ofexpiration ofthis Trading Agreementand Order shall be the earlier of:

a. January 1,2013; b. The date upon which the Respondent demonstrates to the Commissioner's satisfaction that actual NOx emissions from the emission unit, at all times, do not exceed the corresponding AEL(s);

c. The date specified in any written notice from the Commissioner stating thatthe Respondent is no longer allowed to use emissions trading due to the Respondent's violation ofany provision ofthis Trading Agreement and Order; or d. The date specified in any written notice from the Commissioner, notifYing the Respondent that the Commissioner has determined the use of emissions trading as a compliance optionhas been further restricted, modified or nullified by: (i) the promulgation ofan Act, Statute, orRegulations; or (ii) the issuance ofajudgment orcourt order

.

. 2. Respondent shall obtain and use sufficient DERCs and/orAllowances in such a manner as to comply with Paragraphs B.8 and B.9 ofthis Trading Agreement and Order. All Allowances used must come from an emission urnt that is within the same ozone nonattainment area as the Respondent. All Allowances used by the Respondent must befor the current vintage year.Hamilton Sundstrand Corporation 

### 4 Trading Agreement & OrderNo. 8291 All DERCs used during the Ozone Season, shall have been generated during an Ozone Season by the operation ofan emission unit that is not a CAIR NOx Ozone Season unit, as defined in Section 22a-174-22c ofthe Regulations. 3. l"rior to using Allowances in accordance with Paragraph 8.8 ofthis Trading Agreement and Order the Respondent shall obtain a General Account or Compliance Account in the CAIR NATS. 4, Vintage Restriction. For the purposes ofcompliance with Section 22a-174-22 ofthe Regulations and the provisions ofthis Trading Agreement and Order, DERCs shall only remain valid for five (5) calendaryears from the year oftbe generation ofsuch DERCs. DERCs olderthan five (5) calendar years from their creation are not valid for use for compliance with Section 22a-174-22 ofthe Regulations and the provisions ofthis Trading Agreement and Order 5. Respondent shall not cause or allow actual NOx emissions from the operation ofthe emission units described in Table I ofthis Trading Agreement and Order to exceed the corresponding FLERs. Compliance with the corresponding FLERs specified inTable I shall be determined based on the results ofemissions testing performed in accordance with Section 22a-174-22 of the Regulations or NOx emissions monitored and recorded by a continuous emissions monitoring system that waS approved by the Commissioner and thatcomplies with Section 22a-174-4 ofthe Regulations and either40 CFR 60, Appendices B&F or 40 CFR 75. 6. Ozone Season Fuel Use Restriction: Notwithstanding the provisions ofParagraph B.2 ofthis Trading Agreement and Order, when operating the emission units described in Table 1 during the Ozone Season, the Respondent shall operate those units while firing orco-firing the lowest NOx emitting fuel type or combination offuel types thatthe units are authorized to burn in accordance with Departmental permit, registration, or applicable regulation. 7. Notwithstanding Paragraph 8.6 ofthis Trading Agreement and Order, during the Ozone Season, the Respondent may operate the emission units described above on fuels that result in higher emissions ofNOx, ifeither:

a. the availability offuel oil thatcomplies with Paragraph 8.6 is inadequate to meet the needs ofresidential, commercial and industrial users in this state and that such inadequate supply constitutes an emergency; or b. the supply ofgaseous fuels to the emission units is interrupted due to inadequate supply or in accordance with an interruptible supply agreement between the Respondent and the gaseous fuel supplier. 

### 8. DERC/Allowance Use. Before the first day ofeach calendar month, the Respondent shall possess a quantity ofDERCs and/orAllowances that equals or exceeds the quantity ofActual DERCs Required and/orActual Allowances Required in that month. Compliance with Paragraph 8.8 ofthis Trading Agreement and Order shall be determined as follows:

a. Before the first day ofeachmonth, Respondent shall estimate DERCs and/or'Hamilton Sundstrand Corporation 

### 5 Trading Agreement & OrderNo. 8291 Allowances required for such calendar month for each emission unit using the corresponding FLER and AEL from Table I as follows: Estimated

### DERCsl Allowances Required

## = {(Estimated fuel use in MMBtu) x «FLER)

- (0.95 x AEL»}+2000 Ibs/ton Where:

• AEL

- Allowable Emission limit, as defined in Paragraph 

### AA ofthis Trading Agreement and Order

• FLER

## =Full Load Emission Rate, as defined in Paragraph 

### AA ofthis Trading Agreement and Order

• Discount (0.95) 

