Three. It's the magic number

Understanding and reducing scope 3 emissions is key to football's climate challenge

In this post, I’ll draw together recent developments on understanding scope 3 emissions with recent club reporting on it.

From that, I’ll have a pop at identifying key issues and also suggest some next steps.

Yes, some of it will be technical, but dig in as the topic is important to addressing football’s emissions.

As ever, I’m learning as I go along. So before I get to it, just to say again, your feedback, corrections, and queries are always hugely welcome.

And as the focus is on English clubs, it would be particularly good to hear from readers based elsewhere.

---

A quick recap on scope 3

Scope 1 emissions are direct emissions by an organisation, for instance from its boilers when used for heating. Scope 2 emissions are emissions from the energy that is purchased by an organisation and produced for it, especially for electricity.

Scope 3 emissions are any indirect emissions from sources outside of an organisation’s direct control in its value chain. A recent report by Play The Game says that:

“In the case of sports organisations this could include: purchased goods and services – including sports and office equipment, employee catering; athlete and employee travel; spectator travel; and waste disposal, especially from event catering”.

If you want a deeper dive, The Carbon Trust has just published an introductory guide to scope 3 emissions. The Greenhouse Gas Protocol guidance goes into full detail. It includes listing 15 categories of emissions within scope 3, which I’ll return to below.

How important are these scope 3 emissions?

A UK Government document published last week says that “scope 3 GHG emissions can account for anywhere between 80-95% of an organisation’s total footprint”.

Also as the new UK Sport Sustainability Strategy published last week says “You can’t manage what you can’t measure”.

Understanding these emissions is clearly essential to planning and prioritising action, and delivering on targets.

Targets

A number of football clubs and governing bodies, from Forest Green Rovers to FIFA, have signed up to the United Nations ‘Race to Zero’ campaign. Those that do commit to reducing emissions by 50% across all scopes by 2030, and net zero by 2040.

Alongside this, some other football clubs have also independently set targets for reducing their emissions. As a general rule it’s important to look at the small print to see if they have included scope 3 in their targets, and if so, how they are defining it.

Recognising these emissions are not directly under the control of organisations, the Science Based Targets initiative also sets ‘boundary requirements’. Scope 3 targets for 2030 should be comprehensive of 67% of total scope 3 emissions, and 90% of longer-term net-zero targets. It says that meeting these targets

“will be challenging, but it will also drive major opportunities to collaborate across the value chain to support suppliers and customers to decarbonize.”

Recent developments in reporting scope 3

In an update last week, the UN Race to Zero campaign noted that:

“Most striking is the lack of consistency of reporting for scope 3 emissions, which looks at the full value chain of a company. Out of a total of 15 scope 3 categories, about 30% of companies are reporting three categories or fewer, thereby not reporting on the full impact of their companies activities.

In a report last month, a key organisation, CDP, also pointed to these challenges saying:

Companies must recognize that their impact on the environment extends beyond their direct operations … Scope 3 targets only make up 15% of all new or in-progress targets, despite accounting for 11.4 times of the direct emissions per company …Identifying and calculating emissions in all relevant Scope 3 categories is crucial to understand a company’s real carbon footprint.

In Mobilising Green Investment, published by the UK Government last week, it was noted that scope 3 reporting was minimal and that:

“this is a major information gap for investors, preventing them from fully assessing the climate-related risks and opportunities of their investments. However, there is significant uncertainty in the market around the methodologies used to generate and report scope 3 GHG emissions data. With organisations facing increased demand to disclose scope 3 GHG emissions, the UK government wants to explore how it can support Scope 3 reporting and will launch a call for evidence to gather stakeholder views.”

Also last week, a group of all the main supermarkets in the UK announced that they were teaming up with charities, WWF and WRAP to

“ensure consistent measurement and reporting of their scope 3 GHG emissions … [and] … also focus on scoping high-impact areas for collaboration … Phase 2, from 2024, will take action on these high-impact opportunities”.

The message is coming through loud and clear - not enough organisations are reporting on scope 3 emissions. And where they are there is a lack of consistency in the approach. This clearly has the potential to have a big impact on efforts to reduce emissions.

Reporting in football

In the last few weeks and months we have had new voluntary emissions reporting, including scope 3 emissions, from Liverpool, Manchester City, Spurs and Wolves. These are a first of their kind that I know of (alongside VF Wolsburg’s).

