STATE OF CON_ ECTICUT

DEPARTMENT OF ENVIRONMENTAL PROTECTION

In the matter of

The State ofConnecticut

and

The Connecticut Resources,Recovery Authority

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Trading Agreement

and Order No. 8116A

Whereas, the Commissioner of Envirorunental Protection (,'Commissioner") and the Connecticut

Resources Recovery Authority ("eRR..A.") agree that it is in the public interest that they work

cooperatively to improve the air quality within the State ofCOJU1ecticllt and that the use of discrete

emission reduction credit ("DERen) 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 ofCRRA, the Commissioner finds the following:

I.. This Trading Agreement and Order 5upercedes Consent Order 1494A issued on May 4,2001;

and Trading Agreement and Order 8116 issued on April 22, 1997; as amended on October 9,

1997, May 13, 1998 and December 15, 2000, and modified on April 29, 1999 and May 22,

2000.

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2. CRRA is a public instrumentality and political subdivision of the State of Connecticut

established to provide solid wast~ management services to Connecticut's municipalities located

at Reserve-Maxim Roads, Hartford, COIUlecticut ("facility").

3. At the facility, CRRA owns and operates fuel burning equipment which consists of eight (8)

combustion turbines ("peaking units") and one (I) auxiliary boiler ("boiler') which are subject

to section 22a-174-22 oftlle Regulations ofConne.:ticut State Agencies (HRegulations")

pertaining to the control of NOx emissions.

4. On the dates provided in Table 1 of this Trading Agreement and Order, CRRA perfonned NOx

stack emission testing approved by the Commissioner.

5. CRR.A" exceeds the NOx allowable emission rate limit specified in Section 22a·174-22(e) ofthe

Regulations as shown in Table 1 of this Trading Agreement and Order.

(Prinled on Recycled" Paper)

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All Equel Oppor/lUlil)' E",plorer
The Cormecticut Resources

Recovery Authority

Table 1

Trading Agreement and

Order No. 8116A

NOx E~'USSION RATES AND ALLOWABLE LIMITS (IbslMMBtu)

Fuel Burning FUEL FLER NOx Stack Test Date of

Equipment! (lbsIMMBtu) Allowable Rate Stack Test Next Stack

Registration No. Rate (IbsIMMBtu) Test Due

(IbsIMMBtu) Date

llA No.2 or 0.74 03120101 03120106 other , R260 . distillate oil , 0.81 0.289

liB No.2 or 0.75 03120101 03120106

R161 other

distillate oil 0.81 0.289

12A No.2 or 0.76 03121/01 03121106

R.262 other

distillate oil 0.81 0.289

12B No.2 or 0.79 03121101 03121106

R263 other

distillate oil 0.81 0.289

13A No.2 or 0.72 03/22/01 03122106

R264 other

distillate oil 0.81 0.289

13B No.2 or 0.70 03122101 03122/06

R.2V5 other

distillate oil 0.81 0.289

14A No.2 or 0.73 03123101 03123/06

R266 other

distillate oil 0.81 0.289

14B No.2 or 0.71 03123/01 03123106

R.267 other

distillate oil 0.81 0.289

Auxiliary Boiler

No.9 No.4 0.285 12n199 12nl04

R275 fuel oil 0.40 0.25

6. Pursuant to the Department ofEnvironmental Protection ("Department") policy on "Credit

Trading/or Sources with Irregular NOx Emissions" as revised on February 27,2001, and

attached hereto and incorporated by reference into this Trading Agreement and Order as Exhibit

1, each peaking unit has peak daily NOx emissions greater than three times the average daily

emissions during the ozone season and is therefore considered a source with irregular NOx

eIDlSSIODS.

7. Pursuant 10 Section 22a-174-220) of the RegulalioDS CRRA proposes to comply with Section

22a-174-22(e) ofthe Regulations, for the peaking units' emissions, through the use of approved

DERCs until May I, 2005 at the facility in accordance with this Trading Agreement and Order.

