# STATE OF CONNECTICUT DEPARTMENT OF ENVIRONMENTAL PROTECTION

The State ofConnecticut and
Pfizer, Inc ) ) ) 

### ) ) Trading Agreement and Order No. 8136 A

Whereas, the Commissioner ofEnvironmental Protection ("Commissioner") and Pfizer, Inc. ("Pfizer") agree that it is 

### in the public interest that they work cooperatively 

### to improve the air quality within 

### the State ofConnecticut and that the use ofdiscrete emission reduction credit 

### ("DERe") trading to reduce nitrogen oxide (''NOx'') emissions will achieve this result in a timely and cost-effective manner.
A. At the request and with the agreement ofPfizer, the Commissioner finds the following:
1. 

### This Trading Agreement and Order5upercedes Trading Agreement and Order 8136 issued on April 29, 1999, Trading Agreement and Order 8136 Addendum I issued on December5, 2001, and Trading Agreement and Order 8136 Addendum 2 issued on April 29, 2002. With respect to future creation and use for boiler4, this Trading Agreement and Order supercedes Trading Agreement and Order 8093B issued on December 5, 2001 and Trading Agreement and Order 8093B Addendum I issued on April 29, 2002.
2. Pfizeris a corporation that owns and operates apharmaceutical production and research facility at Eastern. Point Road, Groton, Connecticut ("facility").
3. At the facility, Pfizer owns and operates fuel burning equipment which consists of four (4) steam boilers numbered 1,2,3 and 4 {"boilers") capable ofburning natural gas or No.6 fuel oil, which are the subject ofthis Trading Agreement and Order, and are subject to Section 22a-174-22 ofthe Regulations pertaining to the control ofNOx emissions.
4. Pfizermonitors NOx emissions from each boilerusing continuous emissions monitors ("CEMs''), certified to 40 Code ofFederal Regulations Part 60.
5. Pfizer sometimes exceeds the NOx allowable emission rate limits 

### in Section 22a174-22 ofthe Regulations.


### 6. To reduce NOx emissions from the boilers to below the limitations established by Section 22a-174-22(e) ofthe Regulations Pfizer frequently bums natural gas.

(Printed on Recycled Paper) 79 Elm Slreet

. Hafliord. CT 06105·5127 An**~o:Jotl** O;>potTUflIIYemployer • hllP/Idep SlotlE elliS Celebrating a Century ofForest Conservarion Leadership 1901 2001

### Pfizer, Inc. 2 

### Trading Agreement and OrderNo. 8136 A
7. The emissions trading baseline ("baseline emission rate") for the boilers is 0.25 IbslMMBtu ofheat input when operating on No.6 fuel oil and 0.20 lbsIMMBtu of heat input when operating on natural gas. Said baseline emission rates are based on approved emissions tests conducted in 1996 and 1997.
8. In 

### the funue Pfizerintends to use 1\0. 2 fuel oil. The baseline emission rate for the boilers is 0.20 IbsIMMBtu ofheat input when operating on No.2 fuel oil.
9. Pursuant to Sectil(n'22a-174-22(j) ofthe Regulations, Pfizerproposes to generate approved DERCs and to comply with Section 22a-174-22(e) ofthe Regulations through the use ofapproved DERCS until Apri130, 2007, at the facility in 

### accordance with this Trading Agreement and Order.


### 10. When properly documentedby Pfizer, and approved by the Commissioner, the emission reductions identified above, and as computed 

### in accordance with the terms ofthis Trading Agreement and Order, will conform to the requirements of Section 22a-174-22(j)(3) ofthe Regulations. SpecificaIly, the reductions wiIl be:
Real because they will result 

### in a reduction ofactual emissions released into the air, 

### net ofany consequential increase 

### in actual emission resulting from shifting demand. The emissionreductions will be properly measured, recorded, and reported. Quantifiable because they are based on CEM data as applied to an appropriate reliable and replicable protocol, providing the rate and total mass amount of reduction. Surplus because they**ar~** 

### not required by any Connecticut statute orregulation mandatedby a current State ImplementationPlan ("SIP"), and are not relied upon in any applicable attainmentplan, any reasonable further progress plan, milestone demonstration or applicable federal regulation.
Permanent because the 10w-NOx burners will be in 

### place and operating, and an appropriate tracking system is 

### in place to monitor all datarequired to verify and quantify the creation ofDERCs.
Enforceable because the DERCs are approved by the Commissioner retrospectively afterthe submissionbyPfizerofareport that documents their creation.


