Copy of the APRS objection to Fife Council’s planning application in principle – 26/01243/PPP for a data centre campus on Land To The North Of Camilla Road, Gleniston, Auchtertool, Fife. Objection written by Nikki Sinclair, APRS Policy Manager
Fife Council ref: 26/01243/PPP
Scott Simpson, development.central@fife.gov.uk
Fife House, North Street, Glenrothes, KY7 5LT
Dear Scott Simpson,
Planning Application in principle (26/01243/PPP) for a data centre campus (Class 6) comprising data hall buildings, gatehouses and associated infrastructure including electricity substations, fencing, plant and machinery, access roads, paths, parking, drainage and landscaping onLand To The North Of Camilla Road, Gleniston, Auchtertool, Fife
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 and suggest the development should be rescreened and a full environmental report produced.
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 Fife local development plan – FifePlan (adopted 2017) – and Scotland’s Fourth National Planning Framework (NPF4).
Fife Council appears to be considering the application as a “National development – transport and infrastructure”. Presumably this is due to the scale of the proposal and as “green data centres” are potentially included in NPF4 National Development 12. Whilst the application doesn’t use the term “green data centre” it does make many unsubstantiated claims about its likely sustainability. We consider that this application for planning permission in principle fails to include essential details of the development necessary for its determination and should be rejected.
Specific concerns with the proposed development and the current application include:
1. Rural Location
2. Energy consumption and Greenhouse Gas Emissions
3. Flood risk
4. Landscape impact
5. Impact on biodiversity and environment
6. Pollution levels – noise, air quality and heat island
7. Impact on historic assets and places
8. Economic impacts inflated
9. Cumulative impacts
10. Public access and amenity
11. Lack of definition and guidance for National Development 12 ‘Green data centres’
12. Essential infrastructure?
13. Lack of a full EIA
1. The Location – Rural Fife
The application’s supporting statement (“Supporting document Cato Data Centre” by Logan PM Energy Project Management) states that the site is farmland and used for agriculture and that it was zoned in the LDP as employment land for potential expansion of the Mossmorran gas plant. The LDP zoning referred to (LWD020) doesn’t however cover all of the proposed site. The zoning was specifically to allow for the potential expansion of Mosmorran, and the operator there has recently announced its closure, therefore the zoning as employment land specifically for Mossmorran seems irrelevant to this proposal and the land is otherwise considered as farmland/rural in the LDP. The FifePlan, paragraph 27 makes clear that in “Rural areas economy and communities will be supported by allowing appropriate scale and location of development that complements existing village layouts and character.“ Paragraph 29 continues saying “Fife’s rural environmental assets are protected by a suite of policies covering matters such Dunfermline’s and St Andrews’ green belts, controls over development in open countryside, and managing impact of development on natural assets. Prime agricultural land and food security is a continued concern and in assessing development sites for this Plan, the Council has sought to minimise irreversible development in these areas and provided policy protection.”
The main motivation for the choice of location appears to be given In section 2.2 of the Supporting document where it is stated that the Scottish location will reduce energy costs (for the development).
The proposal seems to be contrary to every part of the LDP Policy 7 Development in the countryside and to conflict with NPF4 policy 29, especially 29 b).
It also seems contrary to the 2026 Fife Council Evidence Report for the next LDP which says that Fife will “Consider allocating sites for employment uses in locations related to town centres and local centres, where appropriate, with better access to employment destinations using public transport and other sustainable methods of transport. Focusing on redevelopment of vacant and derelict land sites will be a priority of the next LDP.”
2. Energy consumption and greenhouse gas emissions of proposed Cato data centre
The application suggests the development will have an energy demand of 600MW and run 24/7 using a connection or connections to the grid. Data centres can’t 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 calculation emissions.
By our calculations taking an average load factor of 80%[1] the development will use:
600 x 0.80 x 24 x 365 = 4,204,800 MWh (4.2 TWh) of energy a year. (This is roughly in line with the figures from the applicant’s “Statement of Energy intention” which says that Cato’s ultimate potential annual energy usage would be 4000GW, ie 4 TWh). For illustration of the scale of use, the total energy consumption of Scotland in 2024 was 21.7 TWh so Cato’s predicted usage is comparable to 20% of the whole of Scotland’s energy use in 2024.
