Copy of the APRS objection to Falkirk Council’s planning application – P/26/0237/FUL. Apatura DC Project 5 Ltd (Apatura). Full planning permission for a 300 MW – AI data centre campus on land at Glenbervie Business Park, Stirling Road, Larbert.
Falkirk Council ref: P/26/0237/FUL
FAO Ryan McDonagh
Falkirk Council, The Foundry, 4 Central Boulevard, Central Park, Larbert, FK5 4RU
Dear Sir Madam
Planning Application Application P/26/0237/FUL. Apatura DC Project 5 Ltd (Apatura). Full planning permission for a 300 MW – AI data centre campus on land at Glenbervie Business Park, Stirling Road, Larbert.
APRS requests that this application should be refused for the reasons given below related to lack of support from the development plan and the inadequacy of information provided about the proposed development’s environmental impact. We also raise concerns about the EIA process as it has been applied to this proposal.
Development Plan
Planning legislation requires that the determination of a planning application is to be made in accordance with the development plan unless material considerations indicate otherwise. The proposal appears to be contrary to both the Local development Plan and Scotland’s Fourth National Planning Framework (NPF4).
The proposal consists of two data centre buildings up to 25 metres tall (around 82 feet – or 8 storeys in height), with exhaust flues to 28 metres and an electricity substation with transformers up to 34 metres in height, two hundred (200) standby diesel generators with underground diesel fuel storage, security fencing and access roads, on an undeveloped greenfield site at the edge of Larbert.
Specific concerns with the proposed development and the current application include:
1. Air Quality and the effects of 200 diesel generators
2. Climate: The applicant’s own experts admit major, unavoidable harm to the climate
3. Loss of protected wetland
4. Damage to, and loss of, ancient woodland, two streams and onsite trees.
5. This is not a ‘Green’ data centre
6. Electricity grid benefit overstated
7. Loss of green space and impacts on local homes
8. Economic benefits inflated
9. Cumulative impacts
10. Heat island effect
11. Lack of definition and guidance for National Development 12 ‘Green data centres’
12. Lack of sufficient analysis of ‘lifetime greenhouse gas emissions’ assessment from National Development 12 in NPF4
13. Infrastructure – What is essential?
14. An incomplete EIA
1. Air Quality and the effects of 200 diesel generators
It is completely unacceptable to site 200 diesel generators beside a hospital, a care home, beside homes and near to protected wildlife sites. The applicant’s own air quality report finds that, during testing or when run during a power outage, the result is a ‘Major effect’: nitrogen dioxide above the hourly health limit at homes on Stirling Road and beyond, and pollution above safe levels at three Sites of Special Scientific Interest and at the ancient woodland on the boundary’. Forth Valley Royal Hospital is less than 500 metres away, in an area that already has an Air Quality Management Area because of poor air quality. The two standard ways to cut this pollution, a taller exhaust stacks and NOx filters, were both turned down, the filters on cost grounds. The applicant dismisses the risk as “unlikely”, yet its own climate resilience report relies on these same generators for coping with more frequent power cuts in a changing climate.
Research by Petra Matijevic (documented here – https://aprs.scot/news/larbert-data-centre-will-be-top-10-polluter/ – and in a report in The National) using the energy demand for generators at this proposed Larbert development found that three generators would need to be operating eight hours a day on every working day of the year which would create air pollution roughly equivalent to that produced by Shell’s Fife natural gas liquids plant a mile away from Auchtertool at Mossmorran [SEPA polluter register https://informatics.sepa.org.uk/SPRI/].
As already stated, if these generators supply even half the necessary emergency power (the other half potentially coming from Glenside Farm BESS?) it is still far more than the generating capacity which requires ECU Consent under the Electricity Act.
Policy: NPF4 Policy 23 (Health and Safety). Falkirk LDP2 Policy PE26 (Air Quality). The applicant’s EIA, Chapter 6 )
2. Climate: The applicant’s own experts admit major, unavoidable harm to the climate
The application suggests the development will have an energy demand of 300MW and run 24/7 using a connection or connections to the electricity grid. Data centres can’t usually dial usage up and down so they use energy even when the wind is not blowing and the carbon intensity of the grid is high, which means it is appropriate to use the average for grid carbon intensity in calculating emissions for them.
