Responsible Business Report 2022

CEO introduction

As I write, we have just received news that NATS’ climate targets have been independently validated by the Science Based Targets initiative (SBTi) and awarded ‘Business Ambition’ status – the highest ambition possible.

This assessment relates to our target to be net zero in our business operations by 2035 and builds on the A- rating we received last year from the Carbon Disclosure Project (CDP). We have also been recognised for the second year running in the Financial Times/Statista list of Europe’s Climate Leaders.

Martin Rolfe, CEO

Martin Rolfe, CEO

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Highlights from 21-22

Supported Employees

Our business relies on the competencies, capabilities and experience of our employees. We are committed to providing a safe, inclusive and supportive workplace to help employees thrive.

Claire Odd

Health, Safety & Wellbeing Manager

Claire talks about employee wellbeing and agile working...

As an employer, NATS strives to provide proactive support and to equip employees and managers with the tools and skills to help balance work and home responsibilities. This means adapting as an organisation to look after our people while meeting our customer requirements.

During the year, our priority remained the health and safety of all our employees, contractors and visitors at all our sites across the UK and overseas, including Gibraltar, the Middle East and Asia-Pacific regions. A challenging time was made even more difficult by the complex and shifting Covid restrictions that differed from location to location.

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Katie Foster

Head of People Services

Katie talks about our work with D&I...

We made encouraging progress in narrowing our gender pay gap, moving from 19.2% to 16.8%, which we hope to better again in future years through our gender pay action plan. We also published our Ethnicity Pay Gap Report for the first time, as one of our commitments to Business in the Community’s (BITC) Race at Work Charter, which we signed in January 2022. We strongly believe that attracting and retaining employees with diverse backgrounds, thoughts, experience, knowledge and skills is fundamental to the success of our business.

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Nicky Upton-Goodall

Employee Communications Consultant

Nicky talks about inclusivity and our employee networks…

Creating an inclusive culture where colleagues feel safe to share their personal stories is core to our company values and corporate communications strategy. Our focus this year has been to work with our employee networks to raise their profiles and recognise the many D&I awareness events celebrated throughout the year.  We have also supported colleagues, and provided them with a platform where they can share their life experiences and alternative perspectives, which has created new conversations and connections.

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We are committed to providing a safe, inclusive and supported workplace for our employees to thrive

Healthy Environment

For more than a decade we have reported on how we impact on the environment, including our progress on managing airspace efficiently and our reductions in greenhouse gas emissions and other resource use associated with running our buildings and infrastructure.

Dr George Koudis

Environment Lead, Research and Development

George talks about our work supporting research into the non-CO2 impacts of aviation…

The industry has collectively set a net zero target for 2050 based on its CO2 emissions, but aviation’s overall climate impact is known to be broader than CO2 alone. Other greenhouse gases, including nitrogen oxides, contrails and contrail-induced cirrus have an overall warming effect on the planet – with climate scientists suggesting that when taking these effects into account, the overall climate impact of aviation could be two to three times higher than if non-CO2 effects are ignored.

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Lee Boulton

Head of Airspace Development

Lee talks about our airspace change programme deliverables from the past year…

In the past year, we delivered the first tangible steps in modernising UK airspace to be more efficient and to support sustainable growth in the future.

With sustainable fuels and new engine and aircraft technology still some years away, managing our airspace in a way which allows more efficient flying is already playing a major role in helping the aviation industry reduce its environmental impact.

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Marie Darvill

Strategic and Pre-Tactical Planning Manager

Marie talks about our work supporting the UN Climate Change Conference (COP26) and a perfect flight trial…

We were proud to play our part in supporting COP26 in Glasgow last year in what was a complex proposition. With high numbers of VIP flights, business jet flights and helicopter flights arriving at the same time as commercial flights, months of planning from our teams came together to deliver a safe and efficient service.

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Paul Hughes

Head of Facilities Management

Paul talks about our progress reducing the emissions from running our sites…

NATS’ role is to keep the UK aviation industry operating 24-hours a day, 365 days a year. To do this, we operate a large infrastructure of communications, navigation and surveillance sites across the UK, providing our air traffic control centres and airport towers with the ability to communicate with and see where aircraft are positioned. Understandably, energy consumption is the largest source of our own emissions and a priority focus area for my team, not only to support our net zero trajectory but also to help keep the spiralling costs of energy down.

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Each year we report on the impact we make on the environment and the improvements we are making

Strong communities

As a large company with multiple sites across the UK and overseas, we play a positive role in the socio-economic development of the communities in which we operate, creating highly skilled and paid roles, and secondary employment, as well as supporting a range of charities and other good causes.

