Over the last seven months we have witnessed a flood of greenhouse gas (GHG)— related activityat the Securities and Exchange Commission (SEC), the Commodities Futures Trading Commission(CFTC), and the Environmental Protection Agency (EPA). The guidance and rulemaking that hasemanated from these departments of the Executive Branch have transformed GHG fromenvironmental compliance data to financial data that must be managed by corporate leaders just likeinventory and other expenses that directly affect competitiveness. In the face of this tectonic shift inthe regulatory environment, it would be a mistake to assume that the absence of climate legislationmeans that companies can postpone efforts to gain control over this new cost center.
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