This post has 4 parts to it:
A review of what has happened so far in 2024 and look at what is coming up
A compilation of 60 recommendations made in previous posts in this newsletter
A look at Liverpool’s The Red Way Report and the wider issues it points to
A look at the plans for an Independent Regulator for Football
I hope you find one or more of these up your street. The regular round-up of recent developments will return soon.
Fran
2024: So far, and coming up
The first post of the year in this newsletter looked at what was coming up in 2024 on the football and climate change agenda. Three months into the year, this note takes stock of what has also happened and what more to expect.
What’s already happened
AFCON took place in January with campaigners drawing attention to the unwelcome sponsorship by TotalEnergies. The tournament was played during a period of extreme heat in the region. Elsewhere, football in different parts of the world has been hit by extreme weather, including heat, rain and snow, from Australia, to the US, to the UK (see various posts).
Green Football Weekend took place in early February with lots of media attention. Separately, many clubs have published their annual accounts including, for larger clubs, environment-related information. Others should follow soon. More on those in a future post here.
UEFA has issued its carbon calculator, allocated funding as part of its EURO 2024 climate fund for grassroots clubs, and selected three startups for its Champions Innovate initiative. It has also called on everyone involved in European football to support organisations that are committed to climate action and advocacy.
UEFA also launched its 2024-30 Strategic Vision which contains goals on sustainability but has no mention in it of its previously stated 2030 emissions target. The Premier League has published an environmental commitment, but not the environmental strategy that had been trailed. Several environmental reports that FIFA were due to publish in 2023 have still not been published, and there has been no further information on the potential sponsorship of FIFA by the world’s largest fossil fuel company, Saudi Aramco, which had been widely-trailed.
Looking forward
We should soon see FIFA’s evaluation reports of the three bids to host the Women’s World Cup 2027. The decision on who will host it will be taken at the FIFA Congress on 17th May in Thailand (which is currently experiencing an historic heatwave).
EURO 2024, in Germany, and the 2024 Copa América, in the US, kick off in June, with football also at the Olympics in July in France. We will learn more about how teams are travelling to, and during, the tournaments and learn about other sustainability measures put in place, especially for fan travel. Taking place in June and July, the tournaments will also be watched for potential weather extremes. UEFA are working on having regulations in place to safeguard players and fans.
Bids to host the Men’s World Cups in 2030 and 2034 will be submitted in July 2024 and include environmental information. FIFA will publish these bids, but the timing for that is not clear. Separately, The FA plans to share its new four-year strategy soon, hopefully this time including sustainability.
Later in the year, expanded UEFA club tournaments will begin in the Autumn leading to more matches and emissions. For World Cup 2030, a FIFA Congress is expected to confirm its decision by Q4 2024 and may do the same for World Cup 2034. UEFA should be releasing “codes of conduct for business relationships aligned with environment commitment” (to include high-polluting businesses?) and embed infrastructure sustainability criteria in their regulations, policies and programmes.
Elsewhere, Sport Positive will soon be releasing their annual league tables covering the sustainability of clubs in various leagues. We should get a follow-up to the UN Bigger Than The Game survey and also hear more from the EFDN Football for Climate Justice Project at some point. We will learn more about the responsibilities of the Football Regulator and what, if any, connections it will have to environmental issues.
Also, keep your eyes peeled for further amazing work happening by several fantastic campaigning organisations!
60 recommendations
This compilation is a simple summary of recommendations, suggestions, ideas and questions I have made in previous newsletters. They have been reformatted to all read as recommendations. I planned this as a stock-take for myself, partly to help understand gaps, inconsistencies and biases in my approach. And then thought, why not stick some of that work out there?
The list is in a simple date order with minimal reformatting and no grouping of themes. I’ve added the date links in brackets to the original posts so you can go back to the original and contextualise it. Some recommendations are more detailed and specific than others. Some issues have moved on since the recommendations were made, and in other places my understanding has. But I’ve still included them all here.
The list does not include recommendations put forward by guest posters, or recommendations by others that I’ve simply quoted - that would be a much longer list.
It’s quite long, so to save space here you can find the full compilation of 60 recommendations in this single document.
The Red Way
Liverpool have released their second The Red Way report. Here I’ll just look at the emissions reporting in it, realising that is only part of the picture. I have also put the figures from this, and their previous report, into a spreadsheet here for anyone wanting to do their own analysis.
In summary, the report highlights four key issues facing football: standardised reporting, reducing emissions, the variety of different types of emissions that need addressing, and carbon credits.
Standardised reporting
Since last year's report, Liverpool have revised the figures previously reported for earlier years, including a near 40% revision to the 19/20 baseline. The total emissions for the period 2019/20 - 2021/22 were previously reported as 460,901 tco2e. For the same period, they have now been recalculated to 249,851 tco2e. This is 211,056 tCO2e less. On the one hand, this may be a positive development - the overall emissions may be more accurate and much less than first thought. On the other hand, it may be less so - responsibility for those emissions may have shifted elsewhere out of sight but have still happened. It’s not clear.
