The greenhouse gas emissions of hyperscale AI data centres have not been included in the Scottish Government’s analysis of the impact of ‘green data centres’ on Scotland’s climate targets, according to analysis by environmental charity APRS.
This story has been covered in the following places (among others):
- The Independent Government slammed for ‘shocking’ failure on hyperscale data centre emissions
- The National Scottish Government urged to improve data centre policy
- The Guardian Scotland’s ‘green datacentres’ policy ignores emissions impact of AI, analysis shows
- The Scotsman SNP Ministers under fire over AI data centres ‘major shortcomings’ over climate impacts
Scottish Government documents assessing the lifecycle greenhouse gas emissions of ‘green data centres’ say that they “will likely have an overall negligible impact on achieving national greenhouse gas emissions reduction targets”.[1]
However, investigation by countryside charity APRS has found that the Scottish Government has omitted to include the impact of hyperscale data centres entirely in this assessment. This is despite developers claiming hyperscale AI data centres are ‘green data centres’ to get a preferential hearing from planning authorities. ‘Green data centre’ is a term associated with one of Scotland’s ‘Priority Developments’ in National Planning Framework 4 (NPF4).
This erroneous analysis has been used as evidence that hyperscale AI data centres do not create emissions in council documents relating to the 213MW data centre in Edinburgh which is currently appealing the refusal of planning permission. [2]
The lifecycle greenhouse analysis of the NPF4 was carried out in 2022 and APRS looked in detail [3] at the analysis covering the section which includes ‘green data centres’. The greenhouse gas analysis covers National Development 12: Digital Fibre Network, as a whole, which is intended to facilitate “the installation of new and /or upgraded broadband cabling on land and sub-sea for fixed line and mobile networks”.
The assessment methodology compares projected greenhouse gas emissions in construction, operation over the development’s lifetime, and decommissioning, against a baseline representing the existing situation. This analysis concluded that there could be a small amount of additional use of data centres if people have more devices, or use the internet more, but that this would be counterbalanced by greenhouse gas savings from less travelling, resulting in a negligible overall effect. It is clear from the document and the analysis that the hyperscale AI data centres currently being branded as ‘green data centres’ for the purposes of getting a favourable hearing in planning applications, are not included in this analysis.
The lifecycle greenhouse gas assessment was published in October 2022, before the launch of chatGTP, which led to escalating demand for huge data centres and the AI race, so this is hardly surprising. Hyperscale AI data centres have only emerged since after the publication of NPF4.
The Scottish Government believed in 2024 that Scotland had 10MW of co-location data centres (the UK Government estimated it to be 30MW) but the smallest hyperscale AI data centre now coming into the planning system is 200MW, with the largest being 1000MW and 2000MW [4]. It is clear that the ‘green data centres’ that the Scottish Government envisaged in NPF4 to deal with a marginal increase in device use and use of the internet do not encompass these developments, and they have not been included in their analysis of the climate impacts.
APRS is now demanding that the Scottish Government do a proper lifecycle greenhouse gas assessment for the multiple hyperscale data centres in the planning system and consider what the definition of a ‘green data centre’ should be following that analysis.
Dr Kat Jones, Director of APRS said:
“It is pretty shocking to find out that the vast carbon footprint of hyperscale data centres has been completely excluded from the Government’s greenhouse gas analysis. However it is not surprising because, when our National Planning Framework was being written, Chat GPT had not launched and hyperscale AI data centres simply didn’t exist. One can only conclude that the ‘green data centres’ mentioned in Scotland’s planning framework do not include hyperscale AI data centres, and only include the smaller type of data centres used for business, data storage, research and cloud use.
“The Scottish Government have backed themselves into a corner, and put all of Scotland’s planning authorities into an impossible situation by not coming up with a definition of what ‘green data centre’ is. When we raised this issue back in December with the Scottish Government, and pointed out the lack of a definition, we expected some urgent policy work to be done. Instead we had a sentence in a parliamentary question saying that it was up to local authorities to decide what a green data centre was. The new Scottish Government needs to urgently address the major shortcomings of their current policy on data centres.”
Additional info about how this is relevant to the Edinburgh data centre appeal.
APRS have laid out this information in their representation to the planning appeal for the 212MW AI data centre at the Gyle, Edinburgh Edinburgh Gyle data centre which was turned down for planning permission by the city council in February.
Submission to Planning Appeal on Gyle Data Centre
This is the APRS submission to the appeal of the 212MW AI data centre at the Gyle, Edinburgh written by Nikki Sinclair. It was turned down by the Planning Committee of Edinburgh City Council in February and the developers are now appealing the decision.
This appeal will be closely watched by developers of hyperscale data centres in Scotland and much further afield.
