This is the APRS submission to the appeal of the 212MW AI data centre at the Gyle, Edinburgh written by Nikki Sinclair. The data centre was turned down by the Planning Committee of Edinburgh City Council in February (see analysis here) and the developers are now appealing the decision.

28 April 2026 NOTE: for footnotes see the pdf.

DPEA ref: PPA-230-2794

Christopher.Kennedy@gov.scot, Planning and Environmental Appeals Division, Ground Floor, Hadrian House, Callendar Business Park, Callendar Road, Falkirk, FK1 1XR.

Dear Mr Kennedy

RE: Submission to Planning Permission Appeal (PPA-230-2794), 1 Redheughs Avenue, Edinburgh, EH12 9RH

APRS requests that this appeal should be dismissed for the reasons given below related to lack of support from the development plan. We also raise concerns about the EIA process as it has been applied to this proposal and query why no mention of an application for consent under the Electricity Act is made given the proposal specifies there will be onsite generation of up to 212MW from diesel generators.

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 Edinburgh local development plan (CityPlan2030) and Scotland’s Fourth National Planning Framework (NPF4). Furthermore, as indicated in the local authority decision notice dated 9 February 2026, the application also fails to make a convincing case that the proposed development be considered to be a green data centre as referred to in NPF4 National Development 12. Therefore, we believe the statement in para 1.11 (of the Appeal Statement) that the proposal has “status as development of national priority” is unfounded. Furthermore, various assertions in the appeal statement about the negligible climate impacts of this proposed hyperscale data centre appear to be based on one sentence of NPF4 about the Life-time Greenhouse Gas Emissions of National Development 12 which when thoroughly interrogated gives no support to this proposal (see section below on ‘Lifetime greenhouse gas emissions assessment in NPF4’ for more information).

Green Data Centre definition 

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. 

We disagree with para 2.3 of the Appeal statement  which says “The Appeal Proposal is recognised as a National Development by NPF4”. This is because the proposal fails to make a solid case for the proposal being a green data centre rather than a ‘standard’ data centre. 

The failure to provide reliable information about the environmental credentials of the proposal is partly due to this being an ‘in principle’ application which contains promises and assertions about potential environmental impacts rather than any firm facts about the design and technology which will be utilised. For example, the Planning Statement only indicates that there would be “a possibility of using energy-efficient technologies” (para 1.6),  and potential to “utilise renewable energy sources” (without specifying which or to what extent), also to “minimise water consumption” (without details), and that the proposal will have “the potential for efficient capture and reuse of excess heat generated by the data centre” (para 1.7). Whilst reuse of heat reduces waste, it only makes hyperscale data centres slightly less environmentally damaging, and there is currently no existing heat network in place or an established mechanism for ensuring there is one by 2028.

The application also fails to properly tackle or be frank about the climate impacts of a development with a power capacity of 212MW (See Life-time Greenhouse Gas Emissions below). The estimated power consumption figures for the two proposed data centre units are not included in the main planning statement, but are only found in the submitted “Energy and Sustainability statement including waste heat strategy” (ESS) at section 4.2. Similarly there is scant mention of the backup diesel generators – the ESS says there will be a large number of diesel generators and that their exhaust emissions can pose environmental and health risks but the details have not been finalised.

This means that City of Edinburgh Council are entirely justified in their conclusion that the application does not constitute a green data centre.  The Scottish Government have clarified that it is up to local planning authorities to make that judgement (see for example the answer from Ivan McKee MSP to SPQ S6W-41362 on 28 October 2025).[1]

In the Appeal Statement it is claimed that the proposal is very green and that the Council seems to have an unrealistic expectation of what green means.  The appeal statement says:  “From the information provided in this appeal statement, it is difficult to see how a data centre could be more “green” than this proposal”. APRS’s view is that it is impossible to view a proposal with the expected power consumption of this one to be “green”, particularly without a greater level of detail being provided than is the case here and that just calling a development “green” without backing that up is meaningless. Such scant information regarding climate impacts 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 – let alone one specifically for a green data centre.

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.

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 [2] 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”.[3]

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.”