### II. The Commissioner, in accordance with 

### the provisions ofTrading Agreement and OrderNo. 8136, Order 8093B and Addendum I, pursuant to Section 22a-174- 22(j) ofthe Regulations, approved the NOx DERCs referenced in Table 1 ofthis Trading Agreement and Order. DERC creation serial numbers assigned by the Department to these previously approved DERCs are provided in Table 1 ofthisPfizer, Inc. 3 Trading Agreement and Order No. 8136 A



# ·3 Trading Agreement and Order. These remaining DERCs, to the extent they are unused, are subject to the vintage restrictions ofthis Trading Agreement and Order. Dates after which the unused DERCs will no longerbe eligible for use 

### as a result ofthe vintage restrictions 

### are provided in Table 

### 1 ofmis Trading Agreement and Order in the expiration date column.
Table 

### 1 PreviouslY AQoroved (to the extentnotalreadv used) DERCs Year of Ozone season NQx DERC Ozone Non-ozone seasonNOx Non- Expiration Generation serial numbers season DERC serial numbers ozone Date NO. season DERCs NO. DERC 5/31/96- CT98/8136(DC)NOxnzl-35 35 N/A NlA 12/31/04 9130198 5131/96- O98/8093A(DC)NOxozl-44 1 44 1 N/A N/A 1 '213 1/04 9130198 1998 

### I O9818093B DC)NOxnzl-2 

### I 2 IN/A IN/A 

### I 11J3I104 1999 CT99/8136(DC)NOxozl-l0 10 Cf99/8136{DC)NOxnoz8·11 4 12/31/04 1999 Cf99/S093B(DC)NOxQZ1-8 8 N/A NlA 12/31/04 2000 CToo/8136(DC)No.oz1-15 15 crOO/8136{DC)NOxnoz1-8 8 12/31/05 2000 N/A CTOO/81 36{DC)NOxnoz9 1 12131/05 2000 CT00I8093BIDC)No.ozl-8 I 8 IN/A N/A IWII05 2001 I CT01/8136(DC)NOxoz3-16 114 t CfOl/8136(DC)NOxnozl-2 2 

### I 12131/06 2001 

### I CT01/8093B(DC)NOxozl-11 I 11 J N/A N/A I 12131/06
B. The Commissioner, in accordance with the provisions ofthis Trading Agreement and Order, pursuant to Section 22a-174-22(j) ofthe Regulations, hereby allows Pfizerto:

1. Comply with Section 22a-174-22(d) ofthe Regulations through use ofDERC trading; and
2. Upon sufficient documentation as prescribed in this Trading Agreement and Order, generate additional DERCs. Upon issuance ofan addendum to this Trading Agreement and Orderthe Commissionermay approve the generation of additional DERCs by Pfizerretrospectively. Approved DERCs generated by Pfizermay be held by Pfizer or transferred to otherpersons in accordance with this Trading Agreement and Order.


# c.
.With the agreement ofPfizer, the Commissioner, acting under Sections 22a-6, 22a-171, 22a-174, 22a-176, and 22a-177 ofthe Connecticut General Statutes, hereby orders Pfizer

### as follows:



### . .**-~** 1. Upon issuance ofthis Trading Agreement and Order, Pfizermay generate approved DERCs as allowed under this Trading Agreement and Orderuntil April 30,2007.

### Pfizer, Inc. 4 

### Trading Agreement and OrderNo. 8136 A



### .......' 

### .. 2. Upon issuance ofthis Trading Agreement and Order, at the facility, Pfizer shall comply with Section 22a-174-22 ofthe Regulations through emission reduction trading. Until Pfizer achieves permanentcompliance with 

### the emission standard in Section 22a-174-22(e) ofthe Regulation orby April 30, 2007, whichever occurs earlier:

a. Pfizer shall use approved DERCs as required underthis Trading Agreement and Order; and 

# , b. Pfizer shall have in 

### its possession sufficient approved DERCs to meet applicable NOx emission limits as allowed underthis Trading Agreement and Order.
3. DERC Generation. a. Until April 3D, 

### 2007, when the boilerhas dailyNOx emissions below the applicable baseline emissionrate(s), or the proportioned baseline emission rate, Pfizer shall calculate the amount ofDERCs generated as follows:
DERCs (tons) generated {[Total heat input ofall fuels in MMBtu x

«(proportionedbaseline emission rate)

- (the CEM-recorded NOx emission rate))] + 

### 2000 Ibs/ton} x (0.90)

.

