A proposed consent decree and settlement agreement under RCRA and CERCLA relating to debtors' non-performing properties will be incorporated into the debtors' proposed Chapter 11 plan; under the agreement, debtors must transfer certain properties to an environmental response trust or trusts, and certain secured creditors must make payments to the trusts and pay the full penal sum of certain surety bonds issued for environmental liabilities for certain of the non-performing properties.