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8. Pursuant to Section 22a~174~22(j) of the Regulations CRRA proposes to comply with Section

22a-174-22(e) of the Regulations, forthe boiler's emissions, through the use of approved

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The Connecticul Resources

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Trading Agreement and

Order 0.8116A

DERCs until April 30, 2007, at the facility in accordance with this Trading Agreement and

Order.

9. The Commissioner, in accordance with the provisions ofTrading Agreement and Order No.

8116, as amended on October 9,1997, May 13, 1998 and December 15, 2000, and as modified

on Apri129, 1999 and May 22, 2000, Plmuant to Scotion 22a-174-22(d)(3) ofthe Regulations,

approved the generation of NOx DERCs referenced in Table 2 of this Trading Agreement and

Order. DERC creation seri~l number assigned by the Department to these previously approved

reductions ofNOx emissions are identified, if available, in Table 2 ofthis Trading Agreement

and Order. DERCs are subject to the vintage restrictions ofthis Trading Agreement and Order.

The expiration date, provided in Table 2 ofthis Trading Agreement and Order, indicate the

date after which unused DERCs will no longer be eligible for use.

C G

Table 2

previously Approved DER s enerated

Year of Non-Ozone season NOx DERC serial Non~ozone Expiration Date

Generation number season NOx

DERCs

1998 CT98/8116A3(DC)Noxnoz1-114 114 12131/04

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The Commissioner, in accordance with the provisions of this Trading Agreement and Order,

pursuant to Subdivision 22a-174~22(j) ofthe Regulations, hereby allows CRRA to comply with

Section 22a-174-22 ofthe Regulations, at the facility, through use ofDERC and Budget emission

reduction credits ("BDER-C") trading.

c. Therefore, with the agreement of CRRA, the Commissioner, acting under Connecticut General

Statutes Sections 22a-6, 22a-171, 22a-174, 22a-176 and 22a-J77, hereby orders CRRA as follows:

l. Upon issuance of this Trading Agreement and Order, at the facility, CRRA shall comply \vith

Section 22a-174-22 of the Regulations through emission reduction trading until the peaking

uuiLs al:hieve permanent compliance with the emission standard in Section 22a~174-22(e) of the

regulation or by May 1, 2005, whichever occurs earlier, as follows:

a. CRRA shall use approved DERCs as required under this Trading Agreement and Order;

b. CRRA shall have in its possession sufficient approved DERCs to meet applicable NOx

emission limits as allowed under this Trading Agreement and Order; and

c. CRRA. shall comply during operation of each peaking unit with the FLERs shown in

Table 1 ofthis Trading Agreement and Order.

2. Upon issuance of this Trading Agreement and Order, at the facility, CRRA shall comply with

Section 22a-174-22 of the Regulations through emission reduction trading until the boiler

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The Connecticut Resources

Recovery Authority

Trading Agreement and

Order No. 8ll6A

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achieves permanent compliance with the emission standard in Section 22a-174-22(e) ofthe

Regulations or by April 3D, 2007, whichever occurs earlier, as follows:

a. CRR.A. shall use approved DERCs as required under this Trading Agreement and Order;

b. CRRA shall have in its possession sufficient approved DERCs to meet applicable NOx

emission limits as allowed under this Trading Agreement and Order; and

c.. CRRA sball comply 'during operation of the boiler with the FLER sbown in Table 1 of

this Trading Agreement and Order.

3. DERC use for the Peaking Units.

a. Until May I, 2005, before the first day of each month CRRA shall have in its

possession sufficient approved DERCs for the peaking units based on the following

calculations.

Before the first day of each month, CRRA shall estimate DERCs required for such

month for the peaking units as follows:

(i) At all times (mass calculation);

Estimated DERCs (tons) use {(Estimated fuel use in MMBru)x«(FLER)-(0.95 x

NOx allowable entission limit))).;. 2oo0Ibsiton

Where:

• Allowable limit = allowable limit rate in Ibs/MMBtu shown in Table 1 of

this Trading Agreement and Order.

• FLER = full load emission rate in Ibs&11'v1Btu as shown in Table I of this

Trading Agreement and Order.

