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Santa's Sustainability Audit: Scope 1, 2 and 3

8th December 2024

Santa runs a traditional and globally-renowned operation and as such is facing scrutiny over his net-zero plans. This preliminary assessment aims to provide an overview of Santa's scope 1, 2 and 3 emissions, as well as suggesting some opportunities to pursue.

Santa is not, actually, real (!). But the gifts "he" brings are and so too, in a way, is the "story of Santa" – he’s a cultural creation that we’ve collectively decided is relevant enough to keep retelling. The stories we tell say most about us, the re-tellers – it’s our hopes, fears and values which give them poignancy. When every fiction is possible, the ones we choose are worth introspection. So, let's see how Santa's operation stacks up to a sustainability audit...

Santa and reindeer wait while his EV sleigh charges Above: Santa embraces zero-emissions aviation - illustration by Tess. Click to open full-size.

Before the fun starts, a quick word on life cycle assessment (LCA). LCA is the "compilation and evaluation of the inputs, outputs and the potential environmental impacts of a product system throughout its life cycle" (ISO 14040:2006). It's worth bearing in mind that the "greenhouse gases" we use to structure LCAs today were only properly defined in the 1997 Kyoto Protocol and that the scope 1, 2 and 3 format was only introduced in 2001 as a way to structure corporate emissions reporting.

Today, LCA is the way to methodically analyse the environmental impact of a product, business or operation. Using LCA we can scientifically estimate the positive and/or negative effects of making specific changes to an organisation - and that makes them very powerful tools to support decision making.

Transport / delivery (scope 1)

Kicking things off with a success story, Santa is an unsung hero of low-carbon aviation. While today essentially all aviation depends on the combustion of petroleum based fuels, Santa has remained steadfast in his use of traditional low-impact transport solutions, notably his reindeer-pulled sleigh.

I suppose that, broadly speaking, we could consider a reindeer-pulled sleigh to fall into the category of an aviation biofuel which is of significant contemporary interest. The International Air Transport Association (IATA) considers "sustainable aviation fuel" (SAF, can you believe it?) a key element in reducing the environmental impact of aviation. Unfortunately, the whole basis is fraught with challenges, not least the "food vs fuel" debate.

As an aside, recall that aviation accounts for about 2.5% of emissions but that only 10% of the world’s population fly at all and actually 1% of the world’s population account for 50% of aviation emissions, hardly discouraged by tax loopholes for private jet owners. The amount of aviation emissions is actually growing at a fairly alarming rate and aviation is what we call “hard to decarbonise” i.e. solutions at scale are not coming soon. Bravo Santa!

broadly speaking, we could consider a reindeer-pulled sleigh to fall into the category of an aviation biofuel

Whether Santa’s sleigh may serve as an archetype for the aviation industry to decarbonise is unclear. Reindeer propulsion apparently requires very frequent stops for refuelling (i.e. carrots at every home, which it’s worth commending as a good seasonal choice for European homes at least) which would be impractical for passenger / commercial flights. Passengers accustomed to pressurised cabins may not be prepared to make the switch, and in fact this raises the question of whether Santa’s sleigh even meets regulatory approvals.

I had a skim through FAA design and production documents and needless to say gaining approval for a small aircraft, which is what I suppose a sleigh would count as, is complex and would take into account things like material ratings, fatigue stresses, protection against fire, achievement of certain takeoff and landing performance, manoeuvrability, operability in the case of one or multiple engine stalls, vibration, aerodynamic stability (etc). That said, certain aerospace manufacturers today don’t seem to reliably meet regulatory requirements and thus Santa’s “Ho-eing” airlines may in fact be no less safe and has a far cleaner record on lobbying, war profiteering, corporate evidence coverups and the like.

Reindeer propulsion apparently requires very frequent stops for refuelling (i.e. carrots at every home, which it’s worth commending as a good seasonal choice for European homes at least)

A final note on delivery is that Santa will need to consider alternative final-meter delivery strategies as modern housing now rarely features chimneys, opting for more efficient and less polluting heating solutions like air-source heat pumps (ASHPs). Perhaps he can take a more conventional approach i.e. doors.