Alongside this, the largest category of emissions, merchandise, is also hugely erratic from year to year. These are reported as going up 46% between 2020/21 and 2021/22 (to 60,384 tco2e) and down again by 51% between 2021/22 and 2022/23 (to 29,822 tco2e). The big swings are not explained.
Elsewhere, ‘location-based’ emissions reporting is not included, and no attempt is made at accounting for embodied emissions (for instance, from the expansion of the Anfield Road Stand). Taking these factors together it suggests treating these figures cautiously until there is more clarity on them.
Liverpool and Man City have led the way in reporting on their emissions in the absence of a standardised approach by clubs. However, as this report and a previous look at Man City's report show, their bespoke approaches also have limitations, large differences in approach, and make comparisons on progress difficult.
This reinforces the need for a more consistent and standardised approach to emissions reporting in football which the Premier League has said clubs will work towards, and for which the new UEFA carbon calculator provides a starting point.
Reducing emissions
The club reports a 29% reduction in emissions since the 2020/21 season in its summary headlines. I couldn’t work out where that figure comes from and instead worked out an increase for that period, so I must be missing something. Perhaps it's meant to be a reference to the 29.8% since the last 2021/22 season (due to the fall in the highly erratic merchandise category)? Or something else? I’d be grateful if someone could put me right here, and will provide an update to this post as they do.
Either way, it's important to look at the longer-term trend. This shows emissions have reduced by 2.52%, c.2,000 tCO2e in total, over the 3 years since the baseline year. To reach its target of reducing emissions by 50% by 2030 the club will need to accelerate progress, consistently cutting emissions by c.4,500 tCO2e per year, or over 6% per year from its baseline.
Based on progress so far, this will be a big challenge, and the report recognises that “Reducing our emissions will take time to implement”. It is a challenge not faced by Liverpool alone. Only four other Premier League clubs have expanded their emissions reporting to include more/all of their ‘scope 3’ emissions - Man City, Nottingham Forest, Spurs and Wolves. While data for previous years is very limited, all have seen their emissions go up this reporting year.
Some of the challenges clubs face in reducing emissions may reflect those that society faces too. However, the emissions figures in football are against a backdrop of the UK economy having reduced its emissions by 9% between 2019 and 2022, with provisional figures for 2023 showing a 5.4% in the past year. Based on limited data, football appears to be decarbonising more slowly than this (if at all). There is a need to look more deeply into the specific factors within the football industry that may be holding it back in certain areas. At the same time, this should also help clarify the areas where it also needs to advocate for change by others.
Not just fan travel
There is a commonly held view that fan-travel emissions account for by far the majority of emissions in football. A quick search will highlight estimates ranging from 60%-90% of total emissions. However, at 17% of total emissions, fan travel is only the third largest source of emissions that Liverpool reports. Merchandise and supply chain emissions are both much larger. For Man City and Spurs, although fan travel is the largest source of emissions, their fan travel emissions are also less than 50% of the total. Other big-ticket sources of emissions are embodied emissions, purchased goods and services, and capital goods. This highlights a need to adopt a multi-pronged strategy for emissions reduction in football, and for better data to help inform prioritisation of plans for targeting action and resources.
Carbon credits
Finally, this year’s report leans heavily into offsetting as key to the club’s future approach. Currently covering scope 1 and 2 emissions, the club plans to expand this approach in the coming years. Liverpool are only one of many clubs using offsets. For instance, Manchester United have made a big play of doing so.
A recent article in Global Sustainable Sport has looked in-depth at offsetting noting the increasing awareness that “the practice of offsetting is beset with problems – and can even cause more harm than good” and that “Finding effective alternatives to offsetting may play a big role in that transformation – and, as ever, sport has the opportunity to lead the way.”
The Science Based Target Initiative has recently issued new guidance on carbon credits. It marks a timely point for football to take stock of its approach. This could be done at a national level by football authorities, or at a UEFA level, working with leading independent organisations and experts, perhaps through a citizens’ (or fans’) assembly. This could lead to new guidance ensuring a consistent approach by all clubs with broad support.
Independent Football Regulator
Last month saw the Football Governance Bill introduced in the UK Parliament. It sets out the Government's plans to create a new Independent Football Regulator (IFR) which will “reform the governance of men's elite football in England and put fans back at the heart of the game”.
As previously noted, there is no mention of the environment in the Bill. This note looks at whether the IFR will be allowed to look at environmental issues, or if this means it will be constrained from doing so. It suggests that the picture is unclear, and further understanding and clarification is needed. If you have expertise to help on that, please drop us a line.
The legislation introduced in Parliament sets out what the regulator will do, and what it will ask of clubs. Published alongside it, the accompanying Impact Assessment sets out with stark clarity the problems to be addressed. It’s worth dipping our toes into those here. The problems it sets out are also those holding back football’s progress on environmental issues too, and inform why further action is needed.