• Discawlt (0.95) = 5% dtsign margin app]j~d tu tht alluwablt-limit ratt.

(ii) During the ozone season onlv (peak day calculation);

The maximum actual excess NOx emissions (in lbs) on any ofthe days projected by the

Commissioner to be "moderate to unhealthful," "unhealthful," or "very unhealthful,"

divided by 3 and then divided by 13 (with the result in tons):

EstimatedDERCs (in tons) use = [(Estimate excess NOx in Ibs).;. 3J.;. [13 Ibsldaylton]

b. No later than October 30 of2oo3, 2004, 2005 and 2006 calculate the DERCs used in tbe

preceding ozone season as the greater of:

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The Connecticut Resources

Recovery Authority

Trading Agreement and

Order No. 8116A

(i.) The actual total excess emissions for the ozone season in tons, as follows:

Acrua! DERCs (tons) use = {(Acrual fuel use in MMBtu)x((FLER)-(0.95 x 'Ox

allowable emission limit»)}-:- 20001bs/ton

OR

(ii) The maximum actual excess NOx emissions (in lbs) on any ofthe days projected by

the Commissio~er to be "moderate to unhealthful," "unhealthfuJ,'· or "very unhealthful,"

divided by 3 and then divided by 13 (with the result in tons):

Actual DERCs (in tons) used = [(Acrual excess NOx in Ibs) .;. 3J .;. [13 Ibs/day/ton]

As described in Exhibit I ofthis Trading Agreement and Order, to the extent that DERCs

used to offset on peak day basis exceed the total mass excess emissions, remaining

DERCs may be used in the non-ozone season in the same or subsequent years through

April 30. 2007.

c. During the non-Olone season starting on October 1. 2003: Until May 1, 2005,

from October 1, 2003, tlu"ough April 30, inclusive, each year, the peaking units

shall, in addition to meeting the 24-hour emission limit in Table 22-1 of Section

22a-174-22 ofthe Regulations, meet a non-ozone season emission limit of 0.15

Ib!MMBru. Prior to October I. 2003 and October I. 2004. CRRA shall have in its

possession sufficient approved DERCs or allowances for the non-ozone season to

comply with Section 22a.174.22(e)(3) of the Regulations based on the following

calculations.

Before the first day of each non-ozone season, eRR.A. shall estimate DERCs

required for such non~ozone season for the peaking units as follows:

Estimated DERCs (tons) use = [Estimated fuel use in MMBtu from October J through

April 30 x (Estimated maximum emission rate in lbsIMMBtu during October 1 tlu"ougb

April 30 - (0.95 x 0.15 Ib!MMBru))J.;. 2000 Ibslton

d. No later than May 31 of 2004 and 2005, calculate DERCs used in the preceding nooozone season as follows:

Actual DERCs (tons) used = [Acrua! fuel use in MMBru from October I through April 30

x (Acrual emission rate in IbsIMMBru during October I through April 30 - (0.95 x 0.15

IblMMBru))J .;. 2000 Ibs/ton

4. DERC use for the boiler: Until April 1.2007. before the first day of each month CRRA

shall have in its possession sufficient approved DERCs for the boiler based on the

following calculation.

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The Cormecticut Resources

Recovery Authority

Trading Agreement and

Order No. 8ll6A

a. Before the first day of each month, CRRA. shall estimate DERCs required for such

month for the boiler as follows:

Estimated DERCs (tons) use = {(Estimated fuel use in MMBtu)x«FLER)-(O.95 x

NOx allowable emission limit))}.;. 2000lbslton

Where:

• AlJowabl~ limit allowable limit rate in IbslMMBtu sbown in Table 1 of

this Trading Agreement and Order.

• FLER = full load emission rate in Ibs!M:MBtu as shown in Table I of this

Trading Agreement and Order.

