APRS Resources

Briefing for MSPs – Hyperscale AI Data centres

Members’ Business Motion S7M-00428 

Submitted by: Graham Simpson, Central Scot and Lothians West, Reform UK

Lodged Friday, 19 June 2026 and due to be taken in the Chamber on Thursday, 03 September 2026

That the Parliament notes with concern proposals for hyperscale AI data centres across the Central Scotland and Lothian West region, including at Ravenscraig, Larbert, Newhouse and West Calder, and near communities affected by the proposed AI Growth Zone at Chapelhall; understands that such developments may rely on diesel generators to support 24/7 operation; further understands that there are concerns over potential nitrogen oxide emissions; recognises that there are community concerns about the cumulative impact on air quality, emissions, green space and energy costs; regrets that National Planning Framework 4 does not define “green data centres”, and notes calls for the Scottish Government to issue urgent guidance on the term, including in relation to the use of gas and diesel power and the air quality standards that should apply.

Background

How many data centres and where?

The last update of the APRS data centre map was 31 August 2026 adding on the Greenock data centre planning permission in principle application.

There are 21 now in planning portals, which includes two at Ravenscraig (the developer has divided the original development into two for the purposes of the EIA) and two in the AI Growth zone because, since the Pre-application Notification stage, these two developments (Lancaster road and South Lanrigg Farm, have been separate). Four have submitted planning permission applications, Edinburgh Gyle has been called in by the Scottish Government, Auchtertool and Larbert are under consideration, and Greenock is open for comments.

This gives an estimated c. 7300 MW currently in the planning system. Peak winter electricity demand in Scotland is just over 4,000 MW (NESO)

EIA situation

9 out of 16 which have reached the EIA screening stage have not been required to do EIAs by the local authority (see our data centre map). Three of these decisions have now been overturned by the Scottish Government (Edinburgh Gyle, West Edinburgh/Hermiston and Auchtertool).

The most recent application to come in, Greenock, which was validated on 28 August, does not have an EIA screening online but we believe it will not be required to do an EIA as the developer referenced an EIA screening in the planning application.

Recent Announcement by Scottish Government on Hyperscale Data Centres

On 18th August Minister for Finance Hannah Mary Goodlad announced:

  • A Planning direction that all local authorities need to report within seven days when they receive a planning application or a data centre over 50MW
  • The Scottish Government were calling in the Gyle data centre decision
  • They overturned two decisions that local authorities made on EIAs to ensure that West Edinburgh/Hermiston and Auchtertool data centres need to do EIAs

More information– including our follow up letter with a list of additional actions we would like to see from the Scottish Government.

Only the Larbert application, which has a determination hearing date of 16 September, and the recently validated application for the Greenock Data Centre in Spango valley (closing date for comments also 16th September) have not been stalled in some way.

If it helps to listen to a discussion on hyperscale data centres and the Scottish context – the podcast by the National with an interview with Kat Jones, APRS is a good start.

Issues from the Motion:

Diesel generators to support 24/7 operation

Data centres run to a 99.999% uptime standard which means that they need back-up generation in case of power supply issues. In Scotland, all the developments we have seen so far will use diesel generators. The Larbert application has the most detail as they were required to submit an EIA which covered air and noise pollution from the generators. The proposal has 200 3.2MW industrial diesel generators. The testing regime means that at least three of these generators will need to be on eight hours a day every working day of the year to get through all the testing. Using the consultants’ own figures, the Nitrous oxide emissions from the generators under the testing regime means they will be one of Scotland’s top polluters. And this is without a powercut when the generators will be working at full capacity. 

In Virginia, the state is proposing to exempt data centres from air quality regulations to allow for emergency diesel generators to provide power during peak summer energy usage. They say this is to manage grid instability issues caused by power demand from the large number of data centres. We believe that data centres in Scotland may also seek to use diesel generators for peaks in power demand. For example, the DV3 development which is part of the AI growth zone, already has the go ahead to use diesel generators to augment grid power at times of exceptionally high demand.  

Emissions 

Greenhouse emissions are closely linked to the growth of major data centres because they need to run 24/7 (and AI data centres run at an average load of 80%) and so are not well suited being supported by renewables. The UK’s first major AI data centre, Waspy’s wood, will be powered by ‘behind the meter’ gas turbine generators. 