Production and warehousing facilities (scope 1/2)

The toys and gifts Santa delivers are typically depicted as being handmade by elves in traditional buildings (i.e. in Santa’s workshop). The Christmas spend sits around £800 per person in the UK, by which statistic I want to point out unscientifically that Santa’s elven workforce and facilities must be absolutely massive (which of course in real non mythical human life it is). This type of artisanal workshop-based production arrangement idealises a time before modern methods like the division of labour, standardised mass manufacturing, globalisation and horizontal rather than vertical integration.

Heating for warehousing and production facilities must be a serious energy expenditure for Santa given the cold climate and is probably the dominant scope 1 emission for him to tackle. Traditional images suggest Santa is still using wood-burning stoves for heating, which while romantic is not a sustainable choice as they release particulates and in certain weather conditions can cause a polluting haze in urban areas. An opportunity could be to use gas-fired Combined Heat and Power (CHP) alongside a district heating scheme to improve the efficiency of the production facilities (given their centralisation). Using a modern insulation material on the traditional wooden log-cabin style workshops would also dramatically reduce heat loss. Alternatively, many datacenters are now being located in cold regions as a way to offset cooling costs, so perhaps a synergy could be established through business partnership therein.

Santa is still using wood-burning stoves for heating, which while romantic is not a sustainable choice

The warehousing issue is exacerbated by the highly seasonal production and stocking cycle which Santa is beholden to, resulting in a requirement for a year’s stocking capacity. An opportunity for Santa to investigate is greater international distribution of production and warehousing. Rather than a single warehousing facility in the arctic circle, distribution centers could be located closer to end destinations, reducing heating costs and allowing Santa to support local workforces (meaning less burden on Santa’s elven workforce who are presumably strained trying to keep up with global population increase).

We don’t know exactly where Santa’s workshop is but let's assume Lapland. Looking at electricity use during production, Finland’s electricity grid is relatively decarbonised however heavily dependent on nuclear at 41%. I would suggest a promising opportunity for Santa to pursue decarbonising scope 2 emissions would be an electricity purchasing arrangement specifically in partnership with a wind farm, whereby he would be directly funding the upfront installation costs. Apparantly these Power Purchasing Agreements (PPAs) are of growing importance.

Supply-chain and Products (scope 3)

The toys themselves bring in a range of considerations. Assuming Santa purchases raw materials and components from suppliers then this will fall into scope 3 emissions, i.e. those which occur in the supply-chain. While Santa’s toys are associated with traditional materials like wood, today the big man seems very accepting of plastics, complex electronics and the like. I can only guess at how Santa may (or may not) conduct supplier audits to determine their quality, worker treatment and sustainability credentials. This is certainly an area where improvement is essential.

Santa’s insistence on single-use decorative packaging for presents is a key branding decision which nonetheless requires a significant annual paper supply and subsequent recycling/disposal. Modern gift-wrapping was popularised in America in the late 1910s though similar ideas for the decorative wrapping of gifts have been expressed in many cultures throughout history.

This significant source of scope 3 emissions could be tackled through a reusable packaging initiative, which may require upfront investment but could reduce Santa’s packaging expenditure in the longer term. Thus, Santa could make a return "packaging and waste collection" trip on Boxing Day, ensuring all packaging is collected for reuse or recycling. There's a whole host of waste and packaging regulations across the EU and other regions that Santa needs to comply with and operating a "producer take-back" scheme will ensure he has oversight of the waste from his operations. At the very least, Santa should avoid the use of plastic-layered wrapping papers and glitters, which are not recyclable and add microplastics to the waste-stream.

Santa could address non-recycling of gift wrapping by making a return “waste collection” trip on Boxing Day

Looking to the circular economy, Santa could stand to make significant environmental advances while reducing operating costs by embracing a reused, refurbished and/or remanufactured gift offering. The benefits are clear: would-be waste products are not disposed of and virgin materials for new gifts are not required, reducing scope 3 emissions and costs. A collection and repair scheme also certainly seems possible. This may be a significant business model shift and it would be prudent to conduct customer focus groups and aim for a staged introduction.

