# STATE OF CONNECTICUT DEPARTMENT OF ENVIRONMENTAL PROTECTION

In 

### the maner of The State ofConnecticut and 

# , United Technologies Corporation 

### Trading Agreement and OrderNo. 8134A



### .. Whereas, the Commissioner

### ofEnvironmental Protection ("Commissioner") and The United Technologies Corporation, through its Pratt and WhitneyDivision (''P&W'') 

### agree that 

### it is in the public interest that theywork cooperatively to improve the air qualitywithin the State ofConnecticut and that the use ofdiscrete emission reduction credit ("DERC") trading to reduce nitrogen oxide (''NOx'') emissions 

### will achieve this result in atimely and cost·effective manner:
A. 

### At 

### the request and with the agreement ofP&W, the Commissionerfinds the following:
1. 

### P&W is acompany which 

### owns and operatesjet 

### engine manufacturing facilities at 400 Main Street, EastHartford, Connecticut ("facility I") and Aircraft Road, Middletown, Connecticut ("facility 2") and ajet engine research facility at Pent Road, EastHartford, Connecticut ("facility3").
2. At facility I, P&W owns and operates three (3) dual-fuel burning boilers, numbered 6, 8, and 9 ("facility 1 boil"""), capable ofburning natural gas

.or No.6 fuel oil. At facility 2, P&W owns and operates four (4) No.6 fuel oil burning boilers, numbered 1,2,3 and 4 ("facility 2 boilers") andjet fuel burningproduction GG-8 gas turbine engines ("facility 2 engines"). 

### At facility 3, P&Wowns and operates production GG-8 gas turbine engines, capable ofburning eithernatural gas orjet fuel ("facility 3 

### engines"). At facility 2and facility 3, similarproduction GG-8 gas turbine engines are tested in test cells. The facility 1boilers, facility 2 boilers, facility 2 engines and facility 3 engines are subject to Section 22a-174-22 ofthe Regulations ofConnecticut State Agencies ("Regulations"), pertaining to the control 

### ofNOxemissions.
3. Official U.S. Environmental Protection Agency ("EPA'1 Reference 

### Method 7 emission testingperfonned on February 6,7 and 9, 1996, February 20 and 21, 2001 and January 15, 2002 on facility 1 boilers;

(Printecl on Recyclecl P.pel) 79 Elm Street • Hu-:forcl, CT 06106. }127 b::;»:/lclep.stlte.CLIIS AI: Eql.lcl OppOrfl.lni:y Employe'

### United Technologies Corporation 2 

### Trading Agreement and OrderNo. 8134A January 10 through January 12,1996, January Sand 8, 2001, and March 16,2001 on facility 2 boilers; May I, 1996 and April 18,2001 on a facility 2 engine; and July 28, 1998 on a facility 

### 3 engine (for natural gas only), 

### resulted in NOx emission rates as shown in Table 1below: TABLE I FJeitity/ DEP I Fuel Hcat 1996 and 

## '88l'"' RACl' Equip-ment Rea:is
## W~t 1998 rate nbl !ratioN EminioR

## ~mlt'· MMBtll Pcrmit 

### T'" TestR.ate lOR est ucept 

### ",. hr)- (lblMMBtu Rafe where max- ucep! where**~~MM** otberwise imum otherwise ucep! Roted) raled Iloted) When other.**wiS~'1\** IlDted Facili!)' 1- R39 Noc 169 0.150 OA13" 0.10 Boilerno. 6 

# ,

# .. Mi oil 163 0.321 n 0.465'· 0.15 Facility I- R4' NaL 188 0.293" 0.28 n 0.10 Boiler no. 8 

# ,

# .. #6 oil IS8 0.438·· 0.507" 0.25 Facility I - R42 Nat. 188 0.352-- 0.30·· 0.10 Boiler no. 9 

# ,

# .. :; 6oil '88 0.444·· 0.623·· 0.15 Facility2- RIS 

# I #6 oil IS' 0.326·· 0.29·' 0.25 Boiler no. I Facility2- 

# I R16 

# I #6 oil IS' 

# I 0.306'" 0.33" 0.15 Boilerno. 2 Facility2 - 

# I P2' #6oiJ 18' 0.343" 

# I 0.38.... 0.15


# . Boilerno. 3 Facility2- P36 #6 oil 61 0.378.... 0,43" 0.25 Boiler no. 4**Fac~Jjty** 2- P62 Jet fuel 260 380 423 75 engme ppmvd" ppmvd"· ppmvd Fac!lity3- El NaL 283 26 ppmvd NA 55 mgme 