1. 

### When calculating DERCs, to detennine heat input Pfizer shall use the actual fuel usage data for the boilers in MMBtuiday. 

### Tne CEMrecorded Ox emissionrates shall be calculated pursuant to the methodology described in 40 Code ofFedera! Regulations Pan 60.

11. 

### The baseline emission rate shall be calculated by 1)multiplying the heat input ofeach fuel combustedby the baseline emission rate(s) for such fuel; 2) swnming those products; and 3) dividing the sum by the total heat input. Ifthe boileris operating exclusively on one fuel, Pfizermay replace the proportioned baseline emission rate with the applicable baseline emission rate, for that fuel. Pfizer shall use 0.25 IbsIMMBtu ofheat input when operating on No.6 fuel oil and 0.20 IbsIMMBtu ofheat inputwhen operating on natural gas as the baseline emission rates for the boilers, orthe proportionedbaseline emissionrate when simultaneously operating on more than 

### one fuel.

Ill. 

### Ten (10) percent ofall DERCs (tons) generatedby the boilers shall be retired byPfizer and pennanently removed from all calculations
on a monthly basis to assure abenefit to the environment.
b. When the dailyornon-ozone season CEM-recorded NOx emission rate is used to calculate DERCs generated by the boilers, Pfizer shall not includePfizer, inc. 5 Trading Agreement and OrderNo. 8136 A missing data calculated in accordance with any missing data substitution procedures, including those allowed under Section 22a-174-22a ofthe Regulations.

c. In orderto consider a Daily NOx Averaging Period valid forDERC approval, it must contain valid data hours for seventy-five (75%) ofthe operating hours in that dailyperiod (example: minimum 18 valid hours for
afull 24-hour operating say; minimum 12 hours for 16 operating hours, etc.). A Daily NOx Averaging Period is defined as the total ofall operatingbours in a day during whieb fuel is being fed to the boile". Additionally, for adata hourto be considered avalid hour, seventy-five percent (75%) minimum data capture requirements much be met for each one-bourblockperiod. All NOx and 

### CO,IO, CEMs must comply witb 40 Code ofFederal Regulations Part 60 Appendix F drift criteria.
d. In requesting approval ofDERCs generatedby the boilers, Pfizer shall provide docwnentation containing a sample spreadsheet with calculation formulas used to detennine reponed numbers; monthly operating reports ofactual fuel usage including the fuel BTU content, for each fuel type; daily MMBtu for eaeb fuel type and actual beat input based upon CEMrecorded data; daily actual NOx emission rates (24-hour average); and DERCs generated using the baseline emission rate(s), orthe proportioned baseline emission rate, net ofthe environmental discounts.

e. Requests for approval ofall DERCs generated by Pfizerunder this Trading Agreement and Order shall be submitted in writing to the Commissioner. Suchrequests may be compiled on a monthly or seasonal basis and shall be submitted at least on an annual basis. Approved DERCs generated byPfizer underthis Trading Agreement and Ordermay be held
ortransferred to otherpersons and shall remain valid until they are used or until their vintage expiration date, whichever occurs first.
4. DERC Use. Until April 30, 2007, before the fi"t day ofeaeb month Pfizer shall have 

### in its possession sufficient approved DERCs for such month based on the following calculation.

a. Before the first day ofeach month, Pfizer shall estimate DERCs required for such calendarmonth for the boilers as follows:
Estimated DERCs (tons) = {[Estimated NOx emission rate in Ibs/MMBtu

- ((0.95) x (NOx baseline emission limit or proportioned baseline emission rate calculated pursuantto Section 22a-I74-22(f)(2)(A) oftbe Regulations in Ibs/MMBtu))] x (Estimated fuel
use in MMBtu)} • 2000 Ibs/ton.Pfizer, Inc. 6 Trading Agreement and Order No. 8136 A

'.-/ 

### 5.



### 6. b. No later than the twentieth day ofeach month, Pfizer shall calculate the actual DERCs used in the preceding calendarmonth, as follows:
DERCs (tons)**used~** {[(CEM-recorded NOx daily average emission rate in IbsIMMBru*)

- ((0.95) x (NOx baseline emission limit orproportioned baseline emission rate calculated pursuantlo Section 22a-174-22(f)(2)(A) ofthe Regulations in IbsIMMBru))] x (acrual fuel use in MMBru)) .,. 2000 Ibs/ton.
*This