• Discount (0.95) = 5% design margin applied to the allowable limit rate.

b. No later than the twentieth day of each month, calculate the actual DERCs used in

the preceding calendar month, as follows:

Actual DERCs (tons) used {(Actual fuel use in MMBtu)x«FLER)-(O.95 x NOx

allowable emission limit))}.;. 2000lbslton

5. _. BDERCs shall only be used by other NOx Budget Program sources located in Connecticut. BDERCs

shall only be used to offset ozone season excess emissions, and shall not be used for compliance

during the non-ozone season. BDERCs generated during a given year shall only be used during the

following ozone season. BDERCs are subject to all DERC requirements set forth in Litis Trading

Agreement and Order except for those requirements pertaining solely to non-ozone season DERCs

and as otherwise may be provided.

6. CRRA shall make and keep records of: daily fuel use and fuel type; excess NOx emissions; the

number ofDERCs in its possession, purchased and used (by serial number if assigned) each

month in accordance with the appropriate emission rates and limits in this Trading Agreement

and Order; the number ofDERCs used during the ozone' season and non-ozone season (the

remainder of the year); during the ozone season, tbc ozone c1assitication as forecasted by the

Commissioner on the previous day; as well as documentation attesting to the fact that approved

DERCs used during the ozone season were generated during the ozone season. Generator

certification ofthis fact shall be sufficient. CR.R.J\. shall maintain and submit such records to

the Commissioner in accordance with Section 22a-174-22 ofthe Regulations.

7. Record Keeping. CRRA shall retain records and supporting documentation as described in this

Trading Agreement and Order for a minimum of five years, commencing on the date such

records were created. CRRA shall maintain documentation to anest to the fact that the DERCs

used during the ozone season were generated during the ozone season. generator certification of

this fact shall be sufficient; and provide the records specified above to the Commissioner within

thirty (30) days ofreceipt of a written request from the Commissioner.

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The Connecticut Resources

Recovery Authority

Trading Agreement and

Order No. 8116A

8. Annual Emission Statement. No later than March 1 of every year after issuance of this

Trading Agreement and Order, CRRA" shall include with the Annual Emission Statement

provided to the Commissioner, a record of each sale or other transfer, and use of any and all of

the DERCs approved within and subsequent to issuance of this Trading Agreement and Order

until all such DERCs have been used or are no longer in CRR.A,,'s possession. CRRA shall also

include actual NOx emissions from each of the peaking units and the boiler and the amoWlt of

all DERCs used (including serial nwnbers (if assigned) and approved DERCs generated and/or

purchased from other facilities), generated and/or approved for the previous calendar year. . , These reports shalI be on a form prescribed by the Commissioner and shall be in monthly

increments, and for the peaking units by ozone and nOD-ozone seasons.

9. Allowance Use. Pursuant to Section 22a-174-22(e)(3) ofthe Regulations, CRRA may use NOx

allowances, until May 1, 2005 for the peaking units and through April 30, 2007, for the boiler

pursuant to Section 22a-174-22(j) ofthe Regulations to achieve all or a portion ofthe

reductions required by section 22a-174-22 ofthe Regulations. Any allowance used for

compliance with Section 22a-174-22(e) ofthe Regulations shall be subject to all restrictions

and/or requirements applicable to DERCs contained in this Trading Agreement and Order;

a . In order for CRRA to use NOx allowances, CRRA shall create a general account or

use an existing compliance accoWlt or overdraft accoWlt in EPA's NOx Allowance

Tracking System ("NATS"); and ~.",

.' ) .~ b. 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 22a-174-22 ofthe Regulations when

they are transferred from the facility's NOx general account in the NATS or the

facility's Nox compliance aCCOUDt in the NATS to the CT State NOx Retirement

Account (Account ID·CTOOOOOOO300 in the NATS).

10. DERC Doubling. At a minimum, DERCs required shall be adjusted upwards by 100% if

DERCs are not in CRRA's possession prior to use. However, based on the gravity ofthe

noncompliance, the Commissioner may require additional upward adjustment.

11. VintaQe Restriction. For the purposes of compliance with Section 22a-174-22 of the

Regulations, DERCs/allowances shall only remain valid for five (5) calendar years from the

year ofthe generation/allocation ofsuch DERCs/allowances. DERCsiallowances older than

five (5) calendar years from their creation/allocation are not valid for use for compliance with

Secrion 22a-174-22 ofthe Regulations. Notwithstanding the above, DERCsialiowances

generated/allocated prior to calendar year 2000 are valid for use for compliance with Section

22a-174-22 of the Regulations up to and including December 31, 2004.

