Estate Emissions in Local Authorities: Tackling Scope 3 Risk & Downstream Leased Assets

Explore why estate emissions – especially from leased assets – are often missing from councils’ reported carbon footprints, and how you can close this critical gap in your Scope 3 emissions.

It’s no secret that local authorities play a pivotal role in meeting the UK’s net zero targets. As public bodies with democratic mandates and significant operational footprints, they are expected not only to decarbonise their own activities but to lead by example, thus demonstrating transparency, ambition, and delivery on climate commitments.

However, many local authorities are falling short in a critical area: the emissions from their own estates. These often-unseen emissions – embedded in buildings they own but do not occupy – are routinely underreported or left out of inventories entirely. This has profound implications. Data analysed using CarbonTrack, the first Scope 3 emissions tool for local authorities, suggests that some councils may be underreporting their emissions by as much as 50% due to incomplete estate accounting. Without a clear view of the full footprint, meaningful action toward net zero becomes difficult, if not impossible.

Real-world data from a UK local authority, measured by CarbonTrack, illustrates the significant scale of Scope 3 estate emissions, highlighting their critical role in the authority’s overall carbon footprint.

This article explores why estate emissions matter, how they fit within the Greenhouse Gas (GHG) Protocol framework, and what local authorities can do to start capturing and addressing this hidden half of their carbon footprint.

What Are Local Authority “Estate Emissions”

Put simply, estate emissions are the emissions from energy usage in any building that a local authority owns, regardless of whether it operates out of it. This includes, but is not limited to:

• Social housing (including high-rise blocks)
• Leisure centres
• Libraries
• Community centres
• Care homes
• Depots, pavilions, and industrial units

These buildings, although not occupied by council staff, are still part of the council’s asset base, and thus within the boundary of their climate responsibility.

Currently, most local authorities report emissions from their offices, town halls, or depots – i.e., places where council employees work. However, these emissions often represent only a fraction of the authority’s actual estate footprint. In most councils, the true scale of emissions lies in the leased-out estate, where large, energy-intensive buildings are used by third parties, including housing associations, charities, or commercial tenants.

Direct or Indirect Emissions? The Importance of Categorisation

“A deeper understanding of ‘influence’…warrants a more proactive, leadership-oriented approach”

The GHG Protocol defines emissions in three categories:

• Scope 1: Direct emissions from sources the reporting entity owns and controls.
• Scope 2: Indirect emissions from purchased electricity, heat, or steam.
• Scope 3: All other indirect emissions across the value chain.

For buildings the authority operates, such as offices, emissions clearly fall under Scope 1 or 2. However, the question of whether estate emissions fall into “Direct” (Scopes 1 and 2) or “Indirect” (Scope 3) emissions categorisations hinges on the concept of control. Under a traditional interpretation:

• If the local authority operates the building (e.g. it’s a council office), emissions fall into Scope 1 or 2.
• If the building is leased out, emissions fall into Scope 3, specifically Category 13: Downstream Leased Assets.

Most take this at face value, assuming that once a building is leased, they are no longer responsible for its emissions in a direct sense. However, this overlooks a deeper understanding of “influence” that warrants a more proactive, leadership-oriented approach comes in.

Rethinking Responsibility on Local Authority Emissions: A Leadership-Oriented Approach

For public sector landlords committed to meaningful climate action, simply following the letter of the GHG Protocol is no longer enough. To drive real change, local authorities must think beyond control and consider influence.

While they may not operate leased buildings on a day-to-day basis, local authorities own the assets, control the terms of the leases, and, crucially, make decisions about capital investments and retrofits. In many cases, the buildings are leased on short-term or rolling agreements, giving the authority the flexibility to impose environmental conditions, offer incentives for energy performance improvements, or invest directly in decarbonisation measures.

This raises an important question: Should emissions from these buildings still be considered “Indirect” if the local authority is the only stakeholder with the power to decarbonise them?

We argue that, for local authorities seeking to demonstrate climate leadership, it is more appropriate to voluntarily treat these emissions as “Direct” (Scope 1 and 2), where the local authority is the sole stakeholder with structural control to make capital investment in decarbonising the building’s energy usage.

This forward-looking, impact-driven reporting model is more reflective of the real-world responsibilities local authorities hold. It supports better decision-making and aligns carbon accounting with long-term decarbonisation strategies.

Common Barriers to Accurate Emissions Measurement in Local Authority Estates

Of course, rethinking responsibility is only the first step. Accurately measuring emissions from a complex, diverse estate presents considerable practical challenges.

• Data Availability: Councils often do not have access to tenants’ energy usage data. In some cases, tenants themselves may not track their usage in a way that is accessible or consistent. Engaging with housing associations, charities, or commercial tenants to gather this data requires resources and sustained effort.
• Estate Data Integrity: Many councils do not have a centralised or consistent view of their estate. From our experience, property data may be fragmented across departments, with conflicting records about lease terms, building use, or even building ownership. This lack of a clear understanding of what assets the council holds makes defining the emissions boundary becomes nearly impossible.

Without high-quality estate data, councils cannot build reliable baselines, identify priority sites for decarbonisation, or allocate resources effectively.

How Councils Can Measure Emissions from Their Estate

While perfect data may be years away, councils can and should take immediate steps to improve estate emissions visibility and accountability.

1. Start with What You Know: Even an approximate emissions estimate can be useful. Start with high-energy buildings and use EPC certificate data or standard benchmarks to establish a baseline.
2. Prioritise High-Impact Assets: A small number of large buildings (e.g. leisure centres, care homes) are likely to account for the majority of estate emissions. Focusing initial effort here can produce quick wins and build momentum.
3. Engage Tenants and Partners: Many housing associations and large tenants are already pursuing their own decarbonisation goals. Collaborative data sharing and retrofit partnerships can help improve the quality of your inventory while delivering shared outcomes.
4. Invest in Estate Management Systems: A centralised estate management system that tracks building characteristics, lease terms, EPC data and energy use is a foundational asset for future reporting and decision-making. It supports not only carbon accounting but broader asset strategy, compliance, and risk management.
5. Disclose Transparently: If emissions are reported using alternative interpretations of Scopes 1 and 2 boundaries, or if data is estimated rather than measured, councils should provide clear explanations in their reporting. Transparency builds trust and credibility with both regulators and local communities.

Estate emissions may be the most significant and under reported part of a local authority’s carbon footprint. However, they are also one of the most promising areas for leadership. By rethinking responsibility not as a function of strict operational control, but of influence and ownership, councils can take meaningful steps toward full, fair, and forward-looking carbon reporting.

CarbonTrack supports local authorities in mapping, measuring, and managing their full emissions footprint – including complex estate data – enabling more strategic decisions and more transparent climate leadership. Click below to learn more, and don’t hesitate to reach out!