A nudge
If you have not yet done so, please give your views on: What are the biggest opportunities and/or challenges coming up in 2024 on the football and climate change agenda? Just click this link to do so. You have until Friday and can do it anonymously. Thanks for all the responses so far, and also the ideas for future questions!
A bonus round-up
In a break from the usual fortnightly format, this short extra round-up comes a week after the last one.
As the COP28 international climate talks continue:
Campaigners called on those in football and other sports to raise their voices in support of a transformative outcome from COP. In a widely read tweet, Alastair Campbell said if Saudi Arabia “want to be a global leader -- on sport and in bidding for the World Cup -- they need to prove to the world which side of history they’re on”. Gary Lineker was among those showing support.
A panel session on “The Power of Sport for Climate Action” included UEFA talking about their EURO2024 plans, more on those here.
The transformation is unstoppable say over 400 CEOs. They are among over 1400 leading figures calling for a 1.5C-aligned outcome at COP28. While no one in the football community has yet added their name, it is still open and accepting signatures.
Liverpool is the only club I’m aware of to have an attendee at COP28 with their Director of Impact being interviewed by Al Arabiya English. As part of this, he says that successful collaboration has not yet happened among Premier League clubs as it’s a newer area for a lot of them, but that means there are opportunities too. Does anyone know if other clubs have been at COP28?
Elsewhere
FIFA Women’s World Cup 2027. The three bidders who want to host the tournament have submitted ‘bid books’. Each contains a section on their sustainability proposals.
Global perspectives. A wide-ranging and in-depth two-parter on football and climate change was published in Globo in Brazil. Part 1 is here, and part 2 is here. And in Dawn Newspaper in Pakistan, there is: How climate change is becoming sport’s biggest challenge
Sport Analytics meets Environmental Sustainability. An interesting and innovative initiative in the US. One to keep an eye on and see what it delivers.
Charlton Athletic held their annual ‘Greener Game’ with several activities including walks to the ground.
Team transport. Campaigning organisations have been speaking up on football-related emissions. A Free Ride raised Man Utd’s 30-minute flight after their game against Newcastle. The Campaign for Better Transport has created a letter to Gareth Southgate for fans to sign encouraging sustainable travel by the team at EURO2024. Transport and Environment UK have chipped in with their support for it too.
In Round-up #17 I mentioned the publication of Man City’s latest annual sustainability report and said that I hoped to get round to looking at it in more depth. Here goes …
Long Read: Manchester City Sustainability Report
Man City’s annual accounts were published in mid-November to a lot of coverage. Their annual sustainability report a few weeks earlier though, had no coverage. Is that due to a lack of awareness of it? Or other reasons?
There’s no standard approach to these reports. Man City’s is a whopping 146 pages. Academics say “the substantial length of sustainability reports … makes it challenging for the majority of stakeholders to digest and analyze them”. That seems like a factor here too.
Man City do not submit their work to voluntary initiatives such as CDP or the Science-Based Targets Initiative (many leading companies do, but no clubs have yet). It means we do not have these organisations’ prior work to inform us. In addition, Net Zero Tracker and other similar organisations have not looked at it, and the next Sport Positive matrix of clubs will not be until next year.
This means we do not have any external analysis, validation or verification to refer to and inform our views. I tried ChatReportAI which provided some pointers and shows the potential of AI to help in the future, but it’s not there yet as a tool.
In this context, it may be a fool’s errand to take a look at such a big report. At the same time, I plan to look at all of the annual reports from Premier League clubs as they come out. So here are some observations, while recognising more expert eyes are needed.
Targets and Plans
The club aims for a “credible net zero by 2030”. This is notable as most clubs do not have a target at all. And for those others that do, they have a 2040 net-zero target.
To deliver it, the club “has set an ambitious annual CO2 emissions reduction target of 14% across all activity”. And on pg.9 of the report, the club says it is “On target for credible net zero 2030”.
The report provides more data on emissions than any other club has, by a country mile. It also takes an iterative approach to data, revisiting and revising each year as more is learned, which seems very sensible.
Focusing on the scope 3 reporting, we see it is not yet set out in a way that is aligned with the 15 categories in the GHG protocol scope 3 standard. This means, for all the data here, it’s particularly hard for a lay reader to be sure all those categories of emissions are fully covered (more on this below).
In addition, a 14% reduction in emissions each year requires some proper radical actions. There is extensive, useful detail on club policies and actions taken over the last year in here, and also some information on planned actions dotted around the document. But it’s hard to pin down all of these planned actions, how much these will help cut emissions, and if they are enough. That fits with this sustainability report being intended more as a look at what has recently happened than what’s coming up next. Hopefully, future reports by the club and others will draw more on the new transition plan taskforce framework for setting our robust forward-looking plans.