# ,

# .. 423 ppmvd Jet fuel 380 7J ppmvd.... ppmvd.... ppmvd



## • "Reasonably Avai1abJe Control Technology"



### ** Indicates that emission rate for the specified piece ofequipmentand fuel type is in 

### excess ofthe 

### emission rates specified in 

### Section 22a-174-22, Table 22-1, ofthe Regulations.
Note: To establish the full load emission rate ("FLER") for the facility 2 and

### United Technologies Corporation 3 

### TradingAgreement and Order No. 8134A facility 3 engines, one engine was tested at facility 2, and one engine was tested at facility 3. The facility 2 engine emission testing result was also used as the test result for afacility 3 engine onjet fuel.
4. On and after May 31, 1995, Se<:tion 22a-174-22(e) ofthe Regulations requires that the facility 1 boilers, facility 2 boilers, facility 2 engines, and the facility 3 

### engines emitNOx at rates no greater than theRACT rates shown 

### in Table I above. P&

### Wproposes .to useapproved DERCs for compliance purposes at facility 1, facility 2 and facility 3, when and ifP&W chooses to operate the 

### facility 1boilers, facility 2boilers, facility 2 engines, and facility 3engines on fuels that exceed the RACT rates shov.rn in 

### Table 1above. 5. Pursuantto Section 22a.174.22(j) ofthe 

### Regulations, P&W 

### acquired the following amounts ofapproved DERCs as shown in Table 2 below:

TABLE 2 

### Date Ozone Season DERCs Non-ozone season DERCs 9/28/95 

### 36 tons 28 tons 1/29/96 29 tons 

### 30 tons 4/29/96 50 tons 

### 50 tons 1110/97 

# otons 50 tons
12110/97 

# otons 30 tons 2/01/00 

### 50 tons 100 tons
1130/02 60 tons 

### 90 tons
6. Approved DERCs are defined for thepurpose ofthis Trading Agreement and 

### Order as those for which the Commissionerhas provided written authorization for use in compliancewith Se<:tion 22a-174-22 ofthe Regulations. 

### 7. Section 22a-174-22(k) ofthe 

### Regulations requires that emission testing be conducted when the source is operating at or above 90% ofmaximum rated capacity ("MRC"). During year 2001 emission testing, P&W 

### operated facility 1 boilerno. 6 at 82% ofMRC on both no. 6fuel oil and natural gas, facility 1 boilerno. 8 at 85% ofAfRC on natural gas and 87% ofMRC on no. 6fuel oil, facility 2boilerno. 1at 49% ofMRC on no. 6fuel oil, facility 2boilerno. 2at

### United Technologies Corporation 4 Trading Agreement and Order No. 8134A 

### 61 %ofMRC on no. 6 fuel oil, facility 2boilerno. 3 at 47% ofMRC on DO. 

### 6 fuel oil; and facility 2 boilerno. 4 at 84% ofMRC on no. 6 fuel oil. Duringyear 2002 emission testing, P&W operated facility 1boiler no. 9 at 85% of:MRC on natural gas and 84% ofMRC on no. 6 fuel oil. 8. P&W has agreed to accept the following heat input and steam output operating restrictions, onl