Lifetime greenhouse gas emissions assessment in NPF4

The appeal statement refers to the Report the Council Officials made to the Development Management Sub Committee which said: “The development will likely have a negligible impact on achieving national greenhouse gas emissions reduction targets, as stated in NPF4”. We find that paraphrasing of one line from NPF4 “National Development 12: Digital Fibre Network Statement of Need” extremely misleading and the interpretation of it erroneous. It further suggests the officials and the appellant had not read the supporting background reports relating to the NPF4 Lifetime greenhouse gas emissions impact assessment for national developments or 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 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. 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 doesn’t seem to be 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 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 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 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 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. 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 now were not considered adequately enough for the NPF4 LGGEA to have any useful standing when considering a planning application of this type. So it is completely illogical for statements to be made implying 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 [5].  This emphasises that the assessment included in NPF4 is not adequate to inform a planning decision  – which directly contradicts the appeal statement.

If lifetime greenhouse gas emissions don’t seem to be being addressed properly for a particular case it is also worth being aware of the “Finch case” [6] 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. 

Back-up Electricity Generation and Section 36 of the Electricity Act 1989

Our understanding is that applications for developments with an electricity generating capacity of 50MW or more have to be made under Section 36 of the Electricity Act 1989. While it is not made clear in the planning or appeal statements (para 5.105 of the Planning statement just says the final details of the diesel generators have not been confirmed), we understand from the applicant’s Energy and sustainability statement (ESS) that there will be a large number of diesel generators in order to supply uninterrupted power to the two data centre units. The generator compounds are shown on the illustrative site plan and are referred to in section 4.3 of the ESS, where it states there will be a large number of them and that their exhaust emissions can pose environmental and health risks. From the table in section 4.3 of the ESS we see that one data centre unit (DC01) has an estimated power consumption (maximum power load) of 152.33MW and the second (DC02) of 60.09MW.  We therefore assume that the electric generation capacity of the diesel generators will be far more than 50MW.  It is made clear in the documentation that these generators will be regularly fired up for testing and maintenance as well as being used in the event of any failure in the main power source. The fact this is a back-up emergency power station has been considered by APRS, but doesn’t excuse the need for planning permission or consent. This part of the proposal appears to be a 212MW diesel fuelled power station in a mixed-use (including residential) area of Edinburgh with an expectation that the power station could be used as deemed necessary by the data centre.

Climate

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.” 

The addendum to the ESS (F1) makes some assertions that seem sloppy and could be mislead the reader to think that the grid supplies a much higher percentage of renewable energy than it does (eg para 2.1.1 – the Scottish grid is not 100% renewable annually) and that PPAs don’t increase the percentage of renewables in the mix overall so make no difference to the carbon intensity of energy.

To be able to say that a data centre was powered by 100% renewable energy, generated in Scotland is completely impossible for a data centre of this capacity on a site this size. It would require dedicated renewable generation twice the size of Whitelee windfarm, the largest onshore windfarm in the UK [7],  and a degree of energy storage completely impossible (BESS usually provides only around 2-3 hours of energy storage and the wind can fail to blow for days).  Just being connected to the National Grid in Scotland wouldn’t mean that the energy being used all the time was renewable and generated in Scotland. The idea of direct supply from renewables, a ‘private wires’ or  a power purchase agreement ( PPA) has been proposed in some cases. The ESS addendum (F1) suggests a PPA for renewables somewhere in Scotland is hoped for. 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 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 as described in the previous section.

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.

Emissions and the Energy and Sustainability Statement Addendum (F1) 

The estimated power consumption figures for the two proposed data centre units are not included in the main planning statement, but are only found in the submitted “Energy and Sustainability statement including waste heat strategy” (ESS) at section 4.2. Similarly there is scant mention of the backup diesel generators.  The ESS includes an estimate that the 212MW power consumption of the data centre will result in 200,435.96 T/CO2 annually from the compute of the data centre based on the then UK Government carbon intensity for grid power of 0.177kg/C02/kWh. 

