SIP DESCRIPTION -CRRA -Tradine Aerccment and Order No. 8116B I. SIP

- DESCRIPTION OF DERC CREATION ANDIOR USE SIP SUMMARY TABLE TradinfAereemcot and Order No. 8116B Connecticut Resources Recovery Authority**Reserve~Maxim** Rd Hartford

## cr 06103 (CRRA, Mid

- Conn. ISouth Meadow

### Statio~) Identifier 

# IClient 5497 Town # 75 Premise# 1 Sequence # 158 Contact 

### Mr. Scon Smith, Tel: (860) 757- 7725 Fax (860) 757-7742 Environmental Manae:er Smith(@.crra.onz Pollutant and Regulatory Standard: NOx 

# I Section 22a-174-22 ofthe Regulations of Connecticut State Astencies. Nonattainment Area Classification Serious Annual DERCs needed Estimated < 5 tons. Annual DERCs 2enerated Estimated aoproximately 5 tons Comoliance Time Period Unlil Aori130, 2007. Max. Emission Rate: CEM and fun load emission rate (FLER) for Generation and Use. (See Table I below):
Table 1 CRRA Turbine Generators Trading Agreement and Order No. 81168 NOx Emissions Rate and AJlowable Limits in IbsIMMBtu DEP Permits Fuel Maximum Slack Allowable 

### FLER Date of Next Slack Test and**Re~.** No. Cao3citv Test Rate Rate Stack Test Date IIA NO.20ill 256.5 0.79 0.289 0.81 11130/04 11130/09 R160 distillate liB NO.20ill 256.5 0.70 0.289 0.81 11130/04 11/30/09 R161 Distillate 12A No.20ill 256.5 0.76 0.289 0.81 12101104 12101109 R162 distillate 12B No.20ill 256.5 0.68 0.289 0.81 12101104 12101109 R163 Distillate 13A No.20ill 256.5 0.80 0.289 0.81 12102104 12102109 R164 Distillate 13B No. 2 Oil I 256.5 0.77 0.289 0.81 12102104 12102109 R165 Distillate 14A No.2 Oil I 256.5 0.80 0.289 0.81 12103104 12103109 R166 Distillate 14B No.20ill 256.5 0.68 0.289 0.81 12103/04 12103109 R167 Distillate



# n. SPECIAL REQUIREMENTS

a CRRA operates eight (8) combustion turbines ("peakingunits") in accordance with the data shown in Table I above. b. Calculations ofcredits used shall be as specified in Trading Agreement and OrderNo. 8116B.**~."** 

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# STATE OF CONNECTICUT DEPARTMENT OF ENVIRONMENTAL PROTECTION

In 

### the matter of ) ) 

### The State ofConnecticut ) ) 

### and ) ) The Connecticut Resources Recovery Authority ) ) 

### Trading Agreement and Order No. 8116B

Whereas, the Commissioner ofEnvironmental Protection ("Commissioner") and the Connecticut 

### Resources Recovery Aut}1ority ("eRRA") 

### agree that it

### is in the public interest thatthey work cooperatively to improve the airquality within the State ofConnecticut and that the use ofdiscrete 

### emission reduction credit ("DERC") trading to reduce nitrogen oxide ("NOx") emissions will 

### achieve this resultin atimely and cost-effective manner.

A. At the request and with the agreement ofCRRA. the Commissionerfinds the following: 

### ;: , . I. This Trading Agreement and Order supersedes Trading Agreement and Order 8116A 

### signedby the Commissioner on March 18,2003.
2. CRRA is a public instrumentality and political subdivision ofthe State ofConnecticut established to provide solid waste management services to Connecticut's municipalities located at Reserve-Maxim Roads, Hartford, Connecticut ("facility"). 3. At the facility, CRRA owns and operates fuel burning equipment which consists ofeight (8) combustion turbines ("peaking units") which are subject to section 22a-174-22 ofthe Regulations ofConnecticut State Agencies ("Regulations") pertaining to the control of NOx emissions. 

### 4. On the dates**provid~d** 

### in Table I ofthis Trading Agreement and Order, CRRA perfonmed NOx stack emission testing approved by the Commissioner. 

