by Robert B. McKinstry Jr., Brendan K. Collins, and Jennifer E. Drust (July 2010; 13 pages) The authors of this article argue that comprehensive regulation of greenhouse gas emissions will occur regardless of whether Congress acts or not. They say regulatory actions by the Environmental Protection Agency, guidance from the White House Council on Environmental Quality and the Securities and Exchange Commission, efforts by many states, and potential legal liabilities all will act to put a price on carbon dioxide emissions, creating business risks and opportunities that should play a part in corporate and governmental planning. The authors also say there now is an opportunity to develop a comprehensive federal program that incorporates existing state and regional programs, displaces legislation by judicial fiat, and creates a North American emissions trading regime.