STATE OF CONNECTICUT

DEPARTMENT OF ENVIRONMENTAL PROTECTION

State of Connecticut

&

Sikorsky Aircraft Corporation

)

)

)

)

)

Trading Agreement &

Order No. 8293

WHEREAS, the Commissioner ofEnviromnental Protection ("Commissioner") and Sikorsky Aircraft

Corporation ("Respondent") agree that the Commissioner may issue a permit or order to allow

emissions trading in accordance with Section 22a-174-220) ofthe Regulations of Connecticut State

Agencies ("Regulations") as a method of compliance with Section 22a-174-22 ofthe Regulations:

A. At the request and with the agreement ofRespondent, the Commissioner finds the following:

1. This Trading Agreement and Order supersedes Trading Agreement and Order No. 8120A

and all subsequent modifications thereto.

2. Respondent is a corporation that owns and operates a facility involved in aircraft

manufacturing at 6900 Main Street, Stratford ("facility").

3. At the facility, Respondent operates the emission units described in Table 1 below, which

are subject to Section 22a-174-22 ofthe Regulations ofConnecticut State Agencies

("Regulations") pertaining to the control ofNitrogen Oxide (NOx) emissions.

4. For the 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 unit described in Table 1 ofthis Trading

Agreement and Order.

b. Allowance: CAIR NOx Ozone Season allowance originally allocated to a

CAIR NOx Ozone Season unit located in the State of Connecticut, 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 CAIR NOx Ozone Season unit located in the State of Connecticut after the

date of issuance ofthis Trading Agreement and Order.

(Printed on Recycled Paper)

79 Elm Street • Hartford, CT 06106-5127

www.ct.gov/dep

An Equal Opportunity Employer
Sikorsky Aircraft Corporation 2 Trading Agreement & Order No. 8293

c. Discrete Emission Reduction Credit (DERC): a unit that was generated and

approved by the Commissioner in accordance with a Trading Agreement and

Order issued by the Commissioner or generated 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 1 ton of

NOx emissions and may be used for emissions trading in accordance with

Section 22a-174-22(j) ofthe Regulations, subject to the provisions of Part B of

this Trading Agreement and Order.

d. Non-Attainment Area: means the geographic area which has been designated

as nonattainment pursuant 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-Northern New 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 1 ofthis Trading

Agreement and Order that the Respondent shall not cause or allow the

emissions ofNOx from that emission unit to exceed; and that the Respondent

agrees such FLER shall serve as the basis for determining Estimated DERCs

Required, Estimated Allowances Required, Actual DERCs required, and

Actual Allowances Required in accordance with this Trading Agreement and

Order.

f. CArR NATS: means "CArR NOx Ozone Season Allowance Tracking System"

as defined in 40 CFR 96.302.

g. Ozone Season: May 1 through September 30 of each calendar year 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 (Ibs/MMBtu) ._- - ---

UNIT- Heat Stack FLER AEL Date of Date of

reg. or Input Test Rate (lb/mmbtu) (Ib/mmbtu) Last Stack Next Stack

permit no. Fuel (MMBtu) Test Test

BoilerNo. 1 No.6 oil 48.0 0.379 0.39 0.25 5/16/2005 5/17/2010

R178-0019

Boiler No.2 No.6 oil 48.0 0.289 0.34 0.25 5/16/2005 5/1712010

R178-0018

Boiler No.3 No.6 oil 48.0 0.322 0.35 0.25 5/16/2005 5/17/2010

R178-0017

Boiler No. 4 No.6 oil 48.0 0.319 0.33 0.25 5/16/2005 5/17/2010

R178-0016

Boiler NO.5 NO.6 oil 49.5 0.325 0.35 0.25 9/2/2005 913/2010

P178-0039

.. -- --
Sikorsky Aircraft Corporation 3 Trading Agreement & Order No. 8293

5. The Respondent agrees that the actual NOx emissions rate from the emission units

described in Table 1, when buming the corresponding fuels exceeds the corresponding

AELs.

