# STATE OF CONNECTICUT DEPARTMENT OF ENVIRONMENTAL PROTECTION

State ofConnecticut And United Technologies Corporation ) ) ) ) 

### Trading Agreement and OrderNo. 8289

WHEREAS, the CommissionerofEnvironmental Protection ("Commissioner") and the United Technologies Corporation ("Respondent") agree that the Commissionermay issue a permit ororderto allow emissions trading in accordance with Section 22a-174-22G) ofthe Regulations ofConnecticut State Agencies ("Regulations") as amethod ofcompliance with Section 22a-174-22 ofthe Regulations: A. 

### Atthe request and with the agreement ofRespondent, the Commissionerfinds the following: I. This Trading Agreement and Order supersedes Trading Agreement and Order 8134A and all subsequentmodifications thereto. 2. Respondent is a corporation that owns and operates ajet engine manufacturing facilitiy at400 Main Street, East Hartford, Connecticut. 3. Atthe facility, Respondent operates the emission units described in Table I below, which are subjectto Section 22a-174-22 ofthe Regulations ofConnecticut 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 unit described in Table 1 ofthis Trading Agreement and Order b. Allowance: CArRNOx Ozone Season allowance originally allocated to a CArRNOx Ozone Season unit located in the State ofConnecticut, as defined in Section 22a-174-22c ofthe Regulations, or

aNOx allowance designated specifically for compliance during Ozone Season control periods and allocated to a CArRNOx Ozone Season unit located in the State ofConnecticutafterthe date ofissuance ofthis Trading Agreement and Order.

c. Discrete Emission Reduction Credit (DERC): aunit 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

(Printed on Recycled Paper) 79 Elm Street • Hartford, CT 06106-5127 www.cl.gov/dep An Equal Opportunity EmployerUnited Technologies Corporation 2 Trading Agreement and OrderNo. 8289 Commissioner in accordance with aprotocol submitted and approved pursuant to Section 22a-174-38 ofthe Regulations. Such unit is equivalentto I ton of NOx emissions and may be used for emissions trading in accordance with Section 22a-174-22G) ofthe Regulations, subjectto the provisions ofPart B of this Trading Agreement and Order. d. Full Load Emission Rate ("FLER")

- Nitrogen Oxide ("NOx") emission rate corresponding to each emission unit described in Table I ofthis Trading Agreement and Order thatthe 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/Allowances Required and Actual DERCs/Allowances Required in accordance with this Trading Agreement and Order.

e. CAIRNATS means "CAIRNOx Ozone Season Allowance Tracking System" as defined in 40 CFR 96.302. f. Non-Attainment Area: means the geographic areawhich has been designated as nonattainment pursuantto 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 ofConnecticutare: the Greater Connecticut, CT area and the New York-Northern New Jersey-Long Island, NY-NJ-CT area. g. Ozone Season

- May I through September 30 ofeach calendar year or such period as defined by the U.S. Environmental Protection Agency, subsequentto the issuance ofthis Trading Agreement and Order.

Table I NOx Emission Test Rates, FLERs and AELs in (lbs/MMBtu, unless specified) Facilityl Fuel Heat Input Maximum Test Full Load Allowable Date of Next Equipment Limitation Allowable Rate Emission Emission Last Stack MMBtu/hr Steam rate Limit Stack Test Production (FLER) (AEL) Test Due Limitation Lbs steam/hr Boilerno. 6 Nat. 143 120,000 0.327 0.36 0.20 1127/2006 1/27/2011 R# 053- gas 144 125,000 0.434 0.48 0.25 0039 #6 oil Boilerno. 8 Nat. 171 125,000 0.248 0.27 0.20 1/26/2006 1/26120II R# 053- gas 182 130,000 0.320 0.35 0.25 0041 #6 oil Boilerno. 9 Nat. 165 120,000 0.241 0.27 0.20 1/25/2006 112512011 R #053- gas 171 125,000 0.309 0.35 0.25 0042 #6 oilUnited Technologies Corporation 

### 3 Trading Agreement and OrderNo. 8289

5. The Respondent agrees thatthe actual NOx emissions rate from the emission units described in Table I, when burning the corresponding fuels exceeds the corresponding AELs. 6. Pursuant to Section 22a-174-22G) ofthe Regulations Respondent proposes 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 accordance with the provisions ofthis Trading Agreement and Order. 7. Respondent proposes to use the full load emission rates ("FLERs") identified in Table I for the purposes ofcalculating DERCs and allowances required. 8. Respondent has agreed to comply with the heat input and steam outputrestrictions on the boilers identified in Table I ofthis Trading Agreement and Order. The Commissioner, in accordance with Section 22a-174-22G) ofthe Regulations hereby allows Respondentto comply with Section 22a-174-22 ofthe Regulations at the facility through the use ofemissions 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-l77 ofthe Connecticut General Statutes, hereby orders Respondent as follows: I. 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

