The developer of a 212MW hyperscale AI data centre at the Gyle Edinburgh which was turned down by the Council Planning Committee in February have appealed the decision.
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This means that the developer’s appeal will be heard by a Reporter appointed by the Scottish Government and the decision taken by Ministers. Those who objected to the development will be invited to give a representation to the appeal, and it may also be possible for people and organisations who did not know about the hyperscale data centre plans, while the short window for objections was open, to ask for their representation to be heard.
The confusion over the definition of a ‘green data centre’ seems to be a key point in the developer’s appeal. Their statement says the committee had decided that the development was not a ‘green data centre’ but did not give the criteria by which they came to this conclusion.1
The planning committee had spent a long time discussing the lack of a definition of a ‘green data centre’ and it was clear that the council planners advising the committee were leaning heavily on one sentence from a government response to a Parliamentary Question2 to help them understand what a ‘green data centre’ could be, and which was entirely insufficient for the task. The conclusion taken in the meeting was that, without a clear definition, they were not able to define this as a ‘green data centre’.
In March Edinburgh City Council voted to take steps towards a temporary moratorium on data centre applications until the term ‘green data centre’ is defined by the Scottish Government. This appeal shows how important that move was because council decision makers are putting themselves at risk of challenge as long as no definition exists.
The proposed hyperscale data centre at the Gyle is due to have diesel back-up generation which would be the equivalent of 100,000 idling diesel cars when in operation, and would use the energy of a quarter of a million households. However the developer, in the appeal statement said, “From the information provided in this appeal statement, it is difficult to see how a data centre could be more “green” than this proposal.
They continue saying that the “Council have unrealistic expectations about how “green” a data centre can be”.
This all shows the importance of proper policy development around hyperscale data centres. The next government should put a moratorium on all planning decisions so that hyperscale AI data centres, which are orders of magnitude bigger than our existing stock of data centres, can be properly assessed for their impacts on climate, the grid and communities.
Hyperscale AI data centres are an entirely new industrial sector with energy requirements which are off-the scale compared to all other industries. Our current list of hyperscale data centres in planning and pre-planning would require nearly 6000MW of power (peak electricity demand in Scotland is around 4000MW) and there are others being mooted which would bring this figure almost up to 9000MW. There is a complete lack of Policy around hyperscale data centres. Worse than that, the policy that exists for data centres, assumes data centres the size and impact of our existing data centres and not these hyperscale facilities which are orders of magnitude bigger.
We call on the political parties in the run up to the Holyrood elections to focus on the risks that hyperscale data centres pose to Scotland and pledge to carry out proper studies of what the impacts will be on the grid, energy prices, climate commitments and communities.
The original application was refused on the grounds of being:
- Contrary to NPF4 policy 1 – as it does not address the climate crisis
- Contrary to NPF4 policy 2 – as it doesn’t address lifecycle Green House gas emissions
- Contrary to the City Plan Place- Place 19 policy because it does not support the mixed use vision for Edinburgh Park area.
You can read an analysis of the decision here
You can watch the meeting here
How to respond to the appeal
The decision document from the council is with the planning documents for the development
The Appeal documents are on the DPEA website
Please see Planning Democracy’s excellent guide on Planning Appeals for more information.
If you did not respond to the original planning application you need to make a case to the Reporter as to why you have an interest in responding. The environmental impacts of this data centre, in terms of the energy use, green house emissions and backup diesel generators are such that the development is of interest to people across Edinburgh, and to wider civil society. However the notice of the development only went to a few local properties and the development was not widely known about before the window for objections had closed. We therefore hope that the Reporter will also accept representations from interested parties, who were not able to object. Please lay out the case as to why your representation should be included.
Summary of the grounds for appeal from the developers – as far as we can interpret from the Appeal Statement:
Here is a summary of our interpretation of the grounds that the developer is putting forward for the appeal. Largely these are taken from section 10 of the appeal document (available here)
1. They say that the Council claims the proposal is not a “green data centre” under NPF4, but NPF4 provides no definition of a green data centre, and the Council fails to explain what criteria it used.
2. The developer says that they are already very green and the council seems to have an unrealistic expectation of what green means. The appeal statement says: “From the information provided in this appeal statement, it is difficult to see how a data centre could be more “green” than this proposal, especially since it is sited on brownfield land, is in a sustainable location, with heat network opportunities. It therefore appears that the Council have unrealistic expectations about how “green” a data centre can be”
3. That this is for planning in principle (PPP) and so lots of details are supposed to be resolved at later stage. It’s too early to refuse, the information was appropriate for the PPP stage.
4. They say that NPF4 has Green Data Centres as priority developments and they shouldn’t have turned this down. The appeal statement says: “it is unlikely that a green data centre could be sited and designed to minimise lifecycle greenhouse gas emissions to any greater extent than the appeal proposal. The Council’s decision is therefore tantamount to suggesting that green data centres can never be acceptable, which runs counter to the national designation by the Scottish Government.”
5. They argue that the council did not apply NPF4 as a whole, and says that they ignored that it is on a brownfield site, is delivering digital infrastructure and various other ways they complied with the Development Plan
6.They say the decision “fails to apply the correct interpretation of NPF4 Policy 2. It does not require a development to demonstrate lifecycle greenhouse gas emissions can be minimised; what it does require is that “Development proposal will be sited and designed to minimise lifecycle greenhouse gas emissions as far as possible”
7. They also refer to the Report the Council Officials made to the development Sub Committee which said: “The development will likely have a negligible impact on achieving national greenhouse gas emissions reduction targets, as stated in NPF4” .And say that the council decision provides no explanation for ignoring that statement.
Note from APRS: This reference to NPF4 is to the greenhouse emissions impact assessment for Development 12: Digital Fibre network, which says that developments under National Development 12 are likely to have an overall negligible impact on achieving greenhouse gas emissions targets. This analysis actually seemed not to include data centres energy use in the calculations.
8. They say that the council has misinterpreted Policy Place 19 and there doesn’t need to be residential in every zone of the area*
9. Overall they say that “the whole decision fails to give complete, precise and relevant reasons for refusal.”
*The decision also said: contrary to Policy Place 19 because it does not extend existing grid layout to deliver a cohesive townscape and deliver sustainable movement through the site
Understanding the Energy use of the Gyle Data Centre
It’s a rule of thumb for energy grid provision that it is 1000 homes need 1MW. So 212MW is the equivalent of 212,000 homes.
This is for grid provision, however, which goes on the maximum demand there could be at peak.
When it comes to energy use over the year households dial up and down over night/day and summer/winter, whereas data centres do not. So in total 212,000 homes use a lot less energy than a 212MW data centre.
Since the average Scottish home uses 3100KWh a year the data centre – operating at an average 85% capacity – will use the same energy as 500,000 Scottish homes over the year.
- The Appeal Statement from the developer states: “The Decision Notice states that “The proposal is not considered to be a green data centre as defined in NPF4”. However, NPF4 provides no definition of “green data centres”. The decision notice gives no indication of what definition the Council used in making their decision.” ↩︎
- Parliamentary question S6W-41362: The wording of the second part was: “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.” ↩︎