6. Pursuant to Section 22a-174-22(j) ofthe Regulations, Respondent proposes to comply with

Section 22a-174-22(e) ofthe Regulations, when operating the emission units described in

Table I and buming the corresponding fuels by means of emissions trading in accordance

with the provisions ofthis Trading Agreement and Order.

7. Respondent proposes to use a full load emission rate ("FLER") identified in Table 1 for the

purposes of calculating DERCs and allowances required.

The Commissioner, in accordance with Section 22a-174-22(j) ofthe Regulations hereby allows the

Respondent to comply with Section 22a-174-22 ofthe Regulations at the facility through the use of

emissions trading, subject to the provisions ofthis Trading Agreement and Order.

B. With the agreement ofRespondent, the Commissioner, acting under Sections 22a-6, 22a-174, 22a176, and 22a-177 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 of expiration ofthis Trading

Agreement and 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 that the

Respondent is no longer allowed to use emissions trading due to the

Respondent's violation of any 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 detennined the use of emissions trading

as a compliance option has been further restricted, modified or nullified by:

(i) the promulgation of an Act, Statute, or Regulations; or

(ii) the issuance of a judgment or court order.

2. Respondent shall obtain and use sufficient DERCs and/or Allowances 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 unit that is within the same ozone nonattainment area as the

Respondent. All Allowances used by the Respondent must be for the current vintage year.
Sikorsky Aircraft Corporation 4 Trading Agreement & Order No. 8293

All DERCs used during the Ozone Season, shall have been generated during an Ozone Season

by the operation of an emission unit that is not a CAIR NOx Ozone Season unit, as defined in

Section 22a-I74-22c ofthe Regulations.

3. Prior to using Allowances in accordance with Paragraph B.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 of compliance with Section 22a-174-22 ofthe

Regulations and the provisions ofthis Trading Agreement and Order, DERCs shall only

remain valid for five (5) calendar years from the year ofthe generation ofsuch DERCs.

DERCs older than five (5) calendar years from their creation are not valid for use for

compliance with Section 22a-I74-22 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 1 ofthis Trading Agreement and Order to exceed the corresponding

FLERs. Compliance with the corresponding FLERsspecified in Table 1 shall be detennined

based on the results of emissions testing performed in accordance with Section 22a-I 74-22 of

the Regulations or NOx emissions monitored and recorded by a continuous emissions

monitoring system that was approved by the Commissioner and that complies with Section

22a-174-4 ofthe Regulations and either 40 CFR60, 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 or co-firing the lowest

NOx emitting fuel type or combination offuel types that the units are authorized to bum in

accordance with Departmental permit, registration, or applicable regulation.

7. Notwithstanding Paragraph B.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, if either:

a. the availability offuel oil that complies with Paragraph B.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 of gaseous 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 of each calendar month, the Respondent shall

possess a quantity of DERCs and/or Allowances that equals or exceeds the quantity ofActual

DERCs Required and/or Actual Allowances Required in that month. Compliance with

Paragraph B.8 ofthis Trading Agreement and Order shall be determined as follows:
Sikorsky Aircraft Corporation 5 Trading Agreement & Order No. 8293

a. Before the first day of each month, Respondent shall estimate DERCs and/or

Allowances required for such calendar month for each emission unit using the

corresponding FLER and AEL from Table 1 as follows:

Estimated DERCs/Allowances Required =

{(Estimated fuel use in MMBtu) x ((FLER) c (0.95 x AEL))}+2000 Ibs/ton

Where:

• AEL - Allowable Emission limit, as defined in Paragraph A.4 ofthis

Trading Agreement and Order

• FLER = Full Load Emission Rate, as defined in Paragraph A.4 ofthis

Trading Agreement and Order

• Discount (0.95) = 5% design margin applied to the AEL.

b. No later than the twentieth day of each 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 1 as follows:

Actual DERCs/Allowances Required =

{(Actual fuel use in MMBtu) x ((FLER) - (0.95 x AEL))} +2000 Ibs/ton.

c. At the end of each calendar year, the Respondent shall demonstrate that any

Allowances used for compliance during the year are surplus, quantifiable,

enforceable and pennanent. This shall be detennined 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 Seller by the State

of Connecticut minus the Allowances purchased by the Respondent.