The average home in Scotland uses 3100KWh energy per year so this is the energy of 1.4 million Scottish households (in 2024 there were 2.55million households in Scotland) ie this is equivalent to the domestic energy use of around 65% of the population.
The figure of 4.2TWh can be multiplied up to get greenhouse gas emissions (using the UK Government’s figure for carbon intensity of electricity from the UK grid:- 0.177 kgCO₂e/kWh for 2025). This results in greenhouse gas emissions of around 744,250 tonnesCO₂e per year (based on 2025 figures).
The Fife Council declared a climate emergency in 2019. The level of proposed emissions from Cato seems contrary to Fifeplan, Policy 11 Low Carbon Fife (Fife Council contributes to the Climate Change (Scotland) Act 2009 target of reducing greenhouse gas emissions by at least 80% by 2050). It also seems contrary to the expectations set out in the Evidence Report prepared by Fife Council for the next LDP on the target reduction trajectory for Fife’s territorial carbon emissions (see below Fig 5.8 from Fife Evidence Report 2026).
As a public body, the Council has statutory duties relating to climate emissions. The Council “must, in exercising its functions, act in the way best calculated to contribute to the delivery of emissions reduction targets” (Climate Change (Emissions Reductions Targets) (Scotland) Act 2019). For comparison we note that in responses from the Fife planning team to the applicant it is stated (eg letter dated 25 May 2026) “in recognition of the current climate emergency, Fife Council is aiming to significantly reduce its carbon footprint. For Planning Services, this will mean that fewer sites will be visited by staff in order to reduce the carbon impacts associated with business travel.” However, this potential reduction in emissions is trivial compared with the huge increase that would result from the proposed data centre.
Energy supply and energy use
The applicant’s “Energy Statement of Intention” makes bold statements of intent including that:
- “It will deliver a state of the art energy efficient data centre”
- “The Development will have a PUE below 1.1 representing a highly efficient facility”
- “The Development will utilise off-site low carbon generation via the electricity grid” “The Applicant has made a binding commitment to the use of low carbon electricity through power purchase agreements (“PPAs”).”
- “With agreements in place for only low-carbon power, the carbon emission due to electricity use for the facility is close to zero.”
- “emergency generators should not be required here through a careful approach to technical design. Though, for the purposes of fair assessment, a number of generators were included as this application is for Planning in Principle. Acceptable limits will be set in consultation with Fife Council’s Environmental Health Department, to be stipulated by conditions attached to any consent.”
- “The final selection of equipment shall ensure the stipulated limits are met. Any generators would be subject to licensing by SEPA, and would be fuelled by non-fossil fuel.”
However, the application fails to provide definitive information about the environmental credentials of the proposal and the technology that will be deployed that back up these statements. This is inadequate, even for a planning application in principle, as NPF4 Policy 1 requires significant weight to be given to the global climate and nature crises when considering all development proposals.
Given the dearth of detail it is impossible for the planning authority to properly assess the above claims and contradictions or to determine the climate impacts of the proposal. Therefore the proposal doesn’t meet NPF4 policies 1 and 2. The use of energy from the grid connection means that the energy used will not be close to zero carbon (as calculated above).
We note that the Evidence Report (2026) for Fife’s new LDP makes no mention of hyperscale data centres, let alone the need for a 600MW one. However it does note that even without anticipating such a large additional electricity demand “Substantial additional renewable generation will be required in Fife to support the transition to net zero.” It goes on to say that the new Local Development Plan will provide a strategy that helps to support a reduction in greenhouse gas emissions.
Energy Efficiency
The proposal claims that the appellant 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). The Cato 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.
Climate targets and the Infrastructure Strategy 2026
NPF4 puts significant weight on the climate and nature crises and it is impossible to see how the proposed development, given the minimal level of definite environmental information in the application, can be reconciled with the aims of that overarching policy and especially NPF4 Policy 1. This is primarily because the potential energy use of a data centre of this capacity is vast.
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. Net zero targets are embedded in public sector infrastructure planning.”
Some of the applicant’s assertions could mislead the reader to think that the grid supplies a much higher percentage of renewable energy than it does. To be able to say that a data centre was powered by 100% renewable energy, or zero carbon electricity generated in Scotland seems impossible for a data centre of this capacity. It would require dedicated renewable generation many times the size of Whitelee windfarm[2], the largest onshore windfarm in the UK, and a large amount of energy storage which currently doesn’t seem to be guaranteed. Just being connected to the National Grid in Scotland wouldn’t mean that the energy being used all the time was renewable or generated in Scotland.