By our calculations taking an average load factor of 80% the development will use:
300 x 0.80 x 24 x 365 = 2,102,400 MWh (2.1 TWh) of energy a year. For illustration of the scale of use, the total energy consumption of Scotland in 2024 was 21.7 TWh so the proposal’s predicted usage is comparable to 10% of the whole of Scotland’s energy use in 2024. Using the UK Government’s figure for carbon intensity of electricity from the UK grid:- 0.177 kgCO₂e/kWh for 2025) results in projected greenhouse gas emissions for the development of around 372,125 tonnesCO₂e per year (based on 2025 figures).
Apatura’s own greenhouse gas assessment rates the climate effect of running the data centre as ‘Major Adverse (Significant)’ the worst category of scoring, and says it would stay this bad, even after the compensatory measures they have proposed. Over its life the development is assessed at about 2.37 million tonnes of CO2, most of it from the electricity it draws. In a single five-year period it would account for around 1.4% of Scotland’s entire carbon budget, on its own. The “fixes” offered, such as solar panels, are described as things that “could be considered”, not commitments, and none of these form part of the application. In any event, the impact of (for example) solar on the roof or environmental improvements to the building would have only minor impacts compared to the electricity use of the IT equipment in the data halls.
Policy: NPF4 Policy 1 (Tackling the Climate and Nature Crises) and Policy 2 (Climate Mitigation and Adaptation). Falkirk LDP2 Policy IR13 (Low and Zero Carbon Development). The applicant’s EIA Report, Chapter 7 (Greenhouse Gases).
3. Loss of wetland habitat
The site holds a groundwater-dependent wetland habitat (a GWDTE). The applicant’s own assessments conclude, separately in the water chapter and in the ecology report, that building here would cause its total loss, rated ‘Major Impact’ with ‘no mitigation’ possible.
The ground investigation needed to understand the wetland’s water supply has not been done: the Flood Risk Assessment rates groundwater flood risk as ‘High’, says the depth of the water table is ‘unknown’, and recommends the survey be carried out before construction. So a protected habitat is to be removed, and its ground water supply assessed, on information that has not been gathered. We consider this to be an unacceptable approach which would set a very dangerous precedent for other large scale developments in Scotland.
Policy: NPF4 Policy 3 (Biodiversity), which requires major development to leave nature in a demonstrably better state and to follow the avoid-first mitigation hierarchy. Falkirk LDP2 Policy PE19 (Biodiversity and Geodiversity). The applicant’s EIA Report (Chapter 8 and Chapter 10) and Ecological Impact Assessment.
4. Damage to, and loss of, ancient woodland, two streams and onsite trees.
Beyond the wetland, the proposal would harm more of the natural site. A parcel of ancient woodland, an irreplaceable habitat, sits on the northern boundary, and the applicant’s ecology report finds pollution from the development would exceed safe levels there. Both small streams crossing the site would be culverted, the spring-fed eastern one into a 750 mm culvert with an admitted flood risk if it blocks. Nearly one third of the site’s trees and tree groups would be felled. The ‘biodiversity net gain’ claimed in the Planning Statement is a general statement, not a reliable, measured figure.
Policy: NPF4 Policy 6 (Forestry, Woodland and Trees) and Policy 22 (Flood Risk and Water Management). Falkirk LDP2 Policy PE20 (Trees, Woodland and Hedgerows) and Policy PE22 (The Water Environment).
5. This is not a ‘Green’ data centre
The applicant’s case leans heavily on this being a ‘green data centre’, which is what might give it favourable treatment in national policy. However we consider the applicant’s justification of the green credentials to be insufficient and their definition not consistent with a general understanding of the word ‘green’.
The renewable power supply depends on a battery project that is only at ‘development stage’ with a physical connection “still in the feasibility stage” and must therefore be seen as an ‘aspiration’ only. Moreover, batteries store power, they don’t generate it. The recharging of those batteries is going to have to come from the National Grid, not necessarily from renewables and with a carbon cost (see above).
The heat networks are an aspiration which is difficult to see how it could be secured (with the application itself saying it is “uncertain” if it will be delivered). Until massive financial commitments are made for such green mitigations, e.g. by Section 75 agreements and very large funding bonds, they should be seen as green wash. Empty promises that are not secured should carry little weight in this planning decision.
