By Colin Lavety, Senior Planning Director at Pegasus Group.

What is a green data centre? It’s a question that many are asking and one that the Scottish Government must answer urgently, given the current tensions surrounding data centres across the country. 

Scotland’s National Planning Framework 4 (NPF4) already defines green data centres as ‘National Development.’ However, Scotland lacks guidance on how developers and Local Authorities should apply this status while delivering green data centres. This is at odds with the UK Government’s designation of data centres as Critical National Infrastructure and could lead to unintended consequences.  

A lack of guidance not only leaves developers in the dark but also risks Scotland falling behind on its 2026-2031 AI strategy. More importantly, it could deter data centre investment away from Scotland and towards other nations that do have greater planning predictability. 

 

What opposition do data centres face in Scotland?  

The Scottish Government wants to ‘harness AI’s potential for responsible, transformative economic growth.’ In many ways, Scotland is a great candidate to accommodate more data centres. It has a cool climate, available land, plus abundant renewable energy and storage. 

But protests are mounting against data centres over various concerns. Some fear that data centres will squeeze access to electricity and water. Others fear that data centres will destroy rural areas, or that they won’t contribute enough to the local economy. There is also a perception that data centres could adversely affect heritage sites. We’re seeing such resistance rear its head across the development process, whether it’s during initial Pre-Planning Public Consultation, Environmental Impact Assessment (EIA) Screening Requests, or Planning Application submissions.  

The pushback from communities has led to the SNP calling on the Scottish Government to temporarily freeze planning applications for hyperscale data centres.  The ask is that Planning Authorities need more robust guidance and research on the impact of data centres before determining any more planning applications. But this isn’t logical given that data centres are accepted as being Critical National Infrastructure. 

It is clear that there is an inherent tension in the delivery of green data centres. That is why many Local Authorities, firms, and members of the public are calling for clarity from the Scottish Government before any decisions are made on planning applications. This is all happening against a backdrop where NPF4 is encouraging the accelerated rollout of digital infrastructure across Scotland. In fact, green data centres have been identified as ‘significant developments of national importance‘ – at the top tier of planning policy, no less. 

That is not to say the construction industry has been resting on its laurels. Far from it, developers across the industry have proposed various solutions to building ‘green’ data centres. The World Green Building Council (WorldGBC) has launched a coalition to set credible sustainability benchmarks for green data centres. These derive common sustainability criteria internationally, with buy-in from the likes of the Building Research Establishment (BRE) and Global Real Estate Sustainability Benchmark (GRESB), among others. 

 

What is a green data centre anyway?  

The challenge in defining a green data centre is that there are no ‘one size fits all‘ parameters or features that make a data centre ‘green’ or sustainable. In fact, the Scottish Government has advised the following to date (through answering Ministerial Questions): 

 “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.” 

‘Green’ factors that contribute to a data centres environmental sustainability could, for example, include: 

  • Renewable energy use 
  • Reduced energy use  
  • Reduced water consumption (i.e., through closed loop cooling systems)  
  • Waste-heat recovery 
  • Grid support 
  • Biodiversity enhancement  
  • Reduced air and noise pollution 
  • Lower-carbon/resilient backup solutions  
  • Economic benefits, including direct and indirect employment opportunities, as well as community benefit funds or similar 

From a commercial perspective, spelling out these details is incredibly important for developers and investors. They need to know what actually qualifies as ‘green’ from the outset and what they need to design and invest towards. Otherwise, they run the risk of gambling time and money on projects without a clear steer of achieving a positive planning outcome. 

 

Clearer guidance on data centres can only be a positive thing 

Whatever the definition of a ‘green’ data centre ends up being is for policymakers to agree. However, it must be definitive and supported by unambiguous and quantifiable benchmarking. It must be well understood by — and deliverable for — both developers and the end users of green data centres. 

Given how many factors could arguably make a data centre green, the guidance will need input from a variety of stakeholders. Ideally, this should include the developers who will deliver the facilities. They need clearer guidance now to fulfill Scotland’s AI ambitions and deliver CNI. Any ambiguity will only delay planning decisions. Worse, it could drive investors and developers to other countries, where planning systems are simpler, and outcomes are more guaranteed. 

Such investor flight could have much broader consequences for the country’s AI and economic ambitions. Some AI startups are already reportedly packing their bags and leaving the UK due to struggling to secure the investment they need to scale. A lack of data centre capacity would only further discourage innovators from staying, given how much AI relies on new data centres, which need to be built quickly but also predictably. It is also absolutely clear that a blanket moratorium on data centres is not the answer. This would only delay and undermine the economic benefits that data centres provide. Our own economic modelling at Pegasus Group has shown significant contributions from even a single data centre.  

Wider research from techUK suggests the UK could create 40,200 new jobs before 2035 (likely high-paying) if it increases data centre capacity growth from the recent growth rate of 10% per annum to 15%. Another 18,200 jobs would be created over the same period during construction.  

The Scottish Government must therefore recognise the strategic need for data centres while balancing environmental considerations.  

Further assistance could be provided by clarifying the consenting and planning processes (e.g. where green data centres include a renewable energy component). And more radically, wider thought could be given to alternative consenting regimes that could streamline the planning process – perhaps taking inspiration from England’s Nationally Significant Infrastructure Projects (NSIP) or Masterplan Consent Areas (MCAs).  

Without this, Scotland risks falling behind the curve and losing out on the substantive economic growth opportunities offered by data centres.  

 

If you’re looking to bring forward a data centre development in Scotland, get in touch with Colin Lavety and the Pegasus Group team to learn how we can support you.

Colin Lavety

Senior Planning Director