We found that 100 data centres are applying to connect to the Uk’s gas network, presumably for the same reason (reported in the Guardian). Clean Power 2030, NESO’s plan only includes data centre provision of 1-2GW for the whole GB grid. Anything above this will impact on targets. Scotland’s Climate Plan does not include data centre impacts at all.

In Ireland, where 22% of the country’s energy was used by data centres in 2024 (50% in Dublin), electricity consumption by data centres increased by 32% between 2020 and 2021. Data centres are threatening the country’s climate commitments, while renewable energy which should have displaced fossil fuel use, as per their projections, is being diverted to serving data centres.  

In the US, where the grid is under huge strain in states with data centres, they are building their own infrastructure for energy, called the ‘bring your own power’ model. This is mainly gas turbine powerstations, the new Meta Data Centre in Louisiana, famous for being the size of Manhattan, will require three onsite gas power stations to produce the energy to run it. A shortage of gas turbines means that some data centres have employed jet engines to produce the power they need and stock of FTAI, a jet engine repair company, soared when it announced a new division, dedicated specifically to converting jet engines into turbines for use in electrical power generation.

Green Space and land

Hyperscale AI data centres need a huge amount of land. They are among the biggest buildings on the planet and so have tended to look for extremely large areas to occupy, usually at least 25 hectares, but in many cases it is more, wit the site for the DV6 Ai growth zone development being on well over 100 hecatres of agricultural land. Twelve of the sites in the planning system are on Green Belt sites or farmland, including at least two on grade 2 farmland, the best Scotland has. Two of the sites on Brownfield sites (Ravenscraig and Greenock IBM site) are allocated for housing with planning permission for 1450 homes between them. None of the sites in the planning system are on a priority list of potential sites drawn up by government bodies in 2021 and updated in 2023. 

The Hunterston proposal is a good example, being on agricultural land and yards from a 900 year-old castle, when the Hunterston coal yards, which are on the priority list for a data centre, sit only 200m to the north of the site. The Dunbar proposal would cover two designated battlefield sites. 

Energy costs

Energy costs increase in areas with a lot of demand from data centres. This has been especially stark in the US, where there are numerous reports of price rises due to data centre energy demands. This is due to two factors: firstly the expense of the large amounts of additional energy generating and transmission infrastructure required, and secondly increased reliance on gas which is a more expensive way of generating energy than renewables. A report published in May found that households in Ireland paid an estimated €715 million more in electricity bills between 2015 and 2023 due to the rapid expansion of data centres. 

The fact that data centres in the AI Growth zone (which are those by DataVita/HFD) will receive a £24 per MWh discount on energy (the discount is highest for AI Growth zones in Scotland) makes the existing high energy prices difficult to swallow. APRS has calculated that this will result in £6.7m a year electricity subsidy for the existing DataVira site plus extension, when it is finished, and over £80 million if the full 500MW data centre is built. 

28.7% of households in Scotland are in fuel poverty according to the 2024 Scottish House condition Survey

National Planning Framework 4 and “green data centres”

The root of the issue

Scotland’s National Planning Framework 4 (NPF4) is the overarching policy document for decision makers looking at planning applications. It has 18 National Developments, and one is Scotland’s Digital Fibre Network. Within this priority, green data centres are named. There are no criteria given in NPF4, by which planning authorities can assess whether a proposal is a ‘green’ data centre. 

Scottish Government, in the answer to Written Question S6W-41362 said it is ‘for the planning authority to interpret and apply NPF4 according to the circumstances of each individual case. To be considered a green data centre, planning authorities may wish to consider criteria such as the extent to which the data centre is powered from renewable energy sources; makes use of energy efficient technologies; seeks to minimise water consumption; and supports the re-use of excess heat.’ 

This has resulted in developers labelling proposed data centres ’green data centres’ in the hope that they will be considered a Priority Development and therefore get an easier ride through the planning system. Green-washing claims abound, with data centre developers claiming that use of the Scottish grid means they are green (because it is 73% renewable energy), and that they are green because they have solar panels, low flush toilets or low energy lighting. 

Listing green data centres as a priority in NPF4 has led to substantial land speculation as developers believe they can get planning permission for sites that would be completely unsuitable for any other industrial development, or development at all.