Looking at promotional partnerships and sponsorships, a positive to note is that Santa no longer gives coal to naughty children, ceasing his direct association with the fossil-fuel industry. Unfortunately his (presumably lucrative) promotional partnership with Coca-Cola is ongoing, which no, integrated bottle caps is not as big an environmental win as they would like to make out. Coca-Cola once ran a training campaign to upsell diners bottled drinks over tap-water, called “H2NO”. A partnership with this single-use oriented and profit-first brand could have significant knock-on effect to Santa’s perceived green credentials.

Unfortunately his (presumably lucrative) promotional partnership with Coca-Cola is ongoing...a partnership with this single-use oriented and profit-first brand could have significant knock-on effect to Santa’s perceived green credentials.

Product design and selection has an important part to play and Santa could start by reviewing the product range in terms of production, in-use and end-of-life emissions and thus select best performing products and remove or re-design worst-performing products. He should consider things like embodied carbon, build quality, energy efficiency, repairability and recyclability, as well as avoiding toys which are fad-ish and likely to have a short-lived appeal.

Christmas in a changing climate

Santa is the face of winter for many of us, and it’s perhaps the winter which is changing most notably, becoming wetter and warmer on average. It’s difficult to directly attribute any single event to climate change, but the winter of 2024 (i.e. Dec 2023 – Feb 2024) was, for the UK, the 5th warmest and 8th wettest on record since 1884.

Santa’s operation is particularly exposed to the climatic impacts of a warming climate, with glacial melt, changes to precipitation patterns, surface flooding and more extreme weather events having direct impacts on his operation. This is evident from the need to use Rudolf’s nose to guide deliveries through particularly stormy conditions, which was first necessary in 1939.

Santa’s operation is particularly exposed to the climatic impacts of a warming climate...this is evident from the need to use Rudolf’s nose to guide deliveries through particularly stormy conditions

Santa should identify the likely net impacts of climate change on his workshop, supplychain and delivery strategy, and plan ahead for climate adaptation measures, such as protecting the workshop from flooding and ensuring the sleigh is able to cope with stormier and wetter conditions. Failure to do so would expose both his organisation and workforce to additional risk.

Santa’s Sustainability Audit: Summary

It’s not clear which nation Santa’s emissions should be attributed to (one wonders if his multi-national corporation’s structure is structured for tax/subsidy benefit…) but regardless, Santa will face increased pressure to provide a credible net-zero carbon plan in the coming years, as well as needing to pay carbon taxes. Unless he takes satisfactory actions it’s possible that his culturally-guaranteed monopoly position could be challenged by innovators with clearer environmental commitments.

I’d encourage Santa to do the hard work and get started with a Life-Cycle Assessment covering all areas of his operation. That would help identify the emissions ‘hotspots’ and thus help guide him to a clear and actionable decarbonisation plan, guided by a baseline assessment and science-based targets. He should seek to gain stakeholder buy-in, explaining the benefits of the program and being honest about the challenges ahead.

A certain “fairytale” mystique has been a core part of Santa’s brand appeal in the past half century and this will need to be considered carefully alongside the need to provide a greater degree of transparency and reporting about business practices, sustainability initiatives and progress towards identified net-zero targets.

There are some easy wins that might generate positive publicity (e.g. a switch to plant-based milk and cookies) but these rarely tackle the big emissions – in Santa’s case, the production, storage and distribution of billions of gifts every year. The sooner Santa plans for (and starts addressing) the net-zero transition the less challenging and disruptive it will be. In fact, there may be some significant opportunities in doing so.

Returning briefly to the real world (bah humbug!) in which Santa is not real but the climate crisis is (bah humbug!!) much of the same points apply – as individuals we can consider reused gifts, aim to support brands with robust credentials (i.e. not Amazon), minimise packaging use and aim to reuse for next year. But the real work needs to be done by organisations who have authority over their practices, decisions and agency over their supply-chain selection.

I was originally asked to give a webinar presentation on this topic for the Lighting Industry Association (LIA) but chose to drop out when I started my new role at Synaptec, not wanting to over-commit myself. Well, I thought it was a funny topic then and I think the same now, so I’m writing it into a blog post. Credits to the clever folks at the LIA for the excellent idea and a special thanks to Tess for the fantastic illustration!

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