.Agreement and Order shall be the earlier of:

a. January I, 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 longerallowed 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 Respondentthat the Commissionerhas determined the use ofemissions trading as acompliance option has been further restricted, modified or nullified by: (i) the promulgation ofan Act, Statute, or Regulations; or (ii) the issuance ofajudgment orcourt order.United Technologies Corporation 4 Trading Agreement and OrderNo. 8289

2. Respondent shall obtain and use sufficient DERCs and/orAllowances in such a manner as to comply with Paragraphs B.8 and 8.9 ofthis Trading Agreement and Order. All Allowances used must come from an emission unitthat is within the same ozone nonattainment area as the Respondent. All Allowances used by the Respondent must be for the current vintage year. All DERCs used during the Ozone Season, shall have been generated during an Ozone Season by the operation ofan emission unitthat is not a CAIRNOx Ozone Season unit, as defined in Section 22a-174-22c ofthe Regulations. 3. Prior to using Allowances in accordance with Paragraph B.8 ofthis Trading Agreement and Orderthe Respondent shall obtain a General Account or Compliance Account in the CAIR NATS. 4. Vintage Restriction. Forthe 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) calendar years from the year ofthe generation ofsuch DERCs. DERCs older than five (5) calendaryears 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 orallow actual NOx emissions from the operation ofthe emission units described in Table I ofthis Trading Agreement and Orderto exceed the corresponding FLERs. The Respondent shall not allow the steam production from the boilers specified in Table I to exceed the corresponding maximum allowable steam production limitations. Compliance with the corresponding FLERs and maximum allowable steam production rates specified in Table I shall be determined based on the results ofemissions testing performed in accordance with Section 22a-174-22 ofthe Regulations orNOx 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 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 I 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 B.6 ofthis Trading Agreement and Order, during the Ozone Season, the Respondent may operatethe emission units described above on fuels that result in higher emissions ofNOx, ifeither:

a. the availability offueI 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; orWhere:

• Discount (0.95) 

## =5% design margin applied to the AEL. • FLER = Full Load Emission Rate, as defined in ParagraphAA ofthis Trading Agreement and OrderTrading Agreement and OrderNo. 8289 5

c. At the end ofeach calendar year, the Respondent shall demonstrate that any Allowances used for'compliance during the year are surplus, quantifiable, enforceable and permanent. 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 Sellerbythe State ofConnecticut minus the Allowances purchased bythe Respondent. b. No laterthan the twentieth day ofeach month, Respondent shall calculate actual DERCs and/orAllowances 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. • AEL = Allowable Emission limit, as defined in ParagraphAA ofthis Trading Agreement and Order 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 Respondentand the gaseous fuel supplier.

Estimated DERCs/Allowances (tons) Required = {(Estimated fuel use in MMBtu) x «FLER)

- (0.95 x AEL))}+2000 Ibs/ton a. Before the first day ofeach 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 I as follows:

9. On orbefore January 31 ofeach calendar year, the Respondent shall deduct a quantity of DERCS from the currentbalance ofDERCs possessed bythe Respondent and/ortransfer a quantity ofAllowances from the Respondent's NOx General Account orCompliance Account to the CT StateNOx Retirement Account (Account ID CT0000000300 in the CAIR NATS) such thatthe total is equal to the sum ofActual DERCslAllowances Required pursuant to 8. DERC/Allowance Use. On the first day ofeach calendar month, the Respondent shall possess aquantity ofDERCs and/orAllowances that equals or exceeds the quantity ofActual DERCs and/orAllowances Required in that month. Compliance with Paragraph B.8 ofthis Trading Agreement and Order shall be determined as follows: United Technologies CorporationUnited Technologies Corporation 6 Trading Agreement and OrderNo. 8289 Paragraph B.8 ofthis Trading Agreement and Order for the preceding calendaryear, rounded up to the nearest whole ton. 10. Doubling: Ifthe Actual DERCs/Allowances Required for any month, determined in accordance with Paragraph B.8, exceeds the quantity ofDERCs and/orAllowances in the Respondent's possession on the first day ofthat month, then in addition to the deduction or transfer specified in Paragraphs 8.9, the Respondent shall deduct aquantity ofDERCs from the current balance ofDERCs possessed by the Respondent and/or transfer aquantity of Allowances from the Respondent's NOx General Account or Compliance Account to the CT State NOx Retirement Account (Account ID CT0000000300 in the CAIR NATS) such that the total is equal to Actual DERCs/Allowances Required for the preceding month. Such additional DERC deduction or Allowancetransfer shall be performed atthe same time as any 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 8.8 ofthis Trading Agreement and Order may be subjectto additional enforcementaction as may be deemed appropriate bythe Commissioner in accordance with the Department's enforcementresponse policy. 11. Maintenance and Tune-up. Not more than I year from the date ofissuance ofthis Trading Agreement and Order, the Respondent shall perform maintenance and inspection ofeach emission unit listed in Table I. Such maintenance and inspection shall include, but not be limited to, the following:

a. Inspect the combustion system, and clean, repair, orreplace any components of the combustion system as necessary, in accordance with manufacturer's specification or current good engineering practice; b. For any automated operation, inspectthe system controlling the air-to-fuel ratio, and ensurethat 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 thatthe emission unit is operating in accordance with manufacturer's specification or current good engineering practice priorto 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 performed on the emission units described in Table I in accordance with Paragraph B.II ofthis Trading Agreementand Order has been performed in accordance withthe manufacturer's specifications orcurrent good engineering practice,12. Record Keeping;

b. On orbefore 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 calendarday ofthat calendar month.

f. On orbefore the first day ofeach 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. Trading Agreement and OrderNo. 8289 7 ii. The date and a description ofany maintenance, tune-up, and/or inspection activityperformed on the emission units described in Table I in accordance with Paragraph B.II ofthis Trading Agreement and Order, iii. The name, title and affiliation ofthe person conducting any maintenance, tune-up, and/or inspection activity performed on the emission units described in Table I in accordance with Paragraph B.II ofthis TradingAgreement and Order,

d. On orbefore the first day ofeach calendar month, the Respondent shall record the numberofDERCs and corresponding serial numbers, vintages, purchase/sales dates, and sellerlbuyer for all DERCs purchased or sold during the preceding calendarmonth. 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.

e. On orbefore the first day ofeach calendar month, the Respondent shall record the numberofAllowances and corresponding identification numbers, purchase/sales dates, allocation years, and sellerlbuyer for all Allowances purchased or sold during the preceding calendar month. a. Bythe close ofeach calendar day, the Respondent shall record the actual fuel type and the actual quantity ofeach type offuel in units ofvolume per day or MMbtu perday for each fuel used by any emission unit described in this Trading Agreement and order on the preceding day;

c. On orbefore the first day ofeach calendar month, the Respondent shall record the numberofAllowances and corresponding identification numbers and vintages for all Allowances in its possession on the first calendarday of that calendar month. United Technologies Corporationr---------------------------------------------- -------------

United Technologies Corporation 8 Trading Agreement and OrderNo. 8289
g. On orbefore the twentieth calendarday ofeach calendar month, the Respondent shall record the Actual DERCs/ Allowances Required for the preceding calendarmonth determined in accordance with Paragraph B.8 of this Trading Agreement and Order. h. On or before January 31 ofeach calendaryear, the Respondent shall record the quantity ofDERCs deducted in accordance with Paragraphs B.9 and 8.10 ofthis Trading Agreement and Order. Such records shall include the serial number and vintage ofeach DERC deducted from the Respondents current balance pursuant to Paragraphs 8.9 and B.1O ofthis Trading Agreement and Order.

I. On or before January 31 ofeach calendaryear, the Respondent shall record the quantity ofAllowances transferred in accordance with Paragraphs B.9 and B.I0 ofthis Trading Agreement and Order. Such records shall include the identification numberand allocation year ofeach Allowance transferred pursuant to Paragraphs B.9 and B.I0 ofthis Trading Agreementand Order. J. Foreach month ofthe Ozone season, the Respondent shall maintain records attesting to the fact that any DERCs deducted /Tom its balance in accordance with Paragraphs B.9 and B.I0 were created during an Ozone season. Generatorcertification 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 supplier detailing the duration and circumstances ofthe inadequate fuel oil supply or interruption ofgaseous 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, commencing on the date such records were created. Respondent shall provide the records specified above to the Commissioner within thirty (30) days ofreceipt ofa 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 laterthan March I ofevery yearafter issuance ofthis Trading Agreement and Order, the Respondent shall submit to the Commissioner a written report containing copies of all ofthe records required pursuantto Paragraph 8.12 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 bythe 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 intons ofDERCs orAllowances shall be equal to the FLER exceedance in Ibs/MMBtu, multiplied bythe 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 FLER compliance is achieved as approved by the Commissioner shall