The addendum to the ESS has been introduced at the appeal stage so we have had very little time to assess it, and some of the information in it seems different to that submitted to the planning application.  We make the following comments:-

2.1.1 We have a UK grid so implying a separate carbon intensity for a Scottish grid is not a reality. The proportion of renewable generation in the grid annually in Scotland is not 100%. Having a PPA doesn’t increase the percentage of renewables in the mix overall so makes no difference to the carbon intensity of energy (see section on Climate above).

2.3.1 If water is being recirculated there will be more requirement for cooling the water and this will have knock-on impacts for higher energy use. 

2.4.1 Even if a heat network was a reality, which seemed unlikely from comments at the planning committee, this would only use a very small proportion of the waste heat of the data centre due to the huge energy use of the development.  

4.2.2.2.1 The 99MW figure is different from the 212MW total in the ESS.

4.2.2.2. We note the Additional Information on Power.  The proposal has no onsite renewables or onsite/dedicated energy storage so will use grid energy  – with the resultant grid carbon intensity. 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.

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 letter gives analysis of the estimated emissions from the appeal development.  This looks at grid intensity, power usage and emergency generator emissions.

The figures are below:

You can see from the above table the huge additional emissions that result from use of the diesel generators. And also that the percentage of annual energy demand attributable to the building energy use is much less than one percent of overall energy.

Cooling and Water use

Para 7.241 (appeal statement) suggests the proposal has been developed based upon air cooling which uses “insignificant amounts of water” as the cooling systems are sealed.  The following paragraph states the development will be served from the existing Scottish Water mains infrastructure without affecting the local availability of water. Can this be guaranteed given the final design is not known – if a water cooled system was brought forward at detailed planning stage would it be refused given this alters the environmental impact of the development? Para 7.243 says “Scottish Water has raised no objection to the Appeal Proposal and any potential water use.” The inclusion of “any potential water use” seems misleading given Scottish Water’s verbal evidence to the CEC in February.  

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. The Appellant has submitted a new BREEAM pre-assessment Report (F2) with the appeal to reinforce this. 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 the application on building size and energy consumption that the percentage of annual energy demand attributable to building services in the proposed data centre is around 0.16% (Giddings, H (2026) Unpublished Report for APRS). The planning statement’s emphasis on energy and water 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 including the IT demand.

Site Suitability

We don’t agree with the Appeal statement para 1.7 that the site is ideally suited for a green data centre.  The Scottish Government has commissioned reports of studies to produce long and shortlists of the most suitable sites for green data centres in Scotland – see “Shortlist for Data centre Site development (Scottish Futures Trust/Host in Scotland, Crown Estates Scotland and Scottish Enterprise – June 2023 update) which do not include  the Redheughs Avenue site.

The site is currently adjacent to offices, with a residential area 200m away, and the south west of site is vacant but is part of the Southern Phase of Edinburgh Park – southern Phase masterplan with recently approved planning applications (by Parabola, S1 and Places for People) which includes housing.

Policy Place 19, Building design/landscape and visual impact

We are aware that planning permission (22/05659/FUL) was granted for the site in 2024 for an office development.  It was assessed as being suitable for a mixed use area despite not including any residential use.  The current application appears distinctly different given the data centre will require security measures (see illustrative design and paras 5.14 & 5.15 of Appeal statement) which will impact on the wider locality and impact the permeability of the site and access connections across the grid.  There will be noise from cooling equipment on the roof (para 5.18). Similarly the proposed back up power source of  diesel generators (see ESS) will be polluting and noisy as they will be regularly tested.

Whilst we can accept that policy Place 19 from the LDP does not necessarily mean that residential development is required throughout, it is apparent that the development within the area must be compatible with adjacent residential use. Various parts of the application suggest that “sensitive building design will be ensured” (eg the EIA screening request suggests “appropriate mitigation will be provided”).  However, data centres have high security requirements which will affect access through the site as well as having a negative visual impact and certainly detract from the attempt to deliver a cohesive townscape.  For example, the largest data centre we are aware of in Scotland (24MW) run by DataVita in North Lanarkshire is encircled by a double height high-security fence (see fig 1) which would be out of place in a mixed use housing led area and sit uncomfortably adjacent to the proposed public park area. 

