The United States of America, United Technologies Corporation, and Carrier Corporation (?UTC/Carrier,?) (collectively ?the Parties?) hereby jointly move to modify the First Amended Consent Decree entered in this matter on April 28, 2006, (?Consent Decree?) [Doc. No. 29], and in support thereof state as follows:
1.The Consent Decree provides, among other things, for the implementation byUTC/Carrier of a specified portion of an Interim Record of Decision (?InterimROD?) issued by the United States Environmental Protection Agency,(?EPA?) .
2.The Consent Decree was executed by the Parties, submitted to public comment, and entered as an Order of the Court on April 25, 2006.
3.Attached to the Consent Decree is the RD/RA Statement of Work (?SOW?) which sets forth technical obligations for undertaking the work defined under the Consent Decree.