The report says that there are perverse incentives inherent in the market structure of football, alongside poor financial and operational management. These perverse incentives lead clubs to overreach by chasing short-term gains over a long-term approach. There is “poor corporate governance in football clubs that would not be considered tolerable in other sectors … [and] … the industry does not have the incentives and the governance structures to guarantee the necessary behavioural and structural changes over the longer term”.
Football cannot reform itself due to “Regulatory capture: The constitutional structures mean that these existing authorities [such as the FA, Premier League, and EFL] have vested interests that can lead to bias and/or inaction. Consequently, the regulatory bodies are not sufficiently independent from the entities that they are regulating and have misaligned incentives in designing and enforcing rules … Given the lack of independence under the existing regulatory structures, it is unlikely that these bodies will be able to push through the transformative action that is required.”
An example of this is the recently announced environmental commitments by the Premier League, which this newsletter suggested were necessary but not sufficient (and which have not been included in the new Premier League Rules). Along similar lines, the Government report says that “recent industry-led reform is not sufficient” and in more detail:
“There have been some recent changes in regulations from the Premier League and EFL, such as more disqualifying events as part of Owners’ and Directors’ Tests. While these changes are welcomed, they do not sufficiently address all of the problems identified and do not provide a lasting solution and the proposed reforms seen to date do not go far enough to deliver long-term sustainability. Further, these reforms are not as bold when compared to action taken by international counterparts.”
In addition, survey after survey shows that fans strongly support clubs taking more environmental action1. As the impact report notes, “Clubs do not sufficiently take into account the interests of fans / communities”.
In summary, the deep-seated problems in this ‘impact report’ strongly suggest that the football industry will also not be able to get its own house in order to protect the future of the game from environmental challenges. So will the regulator play a role here?
As stated above, there is no mention of the climate or the environment in the Football Governance Bill or the supporting documentation. This seems like a missed opportunity to set out a clearly defined role. It also leads to the question, does this mean the regulator will not be able to consider environmental issues at all?
The answer to that seems a bit less clear to me. It’s important to look at the Bill in more detail and consider if, while unstated, there are any areas with an obvious connection to environmental issues. This is not an easy task given the complexity of the documents, even with explanatory notes. So anyone who can help here, please get in touch!
In the meantime, one area that jumped out to me as a lay reader was in relation to the second of the three key objectives of the IFR. These objectives are:
to protect and promote the financial soundness of regulated clubs
to protect and promote the financial resilience of English football
to safeguard the heritage of English football
On this second objective, the explanatory notes say this is a:
“macro-focused systemic financial objective. In the advancement of this objective, the IFR will identify, monitor and if necessary take action to mitigate systemic risks in order to protect the aggregate financial sustainability and resilience of English football. These risks might not threaten any one club significantly, but their potential aggregated, correlated, and/or multiplied effects may pose a significant risk to large parts of the football system or the pyramid as a whole. Equally, there may be structural issues in the industry with implications for all clubs. For example, how broadcast revenue is distributed throughout the football pyramid, or a common dependency among clubs on certain sources of income or credit.”
To my untrained eye it seems like a no-brainer that climate change should be considered a systemic risk and structural issue for football. The Government has said that climate change and environmental degradation pose profound risks to the economy, and that both physical and transition climate risks could have material impacts on the value of companies. The recent Game Changer Report has set out the growing risks from more extreme weather to all sports. Zurich Finance have said that “Of 92 stadiums in the top English leagues, 39 will face a high risk from three or more climate hazards by 2050”. Beyond the stadiums itself, we are already seeing fan and player travel affected by adverse weather conditions. Elsewhere, a few clubs have started also recognising climate-related risks in their annual reporting.
It may therefore be that this objective for the IFR allows it scope to act on environmental issues. If so, and it is considered appropriate by the IFR itself, it may be able to act to help protect and promote the resilience of English football from climate risks, choosing from the range of powers at its disposal when doing so. But I’m not an expert here, and may be reading into what I want to read, or taking what is said out of context. It may be that the intention is to exclude the IFR from having any scope to act on environmental issues, or that even if it can do, its powers to act will be very limited. Still, I thought I’d put it out there! What’s your understanding?
Whether or not it does, it demonstrates the need for further investigation and understanding of the details of the Bill and to follow it closely from here. It would be great to hear from others on this. In the meantime, see also this post from Barney Weston of Football For Future, and separately, this from Fair Game.
And with all of this, there is a question of what next? The next stage in the legislative process is ‘Second Reading’ in mid-April which is “the first opportunity for MP’s to debate the main principles of the Bill”. We may learn more from that.
Further Reading: House of Commons Research Briefing on the Football Governance Bill.
Comments, corrections, feedback, and proposals for guest posts or to help out are all welcome!
Fran James (he/him)
Football and Climate Change Newsletter
footballandclimatechange@gmail.com
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For instance, a YouGov poll of 2,000 people found that 63% agreed that the new independent football regulator should have a role on environmental sustainability. A Capgemini survey says 67% of fans feel disappointed that the teams they follow are insufficiently prioritising environmental sustainability. The Football Supporters’ Association 2023 Survey shows that only a quarter agreed their club was doing enough to cut down on the climate change impact of their activities.