## =5% design margin applied to the AEL. b. No later than the twentieth day ofeach month, Respondent shall calculate actual DERCs and/or Allowances used in the preceding calendar month for each emission unit using the corresponding FLER and AEL from Table I as follows: Actual 

### DERCslAllowances Required =

{(Actual fuel use in MMBtu) x «FLER)

- (0.95 x AEL»} + 2000 lbs/ton.

c" At the end ofeach calendaryear, the Respondent shall demonstrate that any Allowances used for compliance during the year are surplus, quantifiable, enforceable andpermanent. This shall be determined by demonstrating that the Seller's actual NOx emissions during the Ozone season as reported to EPA were equal to or less than the amount ofAllowances allocated to the Sellerby the State ofConnecticut minus the Allowances purchased by the Respondent. 9. On or before January 31 ofeach calendar year, the Respondent shall deduct a quantity of DERCs from the current balance ofDERCs possessed by the Respondent and/ortransfer a quantity ofAllowances from the Respondent's NOx General Account to the CT State NOx Retirement Account (Account ID CT0000000300 in the CAIRNATS) such thatthe total is equal to the sum ofActual DERCs/Allowances Requiredpursuant to Paragraph E.8 ofthis Trading Agreement and Order for the preceding calendar year, rounded up to the nearest whole ton. 10. Doubling: Ifthe Actual 

### DERCslAllowances Required for any month, determined in accordance with Paragraph B.8, exceeds the quantity ofDERCs 

### and/or Allowances in the Respondent's possession on the flISt day ofthat month, then in addition to the deduction or transfer specified

### 'in Paragraphs B.9, the Respondent shall deduct a quantity ofDERCs from the currentbalance ofDERCs possessed by the Respondent and/or transfer a quantity of Allowances from the Respondent's NOx General Account to the CT State NOx Retirement

### Hamilton Sundstrand Corporation 6 Trading Agreement & 

### OrderNo. 8291 Account (Account ID CT0000000300 in the CAIR NATS) such that the total is equal to Actual DERCS/ Allowances Required for that month. Such additional DERC deduction orAllowance transfer shall be performed at the same time as the DERC deduction or Allowance transfer specified in Paragraph B.9 ofthis Trading Agreement and Order. Notwithstanding the provisions ofParagraph B.I0 ofthis Trading Agreement and Order, any violation ofParagraph B.8 ofthis Trading Agreement and Order may be subjectto additional enforcement action as may be deemed appropriate by the Commissioner in accordance with the Department's enforcementresponse policy. I I. 

### Maintenance and Tune-up. Not more than I yearfrom the date ofissuance ofthis Trading Agreement and Order, the Respondent shall perform maintenance and inspection ofeach emission unit listed in Table 1. 

### Such maintenance and inspection shall include, but not be limited to, the following:

a. Inspect the combustion system, and clean orreplace any components ofthe combustion system as necessary, in accordance with manufacturer's specification or current good engineering practice; b. Inspectthe system controlling the air-to-fuel ratio, and ensure that itis calibrated and functioning in accordance with the manufacturer's specifications or current good engineering practice;

c. Measure the operating parameters ofthe emission unit used to determine that the emission unit is operating in accordance with manufacturer's specification or current good engineeringpracticepriorto and after any adjustments are made during maintenance, tune-up, orinspection activity; d. Make and keep records including, but not limited to, the following: i. Demonstration that any maintenance, tune-up, and/orinspection activity performed on the emission units described in Table I in accordance with Paragraph B.I I ofthis Trading Agreement and Order has beenperformed in accordance withthe manufacturer's specifications ofcurrent good engineering practice, ii. The date and adescription ofany maintenance, tune-up, and/or inspection activityperformed onthe emission unitsdescribed inTable I in accordance with Paragraph B.I I ofthis Trading Agreement and Order, iii. 