9. On or before January 31 of each calendar year, the Respondent shall deduct a quantity of

DERCs from the current balance 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 Account (Account ID CT0000000300 in the CAlR NATS) such that the total is

equal to the sum ofActual DERCs/Allowances Required pursuant to Paragraph 3.8 ofthis

Trading Agreement and Order for the preceding calendar year, rounded up to the nearest

whole ton.

10. Doubling: lfthe Actual DERCs/Allowances 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 first day ofthat month, then in addition to the deduction or

transfer specified in Paragraphs 3.9, the Respondent shall deduct a quantity ofDERCs from

the current balance 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
Sikorsky Aircraft Corporation 6 Trading Agreement & Order No. 8293

State NOx Retirement Account (Account ID CT0000000300 in the CAIR NATS) such that

the total is equal to Actual DERCslAllowances Required for that month.

Such additional DERC deduction or Allowance 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 of Paragraph B.l 0 ofthis Trading Agreement and Order, any

violation of Paragraph B.8 ofthis Trading Agreement and Order may be subject to additional

enforcement action as may be deemed appropriate by the Commissioner in accordance with

the Department's enforcement response policy.

11. Maintenance and Tune-up. Not more than 1 year from the date ofissuance ofthis Trading

Agreement and Order, the Respondent shall perform maintenance and inspection of each

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 or replace any components ofthe

combustion system as necessary, in accordance with manufacturer's specification

or current good engineering practice;

b. Inspect the system controlling the air-to-fuel ratio, and ensure that it is 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 engineering practice prior to and after any adjustments are made

during maintenance, tune-up, or inspection activity;

d. Make and keep records including, but not limited to, the following:

I. Demonstration that any maintenance, tune-up, and/or inspection

activity perfonned on the emission units described in Table 1 in

accordance with Paragraph B.ll ofthis Trading Agreement and Order

has been performed in accordance with the manufacturer's

specifications of current good engineering practice,

11. The date and a description of any maintenance, tune-up, and/or

inspection activity performed on the emission units described in Table

1 in accordance with Paragraph B.ll ofthis Trading Agreement and

Order,

iii. The name, title and affiliation ofthe person conducting any

maintenance, tune-up, andlor inspection activity performed on the

emission units described in Table 1 in accordance with Paragraph B.ll

ofthis Trading Agreement and Order,
Sikorsky Aircraft Corporation 7 Trading Agreement & Order No. 8293

12. Record Keeping;

iv. The operating parameters ofthe emission unit used to determine that

the emission unit is operating in accordance with manufacturer's

specification or current good engineering practice prior to and after any

adjustments are made during maintenance, tune-up, or inspection

activity performed in accordance with Paragraph B.II ofthis Trading

Agreement and Order.

a. By the close of each calendar day, the Respondent shall record the actual

fuel type and the actual quantity of each type offuel in units of volume 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 of each calendar month, the Respondent shall

record the number of DERCs 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 of each calendar month, the Respondent shall

record the number ofAllowances and corresponding identification numbers

and vintages for all Allowances in its possession on the first calendar day of

that calendar month,

d. On or before the first day of each calendar month, the Respondent shall

record the number of DERCs and corresponding serial numbers, vintages,

purchase/sales dates, and seller/buyer for all DERCs purchased or sold

during the preceding calendar month,

e. On or before the first day of each 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 calendar month,

f. On or before the first day of each calendar month, the Respondent shall

record the Estimated DERCs/Allowances Required for that calendar month

determined in accordance with Paragraph B.8 ofthis Trading Agreement

and Order.

g. On or before the twentieth calendar day of each 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 31 of each calendar year, the Respondent shall record

the quantity ofDERCs deducted in accordance with Paragraphs B.9 and

B.IO ofthis Trading Agreement and Order. Such records shall include the

serial number and vintage of each DERC deducted from the Respondents

current balance pursuant to Paragraphs B.9 and B.IO ofthis Trading

Agreement and Order.
Sikorsky Aircraft Corporation 8 Trading Agreement & Order No. 8293

I. On or before January 31 of each calendar year, the Respondent shall record

the quantity ofAllowances transferred in accordance with Paragraphs B.9

and B.I 0 ofthis Trading Agreement and Order. Such records shall include

the identification number and allocation year of each Allowance transferred

pursuant to Paragraphs B.9 and B.I 0 ofthis Trading Agreement and Order.

