Data Centre campaign hits First Minister’s Questions

Today the Scottish Greens brought the campaign against Hyperscale AI Data Centres to First Ministers Questions:

Kat Jones said:

“Communities, especially across the central belt, have been increasingly effective at raising their concerns about hyperscale data centres proposed in their areas. These projects bring a long list of concerns, including climate consequences, air pollution, loss of green space, and the impact on household energy bills.

“It’s phenomenal to see concern about this issue now taking centre stage at Holyrood. Planning permission simply must not be given for all these hyperscale data centres without taking account of the consequences for the communities who would be living alongside them. 

“This free-for-all cannot continue. We urgently need a moratorium on applications to give Ministers enough time to assess the climate and other environmental implications of this looming wave of applications.”

Look out for more Parliamentary Questions next week:

For Rural Affairs Questions next week on Wednesday 24th June, three oral questions on data centres have been tabled:

5. Mark Ruskell: To ask the Scottish Government what national assessment it has made of the climate impact associated with hyperscale AI green data centres.

9. Gary Bouse: To ask the Scottish Government what assessment it has made of any impact on the environment of the construction and operation of hyperscale data centres. R (S7O-00114)

10. Alan Brown: To ask the Scottish Government whether it plans to carry out a cumulative impact assessment of the number of planning applications proposed for AI data centres, including the power and water resources required and the impact on climate emissions. (S7O-00115)

A briefing on the issues raised at FMQs

Lack of strategy and gaps in the Planning System  

There is no overall strategy, spatial or otherwise, for hyperscale data centres in Scotland. Which we would say is vital given the vast energy requirements and environmental and community impacts from these developments. 

Lack of basic information

The Scottish Government does not seem to have any of the information they would require, or be seeking to get it, in order to have a strategic approach: 

For example:

According to the answer to S6W-42878 ‘The Scottish Government does not hold a centrally maintained dataset specifically identifying developments as data centres within the planning system.’

And ‘The Scottish Government does not hold the regional dataset that underpins the National Energy System Operator’s modelling of data centre demand in its 2025 Future Energy Scenarios (FES) publication.’ S6W-43432

And ‘The Scottish Government has not made its own assessment of the total future electricity demand resulting from expected AI and data centre developments in Scotland.’ (S6W-43431)

No mechanism to align with priority sites that have been identified

In answer to a Written Question: S6W-42876  asking ‘what action it is taking to ensure that the grid connections for planned data centres reserved by National Energy System Operator are matched with the most preferential sites in Scotland, as set out in the report, Short list for Data Centre Site Development, which was published in May 2025.’ The Government only answered the bit of the question about energy, citing that NESO and grid are reserved matters.

We are seeing sites coming through to planning like the one at Hunterston on green fields, 20m from a 900 year-old castle and only 200m from one of the preferred sites on the Scottish Enterprise list.

All info about the Hunterston site is here: https://aprs.scot/hunterston-data-centre/ including screen shots of the relevant pages of the ‘Short list for Data Centre Site Development’

Also none of those sites currently in the planning system (as pre planning notifications, EIA scoping stage, or planning permission applications) are on the Short list for Data Centre Site Development

No definition of a ‘green data centre’ or guidance for local authority decision makers

Definition of a green data centre

A previous written PQ S6W-41362 asking for a definition of a green data centre got the following response: 

‘It will be for the planning authority to interpret and apply NPF4 according to the circumstances of each individual case. To be considered a green data centre, planning authorities may wish to consider criteria such as the extent to which the data centre is powered from renewable energy sources; makes use of energy efficient technologies; seeks to minimise water consumption; and supports the re-use of excess heat.’

This has been the only definition offered so far by the government to support local authorities and the lack of a definition caused difficulties in the decision making for the Gyle data centre. The planning official admitted that they are used to operating with definitions and so it was a challenge for them to interpret what it meant. Full write up of the implications for the Edinburgh decision of a lack of definition here: https://aprs.scot/news/an-analysis-of-the-edinburgh-data-centre-decision/ 

The Chief Planner is still using the wording of that PQ S6W-41362 in advice to Local Planning Authorities – the most recent we are aware of was 13 May in a letter to David Girvan, Chief Planner at Edinburgh City Council. Which is part of the papers for the report about the data centre Moratorium in Edinburgh. 

This lack of a definition is what led to the council voting to move towards a moratorium on data centre decision making until the Scottish Government come up with a decision.

In the recently published AI strategy says that, by 2027, the Scottish Government will 

‘Publish guidance on what factors are prevalent in a ‘green’ data centre.’ This sounds like a very weak commitment to providing the guidance needed by a date that is far too late for the majority of sites that will hit the planning portals.

Guidance for Planners

Planning decisions are taken as they come in by local authorities with no guidance from the Scottish Government. (see answer to Mark Ruskell’s oral question this week). 

In December 2025 we wrote to the Planning Minister Ivan McKee to call for a moratorium on hyperscale data centre planning decisions until they had done a proper study on the impacts, until there was a robust definition of a ‘green data centre’ and until they are on schedule 1 of the EIA regulations. The response came back quickly but did not address any of our requests (see both letters here:https://aprs.scot/news/update-on-data-centres-campaign/). 

Instead they said they “will be working closely with colleagues in The Improvement Service and the National Planning Improvement Champion in the coming months to bring forward tailored support and guidance to assist planning authorities in the determination of Data Centre Development proposals.” 