Scottish Government’s AI Strategy published in March 2026 says that by 2027 they will ‘Publish guidance on what factors are prevalent in a ‘green’ data centre’, which evidently comes too late for the current wave of applications.

A simple solution

We believe that the definition should be very straightforward. It is exactly what the authors of NPF4 intended it to be, covering data centres supporting a small increase in device and internet, applying to small data centres managing data, cloud computing etc and not to hyperscale AI data centres.

We know this for two reasons: 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 size of the applications in the planning system today (200-100MW) were simply inconceivable.

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. This was because it assumed 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.

More information on the case for this definition here and the greenhouse gas calculations work is here.

Cumulative Impact

The cumulative impact of these data centre applications would be huge due to their footprint, as some of the largest buildings on the planet, but mainly due to their electricity demand. If all those in planning portals in Scotland were to get planning permission there would be over 7000MW (7GW) of  demand seeking to connect to the grid. 

Two weeks ago Ofgem revealed in a consultation that they had 73GW of contracted demand in the grid queue for data centres They also note that over 93% of that figure are for data centres over 100MW. In their press release the figure was quoted as ‘at least 80GW’.

Even a tiny fraction of these going ahead would play havoc with the electricity systems, given how close the National Grid came to falling over during the recent heatwaves. It is clear that this needs a strategic approach and an overview of how much capacity of data centres Scotland actually requires, proper investigation of the balance of costs, benefits and environmental and community impacts, and plans that set out where any that need to be built should go.

Community Concerns:

There is increasing public concern over the hyperscale data centres planned for Scotland Community campaigners, in their letter to the First Minister on 24 August highlight 8 local petitions with a total of over 52,000 signatures between them. The APRS petition enclosed with the letter had over 8,000 signatures and the petition we lodged with the Public Petitions Committee now has over 21,000 signatures. 

The community campaigns which are organising against hyperscale data centre planned near them are: Larbert, Hurlford, Auchtertool, Chapelhall, Ravenscraig, Annan and Dumfries, Aberdeen (Blackdog), Bishopbriggs and Lenzie, Hunterston, Edinburgh (Gyle), West Edinburgh (Hermiston/Currie), Lammermuirs (Longformacus), Dunbar, Cockenzie, West Calder (Freeport), Greenock, Clelland/Hareshaw

Other

Employment: Data centres rely heavily on automation, meaning they typically create relatively small numbers of direct jobs. We have produced a report on data centres and jobs which found that typically a data centre employs 20-50 people and the biggest hyperscale facilities in the world (500MW) only are projected to employ 100 people.

Our Freedom of Information request to the UK Government found that direct jobs in the AI Growth zone would be less than 10% of the figure quoted on the UK Government press release. 

What is APRS asking for?

We, with ERCS, wrote a letter to the Scottish Government in December 2025 asking for a moratorium (pause) on planning permission from being granted for any new data centre developments, while they do the following:

  1. Publish an analysis of the impact of data centres on Scotland’s grid and net zero pathway:

including consideration of the cumulative impact of data centres coming forward on Scotland’s energy supplies, energy prices and climate targets, including the impacts of the gas or diesel back-up generation which is required on site.

  1. Publish a planning circular or planning guidance

This needs to clearly define what constitutes a ‘green data centre’, including guidance on alignment with net zero, and which informs developers that they are to include information regarding the capacity and electricity consumption of any proposed data centres clearly in application and pre-application documents; 

  1. Amend the Environmental Impact Assessment Regulations

to make environmental impact assessments mandatory for all planning applications for data centres. This could be done by adding data centres to Schedule 1 of those Regulations. EIAs must ensure that a thorough analysis is carried out of the impact of the energy and water use of data centres, before a decision is made on whether to grant planning permission.

After no progress towards these asks but an indication in an FMQ that the First minister was considering guidance for local authorities, we reiterated our request in a letter to the First Minister on 12 August, including a note on the ‘green data centre definition’ as we believe it was intended by the writers of NPF4 (see detail in briefing above). Following the announcement by Hannah Mary Goodlad on 18 August we added technical detail on the asks in a letter to her.

SCCS has written a briefing giving a list of conditions by which a moratorium would be lifted. And fourteen community campaigns have written to the First Minister with their calls for a moratorium and a list of changes they would like to see.

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