### The name, title and affiliation ofthe person conducting any maintenance, tune-up, and/or inspection activityperformed on the emission units described in Table I in accordance withParagraph B.II ofthis Trading Agreementand Order,Hamilton Sundstrand Corporation 

### 7 Trading Agreement & OrderNo. 8291

iv. The operating parameters ofthe emission unit used to determine that the emission unit is operating in accordance with manufacturer's specification orcurrent good engineering practice priorto and after any adjustments are made during maintenance, tune-up, or inspection activity performed in accordance with Paragraph B.ll ofthis trading Agreement and Order. 12. Record Keeping:

a. By the close ofeach calendarday, the Respondent shall record the actual fuel type and the actual quantity ofeach type offuel in units ofvolume per day or MMbtu per day for each fuel used by any emission unit described in this Trading Agreement and order on the preceding day; b. On or before the first day ofeach calendar month, the Respondent shall record the number ofDERCs and corresponding serial numbers and vintages for all DERCs in its possession on the first calendar day ofthat calendar month,

c. On or before the first day ofeachcalendar month, the Respondent shall record the numberofAllowances and corresponding identification numbers and vintages for all Allowances in its possession on the first calendar day of that calendarmonth,

d. On orbefore the first day ofeach ca1e<ndarmonth, the Respondent shall record the number ofDERCs and corresponding serial numbers, vintages, purchase/sales dates, and seller/buyerfor all DERCs purchased or sold during the preceding calendar month,

e. On or before the first day ofeach calendar month, the Respondent shall record the number ofAllowances and corresponding identification numbers, purchase/sales dates, allocation years, and seller/buyer for all Allowances purchased or sold during·the preceding calendarmonth, f. On orbefore the first day ofeachcalendarmonth, the Respondent shall record the Estimated DERCS/ Allowances Required for that calendar month determined in accordance with Paragraph 8.8 ofthis Trading Agreement and Order. g. On orbefore the twentieth calendar day ofeach calendar month, the Respondent shall record the Actual DERCs/ Allowances Required for the preceding calendar month determined in accordance with Paragraph B.8 of this Trading Agreement and Order; h. On or before January 3 I ofeach calendaryear, the Respondent shall record the quantity ofDERCs deducted in accordance with Paragraphs 8.9 and 

### B.IO ofthis Trading Agreement and Order. Such records shall include the serial number and vintage ofeachDERC deducted from the Respondents current balance pursuant to Paragraphs 8.9 and 8.10 ofthis TradingHamilton Sundstrand Corporation Agreement and Order. 

### 8 Trading Agreement & OrderNo. 8291



### i. On or before January 31 ofeachcalendar year, the Respondent shall record the quantity ofAllowances transferred in accordance with Paragraphs B.9 and B.I

# aofthis Trading Agreement and Order. Such records shall include the identification number and allocation year ofeach Allowance transferred pursuant to Paragraphs B.9 and B.IO ofthis Trading Agreement and Order. j. For eachmonth ofthe Ozone season, the Respondent shall maintain records attesting to the fact that any DERCs deducted from its balance in accordance with Paragraphs B.9 and B.IO were created during an Ozone season. Generator certification ofthis fact shall be sufficient. k. On each day during the ozone season that the Respondent operates in accordance with Paragraph B.7 ofthis Trading Agreement and Order, the Respondent shall make and keep Records ofall emission unit operation in accordance with Paragraph B.7 ofthis Trading Agreement and Order, including copies ofany written correspondence from the Respondent's fuel supplierdetailing the duration and circumstances ofthe inadequate fuel oil supply or interruption.ofgaseous fuel supply to the emission units. 13. Respondent shall retainrecords and supporting documentation required by this Trading Agreement and Order for a minimum offive years, commencing onthe date such records were created. Respondent shall provide the records specified above to the Commissioner within thirty (30) days ofreceiptofa writtenrequest from the Commissioner. All records shall be maintained in accordance with Sections 22a-174-4 and 22a-174-22 ofthe Regulations. 14. Reporting: No later than March I ofevery year after issuance ofthis Trading Agreement and Order, the Respondent shall submit to the Commissioner a written report containing copies of all ofthe records required pursuant to Paragraph B.9 ofthis Trading Agreement and Order. The Commissioner may prescribe the forms to be used for the submission ofthese reports. The Respondent shall submit these reports on such forms, ifprescribed by the Commissioner. 15. FLER Violation. Violation ofan established FLER shall subject Respondent to make restitution by matching the quantity ofemissions ("true up") caused by the exceedance plus a 100% premium. The true up in tons ofDERCs orAllowances shall be equal to the FLER exceedance inlbs/MMBtu, multiplied by the total heat input during the period of noncompliance divided by 2000 

### Ibs/ton. Ifthe period ofnoncompliance is not known, the time period from the completion ofthe last/previous Department witnessed emission test through the date that FLERcompliance is achieved as approved by the Commissioner shall be used. Notwithstanding this requirement, exceedance ofany FLER contained in Table I is a violation in Paragraph B.8 ofthis Trading Agreement and Order subject to enforcement action in accordance with the Department ofEnvironmental Protection's Enforcement Response Policy, in effect at the time ofsuch violation. 16. FLER Modification. FLERs set forth in Table I ofthis Trading Agreement and Order may be modified only after the consent ofthe Commissioner by written modification ofthis Trading Agreement and Order.