The idea of direct supply from a power purchase agreement (PPA) for renewables somewhere in Scotland is aspired to by the applicant. However PPAs are not always effective in reducing power emissions and can put stress on the system by increasing the number of storage schemes required for the grid and crowding out new renewable schemes as fewer grid connections are available. See further information on PPAs in extract from Giddings, H 2026, unpublished report for APRS:-
Power Purchase Agreements (PPAs)
A common argument seen in planning documents for ‘green’ data centres is a claim that the energy demand will be fed through 100% renewable sources through the use of a Power Purchase Agreement (PPA). A PPA is a contract between a renewable power generator and a customer. It is an agreement that the customer will pay a specific rate (p/kWh) over an agreed, long-term timeframe from a specific source. PPAs are attractive to customers as they can guarantee their demand is being fed by renewable sources and their energy prices will be fixed for the length of agreement. Generators benefit as they can use income from the PPA to partially or fully fund the construction of renewable generation, and they typically receive a higher revenue than if they exported and sold the energy on the wholesale market.
There are different types of PPA. A ‘virtual’ power purchase agreement (virtual PPA) is a contract in which a renewable generator sells its electricity into the grid rather than delivering it directly to the buyer. The generator also creates and sells the associated environmental attributes, for example Renewable Energy Certificates (RECs) or Renewable Energy Guarantees of Origin (REGOs), to the buyer. By purchasing those certificates, the buyer can claim the environmental benefits of the generation, even though no physical cable runs from the generator to the buyer. A ‘direct’ or ‘private-wire’ PPA however does supply power physically between from the generating plant to the demand site, and as a result, must be located in close proximity to the development. Direct PPAs from renewable projects however are weather-dependant and cannot guarantee the constant provision of power that a data centre requires, and so a connection to the National Grid will always be required to ‘top-up’ the power as required, or provide full power provision during maintenance, therefore continuing to impact and constrain the grid.
However, because PPAs are a contractual agreement between the generator and the data centre operator (not the developer), they are usually only agreed once the development has a confirmed grid connection and operation date. Promises by data centre developers in planning documents of “100% supplied by renewable energy”, years before an operator has been confirmed or the data centre is built, is therefore unlikely to be guaranteed.
PPA energy generation being ‘volumetric’ means that although the total volume of energy required by a data centre over a year may be matched with that generated by the renewable project, it is unlikely to always be generated at the same time it is produced, with non-renewably produced energy having to fill in the gaps. A Princeton University report [36] found that reliance on volumetric matching of PPAs resulted in more fossil fuel sources being required (for example at night when solar generation is zero). They are also often ineffective at reducing power emissions, and in fact increase the number of energy storage schemes required for the grid and crowd out new large-scale renewable projects.
[Giddings, H, 2026]
Back up/Emergency Electricity generation
The applicant’s “Low carbon Fife/energy intention statement” document vaguely mentions that there could be back up generators (eg “The site may employ uninterruptible backup power to ensure a secure and resilient facility” in section 2.4, page 10; and page 6 “we have included some generators”) . If that is the case much greater detail is required to determine the impacts ahead of planning approval. If 600MW (or anything above 50MW) is required to be generated from generators whether an application for consent under Section 36 of the Electricity Act 1989 might also be required?
Presumably, any generators on site will be tested regularly and produce emissions and pollution. Even if biodiesel is used as fuel, there will still be emissions. The Extract from the currently unpublished report for APRS by Hannah Giddings of University of Edinburgh (2026) ‘The energy demand and carbon emissions impact of Scotland’s proposed hyperscale data centres’ submitted alongside this objection gives analysis of the estimated emissions from data centre back up generators elsewhere. Huge additional emissions and environmental impacts can result from the use of generators at this scale (to provide 600MW).
The proposal is contrary to NPF4 policies 1 and 2 and to Fifeplan, Policy 11 Low Carbon Fife. In particular, NPF4 policy 1 requires significant weight to be given to the climate and nature emergencies in all planning decisions.
3. Flood Risk
The applicant acknowledges that the site is situated in an area at risk of on-site localised flooding as identified by SEPA flood maps and that the affected area is wide and the risk is classified as high (greater than 10 year return). This seems entirely contrary to NPF4 Policy 22 as it is dubious as to whether the development constitutes essential infrastructure, but even if it is considered as such there is no operational reason given why the location has to be in rural Fife, let alone at Auchtertool (see NPF4 Policy 22 a) i.))
