As you know, there has been a fairly sustained clamor for the
SEC to impose a requirement for climate change and sustainability
disclosure. For example, in May, the SEC's Investor Advisory
Committee recommended that the SEC "set the framework"
for issuers to report on material environmental, social and
governance information, concluding that "the time has come for
the SEC to address this issue." (See
this PubCo post.) However, SEC Chair Jay Clayton and others at
the SEC have been fairly vocal about their reluctance to impose a
prescriptive sustainability disclosure requirement beyond
principles-based materiality. But what about a narrower request? A
mandate for just a single piece of information? This rulemaking
petition filed by Impax Asset Management LLC, investment
adviser to Pax World Funds, a "specialist asset manager
investing in the transition to a more sustainable economy,"
requests that the SEC "require that companies identify the
specific locations of their