Anne Marie Black

Corporate PR & Charities Manager

Anne-Marie talks about re-starting in-person events with our corporate charities…

We continued to financially support our corporate charities throughout the pandemic, and as Covid restrictions eased, especially later in the year, both Aerobility and the Jon Egging Trust (JET), were able to re-start their face-to-face programmes and events, which we were delighted to participate in once again.

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Robin Clarke

Community Relations Manager

Robin talks about community engagement and an important airspace change…

As an organisation we are committed to understanding the views of local communities and considering these in decisions we make that may impact the public. While the pandemic largely prevented our usual round of face-to-face meetings with community groups at airport and government forums, we have continued to engage widely with this audience through the now familiar online meeting tools.

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Helen Fuge

Head of Talent

Helen talks about the importance of partnerships…

Despite the continued constraints the pandemic has enforced, we have continued to support the local community through STEM engagement and Apprenticeship support. Our partnerships with local schools and colleges have continued through the delivery of both virtual and face to face sessions centred on innovation and the importance of engineering.

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We strive to play a positive role in the communities where we operate

Good Business Practice

Our business is built on partnerships with our customers, suppliers, peers and other stakeholders. These relationships are built on trust and our high standards of ethical behaviour and integrity.

Simon Lansdowne

GM Customer Affairs

Simon talks about engaging with our airline and airport customers…

The last year continued to be unpredictable and hugely challenging for our airline and airport customers. The summer of 2021 saw travel and air traffic start to recover, but demand remained suppressed by changing restrictions and travellers were understandably apprehensive.

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Stuart Gray

Director Group Treasury & Corporate Finance

Stuart talks about sustainability linked-finance…

Last year, as part of the broader refinancing of its debt structure, NERL agreed a £400 million sustainability-linked revolving credit facility with a syndicate of six banks. The key performance indicators (KPIs) for this facility relate to our scope 1 and 2 emissions, scope 3 emissions (i.e., categories 1, 3, 4, 6 and 7) and the group’s CDP rating. A condition of these GHG emission KPIs was that they needed to be validated by the Science Based Target initiative (SBTi).

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Stephen Rose

Head of Business Services

Stephen talks about responsibly managing our supply chain…

The partners and suppliers that we work with are key to how we deliver our services and investment programmes. We seek to work with suppliers who can help us deliver these outcomes in ways that reflect our own values and ethics. We work with suppliers responsibly and set out our expectations of them, and what they can expect of us, in a Supplier Charter that is published on our company website. The charter covers two-way expectations in terms of ethics, conduct, health and safety, fair treatment of employees and contract staff, corporate & social responsibility, and the environment.

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Our business relationships are built on trust and high standards of ethical behaviour


Our investors, customers, suppliers and other stakeholders are aware of the need for, and benefits of, good environmental, social, governance. Our commitment to the welfare of society, including our employees, and the natural world is an increasingly important measure of our overall performance. We recognise the growing expectations of the public and policymakers regarding transparent reporting on these outcomes.

The NATS board is responsible for non-financial policy and performance. The Board has reviewed how it has applied the principles of the Code of Corporate Governance in each of the main areas of culture, diversity, employees, stakeholders, remuneration and succession. The Board receives regular updates throughout the year on these topics and formally reviews the approach annually.

In addition to the Board, the Executive and various subgroups monitor health and safety, employee relations and environment matters.

Our Chief Executive is accountable for our responsible business policy. And, in accordance with their accountabilities under the Code, our Board takes an active interest in the policy and its implementation as part of their strategic responsibility for the culture of the company. Oversight from the NATS Executive covers our policies for employee relations, environmental performance, anti-bribery and corruption, Health, Safety & Wellbeing, D&I, prevention of modern slavery and human trafficking through various strategy, risk and governance sub-committees.

We have adopted a number of management systems to ensure compliance with legislation and mitigate business risks, many of which are certified, such as: ISO 9001 (quality), ISO 14001 (environment), ISO 27001 (information security), ISO 55001 (asset management) and ISO 45001 (health and safety). Governance processes are in place to ensure oversight for these management systems.

Employee and environmental matters have been determined as material non-financial matters that have an indirect financial impact on our business and have been identified by taking account of the views of our customers, suppliers and employees, including key performance areas subject to regulatory targets, and responsible business issues subject to mandatory reporting. Some of these are addressed further in our Annual Report & Accounts.

Risk management

Governance of risks and opportunities takes place at various levels throughout our company, with ultimate responsibility resting with our Chairman of the Board of Directors and our CEO. The system for the identification, evaluation and management of emerging and principal risks is embedded within the group’s management, business planning and reporting processes, accords with the UK Corporate Governance Code, and is aligned with the ISO 31000 risk management standard.

