The FA Sustainability Strategy
Channelling Lee Carsley
“I think this team has another level to go, maybe two or three levels, and I think if they click, it will be a hell of a performance tomorrow — and I expect them to. I think the bigger the stage, you will see a bigger intensity from the team, so I am looking forward to it”.
Lee Carsley, England Men's Under-21s Head Coach, speaking ahead of the UEFA U21 EURO final on Saturday that England won.
The Football Association of England (The FA) published its five-year sustainability strategy last week. It’s available here. Why is it important?
The FA handles promoting and developing all levels of the game in England, from grassroots to professional. It oversees England's international teams. It also runs the National League System, FA Competitions, Wembley Stadium and St.George’s Park. In 2021/22 it had a turnover of £518.8m and employed 1,082 people. It expects to serve 2 million users through its digital platform this year. Millions more will watch the competitions it organises. But of course, the numbers only tell us so much. Football has a place in our hearts unmatched by any other sport. On sustainability issues, what The FA, or any governing body, says and does matters to the game, its fans, and the planet.
This new strategy starts by setting out the big picture and moves on to three focus areas. For each of these focus areas, it identifies four objectives (see image below). It then goes on to set out actions to deliver on them, and achievements to date. Further information is also provided on the scope of the strategy and the consultation that went into its development.
It’s a key step forward to see a sustainability strategy from the FA, and important to hear it state that the “climate crisis is one of the most pressing issues of our time”.
It also recognises it is “in a unique position to drive wider environmental and societal change across clubs, leagues, and with partners”. It goes on to identify areas that are under its direct control. It also notes, crucially, in other areas, it will need to use its influence and collaborate with others. It is also good to see high-level commitments here covering a broad range of issues. At the same time, without more detail, it is hard to assess these objectives and commitments, and it is unclear whether in practice it is comprehensive or deliverable.
For instance, with 120,000 games a season already being cancelled because of unplayable pitches, what is the strategy for resilience to more extreme weather? What is the carbon footprint of the FA, and are all ‘scope 3’ emissions part of the net zero commitment? What will the £35m investment to 2040 be spent on? What internal governance will be in place to ensure prioritisation, scrutiny and a long-term view? How will The FA work with the Premier League, the EFL and others in the football community going forward?
So there are many important open questions. This need for more detail makes it even more important and urgent to deliver on the commitment it makes here “to create the operational framework to embed this strategy across our whole organisation and facilities, demonstrating success to all stakeholders”. What needs to go into that?
The Royal Spanish Football Federation (RFEF, Spanish football’s governing body) issued its own sustainability strategy two weeks ago. That includes commitments from the RFEF to implement the methodology recommended by the Task Force on Climate Financial Disclosure. This will mean following a framework for disclosure that covers: governance; strategy; risk management; and targets and metrics - points I’ll return to below.
The RFEF also commits to implementing the Science Based Targets initiative model and to measuring their carbon footprint using UEFA industry standards. Will The FA make similar public commitments too?
In addition, both The FA and RFEF could join nearly 20,000 organisations that already disclose data to CDP for assessment, and also join large numbers of football clubs and bodies that have signed up to the UN Race to Zero campaign. Finally, they could agree to work in line with the new Voluntary Carbon Market Integrity Initiative.
Why sign-up for these approaches and initiatives? As a UN high-level expert group notes in a recent report, Integrity Matters transparency and accountability play a key part in ensuring delivery.
Also, the RFEF is making sustainability a key pillar of their joint bid for World Cup 2030 and The FA is placing sustainability as a top priority in its joint bid for the EURO 2028. This makes it doubly important for these bodies to demonstrate ambition, action, best practice and delivery on sustainability issues in their core ongoing activities.
Governance - Strategy - Risk management - Targets and Metrics
In 2021/22, The FA had a turnover of over £500m and more than 500 employees. This means it is in scope for new regulations in the UK on mandatory climate-related financial disclosures (assuming turnover again tops £500m).
This means that in its future annual accounts, it will be required to “disclose its governance, strategy, risk management and use of metrics and targets regarding climate risks and opportunities ... This must include the use of scenario analysis.” The next accounts will be due early in 2024. This only reinforces the importance of the FA to move quickly and ambitiously in implementing an ambitious and comprehensive operational framework.
The FA sustainability strategy was published in a week when the world experienced its hottest-ever recorded days. To paraphrase Lee Carsley, to address climate change we all need to go to another level and with a bigger intensity.
Fran James (he/him)
Football and Climate Change Newsletter
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footballandclimatechange@gmail.com
The focus here has been on the football governing body in England, also touching on the governing body in Spain but not going into detail. It would be particularly good to hear from readers based elsewhere on governing bodies where they are.
Image of The Football Association badge is by Stanley Howe, CC BY-SA 2.0 via Wikimedia Commons.