Elsewhere, pg.22 notes that overall emissions for the year are up by 50.6% year-on-year, compared to a reduction of 31.8% in the previous year. It notes one-off factors behind this, though these could have been explained in more depth. It goes on to say the like-for-like uplift is c9% but that the overall trend remains downward at c13% (is that including scope 3? And over how many years?). The illustrative diagram with predicted trends on pg.86 (with no y-axis numbers), seems to show emissions higher in 2030 than in 2013. A clearer presentation of longer-term emissions trends would likely have helped a lot on these points.
So to my lay-reader eyes, while there’s bucket-loads of information, much of it useful, it was not clear enough to assume the club is on track for net zero by 2030 and has all the plans and actions in place to deliver it. But I’d particularly welcome others’ analysis and perspectives here. The more insights the better!
Risks and Scenarios
The club is the first to produce a report taking into account new UK Government regulations on disclosures for larger businesses. A small number of the largest English clubs (turnover > £500m) will need to do this soon too, including reporting on risks and opportunities.
The risk report here (on pgs.100-101) provides a useful long list of risks and controls in place. What’s presented here is an “example part only form the MCFC Environmental Risk Register”. So this is not the full thing. And it focuses almost exclusively on ‘physical risks’ and not ‘transition risks’. So, for instance, there is no assessment of reputational risks. This leaves open questions such as, what risks are there to the club from sector stigmatisation? In addition, it’s notable that climate risks did not feature in the overall ‘risks and uncertainties’ section in the main annual accounts last year.
New ISSB guidance says that organisations should use scenario analysis to assess their climate risks and resilience. It’s interesting to note that the club says it is “managing its risks and actions based on the 1.5 scenario but is also looking closely at both 2-degree and 4-degree risks”. It would be useful to hear more (from all clubs) about what the risks at these temperatures show, and how strategies might need to change in light of them.
That guidance also suggests organisations with a high exposure to climate risks would benefit from sophisticated scenario analysis. Is this something the club has done and could publish too? And if not, consider doing so? Or, as other clubs may be facing a number of similar challenges, perhaps it is something that a governing body or a new regulator has a role in?
Some final points
The report has many useful summaries of key frameworks, goals and concepts. These are really helpful to the lay reader. At the same time the presentation of data is difficult to understand in some places and re-presented in slightly different (and therefore confusing) ways in others.
That may all be clear to experts, and the points I've raised here easily explained by them. But I don't think I'll be alone in saying it can be tough going. A greater focus on the communication of these reports from all clubs feels key.
This partly also highlights wider ongoing developments with climate reporting. The ISSB’s new Climate Standard is becoming the focus for more consistent, comparable disclosures, and forward-looking transition plans are becoming core too, with further reporting regulation also in the pipeline. More use of these standards, initiatives and frameworks should help make future reporting clearer and more useful.
It also shows how a single reporting framework for clubs emissions could help with accountability. This would require a level of collaboration between clubs not yet seen on these issues, possibly through governing bodies or a regulator playing a key role. It may be that UEFA’s mooted ‘carbon footprint calculator’ provides part, or all, of the answer on this, but details so far on it are sketchy.
Finally, it highlights other important points that Man City, and other clubs, can make progress on. For instance, drawing on the benefits of independent validation and verification by key voluntary initiatives, aiming for greater clarity on progress and plans in line with emerging standards, and as part of that providing a more rounded picture of risks, opportunities, trends and scenarios in football. All of this would aid more and better action by clubs and a clear picture for fans on the progress being made and the challenges ahead.
At the same time, it is important to also keep the spotlight on clubs that have not made commitments. Only 6 of the 20 clubs in the Premier League have a net zero commitment. More and faster action is needed by all clubs, with a collaborative effort and the biggest clubs leading the way. More transparency and accountability has a key role to play in helping achieve that.
That’s it for now. I realise that was quite long but I expect it’s the biggest club report I’ll look at. At the same time, I know it doesn’t cover a number of practical actions, policies and developments that are set out in the report. It could have been longer! For instance, I’ve not looked at the details of several of the initiatives carried out in the last year, nor looked at issues such as embodied emissions, offsets, sponsorship, communication, and governance.
And as ever, I’m learning as I go along about how to read these reports by clubs. So all feedback, corrections, suggestions, and offers to undertake analysis are hugely welcome.
Fran James (he/him)
Football and Climate Change Newsletter
footballandclimatechange@gmail.com
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