Detailed risk identification, assessment, and control mapping is carried out at business unit, departmental, and Executive levels and is recorded and measured in a structured and controlled enterprise-wide database. NATS’ risks are mapped against risk appetite and tolerance statements which have been agreed by the Board.

Risk update reports are submitted to the NATS Executive team which address changes in risk, risk appetite and tolerance, internal controls and the progress of actions associated with NATS’ risks. Regular reviews are also carried out by the Audit, Safety and Transformation Committees in accordance with their remits, as reported in later sections.

Taking into account the work of the Committees, the Board formally reviews emerging and principal risks, and the risk management processes and mitigations in place on a six-monthly basis. In addition, monthly Executive reports to the Board identify by exception any changes in the ‘top risks’ particularly if the change means a risk falls outside agreed appetite.


NATS regularly reviews its internal policies to ensure that they reflect best practice and comply with legislation in the countries in which we operate. The policies we have in place include: 

  • a responsible business policy; 
  • an anti-slavery and human trafficking policy; 
  • a company-wide code of ethics and professional behaviours; 
  • comprehensive HR and recruitment policies; including Respect at Work, Just Culture, work and family and menopause policies; 
  • a code of conduct covering all employees; 
  • a health and safety policy  
  • a wellness, mental health and stress management policy 
  • a whistleblowing policy open to all employees and third parties, including customers and suppliers;  
  • an airspace, energy and environmental data disclosure policy; and 
  • extensive supply chain governance, policies and procedures.

In the reporting year, we developed and launched a new menopause policy, with accompanying support pathways for individuals and manager guidance. This has been well received by the organisation, sparking awareness and positive discussions that may not have taken place previously.

Our responsible business policy sets out our core principles as they relate to human rights, ethics, protecting our natural world, working with communities and transparent reporting.

Environmental governance

Oversight for environmental matters on behalf of the Board rests with our CEO who is responsible for the company’s environment strategy and for the management of any climate related issues. This comprises a set of core principles which cover a wide range of non-financial matters including climate-related issues.

Various subgroups and committees sit across the organisation reporting up to the Executive and Board on environmental matters. This includes:

  • An Executive-level Environmental Strategy Steering Group acts on behalf of the CEO and Board to ensure that environmental issues are monitored and managed and commitments to customers, regulators and other major stakeholders are being appropriately delivered; the Group is also responsible for the evolution of the sustainability strategy. Meeting bi-monthly, the scope covers environmental impacts we influence through our air traffic operation and the estate-based impacts from delivering our business.
  • A Director-level Decarbonisation Implementation Steering Group focuses on the implementation of the sustainability strategy to meet company and industry net zero commitments.
  • The Operations Director oversees the Service Delivery Improvement Group, which is responsible for delivering improved service delivery across airspace-related safety, environmental and delay performance. Meeting monthly, the group monitors risks and opportunities, including tracking a suite of airspace environmental metrics and monitor values to improve airspace efficiency.
  • Numerous panels ensure our capital investment programme is appropriately delivering improved environmental performance and managing compliance requirements.

NATS has an environmental management system that operates across the company and is certified to the international standard ISO 14001:2015. The certified scope covers the planning, management and provision of Air Traffic Management and estates services for activities carried out at our head office in Whiteley, in addition to the activities at all UK airport towers and Aberporth ranges, and seven military towers.

The operation of a robust environmental management system ensures NATS activities and services are assessed to determine all significant environmental impacts and to ensure control measures are reviewed and improvement plans developed.

Public disclosure and performance

Modern Slavery

Our annual Slavery and Human Trafficking Statement describes the steps we have taken during the financial year to deal with modern slavery risks within our supply chain and business. NATS’ policy requires everyone within the organisation to prevent slavery and human trafficking and to comply with the requirements of the Modern Slavery Act 2015.

Gender Pay Report

We report annually on our gender pay gap under the UK Equality Act Obligations. Our latest Gender Pay Report relates to data up to April 2021. Over the past year our pay gap moved from 19.2% to 16.8%, and one of the drivers was a voluntary redundancy programme, which we introduced in response to the impact of Covid on our industry. The programme saw around 10% of colleagues leave the business at the end of 2020, partly driving our pay gap improvement, as higher paid male colleagues and lower paid females left the company.

This created an opportunity to redress some of the previously reported gender imbalances, by actively encouraging female talent to apply for new management opportunities, as we reorganised the business. This has resulted in 36% of our promotions into our senior management grades being female, in comparison to 27% of our overall demographic. Following our recruitment freeze during the pandemic, we have been able to re-open our early careers programme for a September 2022 intake.