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12. FLER Exceedance.. oncompliance with an established FLER shall subject CRRA to make

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

I00% premium. The true up in tons ofDERCs shall be equal to the FLER exceedance in

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The Connecticut Resources

Recovery Authority

Trading Agreement and

Order No. 8116A

IbslMMBtu, multiplied by the total heat input during the period of noncompliance divided by

2000 lbs/ton. If the period of noncompliance is not known, the time period from the

completion of the last/previous Department witnessed emission test through the date the FLER

compliance is achieved as approved by the Commissioner shall be used. However, nothing in

this Trading Agreement and Order shall affect the Commissioner's authority to institute any

proceeding or take any other action to require additional upward adjustment, based on the

gravity of any alleged noncompliance or violation of law.

13. FLER Modification. FLE.Rs set forth in Table 1 ofthis Trading Agreement and Order may be

modified only after the consent ofthe Commissioner by written modification ofthis Trading

Agreement and Order.

14. Emissions Testing. Pursuant to Section 22a-174~22(k) ofthe Regulations CRRA shall conduct

NOx emission tests ofthe peaking units and boiler at least once every five years commencing

from the dates ofthe emission tests for the peaking units and boiler as provided in Table 1 of

this Trading Agreement and Order.

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15. Extension. No later than May 1, .2005, with respect to the peaking units, CRRA shall comply

with the requirements of Subdivision 22a~ 174~22(d)(l) of the Regulations. No later than April

30, 2007, with respect to the boiler, CRR.A... shall comply with the requirements of Subdivision

22a-174-22(d) of the Regulations. However, after full program review of this and other

Trading Agreements and Orders and, if determined to be appropriate, the Commissioner may

grant a written extension ofthis Trading Agreement and Order.

16. Future Compliance Report. On or before September 1,2004, CRRA shall submit.a report

indicating how the facility shall comply with Section 22a~ 174~22 ofthe Regulations with

respect to the peaking units on and after May 1, 2005. On or before September 1, 2006, CRRA

shall submit a rep0r! indicating how the facility shall comply with Section 22a~174·22 of the

Regulations with respect to the boiler on and after May 1,2007.

17. Full compliance. CRRA shall not be considered in full compliance with this Trading

Agreement and Order until all actions required by this Trading Agreement and Order have heen

completed as approved and to the Commissioner's satisfaction.

18. Approvals. CRRA shall use best efforts to submit to the Commissioner all documents required

by this Trading Agreement and Order in a complete and approvable form. lfthe Commissioner

notifies CRRA that any document or other action is deficient, and does not approve it with

conditions or modifications, it is deemed disapproved, and CRRA 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 of the 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 perfonned or with such conditions or

modifications as the Commissioner deems necessary to carry out the purposes of this Trading

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

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The Connecticut Resources

Recovery Authority

Trading Agreement and

Order o.8116A

19. Definitions. As used in this Trading Agreement and Order, "Approved DERCs" are those for

which the Commissioner has provided '."ntteD authorization for use in compliance with Section

22a-174-22 of the Regulations; "Commissioner" means the Commissioner or a representative

ofthe Commissioner; "Ozone season" means the period from May 1 through September 30 in

any given calendar year. 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.

20. 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 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, Sunday or Connecticut or federal holiday.

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21,· Certification of documents. Any document, including but not limited to any norice, which is

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

signed by CRRA or, if CRRA is not an individual, by Respondent's chief executive officer or a

duly authorized representative ofsuch officer, as those tenns are defined in §22a-430-3(b)(2) of

the Regulations ofConnecticut State Agencies, and by the individual(s) responsible for actually

preparing such document, and CRRA or CRRA chief executive officer and each such

individual shall certify in writing as follows:

"I have personally examined and am familiar with the infonnation submitted in this

document and all attachments thereto, and I certify, based on reasonable investigation,

including my inquiry of those individuals responsible for obtaining the information, that

the !\uhmiued information is mle, accurate and complete to the best of my knowledge and

belief. I understand that any false statement made in the submitted inforrnation is

punishable as a criminal offense under §53a-157b ofthe Connecticut General Statutes and

any other applicable law."