### Hamilton Sundstrand Corporation 9 

### Trading Agreement & OrderNo. 8291 17. Emissions Testing. The Respondent shall perfonn emissions testing in accordance with Section 22a-174-22(k) ofthe Regulations for each emission unit described inTable I ofthis Trading Agreement and Orderthat is not equipped with a continuous emissions monitoring system that was approved by the Commissioner and that complies with Section 22a-174-4 of the Regulations and either40 CFR 60, Appendix B&F or40 CFR 75. 18. Full compliance. Respondent shall not be considered in full compliance with this Trading Agreement and Orderuntil all actions required by this Trading Agreement and Order have been completed as approved and to the Commissioner's satisfaction. 19. Approvals. Respondent shall use best efforts to submitto the Commissioner all documents required by this Trading Agreement and Orderin a complete and approvable fOlm. Ifthe Commissionernotifies Respondent that any document or other action is deficient, and does not approve it with conditions ormodifications, itis deemed disapproved, and Respondent shall correctthe deficiencies and resubmit itwithin the time specified by the Commissioner or, ifno time is specified bythe Commissioner, within 30 days ofthe Commissioner's notice ofdeficiencies. In approving any document orotheraction under this Trading Agreement and Order, the Commissionermay approve the document orotheraction as submitted or performed or with such conditions or modifications as the Commissionerdeems necessary to carry outthe purposes ofthis Tradi!1g Agreement and Order. Nothing inthis paragraph shall excuse noncompliance or delay. 20. Definitions. As used in this Trading Agreementand Order "Commissioner" means the Commissioneror arepresentative ofthe Commissioner; The date of"issuance" ofthis Trading Agreementand Order is the date the Trading Agreement and Order is deposited in the U.S. mail orpersonally delivered, whicheveris earlier. 21. Dates. The date ofsubmissionto the Connnissionerofany document required by this Trading Agreement and Order shall be the date suchdocument is received bythe Commissioner. The date ofany notice by the Commissionerunder Trading Agreement and Order, including but not limitedto notice ofapproval or disapproval ofany document or other action, shall be the date such notice is deposited in the U.S. mail or is personally delivered, whicheveris earlier. Except as otherwise specified in this Trading Agreement and Order, the word "day" as used in this Trading Agreement and Ordermeans calendar day. Any document or actionwhich is required by this Trading Agreement and Orderto be submitted orperformed by a date which falls on a Saturday, Sundayor a Connecticut or federal holiday shall be submitted orperformed by the next day which. is not a Saturday, Sunday or Connecticut orfederal holiday. 22. Certification ofdocuments. Any document, includingbut not limited to any notice, which is requiredto be submitted to the Commissionerunder this Trading Agreement and Order shall be signed by the Respondent or, ifRespondent is notan individual, by an individual, employed by the Respondent, who satisfies the criteria set forth in Section22a-174-2a(a)(l) ofthe Regulations ofConnecticut State Agencies and by the individual(s) responsible for actually preparing such document. Each individual who signs documents in accordance with this Paragraph shall certifY in writing as follows: "I havepersonally examined and am familiar with 

