The environmental questions around Scotland’s AI data centre revolution

To others, however, they are an environmental scourge and an immense drain on natural resources, overseen by “alarmingly vague” planning guidance that is tantamount to a “greenwasher’s charter.”

You may never have heard of hyperscale data centres, and with good reason. At present, Scotland’s data centre infrastructure is relatively modest, with less than 20 facilities up and running. The largest among them, DataVita’s Fortis centre in the North Ayrshire village of Chapelhall, is working to expand its capacity to 40MW – the equivalent power of that used by around 30,000 homes.

But the hyperscale centres in the planning pipeline represent a quantum leap in size and scale, with some boasting capacities of as much as 1000MW. From a former oil and gas production site on the Cowal Peninsula on the west coast, to an area spanning swathes of agricultural land on the edge of Dunbar on the east coast, at least 19 sites in Scotland are earmarked for the creation of these new centres, driven by the exponential growth of AI and its voracious appetite for processing power

These endeavours are being supported at the highest level. Such hyperscale facilities are viewed by the Scottish government as a key economic driver, and a means of supporting work to achieve the nation’s net zero emissions. Its dedicated green data centres and digital connectivity vision and action plan aims to position Scotland as a “leading zero-carbon, cost competitive green data hosting location.”

In a sign of proactive approach being taken, the Scottish Futures Trust, Crown Estate Scotland, and Scottish Enterprise have even drawn up a shortlist of potential hyperscale sites as far afield as a decommissioned airport next to Sullom Voe oil terminal in Shetland to the former Chapelcross nuclear power station near Annan

At a UK government level, meanwhile, Labour has claimed the AI sector has attracted upwards of £100 billion in investment since it took office, with the industry growing 23 times faster than the wider economy in 2025. Only last month, it announced that Lanarkshire would host a new AI growth zone, which ministers said will create 3,400 high value jobs and bring in more than £8bn in private investment to the area.

It is little wonder that supporters of this boom regard it as a crucial way of strengthening the backbone of future Scotland’s digital economy. Others, however, are increasingly concerned about its deleterious environmental impact, and question how such energy and water-hungry facilities can be classed as ‘green’ in any way.

In a sector dominated by jargon, acronyms, and dizzying numbers, it can be difficult to comprehend the power and resources required by hyperscale data centres, but there is an existing body of research which lays bare such issues.

Every interaction with AI systems requires water to keep the technology running at optimum temperature, even if it is only a rudimentary prompt to ChatGPT. According to Rich Kenny, co-chair of the UK government’s Government Digital Sustainability Alliance planetary impact working group, a 100MW hyperscale centre is capable of consuming around 2.5 billion litres of water annually, the equivalent to the needs of approximately 80,000 people.

He has said that global projections indicate that AI’s water demand could reach billions of cubic metres per year, posing a “substantial threat” to water security worldwide, and within the UK.

Similar misgivings exist around energy consumption. Only last month, the regulator, Ofgem, pointed out that data centres account for a large proportion of projects in the demand queue, “far beyond forecast future need and what the system can reasonably support.”

The charity, Action to Protect Rural Scotland (APRS), has spoken out about the “mindboggling” amount required by AI and data centres, and warned of the “real risk” that new renewables capacity will be diverted to data centres instead of helping to deliver key climate targets.

It has calculated the energy demands of the hyperscale centres currently in planning or proposed throughout Scotland amount to between 4,749MW and 5,249MW, pointing out that that exceeds the Scotland-wide winter peak electricity demand of 4,000MW.

The charity’s director, Dr Kat Jones, described hyperscale data centres as the “gravest threat imaginable” to Scotland’s climate ambitions, adding that the policy framework to help authorities make informed decisions simply “doesn’t exist.”

“It is completely unrealistic to expect that a facility that has the same energy demand as a whole city, and requires that energy 24/7 can be powered by renewable energy alone,” she said. “When the wind isn’t blowing these data centres will be relying on our grid, which is already creaking at the seams.

“Our policies are entirely unprepared for such a rapid increase in scale of data centres, which are between ten and a hundred times the size of our current centres. Currently we are seeing many hyperscale data centres not being required to produce an environmental impact assessment, but this should be mandatory.”