### ---------------------------------------_._-

United Technologies Corporation 9 Trading Agreement and OrderNo. 8289 be used. Notwithstanding this requirement, exceedance ofany FLER contained in Table 1 is aviolation in Paragraph 8.5 ofthis Trading Agreement and Order subject to enforcement action in accordance with the DepartmentofEnvironmental Protection's Enforcement Response Policy, in effect atthe time ofsuch violation. 16. FLER Modification. FLERs set forth in Table I ofthis Trading Agreement and Ordermay be modified only after the consent ofthe Commissionerby 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 Trading Agreement and Order that is not equipped with acontinuous emissions monitoring system that was approved bythe Commissioner and that complies with Section 22a-174-4 of the Regulations and either 40 CFR 60, Appendix 8&F or40 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 bythis Trading Agreement and Order in a complete and approvable form. Ifthe Commissioner notifies Respondentthat any document orotheraction 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, ifno time is specified by the Commissioner, within 30 days ofthe Commissioner's notice ofdeficiencies. In approving any document or other action underthis Trading Agreement and Order, the Commissioner may approve the document or other action as submitted or performed or with such conditions ormodifications as the Commissionerdeems 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 orpersonally delivered, whichever is earlier. 21. Dates. The date ofsubmission to the Commissionerofany document required by this Trading Agreement and Order shall be the date such document is received by the Commissioner. The date ofany notice by the Commissionerunder 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 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 Orderto be submitted or performed by adate which falls on a Saturday, Sunday or aConnecticut or federal holiday shall be submitted or performed by the next day which is not a Saturday, Sunday or Connecticutor federal holiday.United Technologies Corporation 10 Trading Agreement and OrderNo. 8289 22. Certification ofdocuments. Any document, including but not limited to any notice, which is required to be submitted to the Commissioner underthis Trading Agreement and Order shall be signed by the Respondent or, ifRespondent 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 certi!)' 

### in writing as follows: "I have personally examined and am familiar with the information submitted in this document and all attachments thereto, and Icerti!)', 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. Iunderstand thatany false statement made in the submitted information may be punishable as acriminal offense under Section 53a-157b ofthe Connecticut General Statutes and any other applicable law."
23. Noncompliance. This Trading Agreement and Order is a final orderofthe 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 acriminal offense under Section 53a-157b 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 noti!)' the Commissioner in writing no later than 15 days after transferring all or any portion ofthe facility, the operations, the site orthe business which is the subject ofthis Trading Agreement and Orderorafter obtaining a new mailing or location address. Respondent's obligations underthis Trading Agreement and Order shall not be affected by the passage oftitle to any propertyto 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 otheraction to prevent or abate violations oflaw, prevent or abate pollution, recovercosts 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 Respondent pursuant to this Trading Agreement and Order have 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 Respondentto 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.31. No Creation ofProoerlv Rights. This Consent Order does not create any propertyrights with respect to these DERCs orAllowances. 30. No effect on rights ofother persons. This Trading Agreement and Order neither creates nor affects any rights ofpersons ormunicipalities that are not parties to this Trading Agreement and Order. 29. Access to premises. Any representative ofthe Department ofEnvironmental Protection may enterthe without prior notice for the purposes ofmonitoring and enforcing the actions required or allowed by this Trading Agreement and Order. Trading Agreement and OrderNo. 8289 II

33. Notification ofnoncompliance. In the event that Respondent becomes aware that it did not or may notcomply, or did not or may not comply on time, with any requirement ofthis 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 ensurethat any noncompliance or delay is avoided or, ifunavoidable, 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 ordelay and propose, for the review and written approval of the 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 ordelay, and the Commissioner's approval of any compliance dates proposed shall notexcuse noncompliance or delay unless specifically so stated by the Commissionerin writing. 32. Notice to Commissionerofchanges. Within IS days ofthe date Respondent becomes aware ofachange in any information submitted to the Commissioner under this Trading Agreement and Order, orthat any such information was inaccurate or misleading orthat any relevant information was omitted, Respondent shall submit the correct or omitted information to the Commissioner. 28. No assurance by Commissioner. No provision ofthis Trading Agreement and Order and no action or inaction bythe Commissioner shall be construed to constitute an assurance by the Commissioner thatthe actions taken by Respondent pursuant to this Trading Agreement and Order will result in compliance or prevent or abate pollution.

34. Submission ofdocuments. Any document required to be submitted to the Commissioner underthis Trading Agreement and Order shall, unless otherwise specified in this Trading Agreement and Order or in writing bythe 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) 424-3702 United Technologies CorporationUnited Technologies Corporation 12 Trading Agreement and OrderNo. 8289

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 legallybind Respondentto the terms and conditions ofthe Trading Agreement and Order. United Technologies Corporation Signature:

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