The issue of there being no definition of a ‘green data centre’, and the environmental impacts of hyperscale AI data centres, are central in the appeal of the developers. They argue that the proposal should be considered as a ‘green data centre’ as stated in NPF4 saying “From the information provided in this appeal statement, it is difficult to see how a data centre could be more “green” and say that “It therefore appears that the Council have unrealistic expectations about how “green” a data centre can be”
In the appeal the developers refer to the recommendation of the Council planning officials to approve the application, largely on the basis that it qualifies as a ‘green data centre’ and therefore was a Priority Development according to NPF4.[5]
In the report council officials refer to the lifecycle greenhouse gas emissions analysis from NPF4 to back this up saying: “The development will likely to have a negligible impact on achieving national greenhouse gas emissions reduction targets, as stated in NPF4” and the developers have quoted this in their appeal [6] stating “The decision provides no explanation for ignoring that statement.”
Dr Kat Jones, Director of APRS said:
“The Edinburgh Gyle data centre appeal is set to be incredibly consequential for the future of Scotland’s planned hyperscale data centres. It will bring to light the complete lack of policy that exists around hyperscale AI data centres.
“This planning decision is being appealed, so the decision will be taken by the Scottish Government and the lack of a proper policy framework for hyperscale AI data centres will become glaringly obvious. Surely the only option now is that the Government put a moratorium on all decisions on hyperscale AI data centres so that policy can catch up with the headlong rush to use Scotland’s energy resources and countryside in the service of US tech giants to train and operate their AI models.
“Our argument has always been that the Scottish Government needs to consider the scale of data centres that would actually serve Scotland’s needs, rather than the demands of the US big tech giants. When the developer makes the observation “The Council’s decision is therefore tantamount to suggesting that green data centres can never be acceptable” in their appeal, we have to point out that perhaps it is the sheer scale and energy use of the hyperscale AI data centres which is a problem, rather than data centres as intended by NPF4 policy when it was written.
“This is the data centre with diesel backup generators that would belch out the equivalent air pollution as over 100,000 idling diesel cars when in use and which made no mention of water use on their sustainability statement except to say they would have low-flush toilets. Not to mention the electricity use which would power a quarter of a million homes. If this is what a green data centre looks like then we are well and truly through the looking glass.”
“Given the difficult position this appeal puts the council in, it certainly justifies their vote to move towards a moratorium on data centres until such a definition exists. I would be surprised if other councils were not observing this appeal with interest and considering whether they, too, should be planning to pause data centre planning decisions until there is a definition of a ‘green data centre’.
NOTES
The decision document from the council is with the planning documents for the development
The Appeal documents are on the DPEA website
You can see the letter we send in December 2025 and the response received from the Scottish Government here: https://aprs.scot/news/update-on-data-centres-campaign/
[1] NPF4 National Development 12: Digital Fibre Network includes ‘green data centres’ within the National Development. This phrase in on p112
[2] The documents citing the Government analysis as evidence of negligible impact on emissions were: firstly, the decision that the data centre would not be required to do an Environmental Impact Assessment, and secondly, the recommendation from council officials to approve the development (which was subsequently refused planning permission in principle at the council planning committee)
[3] APRS’s full analysis of the Scottish Government’s lifecycle greenhouse gas assessments on ‘National Development 12: Digital Fibre Network’ is on p4-5 of APRS’s representation to the Reporter on the appeal of the Edinburgh Gyle data centre.
[4] APRS have mapped the proposed data centres in Scotland and there is nearly 6000MW of data centre capacity in the Scottish planning system with at least another 3000MW being proposed. Scotland has a peak energy demand of around 4000MW. aprs.scot/data-centre-map
[5] When questioned by the councillors in the planning meeting the council officials could not come up with any other reason for recommending planning permission, apart from it was a ‘green data centre’ and was therefore a National Priority. So the fact of whether this is a green data centre is very important in this case.
[6] Section 10.3 of the Appeal Statement
APRS’s representation to the Reporter on the appeal of the Edinburgh Gyle data centre.
Submission to Planning Appeal on Gyle Data Centre
This is the APRS submission to the appeal of the 212MW AI data centre at the Gyle, Edinburgh written by Nikki Sinclair. It was turned down by the Planning Committee of Edinburgh City Council in February and the developers are now appealing the decision.
The relevant extract from our submission to the appeal is below relating to the analysis of the greenhouse emissions.
Lifetime greenhouse gas emissions assessment in NPF4
The appeal statement refers to the Report the Council Officials made to the Development Management Sub Committee which said: “The development will likely have a negligible impact on achieving national greenhouse gas emissions reduction targets, as stated in NPF4”. We find that paraphrasing of one line from NPF4 “National Development 12: Digital Fibre Network Statement of Need” extremely misleading and the interpretation of it erroneous. It further suggests the officials and the appellant had not read the supporting background reports relating to the NPF4 Lifetime greenhouse gas emissions impact assessment for national developments or the Scottish Government’s Planning Guidance on NPF4 Policy 2 from June 2025.
