This letter was sent on 18th December 2025 asking for a pause on all Data Centres in the planning system

You can read the response from the Minister to our letter here:

Ivan McKee, Minister for Public Finance, Scottish Government, St Andrew’s House, Edinburgh, EH1 3DG

MinisterPF@gov.scot

18 December 2025

Dear Minister,

RE: Scottish Government policy on data centres and the planning system

Written questions answered in the Parliament on 28 October 2025 asked, among other things, for clarification about the status of ‘green’ data centres in National Development 12 of NPF4, and the results were concerning. 

In summary, the answer to the S6W-41362 indicated that all ‘green data centres’ were to be considered part of National Development 12. The same Question asked what criteria are used to determine whether a data centre qualifies as a ‘green data centre’ under NPF4.  The answer was that it ‘will be for the planning authority to interpret and apply NPF4 according to the circumstances of each individual case’.

We believe that there will be serious unintended consequences of this policy until a strict definition of a green data centre is established, combined with an overall limit to the amount of energy that Scotland intends to divert to data centres. 

We have looked at data centres in development around Scotland and have seen that, in many planning application documents, or pre-application consultations, they are describing themselves as ‘green’ data centres. This can range from claiming to be green because they have solar panels on the roof to claiming the fact they use grid electricity in Scotland makes them green, some mention using waste heat in heat networks. 

The data centres we are looking at in detail are hyperscale data centres, those with a capacity of over 100 MW. We are aware of at least 3900 MW in planning portals and two developments, a total of 550 MW, which are conducting pre-application consultation, although we haven’t found any planning documents associated with them. This gives an estimated capacity of 4450 – 4950 MW that is already in planning or likely to enter the planning system in the next months. See table below for information.

These proposed developments only include two that are on the Scottish Government shortlist of applications. If development proposals for the other shortlisted sites reach planning, they will add a lot more electricity demand. For example, the i3 Irvine site alone is planned to be 1000MW.

The largest data centre currently operating in the UK, according to our information, is VIRTUS London5 in Slough at 90 MW (information from June 2025) but the scale of data centres proposed to be based in Scotland dwarfs that. The ones in planning portals are up to 600 MW and the Irvine data centre would be 1GW. With Torness power station producing 1.2 GW, one data centre could use nearly all the energy from the nuclear power station, which is due to close at the end of this decade.  Data centres need constant energy, and cannot dial up and down according to renewable production. Hyperscale data centres need onsite emergency generation, which will likely be gas turbine generators for any built in Scotland. 

We are concerned about the capacity of Scotland’s grid to accommodate these data centres and the implications for our climate targets. At present peak electricity demand in Scotland, according to NESO is just over 4,000 MW. Which means that the applications already in the Planning system, not including any additional that come forward from the SG shortlist, would require more energy capacity than Scotland’s peak electricity demand.

We ask the Scottish Government to introduce a moratorium immediately to prohibit planning permission from being granted for any new data centre developments, and for that moratorium to remain in place while the Scottish Government carries out the following steps to ensure that a strategic approach is taken to data centre developments which minimises their adverse effects on the environment, the achievement of national climate targets and secure and affordable electricity supply for communities:

1. Carry out and 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;
2. Publish a planning circular (or some other form of planning guidance which would form a material consideration to be considered by planning authorities when determining planning applications) which clearly defines 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; 
3. Amend the Town and Country Planning (Environmental Impact Assessment) (Scotland) Regulations 2017 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.

Hyperscale data centres need backup power on site, and these are likely to be gas turbines, to fire up in the case that the electricity supply goes down. The impact of backup generation from data centres needs to be examined in the context of our net zero targets.  

We would like to meet with you to discuss these concerns and a way forward to deal with the situation. 

Yours sincerely,

Dr Kat Jones, Dr Ben Christman

Director, APRS Legal Director, ERCS 

Table of Hyperscale Data Centres in the Scottish Planning System 

Total Capacity: 4092 plus between 100 & 600 MW for the Argyll Centre and added 350 MW average size for the one that doesn’t have a listed capacity.

Therefore total capacity of data centres in the Scottish Planning system and in pre-planning is between 4450 MW and 4950 MW.