## rat~ 'shall be calculatedpursuant to the methodology described 

### in 40 CFRPart 60.



### c. When calculating the dailyNOx DERCs used by the boilers, Pfizer shall average all valid NOx CEM-recorded readings in a day.
Record Keepine. Pfizer shall make and keep records for the boilers of: daily fuel use and fuel type; the actual NOx emission rates (24-hour average), number ofoperating hours per day, the number ofinvalid data hours ofthe total operating hours per day; the number ofDERCs created and used each day 

### in accordance with the appropriate emission rates and 

### limits in this Trading Agreement and Order; the number ofDERCs 

### in its possession and purchased (by serial number ifassigned.) each month; the number ofDERCs used during the ozone season and non-ozone season (the remainder ofthe year); as well as documentation arresting to the fact that approved DERCs used during the ozone season were generated during the ozone season. Generator certification ofthis fact shall be sufficient. Pfizer shall maintain such records to the Commissioner 

### in accordance with Section 22a-174-22 of the Regulations. Pfizer shall retain records and supporting documentation as described in this Trading Agreement and Orderfor a minimum offive years, commencing on the date such records were created. Pfi2;er shall provide the records specified above to the Commissioner within thirty (30) days of receipt ofa written request,from the Commissioner.
Annual Emission Statement. No laterthan March 1 ofevery year after issuance ofthis Trading Agreement and Order, Pfizer shall include with the Annual Emission Statement provided to the Commissioner, a record ofeach sale or other transfer, and use ofany and all ofthe DERCs approved within and subsequent to issuance ofthis Trading Agreement and Orderuntil all such DERCs have been used or are no longer in Pfizer's possession. Pfizer shall also include actual. Ox emissions from each ofthe boilers and the amount ofall approved DERCs used(including serial numbers (ifassigned) and approved DERCs generated andlorpurchased from otherfacilities), generated andlor approved for the previous calendar year. These repom shall be on a fonn prescribed by the Commissioner and shall be in monthly Increments. Should Pfizerchoose to discontinue the generation ofDERCs,Pfizer, Inc. 7 Trading Agreement and OrderNo. 8136 A
Pfizer will notify the Commissionerupon discontinuance.

7. Allowance Use. Pursuant to Section 22a-174-22(d)(3) ofthe Regulations, Pfizer may use NOx allowances, pursuant to Section 22a-174-22(j) ofthe Regulations to achieve all or aponion ofthe reductions required by Section 22a-174-22 ofthe Regulations. Any allowance used for compliance with Section 22a-174-22(e) of the Regulations shall be subject to all restrictions and/orrequirements applicable to DERCs contained 

### in this Trading Agreement and Order. Each allowance used for compliance witli Section 22a-174-22 ofthe Regulations shall be equivalentto one DERC and sb'all be deducted from Pfizer's NOx Budget Program compliance account upon such use. Allowances shall be considered used for compliance with Section 22a-174-22 ofthe Regulations when they are transferred from the facility's compliance account or overdraft account to a State ofConnecticutNOx allowance retirement account, account ID CTOO00000300 

### in the Ox Allowance Tracking System (NATS).
8. DERC Doublin2. At aminimum, approved DERCs required for compliance with this Trading Agreement and Order shall be adjusted upwards by 100% ifDERCs
are not 

### in Pfizer's possession prior to the first day ofeach month. However, based on the gravity ofthe noncompliance, the Commissionermayrequire additional upward adjustment.
9. Vintage Restriction. Forthe purposes ofcompliance with Section 22a-174- 22 ofthe Regulations, DERCsiallowances shall onlyremain valid for five (5) calendaryears from the year ofthe generation/allocation ofsuch DERCs/allowances. DERCs/allowances generated/allocated more than five (5) calendaryears ago are not valid for use for compliance with Section 22a174-22 ofthe Regulations. Notwithstanding the above the DERCsiallowances generated/allocated priorto calendaryear 2000 shall be valid for use until December 31, 2004.
10. Extension. No laterthan April 30, 2007, with respect to the boilers, Pfizer shall complywith the requirements ofSection 22a-174-22(d)(I) ofthe Regulations. However, after full program review ofthis and otherTrading Agreements and Orders and, ifdetennined to be appropriate, the Commissionermay grant a written extension ofthis Trading Agreement and Order.


