Transport Insights

National Highways’ Annual Report and Accounts, published this week, shows why the company no longer has a target for reducing corporate carbon emissions in the new Road Investment Strategy (RIS 3): it keeps missing its targets, despite constant fiddling.

For the interim year between road investment strategies (2025-26), National Highways was required to:

Achieve a 75% reduction in corporate emissions against the 2019-20 baseline in 2025-26, using the Science Based Targets initiative methodology.

It missed this but achieved a 73% cut to 41,727 thousand tonnes of CO2 equivalent (tCO2e), which implies a baseline of 154,000 tCO2e.

That looks like a big cut, but it has mainly been achieved by discounting electricity from renewable electricity.

Although it was not allowed to do this for its RIS 2 (2020-25) KPI, in its 2021 Annual Report and Accounts, it said:

In April 2020, we invested in a green energy procurement contract to supply the majority of our network with certified green electricity. This has reduced our carbon emissions by approximately 45,000 tonnes annually.

National Highways’ Net Zero Highways 2030 / 2040 / 2050 plan explicitly states that the company will achieve half of the reduction needed to get to net zero corporate emissions by 2030 by using “certified renewable electricity”.

And its 2025 update included a cut in electricity emissions from 85,664 tCO₂e to just 18 tCO₂e.

It effectively wrote off all the electricity it used as zero carbon.

The company appears to have used the same methodology for 2025-26, i.e. to move away from the methodology that went so badly wrong for it during the second roads period (RP2)

According to the Office of Rail and Road’s 2025 annual assessment of National Highways:

At the end of RP2, National Highways achieved a 51% reduction in its corporate carbon emissions compared to the baseline. Therefore, the company did not meet this KPI target of a 56% reduction for the road period. It emitted 45,232 tonnes of carbon dioxide equivalent (tCO₂e) from activities undertaken in the course of its day to day work in the final year of RP2.

This implies a baseline of 92,300 tCO₂e under a different methodology, but both the baseline and the target changed during the course of RIS 2, including because of my reporting.

So, what does RIS 3 say? It has a PI, not a KPI:

Basis of metric: Carbon dioxide emission associated with National Highways’ activities as it operates and manages the estate and network.

Science Based Targets initiative (SBTi) to be used as the standard for measuring emissions. Corporate carbon emissions PI Metric coverage: Metric covers Scopes 1, 2, and 3 emissions under Greenhouse Gas protocol.

National Highways to report separately its corporate carbon emissions as part of its Greening Government Commitment (GGC).

So no target at all. Just like road safety. That’s the kind of target National Highways likes.