The only advice and support we have seen provided to local authority planners on this (although there will have been advice/letters to individual planners/planning authorities such as the letter referred to above from Fiona Simpson to the Chief Planner at Edinburgh City Council) was a webinar delivered by Apatura’s Commercial Director and its Head of Planning. I wrote to the Chief Planner and the Head of the National Planning Hub, after the webinar to raise our concerns about this. https://aprs.scot/resources/letter-to-chief-planner-and-head-of-national-planning-hub/

Hyperscale AI data centres are regularly being screened out of having to do EIAs.

We are tracking hyperscale AI data centres in the planning system. Of those which have reached the stage of planning to have had an EIA screening, 6 have not been required to do an EIA and 4 are being required to do an EIA. To see the data scroll down to the table below the data centre map https://aprs.scot/data-centre-map/

The most egregious so far is the 600MW data centre at Auchtertool which, as well as being the size of some of the biggest data centres in the world currently operating, (see the list here which shows the biggest data centre worldwide and has a robust methodology – https://epoch.ai/data/data-centers) it also will be on Grade 2 agricultural land, and presumably, given the size and location of the site, be impacting on biodiversity and hydrology. There are also concerns about noise and water use from a facility of this size.

Local people have challenged two EIA decisions by Edinburgh City Council, Gyle and Hermiston, and letters written on their behalf by ERCS (Environmental Rights Centre Scotland) resulted in a re-screening by the council. On both occasions, the council re-screened and found that the development did not require an EIA.

In the case of the Gyle development, which has had the most scrutiny as it has reached the planning stage, the justification given by the Council Officials was that it would have no impact on greenhouse emissions using the NPF4 calculations as a justification “The development will likely to have a negligible impact on achieving national greenhouse gas emissions reduction targets, as stated in NPF4” 

This has been covered by investigations that went into the newspapers two weeks ago – showing that the Scottish Government’s analysis of the climate impacts of ‘National Development 12: Digital fibre network’ did not include the climate impacts of hyperscale AI data centres : see here for the full briefing (scroll down for the detail on the Gyle site). https://aprs.scot/news/climate-impacts-of-ai-data-centres-ignored/

Green House Emissions

The Data Centres that are in the planning system (as pre-planning EIA scoping or planning applications) would add up to 6200MW of power demand. Since data centres operate 24/7 at an average of 75-85% capacity (according to NESO figures in CleanPower 2030) this means a huge new demand on our energy networks. Since they operate 24/7 they would push us more often into gas generation at demand peaks (see this report from Ireland about energy prices) we are also seeing developers applying for gas grid connections to operate gas electricity generation ‘behind the meter’. The first data centre in England to be permitted under the new ‘nationally significant regime will be powered by onsite gas generation.

Some work we did with the guardian shows that over 100 data centre developers are looking for gas connections.  And, in Ireland, all additional renewable generation has been offset by the demands of data centres, meaning they are falling way back on targets. 

The answer to some  recent parliamentary questions show how unprepared the government is for the impact of hyperscale AI data centres on greenhouse emissions. And how weak their position is.

“The Scottish Government is not routinely sighted on applications for gas connections, but we are aware there are emerging data centre proposals that may have a gas component. The Scottish Government policy position is that new AI infrastructure developments should minimise reliance on fossil fuel solutions and we encourage developers to explore renewable and sustainable alternatives to gas fired generation wherever possible.” (APRS emphasis) S7W-00336 

Also their lack of information which is critical to knowing what the impact will be:

“The Scottish Government has not undertaken a separate national assessment of emissions associated with gas and diesel back up generation for hyperscale data centres. An assessment of environmental impacts is undertaken as part of the planning process for individual developments.” (S7W-00338)

Green House gas emissions of AI hyperscale data centers not included in GHG analysis of ‘green data centres’

Our work showed that the impacts of Hyperscale AI data centres on climate emissions was not included in the Greenhouse analysis of the NPF4 Policy ‘National Development 12; digital fibre network’ which includes the ‘green data centre’ policy. This GHG calculation is being used to justify that ‘green data centres’ don’t have greenhouse gas emissions (this has been an argument in the appeal of the Gyle data centre)

When the Government were asked about what they were planning to do to update this GHG analysis the answer was very disappointing:

“To support preparation of National Planning Framework 4, the then Scottish Government commissioned independent research on the Lifecycle Greenhouse Gas Emissions of NPF4 proposed National Developments. This was first published in 2021 and updated in October 2022.

As the scale and characteristics of data centre developments evolve, we will continue to monitor developments and consider whether further evidence gathering is required. In the meantime, any proposed development schemes remain subject to planning and environmental assessment requirements.’ S7W-00337

APRS’s asks on hyperscale data centres

APRS have been campaigning for Scottish Government to put in place a temporary Moratorium on hyperscale AI data centres until the following have been met:

• they have carried out a thorough study of the impact of hyperscale data centres on Scotland’s climate targets, electricity grid and communities. 
• until there is a robust and meaningful definition of ‘green data centre’ and 
• Until all hyperscale data centres are required to do an Environmental Impact Assessment (EIA) – ie they are on schedule 1of the EIA Regulations.

We wrote to then Planning Minister, Ivan McKee in December 2025 and received a reply. You can see both letters here

Our campaign is on the basis of the following impacts of hyperscale AI data centres

• Their huge energy requirements and impact on grid, climate emissions and energy prices
• The likelihood that hyperscale AI data centres will increase demand for gas electricity generation due to the baseload power requirements
• That these are 10-500x the size of existing data centres that power our economy, and the benefits will flow to the US tech companies which are the only ones who can fund such huge expenditure
• That they employ extremely few people (see our jobs and data centres report)
• And because of the huge land they require, which means many applications are coming in on farmland and greenbelts, impacting food production, access to the countryside, and biodiversity.