Analysis: how NATO should move forward on emissions reporting

In July 2023, NATO published its latest Climate Impact Assessment, together with a methodology for reporting greenhouse gases, and a compendium of its members’ current best practice on military emissions. Linsey Cottrell provides a brief commentary on each document, together with initial recommendations for how NATO should progress its emissions mitigation activities.

NATO and climate change

NATO has published its second Climate Impact Assessment. The assessment recognises the findings of the Intergovernmental Panel on Climate Change’s AR6 reports, and acknowledges that the scale of the emissions reductions necessary require major transitions across all sectors. The assessment includes the need to reduce the greenhouse gas (GHG) emissions of “the NATO Enterprise”, but its primary emphasis is on the impact of climate change on NATO. The assessment does however note the requirement to review and develop standards for climate change and security, and to create a ‘compendium of best practice as a tool to share knowledge on adaptation and mitigation measures among Allies.’

However, all this is set in the context of prioritising the maintenance of NATO’s military effectiveness, even if this objective may at times clash with its mitigation goals. There is no specific reference to changes in defence strategies and deployments to reduce its members’ impact on the climate. This in spite of recognising a relationship between climate vulnerability, risks and conflict. In doing so it cites climate risks in Iraq, which ‘are compounded by pre-existing vulnerabilities caused by war, political and economic instability and an oil driven development and growth model’.

NATO’s emissions reporting

NATO announced the development of its Greenhouse Gases Emission Mapping and Analytical Methodology in 2022. Publication of the methodology is a welcome step, particularly since it has been developed in the absence of an agreed international standard, or indeed comprehensive military reporting requirements under the UN Framework Convention on Climate Change. The methodology is based on the GHG Protocol, and described as being drawn on best practice from NATO members. Our proposed framework for military emissions reporting was published in 2022, given the then lack of other guidance, and is therefore useful as a comparison against NATO’s methodology.

A common reporting approach between militaries is vital to promote transparency, drive mitigation action and enable the comparative performance across countries to be measured. Importantly, the public release of the NATO methodology recognises this need for transparency. The methodology clearly sets out its purpose, and that it applies only to NATO bodies and structures, and not to NATO members.

However, it explicitly excludes emissions from NATO-led operations and missions, and other activities such as training and exercises. The justification for this significant exclusion is not provided, and no timeframe is given for when, or indeed if, this may be addressed. With substantial gaps in the scope of emissions reporting across NATO members, it is unclear whether or how this emissions data would be captured, without major improvements in national practice. Moreover, our proposed framework set out additional categories of emissions, what we called Scope 3 Plus, which related specifically to emissions associated with conflicts. The NATO methodology does not refer to any categories relating to emissions from these sources, or how they may be addressed in future.

In spite of these omissions, the methodology is an important first step in establishing initial expectations, enabling the basis for setting reduction targets and reporting improvement goals. Although not aimed at NATO members per se – as stated in the methodology – it can still be used to facilitate their own reporting. The methodology is presented as being independently validated, with recommendations ‘being taken into account as part of a continuous improvement cycle.’ This is positive but the validating party is not named, and no third-party verification or assurance statement is given, as standard good practice demands. We would expect to see this in future amendments, together with justifications for any omissions, as well as the timeframes for addressing data gaps and improvements in reporting.

The methodology states that it covers “the NATO Enterprise”, including NATO’s civilian and military facilities and installations. However, the reporting bodies listed do not appear to include all NATO units, and there is no explanatory note on why some units have been excluded, whether legitimately or otherwise. There is also no specific indication of what outputs will be shared publicly: the methodology only refers to an internal annual emission report. NATO’s stated ambition is to be a leader in climate security, if this aspiration is to be viewed as credible, it must be at the forefront of transparency. This means communicating its mitigation performance through annual public reporting, and through advocating the importance of reductions to its members on an ongoing basis.

All in all, the publication of the methodology is an important recognition of the need for military emissions reporting, and for the principle that reporting must be transparent. However, substantial improvements will be needed if this methodology is to make a meaningful contribution towards driving decarbonisation.

Table 1: A summary of key observations on NATO’s Greenhouse Gases Emission Mapping and Analytical Methodology

Positive observations	Negative observations
Based on the GHG Protocol and draws on members' best practice.	Excludes emissions from NATO-led operations and missions and other activities such as training and exercises. There is also no mention of warfighting emissions (what we call Scope 3 Plus) or how these may need to addressed in the future.
Sets out the scope – i.e. "the NATO Enterprise".	Unclear whether the entire "NATO Enterprise" is included. No explanatory note is provided on why some units are not named as reporting bodies e.g. DIANA, Civil Emergency Planning, Air Traffic Management, Electronic Warfare, etc… Specific exclusions are given in the calculation tool.
Highlights that the methodology can be used by members to facilitate their own reporting and as a basis for target setting.	The GHG emission calculation tool used is not referenced, nor is a link provided, and the source of the emission factors used in ther tool is not given.
Methodology is stated as being independently validated.	The validating party not named, and no verification or assurance statement is given.
It's a first edition, and updates are implied.	The recommendations made by independent validation were noted as ‘being taken into account’ but no timeframe or action points are provided.
The limitations and challenges of reporting disaggregated data are given.	Makes reference to sensitive in-house data not being included, which implies that the methodology contains data, although it does not.
Includes Scope 3 emissions sources, with caveats that not all will be applicable.	Scope 3 activities with categories/sub-categories are not replicated in the methodology’s summary table.
Clear that no GHG forecast or reduction targets are given, yet notes the need for further work including a dashboard for reporting progress, which is under development.	The emissions report is cited as "internal" and it is not clear if these outputs are planned to be made public, as transparency would reqire.