We note that the Fife Council’s Structural Services team has formally recommended refusal on this point alone (5 June 2026). The proposal requires the raising of the land and creation of bunds which goes against the first principle of NPF4 Policy 22 of avoidance of flood risk and reducing the vulnerability of future development.
4. Negative landscape impact
The applicant’s Landscape and Visual Appraisal confirms the negative impacts the development will have on the local landscape. It predicts “major adverse” effects during construction and in the early years of operation, with “major to moderate” effects a decade later even once the planting has grown. Six buildings up to 35 metres on open farmland at the edge of a small village will be seen for miles, including from Main Street. There appears to be conflicting statements in the Supporting documents about landscape impacts with “The landform will remain as natural as possible” followed three paragraphs later by “Extensive landscaping is proposed in association with the Development” and then “landscape bunds are proposed in order to reuse any excess excavated material on site, subject to final site levels and detailed cut and fill exercise, “. There is also a potential concern about the uncertain phased development proposals (see page 13 Construction process). Is this PPP the only application that will cover the landscape changes to the whole site and how much deviation will be allowed if subsequent elements are discovered to be unviable or unfeasible at a later phase?
Fife’s design guidance, Making Fife’s Places (2018), makes “an appropriate design response to the surrounding townscape and landscape character” an essential test, and says
a proposal that fails to meet the qualities of a successful place “should be refused on design grounds.” The proposal seems to be contrary to LDP policies 1 and 14, to every part of the LDP Policy 7 Development in the countryside, as well asto conflict with NPF4 Policy 14 (Design, quality and place) and policy 29, especially 29 b).
5. Impact on Biodiversity and Environment
The development sits beside the Auchtertool Linn Wildlife Site, a wooded gorge along the Dronachy Burn. The applicant’s own ecology report records groundwater-dependent habitats on and adjacent to the site, and warns that taking groundwater could harm them, with a note that a further study is still required to determine potential harm. There appears to be a considerable requirement for relocating habitats following the large-scale groundworks and platform building required with little information provided about how successful this will be. There appears to be reliance on artificial “retention pools to ensure the continued health of relocated wetland habitat (marshy grassland and rush pasture)”. Both the Core path on the site and underground services appear to be proposed for relocation in or adjacent to the Wildlife site, which will add to disturbance of habitats and soils and hydrology.
Much of the protected species information in the applicant’s ecological report is redacted so it is entirely unclear if the proposals are adequate or not.
However, given the scale of the earthworks, relocation of habitats and bund building it seems unlikely that the mitigation hierarchy has been applied. Perhaps the location is not suitable so avoiding harm is just not possible?
Another huge factor for the local biodiversity is the heat island effect of a data centre of 600MW. 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 reach not only the Auchtertool Linn wildlife site, but the Camilla Loch SSSI (only 225m away to the east) and potentially to further away sites of biodiversity interest or designation. 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 the SSSI 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. FIFEplan Policy 13 (Natural Environment and Access) is also relevant with one of the outcomes of it being “Biodiversity in the wider environment is enhanced and pressure on ecosystems reduced enabling them to more easily respond to change”.
6. Pollution levels – air quality, water, noise and data heat island effect
Air pollution
For air pollution during operation of the development, the emergency generators are the main pollution risk, and the applicant admits their number, design, location and emissions are all to be confirmed later. Given the lack of a full EIA the impact is hard to assess. However, even if only used in an emergency, generators will be required to be tested and maintained regularly. 600MW is a huge amount of power to produce in this way. From other comparable data centres it seems likely generator testing would be an everyday requirement.
The applicant mentions that the back up generators would not use fossil fuel, which presumably means they would use biodiesel – the same chemical as diesel, but which comes plant or animal fats instead of mineral oil.
Given the dearth of information in this application and the egregious lack of requirement for an EIA we have looked at figures from the detailed air pollution report, which was part of the EIA for a 300MW data centre at Larbert [Falkirk case ref:P/26/0237/FUL], to give a ball-park estimate of the pollution that would be created by the Auchtertool data centre if they used similar generators to those specified in the Larbert data centre application EIA Air Quality Assessment.
The Larbert data centre is 300MW but has 640MW of backup generation, just a bit more than potentially required as a minimum at Auchtertool.