### the facility 1boilers and facility 2 boilers: 

# , TABLE 3 

## IJ:!eat mput limnanon 

# I:>team**~oduclton** Itmllallon (lbs

### ~ruIbr) steamlhr FacitllY I BOller no. I> 

# I**~atural** gas 143 

# I**125,~2~** No.6 fuel oil 144 130,000 Facility I

. HOlier no. 8 

# I**~atural** gas 171**130,~~~** No.6 fuel oil 182 135000 Faclltty 1

. BOlier no. 9 

### atural gas . 165 130,000 No.6 fuel Oil 171 135,000 

### FacIlirv 2 oiler no. 1 5 59AOe 

### FacIlIty 2 Ollerno. 

### 2 lUI> 

### 73.334 raciJitv

### 2- oilerno. 3 7 n,IUC 

### FacllIty2 Ollerno. 4 57 36.886


### 9. This Trading Agreement and Order supersedes Trading Agreement and OrderNo. 8134, issued on January 24,2000,



### B. The Commissioner, in**acco~dance** 

### with theprovisions ofthis 

### Trading Agreement and Order, and pursuant to Section 22a-174-220) oithe Regulations, hereby allows P&W to comply with Section 22a-174-22 oithe Regulations through the use oiDERC trading 

### referenced in Section A herein, to achieve theNOx emission reduction required by Section 22a-174-22(d)(I) oithe Regulations, 

### C. With the agreement ofP&W, the Commissioner, acting under Sections 22a-6, 22a-171, 22a-174, 22a-176, and 22a-l77 oithe Connecticut General Statutes, orders P&W as ioliows:
I. AfterMay 31,1995, and through April 30, 2007 or until P&W achieves compliance with the emission standards in Section 22a-174-22(e) oithe 

### Regulations, whichever occurs earlier, P&W shall acquire and retire approved DERCs and shall document and record the amounts oiall fuel and DERCs used 

### by the facility 1boilers, facility 2 boilers and engines, and the facility 3 engines each month, and provide such records in accordance with the following and Section 22a-174-22 ofthe 

### Regulations;United Technologies Corporation 5 Trading Agreement and Order No. 8134A

a. Document that sufficient approved DERCs are available for the facility 1 boilers, the facility 2 boilers, the facility 2 engines and facility 3 engines no later than the first ofeach calendar month to assure compliance for, at a minimum, that calendarmonth. At a minimum, DERCs required shall be adjusted upwards by 100% ifDERCs are not in P&W's possession prior to the first day ofeach month; 

## , b. No later than the tenth day ofeach month, calculate DERCs used in the preceding calendar month for each boiler and engine, as follows:
BoilerDERCs (tons) [fuel use inMMBru x (FLER in IblMMBru- (0.95 x RACT rate in IblMMBru))) ) 2000 pounds/ton; Engine DERCs (tons) = [(Hours ofOperation x FLER in lblhr)

- (fuel use in MMBru x (0.95 x RACT rate in IblMMBtu))J ) 2000 pounds/ton;
Where:
X RACT rate = RACT rate shown in Tables 1 and 4 ofthis Trading Agreement and Order.
X FLER full load emission rate shown in Table 4 ofthis Trading Agreement and Order.
X 0.95 '" 5% design margin applied to the RACT rale.

c. Document and record monthly consumption offuel and DERCs;
d. No later than March 1, ofeach year this Trading Agreement and Order is 

### in effect, include 

### with its annual emissions statement report to the Commissioner, the monthlyrate offuel consumption for each boiler and engine and DERCs used by each boiler and engine for the previous calendar year;

e. Retain records and supporting documentation as described in this section for a minimum offive years, commencing on the date such records were created; 

### f. Maintain documentation to attest to the fact that DERCs used during the ozone season were**gener~ted** during the ozone season. The ozone season

### United Technologies Corporation 

### 6 Trading Agreement and Order No. 8134A 

### is from May Ithrough September 30 in anycalendar year. Generator cenific2tion ofthis fact shall be sufficient;
g. 

### Providethe records specified 2bove to the Commissioner within thiny 

### (30) days ofreceipt ofawritten request from the ComIJ'ljssioner;
h. Pursuant to Section 22a-174-22(d)(3) ofthe Regulations, Respondent mayUse NOx allowances, through April 

### 30, 2007, pursuant to 

### Subsection (j) ofSectioD 22a-174-22 ofthe Regulations to achieve all or a

### portion ofthe 

### reductions required 

### by Section 22a-174-22 ofthe 

### Regulations. AIly 

### allowance used for compliance with Section 222-174- 22(e) ofthe Regulations shall be subject to all restrictions andlor 