### 5. CRRA exceeds the NOx allowable emission rate 

### limit specifiedin Section 22a-174-22(e) ofthe Regulations as shown in Table 1 ofthis Trading Agreement and Order.

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### The Connecticut Resources Recovery Authority 2 

### Trading Agreement and Order No. 8116B

Table 1 NUx RAT"'" AND ABLE**LL"'I1T~** (Ibs/MMBru) Fuel Burning FUEL FLER NOx Stack Test Date of NextStack EquipmentJ (IbsIMMBru) Allowable Rate Stack Test Registration.No. Rate (IbsIMMBru) Test Due ObsIMMBru) Date 11A !**N~.** Zor 0.79 11130104 11130109 other R260 distillate oil 0.81 0.289 liB No.2 or 0.70 11130104 11130109 R261 other distillate oil 0.81 0.289 12A No.2 or 0.76 1211104 1211/09 R262 other distillate oil 0.81 0.289 

### . 12B No.2 or 0.68 1211104 1211109 R263 other distillate oil 0.81 0.289 13A No.2 or 0.80 1212104 1212109 R264 om", distillate oil 0.81 0.289 BB 

### . No.2 or 0.77 1212104 1212109 R265 om", distillate oil 0.81 0.289 14A No.2 or 0.80 1213/04 1213/09 R266 other distillate oil 0.81 0.289 14B No.2 or 0.68 1213/04 1213/09 R267 other distillate oil 0.81 0.289 

### 6. Pursuant to Section 22a-174-22U) ofthe Regulations CRRA proposes to comply with 

### Section 22a-174-22(e) ofthe Regulations, forthe peakingunits' emissions, through the use ofapproved DERCs until May I, 2007 at the facility in accordance with this Trading Agreement and Order. - i B. 

### The Commissioner, in accordance with the provisions ofthis TradingAgreement and Order, pursuant to Subdivision 22a-174-22(j) ofthe Regulations, hereby allows CRRA to comply with Section 22a-174-22 ofthe Regulations, at the facility, through use ofDERC and Budget emission reduction 

### credits ("BDERC'') trading. 

### C. Therefore, with the agreementofCRRA, the Commissioner, acting underConnecticut General Statutes Sections 22a-6, 22a-171, 22a-174, 22a-176 and 22a-177, hereby orders CRRA as follows: 1. 

### Upon issuance ofthis Trading Agreement and Order, at the facility, CRRA shall comply with Section 22a-174-22 ofthe Regulations through emission reduction trading until the peaking units achieve pennanentcompliance with the emission scandard in Section 22a174-22(e) ofthe regulation orby May 1, 2007, whichever occurs earlier, as follows:

### The ConnecticutResources ,-:--... Recovery Authority f·

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### 3 Trading Agreement and Order No. 8116B

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## .- a. CRRA shall use approved DERCs as required under this Trading Agreement and Order; b. CRRA shall have in,its possession sufficient approved DERCs to 

### meet applicable NOx emission limits as allowed under this Trading Agreement and 

### Order, and

c. CRRA shall comply during operation ofeach peaking unit with the FLERs shown in Table I ofthis Trading Agreement and Order. 2. DERC use for the Peaking Units.

a. Until May I, 2007, before the Ii"t day ofeach month CRRA shall have in its possession sufficient approved DERCs for such month for the peaking units based on the 

### following calculations; Before the Ii"t day ofeach month, CRRA shall estimate DERCs required for such month for the peaking units 

### as follows; (i) At all times: Estimated DERCs (in tons) use; [«(FLER 

### in IbslMMBtu)

- (0.95 x NOx allowable rate in IbsIMMBtu» x (estimated fuel use in MMBtu)]

.. 2000 pounds/ton No laterthan**th~** 

### twentieth day ofeach month, CRRA shall calculate and permanently retire DERCs used in the precedingcalendarmonth, as follows: Actual DERCs (in tons); [«(FLER in IbslMMBtu)

- (0.95 x NOx allowable rate in IbsIMMBtu» x (actual fuel use in MMBtu)]

.. 2000 pounds/ton Where:

• NOx allowable rate ; allowable limitrate in IbsIMMBtu shown in Table I ofthis Trading Agreement andOrder.

• FLER ; full loademission rate in IbsIMMBtu as shown in Table I ofthis Trading Agreement and Order.