### II. Furore Comnliance RecoI1. On orbefore September 

### I, 2006, Pfizershall submit areport indicating how the facility shall comply with Section 22a174-22 ofthe Regulations with respect to the boilers on and after May I, 2007.
12. Full compliance. Pfizer shall not be considered in full compliance with this Trading Agreement and Orderuntil all actions required by this TradingPfizer, Inc. 8 Trading Agreement 

### and OrderNo. 8136 A Agreement and Orderhave been completed as approved and to the Commissioner's satisfaction.
13. Approvals. Pfizer shall use best efforts to submit to the Commissioner all documents required by this Trading Agreement and Order in a complete and approvable fonn. Ifthe Commissionernotifies Pfizer that any document or other action is deficient, and does not approve it with conditions or modifications, it is deemed disapproved, and Pfizer shall correct the deficiencies and

### ~dubmit it within the time specified by the Commissioner or, ifno time is specified by the Commissioner, within 30 days ofthe Commissioner's norice ofdeficiencies. 

### In approving any document or other action under this Trading Agreement and Order, the Commissionermay approve the docwnent or other action as submitted orperfonned orwith such conditions or modifications as the Commissionerdeems necessary to carry out the purposes ofthis Trading Agreement and Order. Nothing in this paragraph shall excuse noncompliance or delay.

14. Definitions. As used in this Trading Agreement and Order, "Approved DERCs" are those for which the Commissionerhas provided written authorization foruse in compliance with Section 22a-174-22 ofthe Regulations; "Commissioner" means the Commissioner or arepresentative of the Commissioner; "Ozone season" means the period from May I through September 30 in any given calendar year. The date of"issuance" ofthis Trading Agreement and Orderis the date the Trading Agreement and Order is deposited in the U.S. mail orpersonally delivered, whicheveris earlier.
15. Dates. The date ofsubmission to the Commissioner ofany document required by this Trading,Agreement and Order shall be the date such document is received by the Commissioner. The date ofanynotice by the Commissionerunder Trading Agreement and Order, including but not limited to notice ofapproval or disapproval ofany docwnent or other action, shall be the date such notice is deposited in the U.S. mail or is personally delivered, whicheveris earlier. Except as otherwise specified in this Trading Agreement and Order, the word "day" as used 

### in this Trading Agreement and Ordermeans calendar day. Any docwnent or action which is required by this 

### Trading Agreement and Orderto be submitted orperformed by a date which falls on a Saturday, Sunday or a Connecticut or federal holiday shall be submitted orperformed by the next day which is not a Saturday, Sunday or Connecticut orfederal holiday.


### 16. Certification ofdocuments. Any document, including but Dot limited to any notice, which is required to be submitted to the Commissionerunder this Trading Agreement and Order shall be signed by PfLZer or, ifPfizeris not an individual, by Pfizer's chiefexecutive officer or a duly authorized representative ofsuch officer, as those terms are defined in Section 22a-430-

### Pfizer, Inc. 9 Trading Agreement and Order No. 8136 A 3(b)(2) 

### ofthe Regulations ofConnec!icut State Agencies, and by the 

### individual(s) responsible for actuallypreparing such docwnent, and Pfizer or Pfizer's chiefexecutive officer or a duly authorized representative ofsuch officer, and each such individual shaH certify in writing as follows:

"I have personally examined and am familiar with the information submitted in this docwnent and all anaclunents thereto, and I certify, based on reasonable investigation, including myinquiry ofthose individuals responsible for obtaining the information,.thct1: the submitted information is true, accurate and complete to the best ofmylaiowledge and belief. I understand that any false statement made in the submined information is punishable as a criminal offense under Section 53a-157b ofthe Cormecticut General Statutes and any other applicable law."
17. Noncompliance. This Trading Agreement and Orderis a final order ofthe Commissioner with respect to the matters addressed herein, and is nonappealable and inunediately enforceable. Failure to comply with this Trading Agreement and Order may subject Pfizer to an injunction and penalties.

,,,,\, 

# J 18. False statements. 

### Any false statement in any information submitted pursuant to this Trading Agreement and Orderis punishable as a criminal offense under Section 53a-157b ofthe Connecticut General Statutes and any other applicable law.
19. Notice oftransfer: liability ofPfizer. Until Pfizerhas fully complied with this Trading Agreement and Order, Pfizer shall notify the Corrunissioner in writing no later than 15 days after transferring all or anyportion ofthe facility, the operations, the site or the business which is the subject ofthis Trading Agreement and Orderor after obtaining a new mailing or location address. PfIzer's obligations underthis Trading Agreement and Order shall not be affected by the passage oftitle to anyproperty to any otherperson or municipality.

i. j '.J 

### 20, Commissioners 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 forpast, present, or future violations oflaw. Ifat any time the Commissioner determines that the actions taken by Pfizerpursuant to this Trading Agreement and Orderhave not successfully corrected all violations, fully characterized the extent or degree ofanypollution, or successfully abated or prevented pollution, the Commissioner may institute any proceeding to require Pfizer to undertake further investigation or further action to prevent or abate violations orpollution.