### requirements applicable to DERCs contained 

### in this Trading Agreement and Order;

J. In 

### orderfor Respondent to use 

### NOx allowances, Respondent shall create a general accouot 

### in EPA's NOx Allowance Tracking System (''NATS'1; and
J. 

### Each allowance 

### used for compliance with 

### Section 22a-174-22 ofthe 

### Regulations shall be equivalent to one discrete emission reduction credit. Allowances shall be considered used for compliance with 

### Section 2220- 174-22 ofthe RegUlations when they are transferred from the facility's NOx general accouot 

### in the NATS to the CT State -Ox Retirement Accouot (Accouot ill CTOOOOO00300 

### in the NATS).
2. 

### Prior to May 1, 2007 P&W 

### shall comply during operation on the fuels shown in Table 4 below with the enforceable maximum FLERs shown 

### in Table 4 below, averaged on a 

### 24-hour basis:

### United Teclmologies Corporation 

### 7

TABLE 4 Trading Agreement and Order No. 8134A

Facility! FLER FLER FLER FLER RAeT rate Equip- Fuel (lblMMBtu (IblMMBtu (lblM1\1Btu (lb/iVL'\ffilU (lblM.'\1Btu ment except where except where except except except where otherwise othenvise where where otherwise noted) from noted) MaytH,1995 noted) from otherwise othenvise uo·ti11996 or 1996 or 1998 noted) from noted) as of 1998 emission emission test 2001 or 2002 May I, 2003 test up to emission May 1, 2003 test up to Mav 1. 2003 Facilicy 1 Nat. NA NA 0.42 0.46 0.20

- Boiler gas no. 6 #6 oil 0.33 0.46 0.46 0.5l 0.25

Facilicy 1 Nat. 0.30 0.30 0.30 0.32 0.20

- Boiler gas 0.5l O.5l 0.56 0.25 no. 8 #6 oil 0.45 Facilicy 1 NaL 0.36 0.36 0.36 0.36 0.20

- Boiler gas no. 9 #6 oil 0.45 0.62 0.62 0.65 0.25 Facility 2 #6 oil 0.35 0.35 0.35 0.40 0.25

- Boiler no. 1 Facility 2 #6 oil 0.35 0.35 0.35 0.40 0.25 -Boiler no. 2 Facility 2 #6 oil 0.35 0.38 0.38 0.45 0.25

- Boiler no. 3 Facility 2 #6 oil 0040 0.43 0.43 0.50 0.25

- Boiler no. 4**Facili~** 2 Jet 230lbJbr**230l~ 230l~** **230l~** 

# I 0.292**~5**

- engme fuel ppmvd Facility3 Jet**230l~ 230l~** **230l~ 230l~**  0.292

## W5

- engine fuel ppmvd



### Each facility 2 and facility 3 engine shall comply with the FLER set forth in Table 4 ahove.United Technologies Corporation 

### 8 Trading Agreement and Order No. 8134A
3. No later than May I, 2007, P&W shall comply with the requirements ofSectioD 22a-174-22(d)(l) ofthe Regulations. However, after full program review ofthis and other Trading Agreements and Orders and, 

### ifdetermined to be appropriate, the Commissionermay grant a written extension ofthis Trading Agreement and Order.
4. 

### FLERs.**emi~s10n** testrates and fuels set forth 

### in Tables 1 and 4 maybe modified only after the consent ofthe Commissionerby written modification ofthis Trading Agreement and Order.
5. Noncompliance 

### v.rith an established FLER shall subject P&W to makerestitution by matching the quantity ofemissions ("true up") caused by the exceedanceplus a 100% premiwn. The true up in tons ofDERCs shall be equal to the FLER exceedance in LbslMMBtu, multiplied bythe total heat input during the period ofnoncompliance divided by 2000 lbsfton. 