• Discount (0.95) ; 5% design margin applied to the allowable limitrate. (ii) 

### During the ozone season onlv: No laterthan December31 $1 

### each year, CRRA shall acquire and permanenrly retire seven ozone season DERCs for every actual ton ofexcess NOx emiued from the peaking units during the previous ozone season based upon the actual emissions for each day that Connecticutone hourozone levels were forecasted to be "moderate to 

### unhealthful", "unhealthful", or "very unhealthful", until such time that the EPA revokes the l·hour**s~andard.** 

### Upon such revocation, CRRA shall calculate and pernlJnently retire seven ozone season DERCs for every actual ton ofexcess NOx emitted from the

### peaking units during such ozone season based upon the actual emissions for each day that Connecticuteight hour ozone levels were forecasted to be "unhealthy for sensitive groups", "unhealthy", or "veryunhealthy". The Connecticut Resources Recovery Authority 4 

### Trading Agreement and Order No. 8116B**~J;**



### Where: Actual ton ofexcess NOx emitted: [((FLER 

### in IbslMMBtu)

- (0.95 x NOx allowable rate in IbslMMBtu)) x (actual fuel use in MMBtu)] .;. 2000 pounds/ton 

### The total actual tons ofexcess NOx emitted from the peaking units during forecasted ozone exceedance days shall be multiplied by seven and then rounded to the nextgreater whole ton, to determine the number ofDERCs to be pennanently retired. This requirementis in addition to the CRRA's requirement to estimate excess emissions and subsequentpennanentretirementofasufficientnumber ofapprovedDERCs in accordance with paragraph C.2.a.(i) ofthis Trading Agreement and Order. 

### b.

c. 

### During the non·ozone season: Until May 1, 2007, from October 1 through April 

### 30, inclusive, each year, the peaking units shall, in addition to meeting the 24-hour emissiQn limitin Table 22·1 ofSection 22a-174-22 ofthe Regulations, meet a non-ozone season emission limit of0.15 IblM:MBtu. Prior to October 1, 2004, October 1, 2005 and October 1, 2006, CRRA shall estimate and acquire the amount ofDERCs orallowances required for such non-ozone season to comply with Section 22a-174-22(e)(3) ofthe Regulations as follows: Estimated DERCs (tons) use: [Estimatedfuel use in MMBtu from October 1 through April 30 x (allowable emission rate in IbsIMMBtu

- (0.95 x 0.15IblMMBtu))].;. 2000 lbslton No laterthan May 31 of2005,2006 and 2007, in addition to 

### the DERCs retired pursuant to paragraph C.2.a. ofthis Trading Agreement and Order. CRRA shall calculate and 

### permanently retire DERCs used in the preceding non-ozone season as follows: Actual DERCs (tons) used: [Actual fuel use in MMBtu from October 1 through April 30 x (allowable emission rate in IbsIMMBtu

- (0.95 x 0.15 lb/MMBtu))j .;. 2000 lbslton 

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,



### 3. 

### BDERCs shall only be used by otherNOx BudgetProgram sources located in Connecticut. BDERCs shall only be used to offset ozone season excess emissions, and shall not be used for compliance during the non-ozone season. BDERCs generated during agiven year shall only be used during the following ozone season. BDERCs are subject to all DERC requirements set forth in this Trading Agreement and Orderexceptfor those requirements penaining solely to non-ozone season DERCs and as otherwise may be provided. 4. CRRA shall make and keep records of: daily fuel use and fuel type; excess NOx 

### emissions; the numbetofDERCs in its possession. purchased and used (by serial number ifassigned) each month in accordance with the appropriate emission rates and limits inTrading Agreement and Order No. 8116B 

### 5 The ConnecticutResources**t~"--'.** Recovery Authority



### ........'".J this Trading Agreement and Order; the number ofDERCs used during the ozone season and non-ozone season (the remainderofthe year); during the ozone season, the ozone classification as forecasted by the Commissioner on the previous day; as well as documentation attesting to the fact that approvedDERCs used during the ozone season were generated during the ozone season. Generatorcertification ofthis fact shall be sufficient. CRRA shall maintain and submit such records to the Commissionerin accordance with Section 22a-174-22 ofthe Regulations. 5. Record Keeping. CRRA shall retain records and supporting documentation as described in this Trading Agreement and Orderfor aminimum offive years, commencing on the date such records were created. CRRA shall maintain documentation to attest to the fact that the DERCs used during the ozone season were generated during the ozone season, generatorcertification ofthis fact shall be sufficient; and provide the records specified above to the Commissioner within thirty (30) days ofreceipt ofa written request from the Commissioner. 6. (a) Annual DERC Reoort. No laterthan March 1 ofevery year afterissuance ofthis Trading Agreement and Order, CRRA shall submit in writing to the Commissioner, arecord ofeach sale orothertransferofDERCs for the previous calendar year. CRRA shall also include actual NOx emissions from the peaking units and the amount ofall DERCs used (including serial numbers (ifassigned) and DERCs purchased from other facilities). These reports shall be on forms prescribedby the Commissioner and shall be in monthly increments, and by ozone and non ozone seasons. (b) Starting on October 1, 2004: No later than July 30 ofevery year after issuance of this Trading Agreement and Order, CRRA shall submitin writing to the Commissionerthe non-ozone season fuel consumption and amount ofall DERCs used (including serial numbers (ifassigned) and approvedDERCs purchased from otherfacilities) for the peaking units during the Octoberthrough April time period in the previous calendar year. These reports shall 