J. For each month 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.I 0 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 of all emission unit operation in

accordance with Paragraph B.7 ofthis Trading Agreement and Order,

including copies of any written correspondence from the Respondent's fuel

supplier detailing the duration and circumstances ofthe inadequate fuel oil·

supply or interruption of gaseous fuel supply to the emission units.

13. Respondent shall retain records and supporting documentation required by this Trading

Agreement and Order for a minimum offive years, conUl1encing on the date such records

were created. Respondent shall provide the records specified above to the Commissioner

within thirty (30) days ofreceipt of a written request 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 of every 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 fonus to be used for the submission ofthese reports.

The Respondent shall submit these reports on such forms, if prescribed by the Commissioner.

15. FLER Violation. Violation of an established FLER shall subject Respondent to make

restitution by matching the quantity of emissions ("true up") caused by the exceedance plus a

100% premium. The true up in tons ofDERCs or Allowances shall be equal to the FLER

exceedance inlbs/MMBtu, multiplied by the total heat input during the period of

noncompliance divided by 2000 lbs/ton. Ifthe period of noncompliance is not known, the

time period from the completion ofthe last/previous Department witnessed emission test

through the date that FLER compliance is achieved as approved by the Commissioner shall

be used. Notwithstanding this requirement, exceedance of any 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 of Enviroumental 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.

17. Emissions Testing. The Respondent shall perform emissions testing in accordance with

Section 22a-174-22(k) ofthe Regulations for each emission unit described in Table I ofthis
Sikorsky Aircraft Corporation 9 Trading Agreement & Order No. 8293

Trading Agreement and Order that 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 either 40 CFR 60, Appendix B&F or 40 CFR 75.

18. Full compliance. Respondent shall not be considered in full compliance with this Trading

Agreement and Order until 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 submit to the Commissioner all

documents required by this Trading Agreement and Order in a complete and approvable

form. Ifthe Commissioner notifies Respondent that any document or other action is

deficient, and does not approve it with conditions or modifications, it is deemed

disapproved, and Respondent shall correct the deficiencies and resubmit it within the time

specified by the Commissioner or, if no time is specified by the COl1l1nissioner, within 30

days ofthe Commissioner's notice of deficiencies. In approving any document or other

action under this Trading Agreement and Order, the Commissioner may approve the

document or other action as submitted or performed or with such conditions or

modifications as the Commissioner deems necessary to carry out the purposes ofthis

Trading Agreement and Order. Nothing in this paragraph shall excuse noncompliance or

delay.

20. Definitions. As used in this Trading Agreement and Order "Commissioner" means the

Commissioner or a representative ofthe Commissioner; 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.

21. Dates. The date ofsubmission to the Commissioner of any document required by this

Trading Agreement and Order shall be the date such document is received by the

Commissioner. The date of any notice by the Commissioner under Trading Agreement

and Order, including but not limited to notice of approval or disapproval of any document

or other action, shall be the date such notice is deposited in the U.S. mail or is personally

delivered, whichever is earlier. Except as otherwise specified in this Trading Agreement

and Order, the word "day" as used in this Trading Agreement and Order means calendar

day. Any document or action which is required by this Trading Agreement and Order to be

submitted or perfonned by a date which falls on a Saturday, Sunday or a COl1l1ecticut or

federal holiday shall be submitted or performed by the next day which is not a Saturday,

Sunday or COl1l1ecticut or federal holiday.