22. Noncomoliance. This Trading Agreement and Order is a frnal order of the 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 C~ to an injunction

and penalties.

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0' -j. False statements. Any false statement in any information submitted pursuant to this Trading

Agreement and Order is punishable as a criminal offense under §53a-157b of the Connecticut

General Statutes and any other applicable law.

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The Connecticut Resources

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Trading Agreement and

Order No. 8116A

24. Notice of transfer: liability ofCRR>\. Until CRRA has fully complied with this Trading

Agreement and Order, CRRA shall notify the Commissioner in writing no later than 15 days

after transferring all or any portion of the facility, the operations, the site or the business which

is the subject ofthis Trading Agreement and Order or after obtaining a new mailing or location

address. CRRA's obligations under this Trading Agreement and Order shall not be affected by

the passage of title to any property to any other person or municipality.

I

25. 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 detennmes that the actions taken by CRRA 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 CRRA to undertake further investigation or further action to prevent

or abate violations or pollution.

26. CRRA's obli2ations under law. Nothing in this Trading Agreement and Order shall relieve

CRRA of other obligations under applicable federal, state aod local law.

27. No assurance bv 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 CRRA pursuant to this Trading Agreement 2Ild -Order

will result in compliance or prevent or abate pollution.

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28. Access to facilitv. Any representative ofthe Department ofEnviromnental Protection may

enter the facility without prior notice for the purposes ofmonitoring and enforcing the actions

required or allowed by this Trading Agreement and Order.

29. NQ effect on rights of other persons. This Trading Agreement and Order neither creates nor

affects any rights of persons or municipaJitie.c; that are not parties to this Trading Agreement and

Order.

30. No Creation ofPropertv RiQhts. This Trading Agreement and Order does not create any

property rights with respect to those DERCs.

3]. Notice to Commissioner of changes. Within 15 days of the date CRRA becomes aware of a

change in any information submined to the Commissioner under this Trading Agreement and

Order, or that any such information was inaccurate .or misleading or that any relevant

information was omined, CRRA shall submit the correct or omined infotmation to the

Commissioner.

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The Cormecticut Resources

Recovery Authority Trading Agreement and

Order No. 8116A

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32. Notification of noncompliance. In the event that CRRA. 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, CRR",- 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, CRRA shall submit in

writing the date, time, and duration ofthe noncompliance and the reasons for the

noncompliance or delay and1propose, for the review and written approval ofthe Commissioner,

dates by which compliance will be achieved, and CRRA shall comply with any dates which

may be approved in writing by the Commissioner. Notification by CRRA shall not excuse

noncompliance 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.

Submission of documents Any document required to be submitted to the Commissioner under

this Trading Agreement and Order shall, unless otheI"'Nise specified in this Trading Agreement

and Order or in writing by the Commissioner, be directed to:

Mrs. Elizabeth McAuliffe

Emissions Trading Unit

Compliance and Field Operations Division

5th Floor

Bureau ofAir Management

Department ofEnvironmental Protection

79 Elm Street

Hartford, Connecticut

06106

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The Connecticut Resources

Recovery Authority

Trading Agreement and

Order No. 8116A

CRRA. consents to the issuance of this 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 CRRA to the tenns and conditions of the Trading Agreement and Order.

Connecticut Resources Recovery Authority

(I

l /,,,1 Q3

Thanas D. Kirk

President

Signature:

Type Name:

Type Title:

Date:

Issued as a final order of the Commissioner ofthe Department of

...... Unvironmental Protection on*',2003.

_' I

Arthur J. oeque, Jr.

Commissi ner

CITY OF HARTFORD LAND RECORDS

MAILED CERTIFIED MAIL,

RETURN RECEIPT REQUESTED

Certified Document

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