In addition, a number of clubs have said they are carrying out a full review of their carbon footprint including, for instance, Arsenal and Aston Villa. So more is coming down the line.

The four clubs who have reported so far should be praised for their leadership and transparency in voluntarily reporting this data. At the same time, looking at their reports in detail, we see similar issues to those facing organisations that have been outlined above. The table below summarises key data from each of these reports.

This helps identify some key points:

Scope 3 emissions are clearly the most important scope of emissions for all these clubs. Manchester City puts scope 3 emissions at nearly 60% of total emissions, while the other clubs all put them at we'll be over 90% of the total.

However, simply reporting on scope 3 emissions is not enough. Within scope 3, it’s essential to understand what categories are included, and are not, and how they are measured.

Fan travel is a very important category for the size of emissions in all reports. That said, there is still work needed to clarify the scale of the challenge. Spurs’ fan travel emissions are reported as being nearly five times higher than those of Manchester City.

Supply chain emissions are reported as a significant source of emissions by Liverpool and Spurs, but not by others. This seems to align with CDP analysis that less than half of companies in their programme are reporting on supply chain emissions at the moment, and the need to include these in the future.

Liverpool is the only club to include ‘merchandising’ in their scope 3 emissions. In doing so, the sheer size of the emissions number presented begs further questions about its definition and why other clubs do not report similar figures. I have written about this more as part of a look at Liverpool’s emissions report here.

Different categories are being used, muddying the picture. Spurs report their Scope 3 emissions against the 15 Greenhouse Gas Protocol categories. Other clubs have a lesser number and different categories within their scope 3 reports.

For those who have signed up to the UN Race to Zero, how those commitments sit with this reporting, may need clarifying. Liverpool’s report says:

“The UN Race to Zero framework commits us to achieving specific climate goals of halving our operational emissions by 2030 and aiming to achieve net zero by 2040” … operational emissions include all direct emissions owned by LFC”. (emphases added)

These statements on operational and direct emissions are not explained further and leave some ambiguity as to whether scope 3 emissions are part of their aims to halve emissions by 2030.

More clearly, Spurs’ report says “We are working to reduce our Scope 1, 2 and 3 emissions on an absolute basis as far as possible towards an ultimate goal of being net-zero by 2040”.

Finally, tempting as it is to try and do so, it is not possible to use these figures to average and estimate the total carbon footprint of the Premier League clubs as the variation in the use of categories and the numbers reported in them is just too large.

What next?

Here are some suggestions I’ve put together from the issues and challenges identified above. I’d be very interested to hear your own additional/alternative reflections.

• All large clubs could commit to voluntarily reporting of full scope 3 emissions annually. “Large clubs” could follow the “large companies” definition. This would take in Premier League clubs plus a small number of other clubs and governing bodies.

• Following the example of the supermarket sector, clubs and governing bodies could come together with independent experts to agree on a single set of categories, methodologies, and reporting procedures that can be applied to scope 3 emissions.

• There is a strong case for also having in-depth reviews on a small number of key issues. This might include reviews on fan travel, supply chains, merchandising, and more (possibly including the high-profile issue of team travel, which I’ve not covered here). These reviews would need to be as open, inclusive and collaborative as possible, recognising the diverse range of stakeholders involved in each issue and the role they can play in helping deliver progress.

• The above suggestions could be done by clubs, governing bodies and others coming together on a voluntary basis. An alternative approach would be to have a top-down mandate to do so.

• The focus here has been on large clubs, but more work is needed to understand scope 3 emissions at all levels in football, and what a proportionate approach is.

---

A few other points

• A report by Planet Super League has also proposed a further scope: “Scope F” describing the impact sporting organisations have by influencing fans to live more environmentally sustainably. I’ve not looked at this here, but this is clearly another very important area for the football community.

• A further example of scope 3 reporting issues is in relation to the FIFA World Cup 2022 in Qatar. FIFA set out its estimate of total emissions in this report. The scope 3 emissions in it include figures for travel and construction. Lancaster University professor Mike Berners-Lee has been amongst those pointing out potential flaws in how both of those categories are defined in the report.

On other fronts

• Sport Positive has systematically collated key environmental sustainability information for every English Football League (EFL) club and ranked them.

• BBC Sport has taken an in-depth look at Premier League domestic flights.

• This post comes slightly over a fortnight since the last one. I hope to get back to more of a regular rhythm from here.

Fran James (he/him)
Football and Climate Change Newsletter
@fbandclimate
footballandclimatechange@gmail.com