Ethnicity Pay Report

We published our first Ethnicity Pay Report this year, which we committed to when we signed up to Business in the Community’s (BITC) Race at Work Charter.

Whilst ethnicity pay reporting is not mandatory, we have chosen to share our data and action plan to illustrate transparency, improve the company’s approach to D&I and improve the equality of opportunity in the workplace.

In its first Ethnicity Pay Report, NATS has identified a pay gap of 20.7%. *  This is our first year of reporting but looking at data from previous years shows a slight improvement in the pay gap as a result of actions already undertaken through our 2020 D&I Strategy

*Currently, 15% of our employees have chosen not to declare their ethnicity data, and so our report does not represent a complete picture of our organisation.

Diversity and Inclusion Steering Group

Following the introduction of our D&I vision, we established a D&I Steering Group, chaired by our CEO, to guide the direction of our D&I agenda and ensure all work is aligned across the business, including our leadership teams, business areas, employee networks, Communications, HR and Trade Unions.  The group will shape the direction, track progress and ensure commitment and focus across the organisation.

Licence reporting requirements

NATS’ en route licence sets out a number of reporting requirements, including an annual update to the CAA (Condition 10) on our environmental performance. This information is also published in our Annual Report & Accounts and the Responsible Business reports. In addition, we report our airspace environmental performance using the 3Di metric on our website, as part of our Condition 11 requirement.

Transparency of environmental reporting

In order to ensure transparency and accuracy in the reporting of our environmental impacts, our greenhouse gas emissions data associated with running our business, and contribution to aviation decarbonisation, is externally verified to the ISO 14064 standard. Achieving this requires us to prepare and publish a technical report outlining how our GHG emissions have been calculated on our website. The verification statement and GHG report are updated annually to take account of updated performance information and any changes in approach, methodology, boundaries, etc. and are also published on our website.


We have sought a third-party CDP (formerly the Carbon Disclosure Project) climate change rating annually since 2016 (except for 2019-20 due to Covid).  CDP is a non-profit charity that runs the global disclosure system for investors, companies, cities, states and regions to manage their environmental impacts. It is considered a gold standard measure of environmental sustainability and stewardship. Each year, CDP takes the information supplied in its annual reporting process and scores companies and cities based on their journey through disclosure and towards environmental leadership and transparency. NATS’ rating is available on the CDP website.

Climate Adaptation Reporting

NATS is exposed to physical climate related risks because of climate change. These can be acute, and event driven, or chronic, arising from longer-term shifts in climate patterns. As a critical infrastructure provider, we periodically respond to DEFRAs (Department Environment, Food and Rural Affairs) Adaptation Reporting Power request under the Climate Change Act 2008. This involves submitting a climate risk and adaptation progress report based on an assessment of how the most recent UK climate projections have the potential to impact our infrastructure. Our most recent report, developed during the reporting year, sets out our latest assessment based on the 2018 UK climate projections.

Effective governance is essential for ensuring we meet our responsible business goals

Environment targets

We have set out an environmental strategy and targets to improve our emissions performance, both in the airspace we manage and from running our business. Our promise is to be a net zero emissions company by 2035 and to work with our customers, partners and suppliers to achieve a net zero aviation industry by 2050.

While our material focus is on climate change mitigation in these areas, our policies and environmental management system ensure that we apply the principles of sustainable consumption and our business practices contribute to the protection and enhancement of our natural world, biodiversity, ecosystems and to prevent pollution.

As a business the reach of our impact is even broader:

  • NATS works closely with wind farm developers to mitigate the impact to radar from wind turbines, helping to improve the CO2 emission factors of electricity on the UK national grid by enabling much larger and more wind farm developments.
  • Under our commercial business we are supporting the industry in the implementation of electric air mobility, which as a new emerging sector could replace short distance transportation with lower emissions or no emissions solutions. Electric advanced air mobility is also widely believed to be an important use-case for future scaling up of low carbon short and medium haul flight.  Understanding how we efficiently integrate all current and future airspace users is a core part of our new corporate strategy.
  • Our commercial business also currently receives revenue from the deployment of technological solutions to improve airspace efficiency to airports and other air traffic providers in the UK and beyond. The deployment of intelligent approach at Toronto in the year is just one example of this.

Community annoyance continues to be of concern, and we work closely with airport operators, airlines, our regulator, the Department for Transport, ICAO and community representatives to help manage aircraft noise concerns near airports.

Running our business

We adopted a net zero target for emissions associated with running our business in 2019 and brought this forward from 2050 to 2035 in early 2021.

