SCCS have written to the First Minister and the other party leaders calling for a moratorium on hyperscale data centres until they have studied the impacts on grid, climate and communities and have an appropriate definition for ‘green data centre’ and have put hyperscale and AI data centres on schedule 1 of the EIA regulations. This briefing gives more information on hyperscale data centres planned in Scotland.

Summary

APRS are urging the Scottish Government to bring in a moratorium on hyperscale data centres through the planning system. The key reasons for this are:

1. The level of energy demand required for those applications either in planning or pre-planning (over 6000MW) would exceed Scotland’s entire winter peak demand (4000MW – NESO). In addition there are 5 sites that are being planned but have not put in a pre-application yet. Data shows 22% of Ireland’s energy was used by data centres in 2024. (information from APRS’s Data Centre Map)
2. Meeting Scotland’s carbon budgets would be directly undermined by the approval of any project of this sort, and the objectives of the Climate Change Plan would be impossible if even a small fraction of these hyperscale data centres were to come online. 
3. Energy bills will come under severe pressure and could rise significantly, as shown by the experience of hyperscale data centres operational elsewhere. Rolling blackouts are threatened for millions of customers in 17 US states, and these projects have been associated with spikes in energy costs in Ireland, Spain and the US.
4. Since these facilities need to run 24/7, they typically require fossil fuel backup. The 213MW project at the Gyle, recently unanimously rejected by City of Edinburgh councillors, would have required backup diesel generation equivalent to over 100,000 idling cars, with substantial negative implications for climate emissions and air quality.
5. The employment associated with hyperscale data centres is extremely limited, compared to other projects of a similar scale.Virginia’s 568 data centres employ 12,140 operational workers according to Virginia’s tech trade association, created by $203 billion investment ($16 million per job created).   
6. 12 of the 16 projects currently being proposed in Scotland are for greenfield and Green Belt sites, not brownfield projects. Hyperscale data centres are an inappropriate use for our green spaces.
7. Grid connection requirements associated with these projects have been shown to obstruct house-building projects. Three boroughs in London, for example, have had to constrain house–building for 10 years due to a lack of grid capacity to connect new homes, caused by demand from data centres in the area.

Background

There needs to be a differentiation between the data centres that keep our modern world moving – the cloud computing, businesses institutions and research- and the hyperscale AI data centres, which require different hardware and orders of magnitude more energy. In June 2024, 11 existing data centres were in operation across Scotland, according to Scottish Enterprise, consuming 10MW of power between them, a 20th of the power required for even the smallest hyperscale project in our planning system.

There are currently plans for 18 hyperscale data centres across the country. Some 16 of these are already in the planning system while two are in the early stages. The largest of these, a 1000MW site proposed in Irvine, would require energy the equivalent of a quarter of the entire peak demand of Scotland. Whitelees, the largest onshore wind farm in the UK, would take eight years of operation to generate the energy needed to power this site for just one year. 

The rapid growth in interest in hyperscale data centres in Scotland is driven by the vast power requirements of LLM training and the fact that this work is less sensitive to ‘latency’ (the time it takes for the data to travel at the speed of light along the fibre cables). This means AI data centres can be set up at a distance from the originator of the workload (usually in the US or London). 

Current Scottish data centre policy

Several Scottish Government policy documents, including the National Planning Framework 4 (see page 112),  and a digital action plan, from 2021, make mention of ‘green data centres’, but provide no definition of what that means. Similarly, the draft Climate Change Plan does not include data centres and the considerable impacts such developments would have on emissions targets.

In answer to a written question, seeking clarification on the position of data centres in NPF4, the Scottish Government said: “All green data centres of a major scale are designated as part of National Development 12: the Digital Fibre Network. This can include AI-focused data centres, provided they meet the criteria for major development and are considered ‘green’.” and said that it was up to the planning authority what should be considered a green data centre for the purposes of NPF4.

Scottish Government documents assessing the lifecycle greenhouse gas emissions of ‘green data centres’ say that they “will likely have an overall negligible impact on achieving national greenhouse gas emissions reduction targets”.[1]  

However, the impact of hyperscale data centres is not included in this assessment. This is despite developers claiming hyperscale AI data centres are ‘green data centres’ to get a preferential hearing from planning authorities.

The lifecycle greenhouse gas assessment was published in October 2022, before the launch of chatGTP, which led to escalating demand for huge data centres and the AI race, so this is hardly surprising. Hyperscale AI data centres have only emerged since after the publication of NPF4.

APRS is calling on the Scottish Government to:

Introduce an immediate moratorium on new hyperscale data centre planning permissions until they:

1. Publish an analysis of the impact of data centres on Scotland’s grid and net zero pathway
2. Consult on and publish an appropriate definition of ‘green data centre’
3. Make Environmental Impact Assessments (EIAs) mandatory for all planning applications for hyperscale data centres.

Part of the task of the Scottish Government in considering a definition of a ‘green data centre’ will be to decide what size of data centre would serve Scotland’s needs, rather than what they are being asked for by US big tech giants. There needs to be a differentiation between the data centres that keep our modern world moving – the cloud computing and the businesses and the research – and the hyperscale AI data centres, which require orders of magnitude more energy and devastate communities.

You can read an analysis of our campaign by the data centre industry here. “Rather than fight APRS, it’s time the industry just met their demands – define what a green data centre is, and stick to it.”

We have written to the Minister Ivan McKee, with ERCS, regarding these asks. You can see the letter and response here.