DEVELOPERS have submitted a planning application for another AI data centre in Scotland, bringing the total to three sites with active proposals.
This includes a 600MW site planned next to the small village of Auchtertool, Fife, and another in South Gyle, Edinburgh, which is being appealed after an initial rejection.
Now, developer Apatura has applied for planning permission for a 300MW facility on around 55 acres of grassland next to an industrial estate in Larbert, near Falkirk in central Scotland.
There are currently more than 20 data centre projects in the pre-planning stage for sites across Scotland, collectively producing a projected energy demand of more than 6.2GW, although it is unlikely that all projects will be approved after submitting planning applications, or completed.
Scotland’s peak energy demand has been registered as just over 4GW according to the National Energy System Operator (Neso), meaning AI data centres could more than double the nation's peak demand.
The Larbert site has been marked as likely to have a "major adverse (significant)" effect on operational and construction greenhouse gas emissions in its Environmental Impact Assessment (EIA).
The developers have proposed several small-scale mitigation measures, including "maximising the use of natural sunlight", using low-energy consumption settings and devices, and using electronic and mechanical equipment with a long effective lifespan.
But local residents and climate campaigners have raised concerns over the true scale of the site's impact.
The Stop Climate Chaos Scotland coalition manager, Fraser Sutherland, who lives nearby in Falkirk, said: "Not only would this extra need for power put a severe strain on existing infrastructure, there is significant concern over the use of fossil fuel back-up generators at these sites."
The Larbert planning application makes reference to the construction of underground diesel stores to hold capacity of 48-hours worth of fuel to power 200 backup generators.
The backup generators planned at the proposed South Gyle centre in Edinburgh, which was rejected in an initial planning decision, would have a carbon output of more than 200,000 tonnes per year, which is equivalent to building a second Edinburgh Airport, according to the developers, Shelborn Drummond. The exact number of generators in the South Gyle site was not published in the planning application, but visualisations of the site showed two large buildings to house them.
“Any new deployment of climate-warming oil and gas risks undoing Scotland's progress on cutting emissions, especially at the levels required for these power-hungry schemes," Sutherland added.
Kat Jones, director of environmental campaign group Action to Protect Rural Scotland added: "This 300MW data centre is right on the edge of houses in Larbert, and very close to Forth Valley Royal Hospital.
"It will draw the same power as 300,000 households and the application says they will have 200 industrial scale diesel backup generators which will create hazardous pollution for locals and the hospital when they are operating."
The developers have said the generators will only operate in situations where their power supply is disrupted or for short testing periods, however there are concerns that this will happen more than the developers have accounted for due to fluctuations in the supply of renewable energy during periods of low wind and sunshine.
Jones previously told The National: “No hyperscale data centre can be green when they need constant 24/7 energy at a scale that dwarfs our country’s current energy needs.
"Scotland’s renewable energy is, by its nature, intermittent, and is not reliable enough for data centres.
“When the wind is not blowing, the energy must be brought in from elsewhere by the grid or, as we are seeing in the US, generated onsite"
Sutherland and Jones also said the community has not been given enough time to organise an informed challenge to the development.
A period for public comments opened on June 5, running for 21 days until June 26.
There are 52 separate documents that make up the EIA alone, something Jones has said is making it "impossible to scrutinise" in the time allotted.
She said: "The developers have made it as difficult as possible for communities to input to this application.
"There are hundreds of documents to look through and the Environmental Impact Assessment alone is split into 52 separate documents, making it impossible to scrutinise.
"We call on the council to allow enough time for people to respond to this application and ask that they collate the documentation into a reasonable number of documents so that local people and wider civil society can see what is actually planned."
The plans also include "waste heat recovery" infrastructure to provide district heating in the future, however no timeframe has been set for when this would connect with a hypothetical local network.
A "major adverse" rating was also given for the impact its operation will have on the area's groundwater ecosystem and a "minor adverse (not significant)" impact on its flood risk. The report states that "no additional mitigation or monitoring is proposed", although a sustainable drainage system (SuDS) is expected to be landscaped and constructed.