We have clearly defined short-term absolute emission targets which have recently been approved by SBTi. These are;

  • NATS Holdings Limited commits to reduce absolute scope 1 and 2 GHG emissions 41% FY2026 from a FY2019 base year.
  • NATS Holdings Limited also commits to reduce absolute scope 3 GHG emissions covering purchased goods and services, fuel and energy related activities, upstream transportation and distribution, business travel and employee commuting GHG emissions 41% within the same timeframe.
  • NATS Holdings Limited further commits that 50% of its suppliers, by spend covering capital goods, will have science-based targets by FY2026

The above represents a comprehensive set of targets covering our material environmental impacts, including direct emissions from electricity and combustion of gas, fuel and oil, and what are often considered some of the hardest to manage e.g. commuting and business travel emissions. NATS Holdings commits to increase annual sourcing of renewable electricity from 0% in 2018-19 to 100% by 2030.

Recently, our Executive and Board set out a new long-term vision for the business, which embedded and further enhanced these goals. By 2040 we aim to be carbon negative across our estate, which marks a further stepping-stone beyond net zero.  During the next year, we will be defining what carbon negative means for us and will continue to prioritise transparency and climate science in all of our reporting.

Our approach to managing down our emissions is based on the following hierarchy;

  • Avoiding – policy decisions to stop carbon intense activities from happening (e.g., size and shape of our business, embedding carbon targets within all of our investment projects, developing minimum purchase standards, review of fleet)
  • Reducing – improving energy efficiency, reducing business and commuting travel emissions
  • Self-generating – installation of on-site renewable energy with energy security and cost co-benefits
  • Offsetting – Any residual CO2e emissions will need to be balanced with direct carbon removals until they can be replaced with zero carbon alternatives, to meet the net zero target.
  • Verifying – ensuring our data is robust and transparent by continuing to have it verified annually to the carbon reporting standard ISO 14064.


As NATS is a monopoly provider of en-route air traffic control services across the UK, the Civil Aviation Authority (CAA) determines our costs and expected performance levels through rolling five-year regulatory ‘price controls’. Since 2012, this has included financial performance targets on the efficiency of UK domestic airspace using a metric called 3Di (three-dimensional insight score). This was a world first, and we believe we are still the only air navigation service provider to have financial incentives based on the efficiency of its overall airspace. Last year, we made available, free-of-charge, the formula 3Di to the wider industry to deliver efficiency gains.

The 3Di metric encourages us to reduce aircraft fuel burn and emissions by improving aircraft trajectories across the UK. It does this by computing an efficiency score for every commercial aircraft, which across the year are averaged and compared to targets set by the CAA. Financial penalties or bonuses apply, depending on how we perform against targets, which have historically been stretching as they get harder year-on-year and as traffic has increased. 3Di targets for the current price control period, called Regulatory Period 3 (RP3), which was set to run from 2020-2024 are outlined in the chart below.

3Di score targets Click to enlarge

As an indicator that captures the overall efficiency of UK domestic airspace, 3Di is inclusive of others’ behaviours and actions. This includes NERL and other ANSPs, pilots, airlines, airports and danger area users amongst others. The metric also captures the impacts of traffic levels upon efficiency.

Due to the reduction in air traffic volumes because of Covid, the RP3 3Di targets are currently not relevant; performance over the past two years has outperformed the regulatory targets during lower traffic levels when our air traffic controllers have been able to provide more optimum routeings and smoother climbs and descents, reducing fuel burn, CO2 emissions and 3Di (see Environmental Results section below). Our proposals for the next regulatory period (NR23) starting from 2023, ensure 3Di continues to incentivise NERL appropriately to deliver the fuel burn and emissions savings airlines highly value. This includes a proposal for targets that adjust up or down with corresponding changes to expected traffic numbers, to manage the risk of uncertainty in traffic levels.

In 2020, the UK aviation industry, including NATS, made a commitment to net zero emissions by 2050 and during consultations on the NR23 business plan, customers and passengers supported ambitious environmental targets. We have set out our expected contribution to reducing airspace CO2 emissions as a result of planned airspace modernisation, new controller tools and other initiatives in RP3 and beyond. Our plan aims for a reduction in carbon emissions of 4.4% between 2020 and 2035, in line with independent assessments of the contribution air traffic control can make to overall aviation emissions reduction. We will achieve this through a range of measures including optimising flight paths to reduce aircraft fuel burn and CO2 emissions and delivering airspace modernisation.

We also have non-incentivised airspace performance indicators aligned with performance regulation KPIs under Single European Sky. This includes ‘KEA’ which measures average horizontal en-route flight efficiency (based on the actual trajectory of flight). With the endorsement of our airline customers and our regulator, our primary focus remains on the 3Di metric which not only includes KEA within its construct but goes beyond it in scope; to include additional areas of horizontal flight efficiency excluded by KEA, as well as all elements of vertical flight inefficiency, also not covered by the KEA metric.