The proposal claims that the applicant will lower operational energy demand and reduce environmental impacts by using more efficient building services, such as lighting, heating and cooling and solar panels. However, while reducing operational energy demand and other environmental harms is beneficial, the emissions related to the data centre’s IT load will dwarf any savings achieved through building‑level measures.
It has been estimated from the information available from six data sites in Scotland (based on building size and energy consumption) that building services account for around a quarter of 1% of the annual energy demand for all six sites, excluding any advanced cooling systems not included within space cooling calculations. (Giddings, H (2026) Unpublished Report for APRS – sent as an attachment).
The Larbert application doesn’t include enough detail for comparison. However, the applicant’s emphasis on energy saving measures should not be given much weight in terms of overall “green” credentials, given the limited impact of these measures on whole-site consumption when the IT demand is included.
Policy: NPF4 Policy 1, Policy 2 and Policy 11 (Energy); Policy 19 (Heat and Cooling). Falkirk LDP2 Policy IR13 (Low and Zero Carbon Development) and Policy IR14 (Heat Networks).
6. Electricity grid benefit overstated
The applicant alleges that the data centre would help the National Grid network by using surplus Scottish wind generated capacity that is currently resulting in constraint compensation. However hyperscale data centres operate 24-hour, 365-day operations that draw power constantly, including on calm days when there is no surplus wind, so it will need to draw from the grid (which will be importing energy from gas and nuclear power plants in England, and even France) when the wind isn’t blowing. This increase in demand will increase the mix of gas in our energy mix, wrecking the chance of meeting our climate targets and potentially increasing energy prices.
The studies cited in the application describe what a coordinated national plan could achieve across many sites, not what one campus delivers, and the UK Government recently rejected the pricing reform that would have rewarded consuming surplus power. There is also no named operator or end user, and the economic case is benchmarked on data centres in the United States. A national target for data centres does not justify this particular speculative scheme on this greenfield, undeveloped site.
There are also five subsea cables currently being developed to take energy from Scotland south which will relieve the bottlenecks in energy distribution that exist at present and help to decarbonise the UK. So the role of a high load energy taker is, at best, temporary in relieving the need for constraint payments.
Policy: NPF4 Policy 11 (Energy) and Policy 18 (Infrastructure First). Falkirk LDP2 Policy IR11 (Digital Infrastructure).
7. Loss of Green space and impacts on local homes
This proposal is a large, industrial-scale development on undeveloped greenfield land at the settlement edge. It has lain undeveloped for 35 years because the site is not well sited for business which is increasingly preferring sites closer to Glasgow or Edinburgh. To the neighbours this is currently rewilding undeveloped land. The two buildings proposed would stand 25 metres tall, roughly an eight-storey block, with exhaust flues to 28 metres and transformers to 34 metres, and possibly taller stacks if the air quality problem forces it. The applicant’s case that homes will not be badly affected leans heavily on screening trees, yet a third of existing trees are to be removed, and 25-metre buildings are not screened by tree belts of around 10 metres, especially in winter and from upper floors. Building here also means the loss of open greenfield land and soils.
Policy: NPF4 Policy 4 (Natural Places), Policy 14 (Design, Quality and Place) and Policy 5 (Soils). Falkirk LDP2 Policy PE18 (Landscape), Policy PE01 (Placemaking) and Policy PE25 (Soils and Agricultural Land).
8. Economic benefits inflated
Data centres are highly automated. This application claims it might employ up to 300 people on site once running. The bigger figure of ‘around 1,400 jobs’ is those same jobs multiplied up by economic modelling and supply-chain estimates, not jobs at the data centre. The headline numbers also do not agree between the applicant’s own documents: the investment is quoted as both £2.1 billion and £2.3 billion, and the construction period as both 18 months and four years. Every benefit also depends on an operator nobody has named.