The site will use a "closed-loop" cooling system, meaning water is recycled continuously in the data centre, transferring between industrial chillers and the computing hall in sealed pipes without evaporating, resulting in significantly lower overall water consumption than "open-loop" data centres, which consume vast amounts of water and have caused drought conditions in areas of the United States.
While the water consumption of closed-loop systems has been found to be much smaller than the open-loop counterparts, this is partially offset by higher energy requirements to power more advanced cooling systems.
The EIA also states that it is likely to have "moderate to major adverse visual effects" for local residents in Larbert, with the impact partially minimised by existing woodland belts and hedgerows that obstruct much of the development site from the roadside.
The proposed site is located on brownfield land next to the existing Glenbervie Business Park.
Despite the impacts the site would have on GHG emissions and water ecology, the EIA determined there would be a "negligible or not significant" impact across all topics on the wider area.
APRS has campaigned for an urgent update to planning regulation around data centres, with Jones saying there has been "Olympic level green washing" by the developers of so-called "green data centres".
"Green data centre" is a specific term within Scottish planning regulations (National Planning Framework 4/NPF4). They are regarded as nationally important projects due to their role in Scotland's digital infrastructure network, meaning they may be given favourable weighting in planning decisions.
However, the Scottish Government offers no definition of what it means, or any requirements for a centre to be classed as green, and instead has said this decision sits with local authorities.
The framework was also designed in 2022 and published in early 2023, before the widespread expansion of large-scale AI infrastructure and demand for the technology; instead, it was primarily intended to support smaller facilities underpinning cloud computing and digital services.
This also means that the predicted impacts relating to energy consumption and carbon emissions from their growth is significantly lower than the expected increase caused by AI.
A new report from the UN found that if it was to be considered a country, global energy demand from AI data centres would rank in 11th place, higher than Saudi Arabia and just one place behind France. By 2030, data centres could rise to become the sixth largest energy consumer in the world.
Commenting on the report, Jones said it: "Outlines the sheer scale of the problem of hyperscale AI data centres globally, which is now extremely close to home for us in Scotland with proposals popping up all over the central belt.
"Everyone from local authority planners and councillors taking decisions on individual hyperscale data centre planning applications, to government officials, ministers and MSPs making policy should read this UN report
Campaigners have raised concerns that the "green" data centre label could lead to environmentally damaging projects being granted permission as planning officers are more inclined to support national infrastructure projects.
Both APRS and SCCS have called on a moratorium on data centre developments until the framework is updated. The City of Edinburgh Council has become the first to pursue a temporary ban on developments, voting in favour of taking steps to examine the feasibility of a moratorium.
Sutherland told The National: "We need an immediate moratorium on the hyperscale data centres until the Scottish Government defines what 'green' actually means and makes proper environmental assessments mandatory.
“Otherwise, these schemes will simply act as a shortcut to more missed climate targets and further environmental breakdown while consumers foot the bill for new power infrastructure.”
Jones added: "The Scottish government urgently needs to put in place a moratorium so that a proper study on the impacts of these data centres on the grid, our climate targets and communities."
When asked by The National if there are plans to update NPF4, a Scottish Government spokesperson did not respond to the lack of definition or requirements, instead saying: “Scotland has significant strengths as a location for green data centres – abundant renewable energy, a highly skilled workforce and a resilient fibre backbone.
“Our aim is to secure commercial investment in data centres that help drive economic growth while aligning with Scotland’s net zero ambitions and delivering benefits for communities.”
On Wednesday, Scottish Greens MSP Mark Ruskell raised the question in Holyrood, asking if local planning authorities have adequate guidance to properly rule on hyperscale data centre applications and if there will be action to update planning frameworks.
Speaking on behalf of the Scottish Government, Public Finance Minister Hannah Mary Goodlad said the Scottish Government could not comment on individual proposals, but said that Scotland's AI strategy sets out expectations that data centre developments "should include steps" to ensure environmental sustainability.
Ruskell's question was followed by additional queries from MSPs of Labour, Reform UK and the LibDems on how effective and up-to-date planning regulations are and what efforts are being made to ensure the needs of local communities are being met.
Apatura did not respond to a request for comment.
The planning application can be found here.