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 newspaper] using the energy demand for generators at the 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/]. This plant will stay open when the Fife ethylene plant closes.
With a 600 MW data centre, it is estimated to require at least 188 generators equivalent to those in the Larbert specification, not including any redundancy (ie extra in case some of them fail during emergency).
Based on 188 generators of the same type as specified for Larbert, it is calculated that generators at Auchtertool would release at least 271 tonnes of NOx (nitrogen oxide) gases a year from routine testing operations alone. This would make the development a large-scale industrial polluter and place it above SEPA’s reporting threshold of 100 tonnes for yearly exhaust gas releases. The latest reporting figures for Shell’s Fife NGL Plant at Mossmorran showed it emitted 280 tonnes of Nox gases in 2024 [SEPA polluter register https://informatics.sepa.org.uk/SPRI/].
In order to fulfil the testing schedule, due to the large number of generators required, it seems likely that any three of the generators would be operational for a 1- and 4-hour staggered scheduled testing for an 8 hours every working day, releasing more than a tonne of NOx a day.
This level of generation of electricity from bio-diesel also raises the question of whether an application under the Electricity Act is required for the proposed development – the threshold for such applications is only 50MW?
Water
The water usage of the site is unclear given the lack of technical specification given. However, despite assurance about low water usage and adequate mains supply, hidden in the Ecological Assessment is a reference to the potential for “ borehole water abstraction” being proposed later in connection with the facility.
Noise
The noise assessment supplied with the application is “indicative” and it is currently impossible to tell how serious the adverse effects on nearby residents will be. Fife Council responded to it stating “the submitted Noise Impact Assessment identifies that the proposed development has the potential to give rise to significant impacts at nearby noise-sensitive receptors. It also highlights that mitigation would be required and that there may be practical difficulties in achieving sufficient control of noise emissions from the site.” The consultee concluded “The Noise Impact Assessment would require to be revisited and updated once the nature, scale and location of plant and associated infrastructure is confirmed, as these factors could materially affect the predicted noise levels and resultant impact.
Given all of the above, the submitted Noise Impact Assessment cannot be relied upon to demonstrate that noise arising from any such proposal could be adequately controlled so as to avoid adverse impact on nearby residents.” Presumably it takes no account of the back-up generators which will add to noise impacts. The village of Auchtertool sits immediately east of the site and would likely be impacted by the noise from the cooling plant that would be required to run 24/7.
Waste heat
The effect of the waste heat emanating from the data halls is not mentioned despite this being a known concern elsewhere in the world, for residents and communities near hyperscale data centres. The proposed use of a portion of any waste heat for a heat network seems uncertain – there is currently no existing heat network in place or an established mechanism for ensuring there is one by 2028. A small heat network for a village would only use a tiny fraction of that generated whilst the 2026 Evidence Report for Fife’s next LDP found that of 153 potential heat network zones across Fife, the ones in Fife’s larger settlements had most potential.
However, an increase in land surface temperature of 2°C in the area surrounding the data centre (an average rise recorded around datacentres, (Marinoni et al 2026) could have a significant impact on the wellbeing and welfare needs of nearby residents, particularly against the background of climate change (Marinoni et al (2026) arXiv:2603.20897v3).
The lack of information currently supplied about air pollution, water, noise and waste heat meant that the proposal is not supported by NPF4 Policy 23 (Health and wellbeing). Nor by FIFEplan Policy 10 (Amenity).
7. Impact on historic assets and places
The proposed development would cause the loss of recorded heritage assets from the location and the partial loss of another. The applicant proposes to deal with the remains of Hallyards Castle, a site of possible medieval origin, by recording and then removing them, keeping it in place only “if viable.” This seems to be contrary to planning policy which generally favours keeping assets in situ eg NPF4 Policy 7 (Historic assets and places), especially Policy 7 o) and FIFEplan Policy 14 (Built and Historic Environment – “All archaeological sites and deposits, whether statutorily protected or not, are considered to be of significance”).
8. Economic impacts appear inflated
Data centres are not huge employers as they are highly automated and the number of jobs tends not to rise in proportion to the MW size of the development. The applicant estimated that Cato would employ about 120 people on site. However, there is no guarantee of this as the operator is unknown, or a guarantee of where any other supposedly supported jobs would be located, despite the postulated “540 jobs in Scotland”. There appears to be no evidence provided for this figure. The construction figure of “9,660 job years” counts one job lasting a year as a single unit, so over a long phased build it means far fewer long-term posts. Furthermore, the potential phased delivery itself is extremely uncertain and subject to change as described in the supporting document (see the contradictory comments on potential phasing in sections 2.5 and 2.6).
