What is a ‘green data centre’? We think it is obvious

This week the Ferret reported on lobbying by Apatura over a definition of a ‘green data centre’ which is important because it is a term used to determine whether a data centre should be considered a ‘National Priority’ according to Scotland’s planning framework (NPF4). We believe the answer is much simpler and we wrote to the Scottish Government to highlight how we believe the term in NPF4 should be interpreted.

The Ferret found, through Freedom of Information Requests, that Apatura, which has eight of the proposed data centres going through the planning system, had lobbied Government officials to sign up to their definition of a ‘green data centre’. The article was also published in the National.

We, however, believe that the definition is far more straightforward. It is exactly what the authors of NPF4 intended it to be: data centres that would support a marginal increase in device and internet use that resulted from the development of Scotland’s high speed fibre network.

How do we know what the authors of NPF4 intended?

Well firstly the consultation on NPF4 (which contained the ‘green data centre’ reference) ran from November 2021, to March 2022 and the final document was published in February 2023. Chat GPT launched in November 2022. Hyperscale AI data centres, of the size we see in Scotland’s planning system today, simply did not exist. The UK Government estimated that Scotland had 30MW of data centre capacity in 2024 (the Scottish Government estimated 10MW) and the smallest hyperscale AI site we see looking for planning permission now is 200MW.

Secondly the Scottish Government’s own greenhouse gas analysis of the impact of the ‘green data centres’ policy calculated that they would have a negligible effect on climate targets, assuming only a marginal increase in data centre use from people using internet-connected devices more, and anticipating that this would be counterbalanced by greenhouse gas savings from less traveling. This shows that the addition of ‘green data centres’ into National Development 12 was intended to support a marginal increase in device use of existing smaller data centres and not hyperscale AI data centres.

Our calls to Government on this:

Our letter to the First Minister on 12th August reiterating our December calls for a moratorium contained this analysis of NPF4 and recommendation that they clarify that this is the meaning intended by NPF4. Our letter to Hannah Mary Goodlad, the Minister responsible for planning also asked for this clarification this asking her to:

• Define the term “green data centres” very tightly so that the impacts of any green data centres match those set out in the existing lifetime greenhouse gas emissions analysis for ND12, and
• Produce a revised statement of need for ND12 that includes all types and sizes of data centres falling within the above definition of “green data centres”.

We have also worked with Stop Climate Chaos Scotland, a coalition of over 70 civil society organisations, to write this paper laying out the conditions to lift a moratorium which says the moratorium should be listed when:

“Scottish Government has produced a clear definition of a green data centre and communicated this to local authorities via statutory planning guidance. This should align with the lifecycle greenhouse gas assessment in NPF4 (National Development 12) and only apply to small data centres to be used in support of fibre broadband.“

More information on Apatura’s influence with Government and Planners

Officials had discussed the definition with Apatura, which is behind more Scottish data centre proposals than any other firm. The emails show that Apatura had created a “green data centre charter” that they wanted the government to sign up to. The Scottish Government declined to become a signatory to the charter.

Apatura was asked to appear on a panel event the Scottish Government was organising at a London investment summit after the lobbying. What was not covered in the Ferret article was that they also were invited to give a training webinar to explain more ab out the government’s policy on ‘Green Data Centres’ to local authority planners organised by the Scottish Government’s Improvement Service, which was attended by 200 people.

This webinar was to explain what a ‘green data centre’ was but had no input from the Scottish Government and consisted of a 30 minute presentation from Apatura’s Head of Planning and Head of Commercial followed by 5 minutes from an officer at SEPA. We wrote to the Chief Planner and the Head of the National Planning Hub to object to this and to call for more to be done to support local authority planning departments by providing guidance and a proper definition of the term, rather than inviting a developer with eight hyperscale data centres in the planning system to have a half hour lobbying session on their own definition with representatives from the very planning departments they would be seeking planning permission from.

Read the letter:

Read the Freedom of Information Request Responses