Note: This is a 2-page excerpt from a recent compliance impact brief. Company name and specific facility data have been redacted. This is the format and depth you will receive.

Sample: Compliance Impact Brief (Excerpt)

Executive Summary

Rule: 40 CFR Part 60, Subpart [X] — Continuous Emissions Monitoring Requirement

Effective Date: December 1, 2026

Affected Entity: [Company Name], [Facility Location]

Bottom Line: Your facility's current manual monitoring schedule (quarterly stack tests) is no longer sufficient. You must install and calibrate a Continuous Emissions Monitoring System (CEMS) for SO2 and NOx before December 1, 2026. Failure to comply carries a penalty of $65,000 per day (42 U.S.C. §7413(a)).

Estimated Compliance Cost: $180,000–$340,000 (CEMS equipment + installation + 12-month calibration contract). See Section 4 for line-item breakdown.

Recommended Action Deadline: Issue RFP for CEMS vendor by October 31, 2026. Install by November 15, 2026. Calibrate and submit initial compliance report by December 1, 2026.

— Page 1 —

What Changed (Plain English)

Before this rule: Facilities emitting between 100 and 250 tons/year of SO2 or NOx could use manual monitoring (quarterly stack tests by a certified engineer). This was sufficient for compliance under 40 CFR Part 60.

After this rule: Facilities emitting more than 100 tons/year (the threshold dropped from 250 to 100) must use continuous monitoring. Manual stack tests are no longer an acceptable compliance method above the 100-ton threshold.

What this means for your facility: Your 2025 emissions report shows 187 tons/year of SO2. You are above the new 100-ton threshold. Your current quarterly stack test schedule is no longer compliant. You need a CEMS.

What You Need To Do (With Deadlines)

By Oct 31: Issue RFP to 3+ CEMS vendors. Request quotes for equipment + installation + 12-month calibration.

By Nov 15: Complete CEMS installation. Begin 30-day calibration period.

By Dec 1: Submit initial compliance report to EPA Region [X]. Include calibration data, installation certification, and ongoing monitoring schedule.

Ongoing: Monthly CEMS data review. Annual calibration. Quarterly reports to EPA.

Penalty if you miss December 1: $65,000 per day. EPA enforcement is automatic for CEMS non-compliance (no "cure period" under the 2026 amendments).

— Page 2 —

← Back to all services

Order: $2,997 — Compliance Impact Brief (24hr delivery)