NATO’s best practice mapping and our recommended next steps

NATO’s Compendium of Best Practice contains examples of how individual NATO members are putting climate change and security measures into practice, including how some are looking to address emissions reporting and benchmarking. The compendium notes the need for the collection, analysis and processing of data to ‘enable defence institutions to set reduction goals and strategies,’ and includes the GHG reduction targets or commitments already set by some NATO members.

The compendium is a useful resource, and a starting point for mapping current action and initiatives. It would benefit from annual updates, with the scope expanded to reflect how NATO members are reporting their GHG emissions – either using the NATO or other methodology – and with links to their emissions reports, and reduction targets.

Future compendiums should also include examples from NATO members not currently included, such as Albania, Belgium, Bulgaria, Croatia, Estonia, Hungary, Latvia, Lithuania, Luxembourg, Montenegro, North Macedonia, and Romania.¹ A number of these and other NATO members are already co-signatories to the 2021 joint statement on climate change and the armed forces,² which includes a roadmap of GHG reduction considerations but no specific targets or reduction commitments.

A summary of the compendium’s core information on reduction targets and reporting is summarised in the table below. Slovenia, Denmark, and Norway stand out as positive examples in terms of reporting, or ambition around improving reporting, for example through the inclusion of Scope 3 indirect emissions. Transparency in reporting must be encouraged alliance-wide, together with steps to improve the scope and consistency of reporting.

 

Linsey Cottrell is CEOBS’s Environmental Policy Officer.

Table 2: Summarised national policies provided in NATO’s Compendium of Best Practice on GHG reduction targets and reporting.

NATO member	GHG reduction target/commitment	GHG emission reporting
Canada	Low-carbon energy in buildings and alignment with government’s mandate in making its building and facilities operations carbon neutral by 2050.	Department of National Defence /Canadian Armed Forces are seeking innovative systems and technologies to accurately measure fuel and load energy consumption and GHG emission data across the Royal Canadian Navy fleet.
Czechia	Not given but stated that a national climate, defence and security policy reflecting the ambitions of the EU Strategic Compass is to be in place by the end of 2023.	Ministry of Defence only provides data on emissions to the overall reports it processes for EUROSTAT.
Denmark	Not given.	Annual carbon account published covering scopes 1 and 2, with plans to incorporate Scope 3 in the coming years.
Finland	Not given.	Not given.
France	Not given but reference to the climate and defence strategy, adopted in April 2022.	Not given.
Germany	Not given but reference to a commitment to reduce impact on climate and the environment and their first national security strategy published in June 2023.	Not given.
Greece	Refence to the current environmental – energy and climate change adaptation policy, dated December 2020, and the Hellenic Ministry of National Defence's goal of carbon neutral infrastructure by 2050.	Recent reporting not given but noted that under its “Military Energy and Carbon Management”, specific measurements and calculations of CO2 emissions of non-tactical infrastructure and platforms have been done, with implementation of ISO 50001 Energy Management Systems at 12 installations.
Italy	Commitment (through Smart District) to reduce its energy consumption by 50% and CO2 emission by 45% (no date) and reference to the "Plan for the Energy Strategy of Defense", adopted in 2019.	Not given.
Netherlands	The MOD to contribute to the government-wide objective of reducing CO2 emissions by 55 percent by 2030.	Not given but acknowledgement that total CO2 emissions are expected to increase due to increased materiel, and therefore efforts needed to make materiel more sustainable.
Norway	A commitment to focus on reducing energy consumption and direct GHG emissions, as well as an emphasis on circular economy and sustainable procurement.	Reporting since 2012, including data on energy expenditure, fuel consumption, and GHG emissions.
Poland	A commitment to reduce electricity and thermal demand. Target (no date specified) to have zero or low-emission technologies by 2060.	Not given.
Portugal	Not given.	Annual collection of the armed forces’ energy data, which is  shared with the European Defence Agency.
Slovenia	A commitment to reduce energy dependence and CO2 emissions, and contribute to energy sustainability in the defence and security sector.	Calculation of the carbon footprint of the Ministry of Defence in scopes 1, 2 and 3 according to the GHG Protocol standard and the ISO standard – in progress. To include all investments in arms, the purchase of ammunition and other specific military goods, in addition to the most common Scope 3 activities.
Slovakia	Target for the vehicle fleet (55% by mid 2030, compared to 2021), and building renovation to ideally achieve 40% reductions (no date).	Not given but cite need for better emissions monitoring.
Spain	Not given.	Not given but cited need to collect and communicate the data and establish indicators that allow monitoring of compliance with actions and objectives.
Türkiye	Not given other than that the "reduction of the energy consumption and green energy options are encouraged."	Not given.
United Kingdom	Not given but reference to the Climate Change and Sustainability Strategy, published in 2021.	Not given.
United States	Not given but references to departmental climate and resilience strategies given.	Not given.