Meeting emission reduction targets is one of six statutory outcomes for NPF4, as introduced by the Planning (Scotland) Act 2019. The Act also introduced a requirement for the NPF to include an assessment of the likely impact of each proposed national development’s lifecycle greenhouse gas emissions on achieving national greenhouse gas emission reduction targets.
The full relevant paragraph from NPF4 (page 112), National Development 12 under “Lifecycle greenhouses emissions assessment” says “depending on the nature of the projects taken forward and considering both direct and indirect effects, the lifecycle greenhouse gas emissions assessment concludes this development will likely have an overall negligible impact on achieving greenhouse gas emissions reduction targets”. The major part of the National Development appears to be not data centres but “the installation of new and /or upgraded broadband cabling on land and sub-sea for fixed line and mobile networks” but it also includes green data centres of a major scale.
The assessment methodology compares projected lifecycle GHG emissions, which covers construction, operation over the development’s lifetime, and decommissioning, against a baseline representing the existing situation [Scottish Government, National Planning Framework 4 – lifecycle greenhouse gas emissions: Annex B: Assessment Methodology, 8 November 2022]. The Digital Fibre Network (ie National Development 12) as a whole has been classed as likely having “an overall negligible impact on achieving national greenhouse gas emissions reduction targets”.
The LGGEA is based on work commissioned by the Scottish Government from LUC, and looks at the whole of National Development 12 together. The drive behind it is said to be “to deliver enhanced digital connectivity providing high speed broadband or equivalent mobile service, prioritising those areas with weaker networks across Scotland”. It is made clear that this will require a roll out of masts and cables and towers, but there is only an assumption of “potential creation of green data centres” and scant mention of what the likely impacts would be from data centres. For example, there is an assumption that the network equipment will include cables and masts but “the quantity is uncertain which may have a significant impact on the potential GHG emissions”. However, there doesn’t seem to be a similar consideration for data centres, even in the further background assessment report. It finds that National Development 12 will have a negligible effect as increases from electricity and maintenance, transport and industrial process could be “counterbalanced by reduced journeys from improved connectivity”. There doesn’t seem to be any further mention of energy or direct impacts from constructing or running a data centre or waste from decommissioning them (the decommissioning section refers to cables and towers only).
The most detailed assessment information in the report (Annex B, table A, page 118) does say that the likely increased number of devices “may lead to overall increased energy demand. This will also increase energy demand from data centres, although for a relatively small number of users overall.” This wording suggests that data centres were treated only as an indirect source of increased electricity demand (stemming from the wider digital fibre network) rather than as a type of development subject to the direct lifecycle assessment. In other words, the reference appears to address additional energy demand caused by the rest of the proposed network, not the total energy use or lifecycle impacts of major data centre developments themselves.
The report goes on to find that for the cumulative indirect impacts the negligible effects across 6 categories are deemed to be cancelled out by the “negligible positive effects from reductions in transport, especially work related commuting.”
The only other time data centres appear to be mentioned in the assessment is under land use where there is judged to be “negligible negative effects from disturbance to soil and vegetation installation of cables, towers and green data centres during construction” and under electricity and operation (direct) it expects “negligible negative effects from the potentially increased number of devices used for internet”. There seems to be absolutely no discussion of back up power sources for data centres and certainly no expectation for them to use fossil fuels on site.
The methodology cites “published information about GHG emissions associated with different types of development” but also notes uneven data availability and reliance on professional judgement where information was not available. No specific data sources are identified, so it is unclear how the stated “indirect” effects on data centre energy demand were quantified. Given the exclusion of data centres as contributors to direct effects, this represents a significant gap. The national scale energy demand and associated carbon emissions from data centres, which are clearly substantial, do not appear to have been accounted for. This is likely due to the fact that the LUC Report dates from October 2022 and NPF4 was published in February 2023, before the recent rapid rise in data centre demand and particularly the development of AI hyperscale data centre demand. At that time the impacts of data centres were considered marginal and the scale of subsequent growth was not anticipated.
It is impossible not to conclude that the huge energy requirements of hyperscale data centres such as those being proposed now were not considered adequately enough for the NPF4 LGGEA to have any useful standing when considering a planning application of this type. So it is completely illogical for statements to be made implying that National Development status itself gives any assurance of how green a data centre might be or that the lifetime greenhouse gas emission of such a development will be negligible.
The Scottish Government’s NPF4 Planning Guidance on Policy 2 – Climate Mitigation and Adaption (June 2025) states at paragraph 1.4 that for National Developments, where individual development proposals come forward, the NPF4 LGGEA assessment can help inform further, more detailed consideration at project level. This emphasises that the assessment included in NPF4 is not adequate to inform a planning decision – which directly contradicts the appeal statement.
If lifetime greenhouse gas emissions don’t seem to be being addressed properly for a particular case it is also worth being aware of the “Finch case” which led to a ruling from the UK Supreme Court, and has already had an influence on several planning permission decisions in England considering when climate analysis is necessary and how it can be carried out.