### be on a fonn prescribed by the Commissioner. 7. Allowance Use. Pursuant to Section 22a-174-22(d)(3) ofthe Regulations, CRRA may use NOx allowances, until May I, 2007 for the peaking units pursuant to Section 22a174-22(j) ofthe Regulations to achieve all oraportion ofthe reductions 

### required by section 22a-174-22 oftheRegulations. ·Anyallowance used for compliance with Section 22a-174-22(e) ofthe Regulations shall be subject to all restrictions and/or requirements applicable to DERCs contained in this Trading Agreement and Order;

a. 

### In order for CRRA to use NOx allowances, CRRA shall create a general account or use an existing compliance account or overdraft account in EPA's NOx Allowance Tracking System ("NATS"); and b. Each allowance used for compliance with Section 22a-174-22 ofthe Regula;ions shall be equivalent to one discrete emission reduction credit. Allowances shall be considered used for compliance with Section 22a-l74-The Connecticut Resources Recovery Authority 

### 6 Trading Agreement and Order No. 8116B 22 ofthe Regulations when they are transferred from the facility's NOx general account in the NATS or the facility's NOx compliance account in the NATS to the 

## cr State NOx Retirement Account (Account ID 

### crOOOOO00300 in the NATS). 8. DERC Shomall. At a minimum, DERCs required shall be adjusled upwards by 

### 100% ifDERCs are not in CRRA's possession for use priorto the first day ofeach month or applicable season. However, nothing in this Trading**Agree~ent** and Order shall affect the Commissioner's authority to institute any proceeding or take any other action to require additional upward adjustment, based on the gravity ofany alleged noncompliance or violation oflaw. CRRA shall permanently retire the quantity ofDERCs equivalent to the excess emissions plus a 100% premium within sixty (60) days ofCRRA's discovery ofthe DERC shomal!. CRRA shall certify andreport any suchDERC retirement to the Commissionerin accordance with paragraph C.30. ofthis Trading Agreement and Order. 9. Vintage Restriction. For the purposes ofcompliance with Section 22a-174-22 ofthe Regulations, DERCsiallowances shall only remain valid for five (5) calendar years from the yearofthe generation/allocation ofsuch DERCsiallowances. DERCsiallowances older than five (5) calendar years from theircreation/allocation are not valid for use for .compliance with Section 22a-174-22 ofthe.Regulations. Notwithstanding the above, DERCsiallowances generated/allocated prior to calendar year 2000 are valid for use for compliance with Section 22a-174-22 ofthe Regulations up to and includingDecember 31,2004. 10. R..ER Exceedance. Noncompliance with an established FLER shall subject CRRA to make restitution by matching the quantity ofemissions ("true up") caused by the exceedance plus a 100% premium. The true up in tons ofDERCs shall be equal to the FLER exceedance in lbsJM:11Btu, multipliedby the total heat input during the period of noncompliance divided by 2000 lbslton. 

### If the period ofnoncompliance is not known, the time period from the completion ofthe last/previous Commissioner witnessed emission test through the date the FLER compliance is achieved as approved by the Commissioner shall be used However, nothing in this Trading Agreement and Order shall affect the Commissioner's authority to institute any proceeding or take any other action to require additional upward adjustment, based on the gravity ofany alleged noncompliance or violation oflaw. CRRA shall permanentlyretire DERCs calculatedin accordance with the above plus a 

### 100% premium within sixty 

### (60) days ofCRRA's discovery ofthe FLERexccedancc. CRRA shall report any 

### FI.ER exceedance to the Commissionerin accordance with paragraph C.30. ofthis Trading Agreement and Order. 

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11. FLER Modification. FLERs set forth in Table 1 ofthis Trading Agreement and Order may be modified only after the consent ofthe Commissionerby written modification of this Trading Agreement and Order. 12. Emissions Testing. Pursuant to Section 22a-174-22(k) ofthe Regulations CRRA shall conduct NOx emission tests ofthe peaking units at least once every five years commencing from the dates ofthe emission tests for the peaking units as provided in Table 1 ofthis Trading Agreement and Order. 

