Trace every reported figure back to the meter, monitor or invoice behind it, with the factor version it used, and hold the report for the designated representative who certifies under penalty of law.
A monitor goes out of control, and the quality-assurance status of the value goes on the record with it.
02
A gap opens in monitoring data, and the substitute value reaches the report marked as substituted.
Reason
03
A quarter closes, and 40 CFR 75.64 allows 30 days and a computer-to-computer transfer.
04
A unit carries add-on controls, and its substitutes must not systematically underestimate.
05
A factor set is revised, and every figure carries the factor version and the period it applies to.
Decide
06
An annual report falls due, and 98.3(b)(6) moved reporting year 2025 to 30 October 2026.
07
A representative changes, and the requirement sits in 40 CFR 72.20, not the monitoring part.
Out
08
A repeal is proposed, and 90 FR 44591 was still only proposed on 23 August 2026.
09
Execute write actions only inside the approval boundaries agreed during implementation.
→Product statement
The agent assembles and reconciles. The named person is the designated representative — one individual, who certifies under penalty of law and submits.
Example workflow
One value, meter to certification
AgentHuman
1Value evidence receivedMeter readings, fuel invoices, monitor records or factor sets
2Value provenance assembledThe unit, the monitor behind it, the factor version applied and the period it covers
3Report assembledThe values, their sources, the substitutions and completeness
4Controls appliedProvenance checks, quality-assurance checks, factor checks and completeness confidence
No human action required
Stages 1 to 4 run unaided, and nothing is certified at any of them — the agent is assembling, and the compliance lane opens at the completeness gate.
5DecisionDivides at the completeness gate
Provenance complete
Goes to the designated representative to certify.
Anything substituted
Adds an environmental engineer read first.
Compliance review
The report is held with its values, its substitutions and the units they sit on.
Certify and submit · Append evidence · Send to review
Submitted — by the designated representative▼
6Monitoring and unit records updatedOnly where write access and records policy allow it
7Outcome evaluatedProvenance completeness, substitution rate, engineer corrections and what review found
Corrections
Each engineer correction is counted in the evaluation.
What should not run autonomously
Human approval stays in control
Outside the boundary — human approval required8 items
Certifying under penalty of law under 40 CFR 98.4(e)(1).
Submitting an annual or a quarterly report to the agency.
Stating that monitoring data met the Part 75 procedures.
Deciding that a substitute value may stand unexplained.
Automation boundaryAgent acts unaided
✓Assemble each figure with the meter or monitor reading behind it.
✓Record the emission factor version that was applied.
✓Mark every substitute value and the reason it was substituted.
✓Carry forward the quality-assurance status of every.
Nothing is certified or submitted except by the named representative or alternate.
Judging whether a reported figure is in fact accurate.
Telling a regulator the estate reported completely.
Setting which source categories a facility reports under.
Changes to monitoring data, factors or reported values.
Example output
One value, annotated
Our sustainability reporting copilot applies your framework mapping; the same meter reading feeds this report, and only this one carries a prison term.
Report assembly · single valueIllustrative example
Value
Recorded as
Unit
Evidence of record
Confidence
Held for
Quarterly mass emissions, Part 75
Measured, quality-assured, not substituted
Unit 3, main stack
Continuous monitor record, 4 August 2026
Held uncertified
The designated representative, by name
As receivedTaken from the continuous monitor and the quality-assurance record — it reaches as far as those sources do.
What the record holdsMonitor record and dateQuality-assurance statusSubstitute values, dated
Why no accuracy call hereAccuracy is what the representative certifies to, not a model output.
ActionCertify and submitAppend evidenceSend to review
What the score decidesBelow the configured threshold the report picks up an engineer read before.
Value
Where AI adds value
The same four claims, placed at the point in the workflow where each one applies.
Where the value landsValue 01 – 04
Every valueFrom the monitor that produced it
03Provenance
Where the report is used
Our compliance reporting assistant assembles a register and names no regime; this page is one statute, with one deadline and one named individual.
01Approved path
One person, personally examined
40 CFR 98.4(b) wants an individual, selected by an agreement binding on the owners and operators; a corporation cannot serve.
02Human review
What was checked, and what was not
The September 2025 reconsideration was still a proposal on 23 August 2026, checked three ways; one state adopted mandatory reporting against that rollback.
04Build an evidence trail
The value, the monitor it came from and the representative who certified stay on the report.
Integrations
Typical integrations
Five system groups connect to the same agent. Which of them are in scope is decided in discovery.
Continuous monitoring systemsCEMS · DAHS historian Quality-assurance records
Fuel and material recordsInvoices · fuel sampling Meter readings
Emission factors and versionsPart 98 subpart factor sets Global warming potentials
Agent
Emissions data certification
Reads the monitors Assembles the values Holds for the representative
Reporting and submissione-GGRT · Part 75 transfer Certificate of representation
A unit-level value-provenance figure can read clean while units on substitute data carry most of the corrections. Nestack reports the correction rate by unit type, not only in total.
