President Barack Obama is calling on members of Congress to do something about climate change.

But it’s becoming increasingly clear that the real action on greenhouse gas and global warming, and the impact that action will have on business, is coming not from the halls of Congress, but from various regulatory agencies with leaders appointed by the president.

In his State of the Union Address Wednesday, Obama called on the U.S. Senate to pass legislation limiting greenhouse-gas emissions, as the House has already done. Such legislation could help spur whole new industries in clean energy and energy efficiency. It could also raise the cost of energy and damage the economies of states that rely on coal, oil, and natural gas for jobs and business.

Still, said Obama: “to create more of these clean-energy jobs, we need more production, more efficiency, more incentives. That means building a new generation of safe, clean nuclear power plants in this country. It means making tough decisions about opening new offshore areas for oil and gas development. It means continued investment in advanced biofuels and clean-coal technologies. And, yes, it means passing a comprehensive energy and climate bill with incentives that will finally make clean energy the profitable kind of energy in America. I am grateful to the House for passing such a bill last year. This year, I am eager to help advance the bipartisan effort in the Senate. I know there have been questions about whether we can afford such changes in a tough economy; and I know that there are those who disagree with the overwhelming scientific evidence on climate change. But even if you doubt the evidence, providing incentives for energy efficiency and clean energy are the right thing to do for our future—because the nation that leads the clean-energy economy will be the nation that leads the global economy. And America must be that nation.”

But the president is no dummy. He knows that such legislation may be an even tougher sell than health care in the Senate—and health care has clearly been no walk in the park. The fault lines on this issue aren’t just partisan, but geographic, and Democrats from coal states like West Virginia could wind up among the toughest opponents to climate-change legislation.

And there are other ways to move that particular ball forward that don’t involve Congress. They’ve been under way for months and were on display Wednesday as well.

Far from the pageantry of the president’s address to the joint session of Congress, the Securities and Exchange Commission on Wednesday changed the reporting rules for public companies so that now they’ll have to take into account the risks and rewards of climate change in their reports to investors. It’s a change the activist, and powerful, California Public Employees Retirement System, as well as others, has long wanted.