How Luton’s iconic Kenilworth Road helped keep emissions low
Exclusive: Luton Town FC was the only Premier League club in 2023/24 not to publish its emissions report. The Asterisk investigates why.
Contents:
Regulations and SECR reporting
Why did Luton not report its emissions?
What qualifies a club for SECR reporting?
Why is SECR important?
Kenilworth Road’s impact on emissions
How the stadium contributed to lower emissions
Challenges of an aging stadium for sustainability
Broader sustainability issues
The risks of releasing emissions data without a solid foundation
Luton’s sustainability policy shortcomings
Why smaller Premier League clubs need more support
The future: Power Court Stadium
Moving to a new home with sustainability in mind
In 2023, Luton Town created history achieving promotion to the Premier League for the first time ever. The ascension to England’s top tier created a huge buzz, as the world was set to catch a glimpse of the country's most peculiar football stadium.
Home to ‘The Hatters’ since 1905, Kenilworth Road is nestled among rows of houses and stands out like a cathedral. It has seen an average attendance of over 11,000 since its return to the Premier League.
The club invested £13 million to redevelop the Bobbers Stand to meet the Premier League's broadcasting requirements. The world was certainly going to watch, and for Luton, that meant increased revenue, sponsorship, and… responsibilities.
“Having gained promotion to the Premier League at the end of the 2022/23 season, and with parachute payments in place for relegated clubs for the foreseeable future, the club has secured significantly increased revenues for at least the next three seasons and can now move forward on a firmly sustainable footing,” the clubs’ parent company, 2020 Holdings (England) Limited, said in its report and financial statements ended for the year 2023.
Many clubs have incorporated the term "sustainability" into their long-term vision. The three pillars of sustainable development are social, economic, and environmental. While companies have often focused primarily on the first two, there is a growing trend of sports organisations taking environmental initiatives worldwide.
Luton Town has also implemented measures to reduce its environmental impact, such as replacing 90% of its lights with LEDs, using heating and lighting only when necessary, recycling waste, reducing or eliminating single-use plastic on matchdays, partnering with local bus and train companies to promote public transport, encouraging staff to use electric vehicles, opting for trains or the team coach instead of flights whenever possible, and providing sustainability education.
“With regards to long term sustainability of the environment, the board always considers the group’s impact when making key decisions,” said 2020 Holdings (England) Limited.
Luton was the only Premier League club that did not publish its Streamlined Energy and Carbon Reporting (SECR) in the 2023/24 season, something every other team had done.
SECR is a regulation that requires large businesses to report their energy usage and carbon emissions in their annual reports.
Why did Luton not report its emissions?
The club’s parent company cited a specific clause in the law to avoid disclosure.
“The group has taken advantage of Paragraph 20E 3(b) under ‘The Companies (Director’s Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018’ (‘Streamlined Energy and Carbon Reporting regulations’) not to disclose the energy and carbon reporting information of the company’s subsidiaries on the basis that neither are required themselves to disclose such information,” said 2020 Holdings.
“As the company has not consumed more than 40,000 kilowatt hour (kWh) of energy in this reporting period, it qualifies as a low energy user under these regulations and is not required to report on its emissions, energy consumption or energy efficiency activities,” the company added.
Nearly every other Premier League club consumed more than a million kWh of energy in the same reporting period, The Asterisk analysed.
What qualifies a club for SECR reporting?
The Asterisk reviewed the Environmental Reporting Guidelines to verify Luton’s claims.
There are three types of businesses that must comply with SECR: quoted companies (those officially listed on a stock exchange), large unquoted companies, and large Limited Liability Partnerships (LLPs).
SECR applies to companies and LLPs that are in compliance with the Companies Act 2006 (Strategic Report and Directors’ Report) Regulations 2013 (‘the 2013 Regulations’) and the Companies (Directors’ Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018 (‘the 2018 Regulations’).
The emphasis here is on large organisations.
Additionally, a company must meet the threshold for two consecutive years before being required to report. It must satisfy the qualifying criteria in both the reporting year and the preceding year.
2020 Holdings met the criteria for the 2021/22 and 2022/23 financial years.
However, the ‘low energy users’ exemption under Section 3 of the guidelines supports Luton’s claim. A company that has consumed 40 kWh or less during the reporting period for which the Directors’ Report is prepared "is not required to make the detailed disclosures of energy and carbon information."
Why is SECR important?
According to the government, the reporting is designed to increase awareness of energy costs within large organisations, identify ways to save energy, reduce the carbon footprint, inform investors and the public about energy efficiency measures, and address climate change.
Furthermore, the adoption of common reporting rules enables easier comparison of energy usage and emissions.