Where we deliver tower air traffic control services to airport customers, it is usual to have local environmental targets and controls to work towards, both financial and non-financial. These typically focus on improvements to continuous descent arrivals, which reduce both noise and emissions, aircraft taxi time, or ensuring local noise restrictions are met.

At the beginning of 2021 we chose to accelerate our net zero goal from 2050 to 2035

Environment results

Summary of 21-22 performance

We continue to focus on improving our environmental performance, both in terms of the impact of running our business and our management of air traffic in airspace we are responsible for.

Estate Performance

We have a good track record, having reduced electricity consumption across our estate by over 35% since 2006. Through the pandemic, as our non-operational workforce moved largely to working from home, we were able to reduce the size and number of buildings we occupy resulting in energy and commuting emissions savings. We continue to introduce and encourage agile working across all of our sites, enabling people to work in new and different ways, supported by a variety of office spaces and technology. While there has been a steady flow of people using the newly reconfigured workspaces, where their role allows, many colleagues have been continuing to work remotely, and our data shows that people are working with a mix of site-based and remote working. Last year, we incorporated emissions calculations within our reported inventory, and this is something we will continue to do.  We have used the eco-act, homeworking emissions methodology to calculate and include emissions from homeworking in our 2022 disclosure.

There has been some significant progress in exploring further energy efficiency measures. This includes:

  • Using newly deployed energy metering to identify opportunities across lighting, heating, cooling, ventilation systems and ways to reduce the energy requirements of our systems.
  • Developing proposals for large-scale on-site renewable power generation.
  • Working with landlords to improve the efficiency of buildings.
  • The establishment of energy targets across our capital investments supported by new governance (a net zero benefits panel) and a new energy (kWh) benefit category in project tracking.

Electricity consumption is and always has been the largest contributor to our estate emissions (see our most recent baseline below) and it is understandably a continued area of focus in our drive towards net zero.

NATS Emission infographic

NATS baseline emissions 2018/19 Click to enlarge

Electricity consumption kWh from 2006 – 2022 Click to enlarge

Emissions resulting from commuting have started to rise again as offices have opened but remain well below past levels. Business travel also remains well below past levels. We have adopted a new fleet policy in the reporting year to reduce the emissions of NATS-owned vehicles and included business emissions reporting in regular director reports.

Overall emissions rose moderately year-on-year as a consequence of the rebound from Covid and last year’s particularly low emissions figures. By the financial year end, we had achieved a -37% reduction in aggregated CO2e emissions compared to a 2018/9 baseline, ahead of our -18% target for FY2021/22.

Estate emissions reductions since baseline Click to enlarge

We were awarded an A- rating by CDP in the latest round covering reporting year 2020-21. This is the first time we have achieved this leadership grade status having previously been awarded B grades in our last two submissions. This score puts NATS in the top 2% of the 13,000 companies around the world that disclosed their data to CDP in 2021. This reflects NATS’ commitment to measuring, managing and disclosing environmental performance.

We have completed our third year of procuring low carbon green biogas certificates for all-natural gas supplied and purchased renewable electricity for over 96% of total electricity consumed during the year.

We were pleased to have been identified for the second year running as one of Europe’s Climate Leaders 2022 by the Financial Times/Statista - for our environmental performance since 2015.

We have continued to expand the scope of our environmental management system with new additions to the NATS operational portfolio; Barkston Heath, Woodvale and St Athan all achieving ISO 14001 certification in the last year. They join 19 other sites across the UK, including all civil airport towers with certification to ISO 14001:2015, and audited by DNV.

Airspace Performance

The reduction in traffic levels through the pandemic has had a significant impact on the efficiency of the UK domestic network. We saw arrival holding almost entirely vanish, direct routeing increase, and constraints impacting vertical flight efficiency largely disappear – all of which tend to improve efficiency and reduce aircraft emissions. We also saw large increases in the number of continuous climb departures given that there were fewer interactions with other traffic. The complex interrelationship between traffic and efficiency is demonstrated across many of the performance measures.


Continuous climb achievement (%) Click to enlarge

Continuous climb is a measure of airspace efficiency between 0-10,000ft across the UK. A flight has achieved a continuous climb if it performs a smooth continuous climb without levelling off. We saw a 15% increase in fuel efficient climbs following Covid. Figure represents monthly averages for all departures across 22 (Sustainable Aviation coalition) member airports.