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### The ConnecticutResources <''-..1 

### Recovery Authority

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### 7 Trading Agreement and OrderNo. 8116B 13. Extension. No later than May 1, 2007, with respect to the peaking units, CRRA shall comply with the requirements ofSections 22a-174-22(d)(I) and 22a-174-22(d)(2)(A) of the Regulations. There is no assurance that afterfull programreview ofthis and other Trading Agreements and Orders that the Commissionerwill grant a written extension of this Trading Agreement and Order. 14. Future Compliance RepoIt. On orbefore September I, 2006, CRRA shall submit a repoIt indicating how the facility shall comply with Section 22a-174-22 ofthe Regulations with respect to the peaking units on and afterMay 1,2007. 15. Full compliance. CRRA 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. 16. Approvals. CRRA shall use bestefforts to submitto the Commissioner 

### all documents required by this Trading Agreement and Orderin acomplete and approvable form. If

### the Commissionernotifies CRRA that any document or other action is deficient, and does not approve it with conditions ormodifications, itis deemed disapproved, and CRRA shall correct the deficiencies and resubmit it within the time specifiedby the Commissioneror, ifno time is specifiedby the Commissioner, within 30 days ofthe Commissioner's notice ofdeficiencies. In 

### approving any document or other action under this Trading Agreement and Order, the Commissionermay approve the document or other action as submitted orperformed orwith such conditions ormodifications as the Commissionerdeems necessary to carry outthe purposes ofthis Trading Agreement and Order. Nothing in this paragraph shall excuse noncompliance or delay, 17. Definitions. As used in this Trading Agreement and Order, "ApprovedDERCs" are those for which the Commissionerhas provided written authorization for use in compliance with Section 22a-174-22 ofthe Regulations; "Commissioner" means the Commissioneror a representative ofthe Commissioner; "Non-ozone season" means the period from October 1 through April 30 in any given calendaryear; "Ozone season" means the period from May 1 through September 30 in any given calendaryear.

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### 18. Dates. The date of"issuance" ofthis Trading Agreement and Orderis the date the Trading Agreement and Orderis deposited in the U.S. mail orpersonally delivered, whicheveris earlier. The date ofsubmission to the Commissionerofany document requiredby this Trading Agreement and Ordershall 

### be the date such document is receivedby the Commissioner. The date ofanynotice by the Commissionerunder Trading Agreement and Order, including but not limited to notice ofapproval or disapproval ofany document orother action, shall be the date such notice is deposited in the U.S. mail oris 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 calendarday. Any document or action which is required by this Trading Agreement and Order to 

### be submitted orperformedby adate which falls on a Saturday, Sunday or a Connecticutorfederal holiday shall be submitted orperfonned by the next day whi:h is not a Saturday, Sunday or Connecticut orfederal holiday.19. Certification ofdocuments. Any document, including but not limited [0 any notice, which is required to be submitted to the Commissionerunder this Trading Agreement and Order shall be signed by CRRA or, ifCRRA is not an individual, by Respondent's chief executive officeror a duly authorized representative ofsuch officer, as those terms are defined in §22a-430-3(b)(2) ofthe Regulations ofConnecticut State Agencies, and by the individual(s) responsible for actually preparing such document, and CRRA or CRRA chiefexecutive officer and each such individual shall certify in writing as follows: The Connecticut Resources Recovery Authority 

### 8 Trading Agreement and OrderNo. 8116B 

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"1 have personallyexamined and am familiar with the information submitted in this document and all attachments thereto, and 1certify, 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. 1understand that any false statement made in the submitted information is punishable as a criminal offense under §53a-157b ofthe Connecticut General Statutes and any other applicable law." 20. Noncompliance. This Trading Agreement and Orderis a final order ofthe Commissioner with respect to the matters addressed herein, and is nonappealable and immediately enforceable. Failure to comply with this Trading Agreement and Ordermay subject .CRRA to an injunction and penalties. 21.