### Ifthe period ofnoncompliance is not knov.rn, the timeperiod from the completion ofthe last/previous Department witnessed emission test through the date theFLER compliance is achieved as approved bythe 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 orviolation oflaw.
6. Emissiop Tests. In accordance 

### with Section 22a-174-22(k) ofthe Regulations, P&W shall conduct NOx emission tests oftheIacility I boiler.;, facility 2 boilers. facility 2 engines and facility 3 engines at least once every five years. Such NOx emission.tests shall be conducted prior to five years from the date of the last test for each such unit.
7. From the date ofthe most recent NOx emission testS identified in paragraph A.3. and prior to May I, 2007, P&W shall limit the maximum rated capacity of facility 1 boilerno. 6 to 143 MMBtu/hr heat input and 125,000 poundsJhr steam production for gas and 144 MMBtu/hrheat input and 130,000 poundsJhr stearn productioo for no. 6 oil; facility I boilerno. 8 to 171 MMBtu/hrheat input and 130,000poundslhrsteam production on natural gas and 182 MMBtu/hr heat input and 135.000 poundslhrsteam production on no. 6 oil; facility 1 boiler DO. 9 to 165 MMBtu!hr heat input and 130,000poundslhr steam production on natural gas and 171 MMBtu/hrheat input and 135,000poundslhr steam production for no. 6 oil; facility 2 boiler no. 1 to 85 M:MBtu!hr heat input and**59~400** poundslhr steam production on no. 6 oil; facility 2 boiler no. 2 to 106 

### :MMBtuIhr heat input and 73,334 poundslhr steam production on no. 6 oil; facility 2 boiler no. 3 to 97 MMBtuIhr heat input and 78,100 poundslhr steam production on no. 6 oil; and facility 2 boilerno. 4 to 57 M-1\ffitu/hrheat input and 36,886United Technologies Corporation 9 Trading Agreement and OrderNo. 8134A pounds/hr steam production on no. 6 oil. P&W shaII demonstrate compliance with these limitations by monitoring and documenting hourly stearn production. However. ifat any time after the date ofthe most recent emission tests specified in paragraph A.3. during the period that this Trading Agreement and Order remains in effect. P&W is unable to limit maximum rated capacity as stated above, P&W shall conductNOx emissions testing ofthe facility I boilerno. 6, facility I boilerono. 8, facility I boilerno. 9, facility 2 boiler no. I, facility 2 boilerno. 2, facility 2 boilerno. 3, orfacility 2 boilerno. 4 on orbefore sixty (60) days after exceedance ofthe above limits in accordance with the following:

a. P&W shall submit to the Commissioner for his review and written approval an Intent-To-Test ("lIT') protocol not less than thirty (30) days prior to the emissions testing required pursuant to this Trading Agreement and Order. The 

## m protocol shall include at least:
1. The Department ofEnvironmental Protection's Bureau ofAir Management Test FormNo.1, "Intent to Test"; 

# .' 2. System operatingparameters indicative ofproper operation, including, but not limited to, fuel firing rate. NOx emissions rate, temperature and pressure, and steam production rate. The ITT protocol shall provide that Respondent shall perfonn testing as specified in Sections 22a-174-5 and 22a-174-22 ofthe Regulations, including operatingthe facility 1 boiler no. 6, facility I boilerno. 8, facility 1 boilerno. 9, facility 2 boilerno. 1, facility 2 boiler no. 2, facility'2 boilerno. 3, or facility 2 boiler no. 4 at not less than ninety percent (90%) ofits maximum capacitylimit orhighest operating rate since its previous emission test, whichever is higher.
b. Respondent shall perform all testing in accordance with the approved ITT protocol.

c. In conducting and performing therequired testing, and in analyzing the results ofsuch testing, Respondent shall adhere to methods specified in Sections 22a-174-5 and 22a·174-22 ofthe Regulations and as approved bythe United States EPA and the Co=issioner.
d. Respondent shall schedule all emissions testing so as to allow the Commissioner to bepresent during such testing and to independently verify facility operations, 

### airpollution control equipment parameters, and testing procedures.United Technologies Corporation 

### 10 Trading Agreement and Order No. 8134A

e. Within 30 days aftercompleting any emissions testing required by this Trading Agreement and Order, P&W shall submit to the Commissioner a written repon providing the results ofsuch testing; within 15 days ofa notice from the Commissioner indicating any deficiencies in such report, P&W shall submit a revised report. I 8. Emission