Horizontal track efficiency (KEA%) Click to enlarge

Horizontal track efficiency is a proxy measure of efficiency in the horizontal plane of flight, measuring how direct a flight’s path is across our airspace (100% is achieved by every aircraft taking the most direct track over the earth). Figure represents monthly averages of all flights within UK domestic airspace.

Continuous descent achievement (%) Click to enlarge

Continuous descent is a measure of arrival emissions and noise efficiency near to airfield level in the UK (local height definitions apply). Performance levels have been able to be maintained over the past year. 100% is achieved when every aircraft achieves a continuously descending profile without levelling off. Figure represents monthly averages of all arrivals across 22 Sustainable Aviation member airports.

Total arrivals holding minutes (within inner holds) Click to enlarge

Total amount of time aircraft spent within inner arrivals holds. A zero score represents zero inefficiency. Figure represents monthly totals across all 22 Sustainable Aviation member airports.

3Di performanceClick to enlarge

UK flight efficiency performance, as measured by 3Di. A zero score represents zero inefficiency. Figure represents monthly averages of all flights in UK domestic airspace.

The NERL 3Di target for calendar year 2021 was 27.5 (threshold for bonus and penalty being 26.2 and 28.9 respectively). The overall average 3Di score in 2021 was calculated to be 21.51 largely arising from low traffic levels. By comparison, in 2020 the score was less efficient (23.9) as the first quarter of the year operated with typical traffic levels.

The lower traffic levels during Covid have allowed our air traffic controllers to provide more optimum routeings and smoother climbs and descents, reducing fuel burn, CO2 emissions and 3Di. As a result, NERL proposed that the performance incentive scheme is set aside for RP3, during which traffic has been and is forecast to continue to be, atypical to the levels against which the financial incentives were originally calibrated. We have not and will not claim any bonus for our 3Di performance in RP3 (2020 – 2022).

The 3Di performance chart above shows that as traffic has started to return during the first quarter of 2022, the gains in airspace efficiency seen over the past two years have started to be eroded, with 3Di correspondingly increasing, although still significantly below historic levels. A comparison of 3Di scores at equivalent traffic levels, pre- and post-pandemic, show that relative efficiency has improved. Our focus has been on retaining as much of the efficiency we’ve seen across our network as possible. To support this, we have set internal targets across a range of environmental metrics for holding, climb, cruise, descent and how direct aircraft fly, all with the principle to outperform our historic performance for any given level of traffic. This has helped us identify a number of emissions improvement opportunities with our airline customers.

An example of this includes work to reduce the early morning arrival of aircraft when runways are not open, which leads to airborne holding and increased emissions. We have engaged with Wizzair at Luton and American Airlines, Etihad, Qatar Airways and British Airways at Heathrow on this. The outcome of this engagement, which is still ongoing, has been to lower the average amount of time aircraft spend holding before making an approach and landing. This work was later extended to cover Saudi Arabian, Virgin Atlantic, United and Jet Blue. The fuel and emissions savings for even small interventions are worth it, for example a B777 will use c.100kg of fuel (over 300kg CO2) per minute holding. A spin-off benefit is that many of our customers have had a higher level of engagement with NATS, and through sharing performance data with them, they have better information on environmental performance at their fingertips.

We have engaged a range of airlines (DHL, Loganair, Stobart, West Atlantic, Qatar, Lufthansa, Aurigny, and BA Cityflyer) to improve the accuracy of flight planning to ensure we are able to deliver the cruising flight levels our customers want and to improve predictability.

Each year we model the CO2 emissions from aircraft under our control within domestic UK airspace, airports where we provide a tower service (data availability permitting) and oceanic airspace and report them as our scope 3 category 11 emissions. The table below shows how the quantum of these emissions has changed across the pandemic.

  2018 2019 2020 2021
Modelled CO2 emissions in UK Domestic and Oceanic airspace (000,000s) 25.0 24.4 7.1 13.9

Separately, aircraft fuel burn and CO2 emissions avoided as a result of our actions are modelled across the same geographical scope and reported as our scope 4 emissions. These arise from either structural changes to airspace or improved tactical performance within the confines of fixed airspace. Across the reporting period we have continued to develop and implement specific changes to improve airspace efficiency.

As a result of structural changes to domestic airspace we helped avoid 7,702 tonnes of CO2 emissions in aggregate across the financial year. This was the result of:

  • The introduction of Free Route Airspace Deployment 1 into UK Airspace in December 2021, which enabled 10,539 tCO2 saving.
  • A large number of small-scale improvements to airspace, delivered under the Operational Service Enhancement Project (OSEP) and by our environmental focal points, which enabled emissions savings of 3,307 tCO2.
  • The implementation of Swanwick Airspace Improvement Project AD6, jointly sponsored by NATS and Luton Airport, marked a significant change to Essex and Luton airspace. The development separated Luton and Stansted airport arrival flows from one another to reduce complexity, allowing both airports to have their own arrivals routes and holding procedures. This has delivered an overall disbenefit of -6,144 tCO2 emissions against the past airspace design; however, when the reduced likelihood of holding in future is taken into account, by 2032 the disbenefit is forecast to reduce to -4,500 tCO2. The change has not reduced the potential for tactical inventions to offer direct routes.