9. Cumulative impacts
We are concerned that the proposal raises issues of the level of cumulative impacts on the landscape and environment of the Fife locality, and the potential cumulative environmental impact of a mass roll out of hyperscale data centres across Scotland – particularly on the country’s ability to meet its climate emission targets.
The local area already has two battery storage plants right next to the proposed development, a newly consented solar farm with more battery storage directly to the east, several nearby wind farms, two substations with pylons, and the Mossmorran complex. The combined effect on landscape, amenity, nature and infrastructure has to be looked at together, rather than site by site. This should be considered against FIFEplan Policy 1 (Development Principles) and Policy 3 (Infrastructure and Services) as well as NPF4 Policies 4, 11 and 14.
10. Public access and amenity
The application’s design and access statement (DAS) says the proposal has an “aim of creating a coherent development within its landscape setting” (DAS page 15) and there is mention in the DAS of the Core Path that runs through the site being re-routed and improved. However, it is unclear how viable this plan is given the lack of detailed information and references to routing waste water and services through the same area. There is also mention of an alternative route for the path being identified if the route through the railway cutting proves unviable. There is no obvious mention of how the core path arrangements sit with the security measures mentioned elsewhere in the application documents and these security measures are not visible in the “architects impression visualisation” included at section 2.7. (For comparison see photograph of existing data centre and double height fencing below.) From the information currently provided it is not clear that the proposal aligns with NPF4 Policy 14 (Design, quality and place) .
Figure 1 – North Lanarkshire Datacentre showing double height security fence
Page 11 of the Supporting statement says that “Site security will include a 24/7 staffed security gatehouse, cameras, remote sensors, and a secure fence all around the facility, expected to be predominately of trident topped palisade fence at 3m height.” It goes on to mention additional security measures that will depend on the end user but may include “mantraps”. (“Additional security measures will depend on the end user and technical design, but may include; double fence / mantraps; barbed wire tops; anti-climb spiked collars; electronic gates and doorways; vehicle traps; multi-step biometric access; dedicated guards and escorts. Infrared security lighting will be used which is not visible to the naked eye. Audible intruder alarms will not be used.”)
11. Lack of definition or 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.
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.
For example the Scottish Government Update to the Digital Strategy for Scotland (March 2021) does not define the term ‘green data centre’ but it does set out some clear expectations including:-
- “We can and must build a digital Scotland in which green thinking is incorporated into all our digital solutions, so we can continue to meet our statutory commitments to be a net zero society by 2045”.
- “We will establish Scotland as an attractive location for green data centres”.
- It pledges alignment with National Performance Framework Outcomes including “we value, enjoy, protect and enhance our environment.”
- It sets out a wider ethical approach encompassing both how raw materials are sourced[3] and how Scotland’s data capabilities are to be used to ‘address climate change targets’ so that the sector has “a positive impact on climate change[4]”.
The “Green Datacentres and digital connectivity: vision and action plan for Scotland” (March 2021) also 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.”
Scant information regarding climate impacts from a development potentially of a 600MW capacity shouldn’t be considered acceptable, even for a planning application in principle, given NPF4 Policy 1 requires significant weight to be given to the global climate and nature crises when considering all development proposals.
Note on Data Centres, National development 12 and Lifetime greenhouse gas emissions’ assessment 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.
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 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 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[5]. 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.”
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 Cato 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 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[6]. 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[7]” 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.
12. Essential infrastructure
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 Fife’s “fair share” to deliver the Digital Fibre Network. Has Fife 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 Fife, or indeed in Scotland? We think this analysis should be done before a development of this scale can be properly considered.
The applicant’s supporting statement claims in section 15 (Conclusion) that they will provide “sovereign data security”, however, this is presumed to be just an aspiration given ambiguity over what the phrase means and no certainty over the end user for the proposed development or what it will be used for.
13. Lack of a full EIA
We are extremely concerned that the reasoning used in the EIA screening decision 25/03079/SCR) appears flawed and put too much weight on assumptions that the subsequent planning application has contradicted (eg that landscape effects would not be significant, and that the application would not be in an area of flood risk).