22.

23.

24. False statements. Any false statementin anyinformation submitted pursuant to this Trading Agreement and Orderis punishable as a criminal offense under §53a-157b ofthe Connecticut General Statutes and any otherapplicable law. Notice oftransfer; liability ofCRRA. Until CRRA has fully complied with this Trading Agreement and Order, CRRA shall notify the Commissionerin wtiting no laterthan 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 or after obtaining a new mailing or location address. CRRA's obligations under this Trading Agreement and Order shall not be affected by the passage oftitle to anypropeny to any other person or municipality. 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 orabate pollution, recovercosts andnatural resource damages, and to impose penalties for past. present, orfuture violations oflaw. 

### Ifat any time the Commissionerdetermines that the actions taken by CRRA pursuant to this Trading Agreement and Orderhave not successfullycorrected 

### all violations, fully characterized the extent or degree ofany pollution, or successfully abated or prevented pollution, the Commissioner may institute any proceeding to require CRRA to undertake further investigation or further action to prevent or abate violations or pollution. CRRA's obligations underlaw. Nothing in this Trading Agreement and Order shall relieve CRRA ofother obligations under applicable federal, state and local law. 

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... 25. No assurance bv Commissioner. No provision ofthis Trading Agreemen( and Order and no action or inaction by the Commissioner shall be construed [0 constitute an assuranceThe Connecticut Resources /':'"":,. Recovery Authority r':

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### 9 Trading Agreement and Order No. 8116B by the Commissioner that the actions taken by CRRA pursuant (0 this Trading Agreement and Order will result in compliance or prevent or abate pollution. 26. Access to facility. Any representative ofthe Department ofEnvironmental Protection may enter the facility without prior notice for the purposes ofmonitoring and enforcing the actions required or allowed by this Trading Agreement and Order. 27. No effect on rights ofotherpersons. This Trading Agreement and Order neither creates nor affects any rights ofpersons or municipalities that are not parties to this Trading Agreement and Order. 28. No Creation ofProperty Rights. This Trading Agreement and Order does not create any propertyrights with respect to those DERCs. 29. Notice to Commissioner ofchanges. Within 15 days ofthe date CRRA becomes aware ofa change in any information submitted to the Commissioner under this Trading Agreement and Order, or that any such information was inaccurate or misleading or that anyrelevant information was omitted, CRRA shall submit the correct or omitted information to the Commissioner. (' 30. Notification ofnoncompliance. In the event that CRRA becomes aware that it didnot or may not comply, or did not or may not comply on time, with any requirement ofthis Trading Agreement and Order or ofany documentrequired hereunder, CRRA shall immediately notify by telephone the Unit identified in the next paragraph and shall take all reasonable steps to ensure that any noncompliance ordelay is avoided or, if unavoidable, is minimized to 

### the greatest extent possible. Within five (5) days ofthe initial notice, CRRA 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 which compliance will be achieved, and CRRA shall comply with any dates which may be approved in writing by the Commissioner. Notification by CRRA shall not excuse noncompliance ordelay, and the Commissioner's approval ofany compliance dates proposed shall not excuse noncompliance or delay unless specifically so stated by the Commissionerin writing.

..,. 31. Submission ofdocuments. Any docwnent required to be submitted to the Commissioner underthis Trading Agreement and Ordershall, unless otherwise specified in this Trading Agreement and Orderorin writing by the Commissioner, be directed to: Emissions Trading Unit Compliance andField Operations Division 5th Floor Bureau ofAirManagement Department ofEnvironmental Protection 79 Elm Street Hartford, Connecticut 06106

### CRRA consents to the issuance ofthis TradingAgreement and Order withoutfurther notice. The undersignedcertifies thathe/she is fully authorized toenterinto this TradingAgreementandOrder and to legally bind CRRA to 

### the tenns andconditions ofthe Trading Agreement and Order. The Connecticut Resources 

### Recovery Authority

Signature: . 

### Type Name: 10

Floyd M Gent 

### Trading Agreement and 

### OrderNo. 8116B 

### A V

Type Title: Date: Director of Operations



### Issued as afinal Orderofthe CommissionerofEnvironmental Protection.

Date

MAll.ED 

### CERIIFIED MAIL, RETURN RECEIPT REQUES1ED

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