How Kenilworth Road played a role in Luton’s low emissions
Playing at the Premier League’s smallest stadium in the 2023/24 season may have just spared Luton’s staff from compiling intricate environmental data.
Manchester United was one of the largest producers of Scope 1 and Scope 2 emissions. Old Trafford, the league’s biggest stadium with a seating capacity of 74,310, played a significant role in contributing to the club’s emissions.
At the other end of the table, Luton Town (12,056) did not appear in the emissions report.
“If we look at the Scope 1 and Scope 2 emissions from across the Premier League in the last few years, generally it's the clubs with the larger grounds that have higher emissions,” Dr. Leslie Mabon, environmental expert and Lecturer in Environmental Systems in the School of Engineering and Innovation at the Open University, tells The Asterisk.
Bigger stadiums mean more spectators, more games, and additional events such as concerts and corporate summits. Furthermore, clubs participating in European competitions tend to generate higher emissions.
“I don't think it's surprising that Lutoners, having had the smallest club in last season's Premier League, would have the lowest emissions,” says Dr. Mabon.
“Bournemouth, Fulham, Burnley, Crystal Palace, there are other clubs with quite small emissions too.
“In absolute terms, there's probably quite a close correlation between Scope 1 and Scope 2 emissions, and the size of the stadium.”
‘Releasing data without a solid foundation may be disadvantageous’
Although reporting emissions promotes transparency and accountability, there is much more to consider before publishing this data. If done improperly, it could even be disadvantageous, according to Dr. Brian McCullough, associate professor and program chair of Sport Management at the University of Michigan.
"Sport organisations encounter challenges with their environmental sustainability efforts and reporting, particularly regarding emission data that isn't legally required,” he tells The Asterisk.
“Practitioners often worry that such figures lack context and could be misinterpreted by the public.
“Moreover, publishing this data makes it difficult to compare teams in the same league due to various confounding factors, such as differing organisational contexts and local infrastructure.”
While comparing clubs' Scope 1 and 2 emissions for the 2022/23 season, The Asterisk found that the Manchester clubs provided location- and/or market-based emissions data. However, it was unclear under which category most clubs' data fell, thereby muddling the comparison.
“Understandably, sports practitioners may hesitate to release this data without a solid context or a strategic approach, like an environmental sustainability plan. Without this foundation, they might view reporting as more disadvantageous than advantageous," notes Dr. McCullough.
Dr. Mabon adds that a lack of reporting does not necessarily indicate a red flag for an organisation.
“If we go back a couple of years, Nottingham Forest also didn't report their emissions because they had also just come up from the Championship,” says Dr. Mabon. “So it's not as if Luton are the only club in recent years that have come up. We've been in that situation.”
Forest publicly reported its Scope 1, 2, and 3 emissions for the first time last season.
The club did not respond to whether its reporting was influenced by regulatory expectations, internal sustainability goals, or other factors.
Luton falls short on sustainability policy
While Luton may not have been legally required to publish its emissions, the club has failed to align with its own sustainability policy.
Section 2.7 of the club’s Communication and Reporting Policy states: “Monitor and review our environmental performance in respect of this (Sustainability) policy and produce an annual progress report.”
Luton Town is yet to produce the report.
The Asterisk could not verify when the policy went live. However, it is very likely that it has been in place for over a year, as it was mentioned in the Sport Positive report published in April 2024.
The club did not respond to requests for comment.
While the policy does not explicitly mandate the publishing of emissions statistics, given football's influence and impact, should clubs be required to report their emissions?
“It's certainly a good idea for clubs to be able to report emissions and it's something that can set a good example across society, given the high prominence of football,” says Dr. Mabon.
“It helps to focus society's attention on where emissions come from and the different types of emissions as well (Scope 1, 2 and 3).
“It's worth remembering clubs like Luton can become very successful very quickly on the pitch, but don't necessarily always have the knowledge and the infrastructure around that,” points Dr. Mabon.
Smaller, new Premier League clubs need support
“It’s very important that clubs are supported with knowing how to do that, how you would go about measuring and assessing emissions, how you would tell you would do that and who the people are that would have the knowledge to help you do that.”
The Asterisk can confirm that Premier League clubs have been provided with resources and expertise to help minimise their environmental impact.
In February 2024, the Premier League announced that clubs must develop a standardised greenhouse gas (GHG) emissions dataset by the end of the 2025/26 season.
All Premier League clubs will have to report their scope 1, 2 and 3 emissions.
For clubs like Luton, which must punch above their weight on the field in the Premier League, reducing their environmental impact is just as challenging, if not harder.
Luton did not rank highly compared to the rest of the Premier League teams for green measures in the 2023/24 season.