### the information submitted in thisHamjlton Sundstrand Corporation 10 Trading Agreement & OrderNo. 8291 document and all attachments thereto, and I certifY, based on reasonable investigation, including my inquiry ofthose individuals responsible for obtaining the information, that the submitted information is true, accurate and complete to the best ofmy knowledge and belief. I understand that any false statement made in the submitted information may be punishable as a criminal offense under Section 53a-157b ofthe Connecticut General Statutes and any other applicable law." 23. Noncompliance. This Trading Agreement and Order is a final order ofthe Commissioner withrespect to the matters addressed herein, and is nonappealable and immediately enforceable. Failure to comply with this Trading Agreement and Order may subject Respondentto an injunction and penalties. 24. False statements. Any false statement in any informatioJ submitted pursuant to this Trading Agreement and Order may be punishable as a criminal offense under Section 53a157b ofthe Corniecticut General Statutes and any otherapplicable law. 25. Notice oftransfer: liability ofRespondent. Until Respondent has fully complied with this Trading Agreement and Order, Respondent shall notifY the Commissioner in writing no later than 15 days after transferring all or any portion ofthe facility, the operations, the site or the business which is the subject ofthis Trading Agreement and Order orafter obtaining anew mailing or location address. Respondent's obligations under this Trading Agreement and Order shall not be affected by the passage oftitle to any property to any other person ormunicipality. 26. Commissioner's powers. Nothing in this Trading Agreement and Order shall affect the Commissioner's authority to institute any proceeding or take any otheraction to prevent or abate violations oflaw, prevent or abate pollution, recover costs and natural resource damages, and to imposepenalties for past, present, or future violations oflaw. Ifat any time the Commissioner determines that the actions taken by Respondentpursuant to this Trading Agreement and Orderhave not successfully corrected all violations, fully characterized the extent or degree ofany pollution, or successfully abated or prevented pollution, the Commissioner may institute any proceeding to require Respondent to undertake further investigation or further action to prevent or abate violations or pollution. 27. Respondent's obligations under law. Nothing in this Trading Agreement and Order shall relieve Respondent ofother obligations under applicable federal, state and local law. 28. No assurance by Commissioner. No provision ofthis TradingAgreement and Order and no action or inaction by the Commissioner shall be construed to constitute an assurance by the Commissionerthat the actions taken by Respondentpursuant to this Trading Agreement and Order will result in compliance or prevent or abate pollution. 29. Access to premises. Any representative ofthe DepartmentofEnvironmental Protection may enter the without prior notice for the purposes ofmonitoring and enforcing the actions required or allowed by this Trading Agreemimt and Order.Hamilton Sundstrand Corporation 

### II Trading Agreement & OrderNo. 8291 30. No effect on rights ofother persons. This Trading Agreement and Orderneither creates nor affects any rights ofpersons or municipalities that are not palties to this Trading Agreement and Order. 31. No Creation ofPropetty Rights. This Consent Order does not create any property rights with respect to these DERCs orAllowances. 32. Notice to Commissioner ofchanges. Within 15 days ofthe date Respondent becomes aware ofa change in any information submitted to the Commissioner under this Trading Agreement and Order, orthat any such information was inaccurate ormisleading or that any relevant information was omitted, Respondent shall submit the correct or omitted information to the Commissioner. 33. Notification ofnoncompliance. In the event that Respondent becomes aware that it did not or may notcomply, ordid not or may not comply on time, with any requirement of this Trading Agreement and Order orofany document required hereunder, Respondent shall immediately notifY by telephone the individual identified in the next paragraph and shall take all reasonable steps to ensure that any noncompliance or delay is avoided or, if unavoidable, is minimized to the greatestextentpossible. Within five (5) days ofthe initial notice, Respondent shall submit in writing the date, time, and duration ofthe noncompliance and the reasons for the noncompliance or delay and propose, for the review and written approval ofthe Commissioner, dates by whichcompliance will be achieved, and Respondent shall comply with any dates which may be approved in writing by the Commissioner. Notification by Respondent shall not excuse noncompliance or delay, and the Commissioner's approval ofany compliance dates proposed shall not excuse noncompliance or delay unless specifically so stated by the Commissioner in writing, 34. Submission ofdocuments. Any documentrequired to be submitted to the Commissioner underthis Trading Agreement and Order shall, unless otherwise specified in this Trading Agreement and Order or in writing by the Commissioner, be directed to: Supervisor Administrative Enforcement Group Engineering and Enforcement Division Bureau ofAir Management Department ofEnvironmental Protection 79 Elm Street, 5th Floor Hartford, Connecticut 06106 (860) 424-3702Hamilton Sundstrand Corporation 12 Trading Agreement & OrderNo. 8291

Respondent consents to the issuance ofthis Trading Agreement and Order without further notice. The undersigned certifies that helshe is fully authorized to enter into this Trading Agreement and Order and

. to legally bind Respondent to the terms and conditions ofthe Trading Agreement and Order.

HAMILTON SUNDSTRAND CORPORATION
Signature:

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Issued as a final consent order ofthe Commissioner ofthe Department ofEnvironmental Protection.

G S. se, Director Engineering & Enforcement Division Bureau ofAir Management

TOWN OF WINDSOR LOCKS MAILED CERTIFIED MAIL, RETURN RECEIPT REQUESTED Certified Document 

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## 'Lofo Date