# teru required pursuant to paragrapb C.6. ofthis Trading Agreement and Order shall be conducted in accordance 

### With the procedure set forth 

### in paragraph C.7.a. through C.7.e. ofthis Trading Agreement and Order; provided that ifthe facility I boiler DO. 6, facility 1 boiler DO. 8, facility I boiler no. 9, facility 2 boiler DO. I, facility 2 boilerno. 2, facility 2 boilerno. 3, or facility 2 boilerno. 4 is tested at 90% ofits maximum rated capacity, the maximum capaciry limit specified 

### in paragraph 

### C.7. shall no longer apply.
9. VintalZe Restriction. For the purposes ofcompliance with Section 22a-174-22 of tbe Regulations, OERCsiallowances sball onlyremain valid for five (5) calendar years from the year ofthe generation/allocation ofsuch DERCs/allowances. OERCsiallowances olderthan five (5) calendaryears from their creation/allocation are not valid for use for compliance with Section 22a·174-22 ofthe Regulations. Notwithstanding the above, OERCsiallowances generated/allocated priorto calendar year2000 are valid for use for compliance with Section 22a-174-22 ofthe Regulations up to and including December 31, 2004.
10. Aporovals. P&W shall use best effons to submit to the Commissioner all documents required'by this Trading Agreement and Order in a complete and approvable form. lfthe Commissionernotifies P&W that any document or other action is deficient, and does not approve it with conditions or modifications, it is deemed disapproved, and P&W shall correct the 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 

### aDy document orother action under this Trading Agreement and Order, the Commissionermay approve the document or other action as submined orperformed or with such conditions or modifications as the Commissioner deems necessary to carry out the purposes ofthis Trading Agreement and Order. Nothing in tl:l.is paragraph shall excuse noncompliance ordelay.
11. Definitions. As used 

### in this Trading Agreement and Order, "Commissioner" means the Commissioner or arepresentative of the Commissioner; "Ozone season" means the period from May 1 through September 30 in any givenUnited Technologies Corporation 11 Trading Agreement and OrderNo. 8134A
calendar year, and uNOx RACT" means NOx Reasonably Available Control Technology. The date of"issuance" ofthis Trading Agreement and Order is the date the Trading Agreement and Order is deposited in the U.S. mail or personally delivered, whichever is earlier.
12. Dates. The date ofsubmission to the Commissioner ofany document required by this Trading Agrlfement and Order shall be the date such document is received by the Commissioner. The date ofany notice by the Commissioner under this Trading Agreement and Order, including but not limited to notice ofapproval or disapproval ofany document or other action, shall be the date such notice is deposited in the U.S. mail or is personallydelivered, whichever is 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 action which is required bythis Trading Agreement and Order to be submitted or performed by a date which falls on a Saturday, Sunday or a Connecticut or federal holiday shall be submitted or performed by the next day which is not a Saturday, Sundayor Connecticut or federal holiday.
13. Certification ofdocuments. Any document, including but not limited to any notice, which is required to be submitted to the Conunissioner under this Trading Agreement and Order shall be signedbyP&W or, ifP&W is not an individual, by P&W's chiefexecutive officer.or a duly authorized representative ofsuch officer, as those tenns are defined 

### in §22a-430-3(b)(2) ofthe Regulations ofConnecticut State Agencies, and bythe individual(s) responsible for actuallypreparing such document, and P&W orP&W's chiefexecutive officer and each such individual shall certifyin writing as follows: "1 have personally examined and am familiar with the information submitted in this 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 ofmyknowledge and belief. Iunderstand 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."
14. Noncompliance. This Trading Agreement and Orderis a fInal order oftbe Commissioner with respect to the matters addressed herein, and is nonappealable and immediately enforceable. Failure to comply with this Trading Agreement and Order may subject P&W to an injilllction and penalties.
15. False statements. Any false statement in any information submitted pursuant to this Trading Agreement and Order is punishable as a criminal offense illlder §53a157b ofthe Connecticut General Statutes and any other applicable law.United Technologies Corporation 12 Trading Agreement and Order o.8134A

