Minister for Public Finance, Scottish Government, St Andrew’s House, Regent Road,Edinburgh, EH1 3DG
19 August 2026
Dear Hannah Mary Goodlad MSP, Minister for Public Finance
Re: Recent announcements on data centres over 50MW
It was really heartening to read the planning direction you issued yesterday along with the screening directions for the hyperscale data centre proposals at West Edinburgh/Wester Hermiston and Auchtertool, Fife. APRS has been raising the need for urgent strategic consideration of the potential impacts of hyperscale data centre developments since last year.
Environmental Impact Assessments
APRS’s own monitoring suggests that there are four other hyperscale data centre developments at a similar stage of the planning process as the Wester Hermiston case, which have been screened out of an EIA, and which are listed below. We request that the Scottish Government issues a screening direction for each of these cases to ensure a consistent approach is being taken.
- Ravenscraig (West) 25/00556/EIA
- Ravenscraig (East) 25/00744/EIASCR
- Coldstream 25/00556/SCR
- Chapelhall (DV4) 26/00707/EIASCR
To demonstrate consistency to both the public and potential developers we suggest that Scottish Ministers could go further and issue a direction under The Town and Country Planning (Environmental Impact Assessment) (Scotland) Regulations 2017, Regulation 50. This would ensure that all hyperscale data centres are required to conduct an EIA timeously. A longer term approach might be to amend schedule 1 of the EIA regulations to include large data centres. We would be happy to discuss these proposals further.
Planning Direction 17 August 2026
We welcome the planning direction related to information the Scottish Government needs to monitor the planning pipeline of hyperscale data centres. We request that the data gathered from local authorities regarding applications for hyperscale data centres is made public timeously, in a format that is accessible for communities and non-specialists. In order to give a better measure of the potential hyperscale data centre pipeline, it would be helpful if the information published by the Scottish Government included any data centres over 50MW which have applied for EIA screening and Pre Application Notifications.
I am sure that you have already seen APRS’s data centre map where we have been trying, despite our limited resources, to maintain an up-to-date record of hyperscale data centres in planning and pre-planning in Scotland. We updated it last week, for instance to split the single Ravenscraig proposal into two as the developer appears to have pursued two separate EIA screening requests, despite clear links between the two.
It may be informative to look at some of the details we have put on our webpages for each application, especially, at the AI Growth zone site. By bringing the information together in one place you can see how inadequate the public information about the AI Growth zone is, with applications spread across various local authority planning applications and the ECU portal. We previously wrote to ECU, North Lanarkshire Council and the UK Government to say that this is hindering local community engagement in the project and to ask for transparency. This allows confusing information to spread such as the press yesterday suggesting a new development was starting in the AI Growth zone, whereas the DataVita press release was actually about two extensions to the existing data centre which are already being built.
We believe that the 17 August 2026 planning direction is the first action necessary for a more strategic approach to be taken by the Scottish Government. We hope we will see further announcements shortly, on what you intend to do with the information you receive via this planning direction.
Next Steps
We understand from the Planning Direction that you will receive notification of two applications which we know about from Fife and Falkirk councils within seven days (and potentially others that we have missed). We further note the news that you are recalling the Edinburgh Gyle appeal for decision by Scottish Ministers and we suggest that any other imminent decisions on current applications should be postponed until crucial research and policy development has been undertaken. This seems necessary to ensure, as you said in your announcement, a balance of “national energy, climate and community wealth building ambitions, which are vital to our future prosperity, as well as the potential impact on local communities.” In particular, the community in Larbert are potentially facing a very consequential planning application decision being taken by the local authority despite a clear gap in planning policy and guidance.
We wish to emphasise again, as we said in our letter to the First Minister earlier this week, that we are not calling for these decisions to be made at Government level, we are asking for a moratorium or pause in planning, so that the impacts (individually and cumulatively) can be thoroughly and independently assessed, a strategic approach can be taken, and that these inform new national planning policy and planning guidance.
We would be very happy to discuss this further but some of the elements we are hoping to see are:
- A proper assessment of the impact of new hyperscale data centres on Scotland’s climate targets, communities, land and water resources and the electricity grid to inform the guidance.
- National Planning policy on data centres – either in NPF5, or stand alone national planning policy. This must include a statement of need in the national interest for any data centres covering the full range of data centre types, scales and purposes (ie how much capacity is required and what purpose it serves).
- Direct all data centres to be EIA development, (or add data centres to schedule 1 of EIA regulations).
- Reconsider the inclusion of “green data centres” in National Development 12 in NPF4. This could either: Remove “green data centres” from ND12, or:
- Define the term “green data centres” very tightly so that the impacts of any green data centres match those set out in the existing lifetime greenhouse gas emissions analysis for ND12, and
- Produce a revised statement of need for ND12 that includes all types and sizes of data centres falling within the above definition of “green data centres”.
- National Developments – provide a clear ‘Statement of Need’, ie. need in the national interest, for any data centre deemed to merit the status of a ‘National Development’.
- The development of Scottish Government guidance that encourages data centre developers to submit full planning applications. Local planning authorities should be encouraged to use their power to request further information from applicants in order to determine applications, especially if PPPs continue to be submitted.
- The development of planning guidance, including on the effective use of planning conditions to control environmental harms and negative impacts on community health and wellbeing, and how these will be monitored and, if necessary, enforced – as well as the delivery of community benefits.
- Consider making Distribution Network Operators and Transmission Network Operators statutory consultee on data centre planning applications
- A requirement that all data centres have to report water and energy usage regularly and transparently, including resulting discharge of pollutants (eg refrigerants, waste heat, exhaust gases).
Yours sincerely,
Kat Jones, Director, APRS