As well as calculating the impact from changes to the design of airspace, we calculate year-to-year changes to the tactical performance of airspace in several areas, namely changes to the number of continuous climbs and continuous descents, and airfield taxi-time. The assessments form part of our reported annual emissions assertions, as under normal conditions they would show changes in performance.

However, as with 3Di, it is clear that these measures are also significantly affected by traffic volume. Given the increase in traffic levels between 2020 and 2021 financial years, we have seen a disbenefit in performance in these ‘tactical performance’ areas compared to the previous reported year. This is essentially showing a correction or return to the past years’ performance as a result of changing traffic levels. Combining the results from the structural changes to airspace with tactical performance measures results in a net increase in CO2 emissions of 22,646 tonnes for 2021.

Since 2006, our average annual reduction in CO2 emissions stands at 116,000 tonnes, taking this year’s performance into account.

Summary Results

The environment metrics below have been prepared in accordance with non-financial information reporting guidance from the Financial Reporting Council, the European Commission, the Climate Disclosure Standards Board (CDSB) and the Task Force on Climate-related Financial Disclosures. An operational control approach is taken to non-financial information using the same boundary as the NATS Holdings group.

Description* FY 2021-22
(or CY 2021)
FY 2020-21
(or CY 2020)
Service performance and resilience    
3Di (calendar year) 21.5 23.9
Environmental performance^    
Scope 1 emissions (location-based tonnes CO2e) 2,708” 3,706”
Scope 1 emissions (market-based tonnes CO2e) 2” 2
Scope 2 emissions (location-based tonnes CO2e) 11,774” 12,500”
Scope 2 emissions (market-based tonnes CO2e) 718” 668
Scope 3 categories 1, 3, 4, 6 and 7 emissions (tonnes CO2e) 10,754” 6,111”
Total scope 1, 2 and 3 categories 1, 3, 4, 6, 7 (tonnes CO2e) – location based 25,236” 22,317”
Scope 3 categories 11 emissions (tonnes CO2e) 13,920,072” 7,146,000”
Avoided / modelled enabled ATM-related CO2 reduction in tonnes)*** -22,646” 37,950”^
Water supply and treatment (m3) 27,508” 45,091”
Energy consumption (gas + electricity) MWh 66,520” 63,864”
CO2 intensity metrics    
Total 1 + 2 emissions (location-based tonnes CO2e) 14,482” 16,206”
Total 1 + 2 emissions (market-based tonnes CO2e) 720” 670
Total 1 + 2 intensity metric (location-based tonnes CO2e per £m of revenue) 19.3” 19.7”
Total 1 + 2 intensity metric (market-based tonnes CO2e per £m of revenue) 1.0” 0.8
Net zero metrics    
Percent change in CO2e against 2018-19 baseline towards net zerp 2035 target (scope 1 and 2 emissions)** -30%” -22%
Percent reduction in CO2e against 2018-19 baseline towards net zerp 2035 target (scope 3 categories 1,3,4,6,7)** -43%” -69%

” GHG assertions independently verified by DNV to the international standard ISO14064. The verification statement from DNV and technical GHG report detailing how our emissions have been calculated are available on here.

^ restated due to inclusion of additional information, improvements to modelling accuracy and data quality.

* The Responsible Business statement and the environment metrics reported above have been prepared in accordance with non-financial information reporting guidance from the Financial Reporting Council, the European Commission, the Climate Disclosure Standards Board and the Task Force on Climate-related Financial Disclosures. An operational control approach is taken to non-financial information using the same boundary as NATS Holding Limited.

** Our net zero target applies to total scope 1 and 2, plus and 3 (categories 1, 3, 4, 6, 7) CO2e location-based emissions by 2035, using a 2018-19 baseline.

*** Modelled enabled ATM-related CO2 reductions represent the saving in CO2 emissions from improvements to the ATM network, such as technical changes which enable us to provide more fuel-efficient flight profiles, based on projections of the volume of flights likely to take advantage of the improvements. The enabled reduction in emissions is reported in full in the year in which the improvement is made. This is modelled based on industry best practice and is outlined in detail in our GHG report, available here.

We continue to improve our environmental performance in the way we run the business and ATC operation

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