16. Notice oftransfer: liability ofP&W. Until P&W has fully complied with this Trading Agreement and Order, P&W shall notify the Commissioner in writing no later than 15 days aftertransfening all or anyportion ofthe facility, the operations, the site or the business which is the subject ofthis Trading Agreement and Order or afterobtaining anew mailing or location address. P&W's obligations

### Ull.d~ this Trading Agreement and Order shall Dot be affected by the passage oftitle to anypropertyto any other person or municipality.
17. Commissioner's powers. Nothing 

### in this Trading Agreement and Order shall affect the Commissioner's authority to institute anyproceeding or take any other action to prevent or abate violations oflaw, prevent or abatepollution, recover costs and natural resource damages, and to impose penalties for past, present, or future violations oflaw. 

### Ifat any time the Commissioner determines that the actions taken by P&W pursuant to this Trading Agreement and Order have not successfully corrected all violations, fully characterized the extent or dygree of anypollution, or successfully abated orprevented pollution, the Commissioner mayinstitute anyproceedingto require P&W to undertake further investigation or funber action to prevent or abate violations orpollution.
18. P&W's obliszations under law. Nothing in this Trading Agreement and Order shall relieve P&W ofother obligations under applicable federal, state and local law.
19. No assurance bv Commissioner. 0 provision ofthis Trading Agreement and Order and no action.or inaction bythe Commissioner shall be construed to constitute an assurance bythe Commissionerthat the actions taken byP&W pursuant to this Trading Agreement and Order will result in compliance or prevent or abate pollution.
20. Access to facility. Anyrepresentative oftheDepartment ofEnvironmental Protection may enterthe facility without priornotice for the purposes of monitoring and enforcing the actions required or allowed bythis Trading Agreement and Order.
21. No effect on riszhts ofotheroersons. This Trading Agreement and Order neither creates nor affects anyrights ofpersons or municipalities that are not panies to this Trading Agreement and Order.
22. No Creation ofPropertvRie:hts. This Trading Agreement and Order does not create anyproperty rights with respect to these DERCs.United Technologies Corporation 13 Trading Agreement and OrderNo. 8134A
23. Notice to Commissioner ofchanges. Within 15 days ofthe date P&W 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 orthat any relevant information was omitted, P&W shall submit the correct or omitted information to the Commissioner.
24. Notification ofnOncompliance. In the event that P&W becomes aware that it did not ormaynot comply, or did not ormay not comply on time, with any requirement ofthis Trading Agreement and Order or ofany document required hereunder, P&W shall immediatelynotify 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, ifunavoidable, is minimized to the greatest extent possible. Within five (5) days ofthe initial notice, P&W 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 wrinen approval ofthe Commissioner, dates by which compliance will be achieved, and P&W shall comply with any dates which may be approved. in writing by the Commissioner. Notification by P&W shall not excuse noncompliance or delay, and the Commissioner's approval ofany compliance dates proposed shall not excusenoncompliance ordelay unless specifically so stated by the Commissioner

### in writing.
25. Submission ofdocuments. Any document required to be submitted to the Commissionerunderthis Trading Agreement and Ordershall, unless otherwise specified in this Trading Agreement and Order or in writing by the Commissioner, be directed to: Wendy Jacobs Department ofEnvironmental Protection Bureau ofAir Management Emissions and Credit Trading Section 79 Elm Street Hartford, Connecticut 06106-5127

### United Technologies Corporation 14 Trading Agreement and Order No. 8134A



### P&W consents to the issuance ofthis 

### Trading Agreement and Order without furthernotice. The undersigned certifies thathe/she is 

### fully authorized to enter into this Trading Agreement and Order and to legallybind P&W 

### to the terms and conditions ofthe Trading Agreement and Order.



# , United Technologies Corporation

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Issued as afinal order ofthe 

### CommissionerofEnvironmental 

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CITY OFEASTHARTFORD, TOWN OFMIDDLETOWN LAND RECORDS M.tuLED CERTIFIED MAIL, RETURN RECEIPT REQUESTED