More information on this can be found in our report https://aprs.scot/resources/employment-and-data-centres-aprs-report/
9. Cumulative Impacts
This is but one of around 17 proposals currently in planning or pre-planning, with 6 more proposals yet to reach planning, in Central Scotland. Apatura is promoting a large portfolio of energy and data centre projects across central Scotland (it describes a 10.6 GW pipeline of its own), and the wider Scottish data centre pipeline now runs to several gigawatts, far more than the country’s own peak electricity demand. A single 300 MW campus is around a tenth of the entire current UK data centre capacity on its own. The combined effect of all this on the electricity system, the landscape and water and nature has to be looked at together, rather than site by site.
Policy: NPF4 Policy 1, Policy 11 and Policy 18. Falkirk LDP2 Policy PE01 (Placemaking).
10. Heat island effect
Research findings suggest that existing large data centres have a remarkable impact of raising the temperature in the surrounding area by several degrees C with the effect reaching for more than 5km. Given that the proposal is large by existing data centre standards it is worrying that no account appears to have been taken of this. The heat island effect would be expected to extend for 10km around the site. We refer to Marinoni et al (2026) The Data Heat Island Effect: Quantifying the Impact of AI Data Centers in a Warming World, arXiv:2603.20897v3 from April 2026. The paper sets out a robust assessment of the temperature increase recorded in the areas surrounding AI data centres globally and estimates that the land surface temperature increases by 2°C on average after the start of operations of an AI data centre, inducing local microclimate zones. The authors refer to this as the data heat island effect. It could have significant negative effects on habitats and species in the locality including nearby protected sites and the precautionary principle should be applied (NPF4 Policy 4). NPF4 Policy 3 requires major development to leave nature in a demonstrably better state and to follow the mitigation hierarchy.
As pointed out in Marinoni et al (2026) the Heat Island effect also raises significant concerns about human health and welfare in the surrounding area where an extra 2 degrees C of warming will exacerbate climate change impacts that are already unavoidable. In addition to the existing residential, hospital and mixed uses in the surrounding area, we note that the long list and short list of committed developments included in the application EIA at Appendix 5-1 documents residential developments in the vicinity. It includes both granted and registered live applications. Considering only those developments within 10km from the site, where the average recorded 2C increase in land surface temperature around data centres would have effect there are well over 2000 residential units already granted and a further 800 plus with applications under consideration. As far as we can tell the EIA has given no consideration to the impact of the proposed development’s additional heating to these new developments – let alone to the existing developments around the proposed data centre.
Given the uncertainty that the facility will be connected to a heat network in future, and that even if this does happen the percentage of the waste heat produced that is re-used rather than released into the atmosphere will be low, the heat Island effect is likely to be significant.
Policy: NPF4 Policy 1 and 2, Policy 3 and 4, Policy 14, and Policy 23 (Health and Safety) particularly 23 b), d) and e).
11. Lack of definition and guidance for National Development 12 ‘Green data centres’
The term “Green Data Centres” is used once in NPF4 – turning up in Annex B – National Developments Statements of Need, under National Development 12 Digital Fibre Network which “supports the continued roll-out of world-class broadband across Scotland”. However, the term is not defined in the NPF4 glossary or anywhere else in the document.
Given Scotland’s approach to statutory climate (and now nature) targets it presumably was (and remains) the policy intention for the term “Green Data Centres” to be meaningful rather than just green window-dressing. Evidence from this comes from Scottish Government documents that predate NPF4, eg the Scottish Government Update to the Digital Strategy for Scotland (March 2021). The “Green Datacentres and digital connectivity: vision and action plan for Scotland” (March 2021) says “Through co-ordinated action, we can position Scotland as a leading zero-carbon, cost competitive green data hosting location, which can contribute towards our ambition of achieving net zero by 2045.”
Whilst these government documents do not give a definition of a green data centre they do give a clear steer that the introduction of new digital solutions and infrastructure must allow Scotland to meet statutory commitments to be a net zero society by 2045. Furthermore, the recent Scottish Government paper on a new Infrastructure Strategy (2026) states “Addressing the cumulative effect of carbon emissions from infrastructure delivery requires a holistic approach that spans sustainable design, material choices, energy use and operational strategies. Greater integration of environmental considerations into decision making processes is key to ensuring that what we build today does not jeopardize the climate goals of tomorrow.”