22. Certification of documents. Any document, including but not limited to any notice, which is

required to be submitted to the Commissioner under this Trading Agreement and Order shall

be signed by the Respondent or, if Respondent is not an individual, by an individual,

employed by the Respondent, who satisfies the criteria set forth in Section 22a-174-2a(a)(I)

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 have personally examined and am familiar with the infoffilation submitted in this

document and all attachments thereto, and I certify, based on reasonable investigation,
Sikorsky Aircraft Corporation 10 Trading Agreement & Order No. 8293

including my inquiry ofthose individuals responsible for obtaining the information, that

the submitted information is true, accurate and complete to the best of my 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

with respect to the matters addressed herein, and is nonappealable and immediately

enforceable. Failure to comply with this Trading Agreement and Order may subject

Respondent to an injunction and penalties.

24. False statements. Any false statement in any information submitted pursuant to this

Trading Agreement and Order may be punishable as a criminal offense under Section 53a157b ofthe Connecticut General Statutes and any other applicable 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 or after

obtaining a new 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 or municipality.

26. Commissioner's powers. Nothing in this Trading Agreement and Order shall affect the

Commissioner's authority to institute any proceeding or take any other action to prevent or

abate violations oflaw, prevent or abate pollution, recover costs and natural resource

damages, and to impose penalties for past, present, or future violations oflaw. If at any

time the Commissioner determines that the actions taken by Respondent pursuant to this

Trading Agreement and Order have not successfully corrected all violations, fully

characterized the extent or degree of any 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 of other obligations under applicable federal, state and local law.

28. No assurance by Commissioner. No provision ofthis Trading Agreement and Order and

no action or inaction by the Commissioner shall be construed to constitute an assurance

by the Commissioner that the actions taken by Respondent pursuant to this Trading

Agreement and Order will result in compliance or prevent or abate pollution.

29. Access to premises. Any representative ofthe Department of Environmental Protection

may enter the without prior notice for the purposes ofmonitoring and enforcing the

actions required or allowed by this Trading Agreement and Order.

30. No effect on rights of other persons. This Trading Agreement and Order neither creates

nor affects any rights of persons or municipalities that are not pmties to this Trading
Sikorsky Aircraft Corporation

Agreement and Order.

11 Trading Agreement & Order No. 8293

31. No Creation of Property Rights. This Consent Order does not create any property rights

with respect to these DERCs or Allowances.

32. Notice to Commissioner of changes. Within 15 days ofthe date Respondent becomes

aware of a 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

any relevant information was omitted, Respondent shall submit the correct or omitted

information to the Commissioner.

33. Notification of noncompliance. In the event that Respondent becomes aware that it did

not or may not comply, or did not or may not comply on time, with any requirement of

this Trading Agreement and Order or of any 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 greatest extent possible. 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 which compliance 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 of any compliance dates proposed shall not

excuse noncompliance or delay unless specifically so stated by the Commissioner in

writing.

34. Submission of documents. Any document required to be submitted to the Commissioner

under this 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 of Environmental Protection

79 Elm Street, 5th Floor

Hartford, Connecticut 06106

(860) 424-3702
Sikorsky Aircraft Corporation 12 Trading Agreement & Order No. 8293

Respondent consents to the issuance ofthis Trading Agreement and Order without further notice. The

undersigned certifies that he/she 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.

SIKORSKY AIRCRAFT CORPORATION

Signature: '~\"2i1N\01IVY\-V-....

Type Name: _YV1_._1'!_1._'~--"C\:..cll\,-,-,_e-=-v=--_

Type Title: _",-S-,V_(7-fI-,-l!+-e('-'.~-,-r;.:.::.·~_1_1A_J_

Date: __---:.L(_-_{-elf_-.!:-UJ-"-'-',\)'--__

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

,k

G . R s ,Director

Engl eeril & Enforcement Division

Bureau of Air Management

CITY OF STRATFORD

MAILED CERTIFIED MAIL,

RETURN RECEIPT REQUESTED

Certified Document

Date

01-- IS - :J..:t:, {O