Figure 1 – North Lanarkshire Datacentre showing double height security fence

EIA screening

We are extremely concerned that the reasoning used in the EIA screening decision  – and repeated in the Appeal Statement at para 4.9 – appears flawed and based on the assumption that calling the proposal a green data centre is enough to justify the statement that “the development will likely have a negligible impact on achieving national greenhouse gas emissions reduction targets, as stated in NPF4.”  We have dissected this reasoning in the sections above (“Green data centre definition in NPF4” and “Lifetime Greenhouse Gas Emissions Assessment”).

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 “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.

For the proposed development, slightly more detail is included in the December EIA screening decision compared to the earlier one, but there is no assessment of any impacts of electricity use, climate impacts or even mention of the back up diesel generators.  (The generator compounds were shown on the illustrative site plan and were referred to in section 4.3 of the applicant’s Energy and sustainability statement where it states there will be a large number of them and that their exhaust emissions can pose environmental and health risks). 

The planning statement doesn’t seem to mention the power capacity of the development. We note that the Energy and Sustainability statement (ESS) says at para 4.3 that the estimated power capacity of the data centre is 212MW (60MW +152MW).  It estimates this will result in 200,435.96 T/CO2 annually from the compute of the data centre based on the then UK gov carbon intensity for grid power of 0.177kg/C02/kWh. However, we note the newly submitted Addendum to the ESS (F1) uses a figure of 99MW for the site IT load. 

There is also a question about how the 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 connections have been secured but also that a power purchase arrangement will hopefully be secured from a bespoke renewable energy provider.  Will the environmental impacts of all this be assessed together?

An unevidenced claim is made in the Appeal statement that “it is unlikely that a green data centre could be sited and designed to minimise lifecycle greenhouse gas emissions to any greater extent than the appeal proposal.” Given the downtown Edinburgh location, there is no potential for meaningful onsite renewable generation and/or energy storage which means that the proposal seems to be designed to be powered from the grid (which is not only fed by renewables) and on-site diesel generators. There is no mention of the generators in the new Addendum to the ESS (F1). Unless, the back-up generation has been removed from the scheme (which does not seem to be the case) this is still the equivalent of an application for a 212MW (or perhaps 99MW) diesel fuelled power station within a mixed-use and residential area.

We also think the EIA should have considered the cumulative impacts across Scotland of hyperscale data centres and their vast energy usage for example on grid infrastructure and climate, and on the ability to meet national net zero targets. 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 deal with a marginal increase in device use and use of the internet cannot encompass these developments and they have not been included in their analysis of the climate impacts.

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

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

Footnotes

[1] S6W-41362 Asked by Arian Burgess MSP, 15 October 2025. “To ask the Scottish Government
what criteria are used to determine whether a data centre qualifies as a “green data centre” under
the fourth National Planning framework (NPF4), and whether AI-focused data centres are included
in the scope of national developments under NPF4
Answered by Ivan McKee on 28 October 2025. “National Planning Framework 4 (NPF4) designates
all green data centres of a major scale as part of National Development 12: Digital Fibre Network.
This includes AI-focused green data centres meeting the major development criteria.
It will be 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.”

[2] “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.”

[3] “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]  A copy of the research informing this assessment can be obtained from the Scottish Government by emailing chief.planner@gov.scot

[6]  UKSC/2022/0064

[7]  Whitelee is 513MW and has a load factor of 0.266

Documents referred to in APRS submission to PPA-230-2794

Giddings, Hannah (2026) Unpublished Report for APRS – The energy demand and carbon emissions impact of Scotland’s proposed hyperscale data centres (Full document available on Request from APRS – Excerpt submitted as separate document)

Scottish Government – NPF4 Planning Guidance on Policy 2 – Climate Mitigation and Adaption (June 2025)

Scottish Government – NPF4 Research Project: Lifecycle Greenhouse Gas Emissions of NPF4 Proposed National Developments Assessment Findings (October 2022 by Land Use Consultants Ltd)

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 2022UK 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