12. Lack of sufficient analysis of ‘lifetime greenhouse gas emissions’ assessment for National Development 12 in NPF4
NPF4 has relevant supporting background reports relating to the NPF4 Lifetime greenhouse gas emissions impact assessment for national developments (2021 and 2022) and the Scottish Government’s Planning Guidance on NPF4 Policy 2 from June 2025. These should be carefully considered before any weight is given to the proposal being part of national development 12 given a danger of false assumptions being made about emissions from data centres being negligible due to flaws in the reports.
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 is not referring to 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 development scale. However, this dates to a time when the huge hyperscale data centres we are now facing were not conceived of.
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”.
However, 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 isn’t 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 isn’t 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 at the time (2022) 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 necessarily 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.” Considering the likely carbon emissions from just the proposed Larbert data centre alone this seems categorically inadequate.
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 if or 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 hyperscale 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 leading to planning applications for data centres of power capacity that were unthinkable in 2022. 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 at Larbert were not considered adequately enough for the NPF4 LGGEA to have any useful standing when considering a planning application for a hyperscale data centre now. So it would be completely illogical if 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 (which is clearly not the case).
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 highlights that the assessment included in NPF4 is not adequate to inform a planning decision on its own, and yet the current application has not given an appropriate level of information about the environmental impacts that will result from the proposed development.
If lifetime greenhouse gas emissions don’t seem to be being addressed properly for a particular planning 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.
Policy: NPF4 Policy 1 and 2
13. Infrastructure – What is essential?
We are aware that data centres have an important role in allowing digital systems to run effectively and when NPF4 was presented to the Scottish Parliament for approval and adoption, green data centres were included in National Development 12. The “Need” for this National Development as a whole is described in NPF4 as “This is a fundamentally important utility, required to support development, community wellbeing, equal access to goods and services, and emissions reduction from reduced demand for travel.” Some data centres are needed to enable this, but there is no evidence provided that a proposal of the current scale is essential – either in NPF4 or in the application under consideration. It seems far beyond what might be considered Falkirk’s “fair share” to deliver the Digital Fibre Network. Has Falkirk Council had guidance on how to go about deciding what is an appropriate size of green data centre to support the operation and use of the fibre network in Falkirk, or indeed in Scotland? We think this analysis should be done before a development of this scale can be properly considered.
We also note that the application makes various assertions about benefits of sovereign infrastructure, the importance of data centres as edge facilities and for cloud services. However, there is no indication or guarantee that this proposal will be used to provide those or what the end use will be.
14. An incomplete EIA
There is a question about how the recent Raeshaw Farms Ltd v Scottish Ministers ruling affects the EIA scoping in this case, given there are suggestions in the planning application that the data centre will rely on the Glenside Farm BESS at Plean, Stirling and that “physical connection is still in the feasibility stage”. This implies the developments would be interdependent, or at least that the data centre relies on the BESS for some appearance of “green” credentials. Will the environmental impacts of all this be assessed together in an EIA?
We also think, in the absence of any National analysis, that an EIA should consider the cumulative impacts across Scotland of hyperscale data centres and their vast energy usage on grid infrastructure and climate, and on the ability to meet national net zero targets. This seems vital information given the Scottish Government have not carried out that assessment already. The Scottish Government believed in 2024 that Scotland had 10MW (Data Centres in Scotland FOI Request (ref 0707) Scottish Enterprise) of co-location data centres (the UK Government estimated it to be 30MW (in UK Government (May 2025) Estimate of Data Centre Capacity: 2024)) but the smallest hyperscale AI data centre now coming into the planning system is 200MW, with the largest being 1000MW – 2000MW. It is clear that the ‘green data centres’ that the Scottish Government envisaged in NPF4 to support a marginal increase in device use and use of the internet cannot encompass these proposed developments of a much greater scale and they were certainly not included in the Scottish Government’s 2022 analysis of the climate impacts of National Developments (by Land Use Consultants).
Astonishingly, even the Scottish Government’s AI Strategy published in March 2026 which includes a section on data centres, contains no indication of the capacity of data centre infrastructure that could be considered “essential” to Scotland.
In conclusion, APRS believes this development goes against the Local Development Plan and NPF4 and asks that Falkirk Council reject this application.
Yours sincerely,
Kat Jones
Director, APRS