Slice performance — reported separately, not only in aggregateIllustrative example
Slice
Failure rate
Lift
Lift vs. threshold
Status
Units on substitute data
8.0%
3.6×
Review
Units with add-on controls
5.7%
2.6×
Review
Combustion units on fuel records
3.5%
1.6×
Watch
Units on continuous monitors
2.0%
0.9×
Normal
Bar: correction-rate lift vs. continuously-monitored unit baseline · scale 0–4.0× · tick marks the 2.0× review threshold2 of 4 slices over threshold
Evidence-linked improvement
What an unexplained substitute costs
A cycle ends when the unexplained substitute value is a standing case. That suite is what the next report assembled is measured against.
Improvement cycle · five stagesSwitchback — the path turns at Improve and returns at Learn
01Detect
Correction rate rises on units running substitute data.
02Diagnose
The hour of missing monitor data that nobody could explain nine months on is read back until one cause remains.
03Improve
Changes leave numbered, and the values behind them travel attached.
04Verify
A single failing value case is enough to stop the release.
05Learn
The case is kept, and the substitution rules are rewritten alongside it.
Learn → DetectThe return edge. The next report is measured against a suite one case longer.
Typical build scope
Twelve workstreams across six weeks
The build scope read against the delivery timeline. Week structure follows the six-week plan — discovery, sources, evidence assembly, evaluation, integration, then production validation and handover.
WorkstreamWeek 1Week 2Week 3Week 4Week 5Week 6
01Reporting-duty discovery and automation-boundary work.
02Monitor, fuel and factor sources.
03Value-to-source and quality-assurance mapping.
04Value evidence ingestion.
05Unit, monitor and factor binding.
06Completeness scoring and review routing.
07Representative certification workflow.
08Historian and monitor integration.
09Substitution and factor cases.
10Guardrails and representative controls.
11Value-trail instrumentation.
12Deployment, documentation and Agent Care handover.
12 workstreams · 6 weeks · bar shows the weeks a workstream is active — several run in parallelFinal scope and sequence confirmed in discovery
Engagement tiers
What each tier includes
Rows are the capabilities named in each tier's scope. Higher tiers include everything below them.
Capability✓ in scope · — not at this tierPilotOne unit type, one yearProductionProduction reporting workflowAdvancedMultiple units / facilities
Introduced at Pilot
Report assembly to your monitors✓✓✓
Designated-representative release✓✓✓
Monitor-provenance baseline✓✓✓
Introduced at Production
Reporting by unit—✓✓
Certification workflow in your systems—✓✓
Approved write-back—✓✓
Historian and monitor integration—✓✓
Introduced at Advanced
Multi-facility reporting duties——✓
Cross-programme evidence packs——✓
Large monitored estates——✓
Multi-programme certification controls——✓
Build priceFrom $5,000From $8,000Custom quote
Final build priceConfirmed after discovery based on integrations, workflow complexity, transaction volume, approval controls and deployment requirements.
Separate from buildBuild pricing is separate from recurring Agent Care, which covers managed monitoring, evaluations, incidents and verified improvements after launch.
What we need from you
What you bring, and what we build with it
Each input maps to a piece of build scope and a week in the delivery timeline.
You bringWe build with it
01Your reporting units and their source categories→Unit-inventory mapping and value captureWeek 1
02Representative meter, monitor and fuel records→Source binding, factor logic and the provenance baselineWeek 2
03Your certificate of representation under 40 CFR 98.4(d)→Value mapping, source binding and the automation boundaryWeek 1
04Access to relevant APIs, feeds or exports→Monitor, historian and fuel-record assessment, then integration setupWeek 2
05Values you would not want certified→Substitution cases and the evaluation suiteWeek 4
06What no emissions report may imply→Completeness scoring, engineer routing, guardrails and certification controlsWeek 3
07A designated representative, and an alternate if named→Certification workflow, then pilot and production validationWeeks 5–6
Nothing else is requiredDeployment, documentation and Agent Care handover are ours.
Delivery timeline
Four phases across six weeks
The bars are drawn to the weeks the work genuinely takes, which is why the fifth one carries a pair.
PhaseW1W2W3W4W5W6
DiscoveryW1
BuildW2 – W3
EvaluateW4 – W5
Pilot & LaunchW5 – W6
Week focusW1Reporting workflow discovery, value mapping and the automation boundaryW2Source integration and the value-provenance baselineW3Report assembly, factor logic and release controlsW4Evaluation suite, substitution cases and failure-mode testingW5Record integration, pilot reports and targeted correctionsW6One reporting year run under the designated representative, then Agent Care handover
Reading the bandA bar covers only the weeks its own work is named for, and the fifth week carries two because the work does.
At the end of W6When the emissions record validates, Agent Care picks the agent up.
DurationSix-week plan shown · typical delivery 4–6 weeks depending on scope confirmed in discovery.
Next step · Energy AI agent
Build an emissions data agent around the values one person has to personally examine.
Show us one reported figure and the monitor behind it. Not a framework workpaper. A statutory report certified under penalty of law, due 30 October 2026 under 98.3(b)(6). Site permit conditions and deviation reports are a different agent.
