Football authorities' environmental reporting
Insights from the annual reports of The FA, Premier League and EFL
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This post delves into the streamlined energy and carbon reporting (SECR) of three football authorities in England - The Football Association (FA), the Premier League, and the English Football League (EFL). Their SECRs are in their annual accounts.
These bodies have different objectives, structures and rules and regulations that they set for others. So I will not make comparisons between the size of their emissions here. Yet, looking across their reports some important themes emerging.
In summary, there have been practical steps forward with individual initiatives. But progress at a strategic level is very mixed, and a step up in pace, ambition, and implementation is needed. Collaboration between these bodies and with others is crucial, and other countries are taking steps that can help provide lessons.
If you want a reminder on different emission scopes look here. And a final note before you head in - the reporting by these authorities does not cover emissions by clubs. See here for more on clubs. Otherwise, here we go …
The FA
The FA annual accounts are here. The FA has responsibility for Wembley Stadium, the England national football teams, and more. This means their emissions and energy use are in the same ballpark as some Premier League clubs.
The FA reports scope 1 and 2 emissions of 7,269 tCO2e for 2021/22 (down 17% on 2019/20). For reference, Spurs reported 7,888 tCO2e and Chelsea 6,621 tCO2e emissions for the same period.
The figures presented here on scope 3 emissions only meet the minimum mandatory reporting requirements. Scope 3 emissions form by far the biggest share of emissions in football. Regular readers will have heard me bang on about this in previous posts. Without knowing these we only get a very limited picture of the full carbon footprint of the FA and also where the opportunities to reduce emissions lie.
For instance, what are the emissions due to fan travel to Wembley for FA Cup matches? Could they reduce them by hosting elsewhere? What is the size of emissions due to sales of England merchandise? (Liverpool reported 117,598 tCO2e of emissions in 21/22 due to merchandising).
A further section in the annual accounts also covers sustainability. It starts with the statement that:
The climate crisis is one of the most pressing issues of our time. At its current rate, climate change will have a wide-reaching impact on all of us. In football, we’re already seeing matches affected due to extreme weather – particularly in our grassroots communities.
Elsewhere, Debbie Hewitt, Chair of the FA has said that:
“something like 120,000 games a season [are] cancelled because the pitches are not playable”.
I’m not at all surprised by this figure having seen several of my son’s U12 matches cancelled due to extreme weather. It would be good to be able to dig into this FA data further. For instance, how many games are cancelled due to extreme weather? Are there any patterns over time? If anyone knows if that data might be made available then please say!
The section on sustainability also lists 12 sustainability achievements and goes on to say:
“We are developing our longer-term sustainability strategy, due to be published in Spring 2023, and this will cover all activity across our organisation – as well as our venues at Wembley Stadium and St. George’s Park. The strategy will set out our plan to make a positive impact on the environment and the communities in which we operate by 2028, promote circular economic practices and embed strong sustainability governance across the game.”
It’s good news that we can expect further progress very soon. Keep your eyes peeled for it, and a post here looking into it.
Finally, the FA has over 500 employees and over £500m turnover per year. This means that from next year they will be subject to new Government reporting regulations. These require that in future annual accounts they “disclose their governance, strategy, risk management and use of metrics and targets regarding climate risks and opportunities. This must include the use of scenario analysis.”
The Premier League
The Premier League annual accounts are here. Their scope 1 and 2 emissions are up 61% on the previous year (to 202 tCO2e) and energy use is up 72%. These increases are attributed to moving to new office premises.
The SECR lists five actions taken with three of these relating to broadcasting. It also mentions an internal sustainability steering group. This is good to note as reducing emissions is a cross-organisational effort. It would also be interesting to know more about its scope and any senior management or Board level involvement. To reflect the importance of sustainability work, could it also be formalised in Premier League structures? For instance, as a new Board sub-committee or formal advisory group?
Similar to the FA reporting, the Premier League's scope 3 emissions figures only meet the minimum requirement of mandatory guidelines. This means we don’t get a full picture of the organisation’s carbon footprint.
During this reporting period, the Premier League became a signatory of the UN Race to Zero campaign. This commits the organisation to the aim of reducing 50 per cent of its emissions by 2030 and achieving net-zero emissions by 2040 - inclusive of scope 3 emissions. (By contrast, the FA is a signatory to the UN Sport for Climate Action Framework. This commits the FA to a set of principles but no specific targets).
In looking at scope 3 emissions, as with the FA, there will be important issues to work through. For instance, who is responsible for reporting on emissions due to the new Summer Series - does that fall to the Premier League or to the individual clubs taking part? What rules or regulations can the Premier League implement that can lead clubs to reduce their scope 3 emissions?
Elsewhere it says “the Company has been working to formalise its efforts in this area through the development of an Environmental Sustainability Plan”. This had been due to be published in 2022 so hopefully, it’s now due very soon and will address the points raised above - in relation to governance, metrics, rules and regulations - and more besides.
EFL
The EFL accounts are here. It includes emissions and energy figures and mentions a single energy efficiency measure - moving to electric and hybrid cars. Scope 1 and 2 emissions are steady year-on-year (at 72 tCO2e). As with the FA and the Premier League, scope 3 reporting here is minimal.
Curiously, there is no mention of the EFL Green Clubs initiative which was launched in the October of the reporting year. 52 out of 72 clubs signed up for the initiative. It “comprises an accreditation scheme that assesses clubs’ environmental rating and offers steps for continual improvement”.
I could not find any update on the initiative since its launch in October 2021, so it is unclear how this work has been faring. Can anyone help fill us in?
In the meantime, and independently of the EFL, Sport Positive Leagues have systematically collated sustainability information for every EFL club in a super helpful matrix.
Elsewhere
Here I’ve limited myself to three football authorities. I am very aware there is work going on elsewhere that deserves much further attention.
Domestically, there is some very interesting work going on by related bodies. For instance, by the likes of the award-winning Birmingham County FA. Also, the EFL Trust has published a carbon reduction plan.
Elsewhere, the Football Association of Wales has published a sustainability strategy. The Scottish FA has published best practice guidelines on environmental sustainability. In Germany and France, bodies are incorporating sustainability criteria in their licensing systems.
I’d love to learn more from readers about the opportunities, challenges, and lessons from what is happening in these countries or elsewhere. Please feel free to reach out!
In summary
The SECRs of these football authorities show they have undertaken some practical initiatives. But there is clearly more to do on the strategy, delivery plans, governance, targets and metrics. These are essential underpinnings to the delivery of their actions in response to the urgent climate challenge. These responses can be through their own activities or through the rules, regulations and frameworks they set for others to operate within.
That’s why collaboration is also vital here, especially considering the wide variety of stakeholders involved. Although little has been mentioned about this in the authorities' plans, it is hoped that there are ongoing efforts behind the scenes that will become clearer as their strategies unfold. The FA strategy, due imminently, will help provide more of a picture of the state of progress.
While some of these challenges are unique to football authorities and clubs, others are not. The United Nations will have a global stocktake this Autumn on climate change work to look collectively at where progress is being made and where it is not. Perhaps the football community and its partners need their own collective stocktake too.
As ever, I’m learning as I go along. Your analysis, comments, corrections, and pointing me to things I’ve missed are all hugely useful feedback. So please do share those, and thanks again for reading (and fill in the survey if you haven’t !!!)
Fran James (he/him)
Football and Climate Change Newsletter
@fbandclimate
footballandclimatechange@gmail.com
When you say the FA has responsibility for the England football teams, does this mean the English National Teams that play international matches?