The EIA screening opinion does not seem to take account of the Scottish Government’s NPF4 Planning Guidance on Policy 2 – Climate Mitigation and Adaption (June 2025). This says that even “for National Developments, where individual development proposals come forward, the NPF4 LGGEA assessment can help inform further, more detailed consideration at project level”. This indicates that the assessment included in NPF4 is not adequate to inform a planning decision and presumably this applies to an EIA as well.
There is also a question about how the recent Raeshaw Farms Ltd v Scottish Ministers ruling affects the EIA decision in this case, given there are suggestions in the application that substations and electricity grid connections have been secured but alternatives may be found and used. Additionally a power purchase arrangement will potentially be secured from a bespoke renewable energy provider/or the applicant themselves(?) suggesting these developments would be interdependent. Will the environmental impacts of all this be assessed together in an EIA?
We further note that the applicant’s supporting statement section 2.2 (final paragraph) says “Cato Data Centre will be the flagship of three interconnected data centres, known as ‘The Stoics’. The projects would provide essential infrastructure across the Scottish Central Belt where IT services can be delivered in close proximity to the majority of end users, and where sufficient land electrical connection and renewable energy supply are available.”
Given the applicant states this is one of three interconnected data centres we wonder whether, following the Raeshaw Farms Ltd decision, if an EIA should consider the impacts of all of “the Stoics” together?
We also think 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 strongly disagrees with the supporting statement’s assertion that “The Development is compliant with all relevant policies under National Planning Framework 4 and Fife’s Local Development Plan” and asks that Fife Council reject this application.
Yours sincerely,
Kat Jones,
Director, APRS
Reference List (documents can be supplied):
Scottish Government’s NPF4 Planning Guidance on Policy 2 – Climate Mitigation and Adaption (June 2025)
Scottish Government, National Planning Framework 4 – lifecycle greenhouse gas emissions: Annex B: Assessment Methodology, 8 November 2022
Scottish Government – March 2021 Update to the Digital Strategy for Scotland
Scottish Government – Green Datacentres and digital connectivity: vision and action plan for Scotland” (March 2021)
The Electricity Act 1989
The Planning (Scotland) Act 2019
The Finch Ruling – UKSC/2022/0064. R (on the application of Finch on behalf of the Weald Action Group) (Appellant) v Surrey County Council and others (Respondents)
The Raeshaw Farms Ltd v Scottish Ministers ruling – Raeshaw Farms Limited v Scottish Ministers [2026] CSIH 10.
Data Centres in Scotland FOI Request (ref 0707) Scottish Enterprise – March 2025
Energy Consents Unit: Good Practice Guidance for Applications under Section 36 and 37 of the Electricity Act 1989 – February 2022
Giddings, Hannah (2026) Unpublished Report for APRS – The energy demand and carbon emissions impact of Scotland’s proposed hyperscale data centres
Marinoni et al (2026) The Data Heat Island Effect: Quantifying the Impact of AI Data Centers in a Warming World, arXiv:2603.20897v3
Fife Council, LDP Evidence Report (Submitted to DPEA 2026)
UK Government (2025) Estimate of Data Centre Capacity: 2024 (published May 2025) https://www.gov.uk/government/publications/estimate-of-data-centre-capacity-great-britain-2024/estimate-of-data-centre-capacity-great-britain-2024
[1] Ref: 80% is a figure taken from NESO Future Energy Scenario (FES) Pathway Assumptions (2025) workbook which states that the fleet wide average load factor is 70%, yet this has been judged to increase to 80-85% for hyperscale facilities and data centres dealing predominately with AI.
[2] Whitelee is 513MW and has a load factor of 0.266
[3] “This is about more than the use of data. It is about trust, fair and rewarding work, democratic, social and cultural inclusion, climate change, the circular economy and making sure that the raw materials used in production are ethically sourced.”
[4] “Use Scotland’s data capabilities to address climate change targets: For example, by extending our Earth Observation programme to monitor peatland restoration and waste monitoring, and building on the work of our AI for Good Climate Change programme.”
[5] NPF4 Research Project: Lifecycle Greenhouse Gas Emissions of NPF4 Proposed National Developments Assessment Findings (October 2022 Land Use Consultants Ltd)
[6] A copy of the research informing this assessment can be obtained from the Scottish Government by emailing chief.planner@gov.scot
[7] UKSC/2022/0064