opportunities to identify additional gaps and areas for improvement. It’s worth mentioning that it’s also a good idea to step out of your routine operating rhythm and evaluate and assess whether any factors have changed at some regular cadence, potentially at the six or twelve-month mark. Use this opportunity to determine if any circumstances have changed that would require you to re-evaluate your current compliance plans. A few questions to ask yourself: › Have new risks arisen? › Has staff turnover created knowledge gaps? › Have operating processes changed? › Are there new obligations on the horizon? › Have market factors shifted in a significant way? When companies install a new piece of equipment, they often go through rigorous Management of Change processes to ensure risks are identified and accounted for. Using a similar, careful, rigorous Management of Change mindset when it comes to your business and environmental planning can help ensure that the cumulative impact of small changes is evaluated. In 2020, a large asset management firm took voting action against 53 companies and told 191 more they were on watch for “making insufficient progress integrating climate risks into their business models and/ or disclosures,” which has presented a rapid market shift for companies looking to gain access to investor capitol, particularly in the European Union. As a cautionary tale: in the United States, seven large utility companies were charged with violating the Clean Air Act , including one company who received a Notice of Violation and a $14 million fine for making a series of small changes to their operating equipment, with the EPA ruling that the cumulative effect of the changes required they get a New Source Review permit. 12 © CORITY SOFTWARE INC.