Energy AI agent · Emissions data certification
Emissions Data Certification AI Agent
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.
- Typical delivery
- 4–6 weeks
- Deployment
- Your stack
- One individual
- Value-bound
- After launch
- Agent Care
What this agent does
Assembles the figures, not the certification
In
- 01
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
- 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.
Goes to the designated representative to certify.
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 required
8 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 boundary
Agent 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 value
Illustrative example- Value
- Quarterly mass emissions, Part 75
- Recorded as
- Measured, quality-assured, not substituted
- Unit
- Unit 3, main stack
- Evidence of record
- Continuous monitor record, 4 August 2026
- Confidence
- Held uncertified
- Held for
- The designated representative, by name
As received
Taken from the continuous monitor and the quality-assurance record — it reaches as far as those sources do.
What the record holds
- Monitor record and date
- Quality-assurance status
- Substitute values, dated
Why no accuracy call here
Accuracy is what the representative certifies to, not a model output.
What the score decides
Below the configured threshold the report picks up an engineer read before.
Action
Certify and submitAppend evidenceSend to reviewValue
Where AI adds value
The same four claims, placed at the point in the workflow where each one applies.
Where the value lands
Value 01 – 04
Every value
From the monitor that produced it
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.
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.
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.
Build 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 systems
- CEMS
- DAHS historian
- Quality-assurance records
Fuel and material records
- Invoices
- fuel sampling
- Meter readings
Emission factors and versions
- Part 98 subpart factor sets
- Global warming potentials
Agent
Emissions data certification
- Reads the monitors
- Assembles the values
- Holds for the representative
Reporting and submission
- e-GGRT
- Part 75 transfer
- Certificate of representation
Observability & evaluation
- OpenTelemetry
- Langfuse
- Supported monitoring/evaluation sources
Integration availability depends on the client's existing systems and API access.
Agent controls
Six filters between the model and the representative
Six filters set in series, each finer than the one before. Whatever survives is set out in the map below.
L6 · Outermost — last line of defence
Inward → L1 · closest to the model
- L1 – L2
- Test whether a report may stand
- L3
- Puts the certification in a person's hands
- L4 – L5
- Keep the value and the monitor behind it
- L6
- Holds the report uncertified when signals degrade
How Nestack evaluates it
Evaluate the whole assembly — not only the report that comes out.
Coverage runs the whole depth of the workflow, and every layer is cut by slice.
Surface — the report a representative certifies
- E1Final-output evaluationDid the report carry the source behind every value?
- E2Step-level evaluationDid the agent read the right unit, the right monitor and the live factor set?
- E3Tool evaluationDid it read and write the correct unit record and the correct period?
- E4Confidence calibrationDo low-confidence reports actually attract more engineer corrections?
- E5Slice evaluationHow does performance change across specific unit types?
- E6Business outcomeHow many reports needed a correction before the representative certified?
Floor — the outcome the owners and operators answer for
Failure modes
Where each failure originates in the agent
Seven failure modes, placed at the stage in the agent where each starts.
Agent lifecycle
Direction of processing →
01 · Retrieval
1 mode
- JA-03
Stale factor read
The factor set read is not the one the period requires.
Stage gathers
The units, the monitors, the factors and the periods
02 · Reasoning
2 modes
- JA-04
Value asserted, not sourced
A figure is reported without the record behind it.
- JA-06
Proposed repeal read as final
The September 2025 proposal is worked as if final.
Stage proposes
The values, their sources and their completeness
03 · Tool / write
2 modes
- JA-02
Thin report passed forward
A report moves on without the engineer read.
- JA-05
Value bound to wrong unit
A reading is filed against the wrong unit.
Stage writes
Only where write access and approval policy allow it
04 · Output
1 mode
- JA-01
Certified, provenance unrecorded
The report shows a figure but not what produced it.
Stage returns
The report a representative certifies and submits
05 · Change / Version
1 mode
- JA-07
Silent factor regression
A factor update moves the value, not the record.
Stage tracks
Model, prompt, factor sets and report fields
- Sev-1 · a report certified on no provenance
- Sev-2 · a wrong value reaches the report
- Sev-3 · source degrades, report uncertified
Affected slices
Substitute data absorbs the corrections
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 aggregate
Illustrative 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 threshold
2 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 stages
Switchback — the path turns at Improve and returns at Learn
- 01
Detect
Correction rate rises on units running substitute data.
- 02
Diagnose
The hour of missing monitor data that nobody could explain nine months on is read back until one cause remains.
- 03
Improve
Changes leave numbered, and the values behind them travel attached.
- 04
Verify
A single failing value case is enough to stop the release.
- 05
Learn
The case is kept, and the substitution rules are rewritten alongside it.
Learn → Detect
The 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.
Workstream
Week 1Week 2Week 3Week 4Week 5Week 6
- 01Reporting-duty discovery and automation-boundary work.Week 1
- 02Monitor, fuel and factor sources.Week 1, Week 2
- 03Value-to-source and quality-assurance mapping.Week 1, Week 2
- 04Value evidence ingestion.Week 2
- 05Unit, monitor and factor binding.Week 2, Week 3
- 06Completeness scoring and review routing.Week 3
- 07Representative certification workflow.Week 3, Week 4
- 08Historian and monitor integration.Week 5
- 09Substitution and factor cases.Week 4, Week 5
- 10Guardrails and representative controls.Week 4
- 11Value-trail instrumentation.Week 5, Week 6
- 12Deployment, documentation and Agent Care handover.Week 6
12 workstreams · 6 weeks · bar shows the weeks a workstream is active — several run in parallel
Final 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 tier | PilotOne unit type, one year | ProductionProduction reporting workflow | AdvancedMultiple 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 price | From $5,000 | From $8,000 | Custom quote |
- Final build price
- Confirmed after discovery based on integrations, workflow complexity, transaction volume, approval controls and deployment requirements.
- Separate from build
- Build 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 bring
We build with it
01Your reporting units and their source categories
→Unit-inventory mapping and value capture
Week 102Representative meter, monitor and fuel records
→Source binding, factor logic and the provenance baseline
Week 203Your certificate of representation under 40 CFR 98.4(d)
→Value mapping, source binding and the automation boundary
Week 104Access to relevant APIs, feeds or exports
→Monitor, historian and fuel-record assessment, then integration setup
Week 205Values you would not want certified
→Substitution cases and the evaluation suite
Week 406What no emissions report may imply
→Completeness scoring, engineer routing, guardrails and certification controls
Week 307A designated representative, and an alternate if named
→Certification workflow, then pilot and production validation
Weeks 5–6
Nothing else is required
Deployment, 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.
Phase
W1
W2
W3
W4
W5
W6
- DiscoveryW1
- BuildW2 – W3
- EvaluateW4 – W5
- Pilot & LaunchW5 – W6
Week focus
W1Reporting workflow discovery, value mapping and the automation boundary
W2Source integration and the value-provenance baseline
W3Report assembly, factor logic and release controls
W4Evaluation suite, substitution cases and failure-mode testing
W5Record integration, pilot reports and targeted corrections
W6One reporting year run under the designated representative, then Agent Care handover
- Reading the band
- A 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 W6
- When the emissions record validates, Agent Care picks the agent up.
- Duration
- Six-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.
- Typical delivery
- 4–6 weeks
- Deployment
- Your monitoring estate
- One individual
- Value-bound
- After launch
- Agent Care available
Nestack Agents · Emissions data
AGT-EN-13 · Agent Care available after launch