“Luton haven't had as much time to develop some of the measures and reporting and things that we see that some of the top clubs have so clearly,” notes Dr. Mabon.
“Manchester City get a lot of good press for some of their Scope 1 and 2 work. But they've had time to do that.”
Meanwhile, Luton had to prioritise meeting Premier League requirements while also strengthening its squad to compete with top-flight teams and, hopefully, avoid relegation.
“The sustainability angle is maybe just one among a number of pressures that they were facing as they were trying to get their ground ready for the Premier League,” says Dr. Mabon
“It's absolutely fair and understandable that sustainability reporting and things like that maybe aren't going to be top of the agenda,” he adds.
Kenilworth Road’s age limits green initiatives
Luton managed to add executive boxes, new press and TV facilities, 1,000 spectator seats, wheelchair facilities, toilets, dugouts, and VAR (Video Assistant Referee) facilities within a short time. However, the stadium’s age makes it difficult to implement green initiatives.
“Luton doesn't have a building management system for energy in the ground, and that's because of the age of Kenilworth Stadium,” points Dr. Mabon.
“Also, outside of the emissions, the sport positive report also picks up on the fact that they are trying to do things like improving water consumption and improving biodiversity which is also very difficult for Luton to do at Kenilworth Road.”
The environmental expert added that the 120-year-old stadium may have also faced additional challenges, such as implementing green technology and having the necessary space for such initiatives.
That is set to change.
Power Court stadium: Moving to a new home
Luton Town has a new stadium in the works, with its capacity set to double from 12,000 to 25,000.
“The stadium development project at Power Court has been designed with the environment in mind incorporating cutting edge design which minimises impact upon the environment and promotes long term sustainability,” said 2020 Holdings.
Luton’s new stadium will include features designed to reduce emissions. Heat pumps will be used to heat and cool indoor areas, according to The Earthbound Report. Another set of heat pumps will generate hot water, while solar panels installed on the roof will power the electrical system.
“The proposals that Luton have put out are actually great,” says Dr. Mabon. “That would significantly reduce the Scope 1 and 2 emissions.”
The Hatters have, most importantly, addressed reducing the impact of Scope 3 emissions, which include travel, the largest contributor to club-related emissions.
The Power Court stadium will be located in the town centre, just a five-minute walk from the train station and bus interchange, according to The Earthbound Report.
“It’s very important to consider where the stadium is located and the impact that has on transportation,” says Dr. Mabon. “It's very easy to build a giant stadium out in the middle of nowhere and then everybody has got to drive to it. We're seeing this to some extent now with Everton's new stadium.”
Everton recently opened the doors to its new 52,888-seater stadium for an Under-18s' game to test the venue.
The new £800 million stadium at Bramley-Moore Dock will be one of the most sustainable venues in the country, an Everton spokesperson told The Asterisk.
Fans complained about the lack of public transport, as well as parking and safety concerns, at Sandhill Station, the closest to the ground.
Although Power Court’s proximity to public transport hubs has the potential to reduce fan travel emissions, Luton should prepare for similar challenges.
“Together with the recent confirmation of planning approval for our earthworks and site remediation efforts, our project team are now fully engaged on a construction timeline that would complete in 2027,” said Michael Moran, Chief Operating Officer of 2020 Developments after a detailed planning application for the new stadium was submitted to Luton Borough Council in September of last year.
The council gave planning approval in December.
The club aims to achieve a BREEAM ‘Excellent’ rating for sustainable construction, a status that Tottenham Hotspur’s £1 billion stadium has already attained.
Tottenham Hotspur’s stadium, one of the most sustainable venues in the world, saw the club’s Scope 1 and 2 emissions drop by 14% last season.
Although clubs may claim their stadiums will be sustainable, Dr. Mabon points out that construction and the built environment generate a significant amount of emissions.
The built environment contributes to 42% of annual global CO₂ emissions, according to Architecture 2030, an organisation committed to transforming the industry from “the major emitter of greenhouse gases to a central solution to the climate crisis.”
"There's a question there about if you are building a new stadium as a club," says Dr. Mabon. "How long does it take before the emissions produced during construction are offset by the reductions in emissions from the new stadium?"
While Kenilworth Road may have unintentionally demonstrated that small stadiums can be sustainable, this may not be a viable option for big clubs chasing higher revenues. A new stadium will cost Manchester United over £2 billion, but repurposing Old Trafford could save the club nearly £500 million.
Kenilworth Road’s minimal environmental impact highlights how low emissions can start from humble beginnings, offering big clubs a valuable lesson in sustainability.
More on sustainability in the Premier League:
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