### Pfizer, Inc. 10 

### Trading Agreement and OrderNo. 8136 A

" 

### 21. Pfizer's obli£ations under law. Nothing in this Trading Agreement and Order shall relieve Pfizerofotherobligations under applicable federal, state and local law.
22. No assurance bv Commissioner. No provision ofthis Trading Agreement and Orderand no action orinaction by the Commissioner shall be construed to constitute an assurance by the Commissionerthat the actions taken by Pfizerpursuant to this Trading Agreement and Orderwill result in compliance or**pr~vbnt** 

### or abate pollution.
23. Access to premises

. .Anyrepresentative ofthe Department ofEnvironmental Protection may enterthe premises withoutpriornotice for the purposes of monitoring and enforcing the actions required or allowed by this Trading Agreement and Order.
24. No effect on rights ofotherpersons. This Trading Agreement and Order neithercreates nor affects anyrights ofpersons or municipalities that are not parties to this Trading Agreement and Order.
25. No Creation ofPropenv Rights. This Trading Agreement and Orderdoes not create anyproperty rights with respect to these DERCs.
26. Notice to Commissioner ofchanges. Within 15 days ofthe date Pfizer becomes aware ofa change in any information submitted to the Commissionerunderthis Trading Agreement and Order, orthat any such information was inaccurate ormisleading orthat any relevant information was omitted, Pfizer shall submit the correct oromitted information to the Commissioner.
27. Notification ofnoncompliance. 

### In the eventthat Pfizerbecomes aware that it did not ormay not comply, ordid not ormay not comply on time, with any requirement ofthis Trading Agreement and Order orofany document required hereunder, Pfizer shall immediately notifyby telephone the individual identified in the next paragraph and shall take all reasonable steps to ensure that any noncompliance ordelay is avoided or, ifunavoidable, is minimized to the greatest extent possible. Within five (5) days ofthe initial notice, Pfizer 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 ofthe Commissioner, dates by which compliance will be achieved, and Pfizer shall comply with any dates which may be approved in writing by the Commissioner. Notification by Pfizer shall not excuse noncompliance ordelay, and the Commissioner's approval of any compliance dates proposed shall not excuse noncompliance ordelay unless specifically so stated by the Commissioner in writing.Pfizer, Inc. II Trading Agreement and Order. TO. 8136 A**.~** 

### J

) 28. Submission ofdocuments. Any document required to be submined 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:
Mrs. 

### Elizabeth McAuliffe Department ofEnvirorunental Protection Bureau of

### AirManagement Compliance and Field Operations Division Emissions and Credit Trading Section 

### 79 Elm Street Hartford, Connecticut 06106

### Pfizer, Inc. 12 

### Trading Agreement 

### and OrderNo. 8136 A

; ./

, 

### Pfizer consents to 

### the issuance ofthis Trading Agreement and Orderwithout funher notice. The undersigned cenifies that he/she is fully authorized to 

### enterinto this Trading Agreement and Order and to legally bind Pfizerto the terms and conditions ofthe 

### Trading Agreement and Order.

Signature:

## -~bD'ili1=t~**~~"l:l~:::::::='_2** 

# _ TypeName:

_ ... 

### K""rrv1.i-.>L

....

H"'e"rt-"e"n"s"'te"i!!n

_ Type Title: _-"S"it"-e"D"'ir"e"'ct"'o!!r

_ Date: ..!M"ar""'ch!!.£Z8.,.-'Z"'O,,03L-

_

Issued as afinal orderofthe 

### Commissionerofthe 

### Deparunent ofEnvironmentaJ

# ,1~; 

# I 

# .4- Protection on

__**--'-p-+,.~=-'---_'._"_.** 

## :--. 2003. 

## 7

ArthurJ 

### Rocque, Jr. Com ssioner



### CITY OF GROTONLAND RECORDS
MAILED CERTIFIED MAIL, RETIJRNRECEIPT REQUESTED
Cenified Document No.