She added: “We need to see a proper assessment done of the impacts of these hyperscale data centres on our climate plans, our grid and our communities. And we need a moratorium on them in the meantime to allow this work to be carried out.”

Yet there is an anomaly at play. Several of the hyperscale centres planned across Scotland are described by developers as ‘green’. They include a cluster of sites being brought forward by Hamilton-based Intelligent Land Investments Group (ILI).

Although it may not be a household name, the ILI group can rely on some experienced business figures. Its chairman is Dr Michael Kelly, the former economics lecturer who went on to serve as Lord Provost of Glasgow, and sat on the board of Celtic FC until 1994. Its policy advisor, meanwhile, is Brian Wilson, the former Labour MP and UK energy minister.

The firm has already secured land rights and permission to use the local electrical grid for three hyperscale centres, which will form what it calls The Stoics, a “green digital network” spanning the central belt. With sites in East Ayrshire, North Lanarkshire, and Fife, ILI says it will be one of the largest hyperscale data clusters in the world, more than twice the size of many contemporary leading campuses.

The company claims the cluster will generate £1.8 billion for the Scottish economy and support “around 1,400 jobs” across the country once operational, a figure which includes indirect supply chain roles and “induced jobs supported by wider economic activity and spending.”

The cluster, ILI says, could scale to around 1.5GW, which is almost equivalent to the entire UK data centre capacity in 2024. The firm says this would serve as “the foundation for a sustainable, AI-ready Scotland that leads in both energy and technology.”

One of the hyperscale centres it is planning, known as Rufus, is earmarked for a site next to the village of Hurlford near Kilmarnock. A website set up by ILI for the project emphasises its proposals are at a “very early stage.” To date, it has only submitted a proposal of application notice to East Ayrshire Council, but the firm’s site says it is aiming for the 540MW site to be entirely powered by off-site renewable energy sources.

A spokesman has said it is “possible” that all the project’s water needs could be met by harvesting rainwater on-site. It states it will bring “hundreds of jobs” during construction and skilled tech jobs when operating, while also bringing new opportunities for local businesses and suppliers.

Many, however, are unconvinced by the Lanarkshire company’s vision. Lisa Beacham, a student in Hurlford, has been raising awareness about the scale of ILI’s proposals and its impact on the local environment, and is a driving force behind the Ayrshire Major Development Community Group.

“From the get go, it has been clear that ILI knows nothing about data centres, and the definition of ‘green’ they are using is based on the input of how they are getting electricity into the centre,” she said.

The 29 year-old, who is studying international relations and political science at the University of Strathclyde, added: “As soon as you start to question the output of the data centre, that’s when they become unsure and you find holes in their story. There’s a lot of contradictions, and the one point they just really want to avoid is the water consumption.”

Another Hurlford resident, Arlene McMichael, said: “The water usage is a massive concern me, and there are questions about if the infrasturcuture is big enough to take it? It’s just wrong on so many levels. The data centre is planned on farming land, and the scenery around a path where thousands of people walk and cycle is going to be lost.

Alan Brown, the former SNP MP for Kilmarnock and Loudoun, who served as the party’s energy spokesman at Westminster, is also concerned about the initiative, and said there is a need for definitive answers around key questions such as power usage, water supply, jobs, and community benefits.

“Their quoted figures for water usage have been contradictory – talking about reusing rainfall collected from the roof area is clearly a distraction as that will not come close to being the main source for the site,” he explained. “Then quoting the demand is only equivalent to around 10 per cent of the water demand for Hurlford, as if this means it is of little concern, is not robust either.”

“The big problem here is that ILI does not have definitive developed proposals. It is an outline application, with a view to receiving planning permission and selling the permissions on to an end user, or more likely, another developer.

Asked by Scotland on Sunday for details on projected annual water usage of the Rufus site and the other centres in The Stoics, a spokesman for ILI said the projects were still being designed by its technical team, with input from key stakeholders including Scottish Water and the local community.

He said an “indicative assessment” suggests the Rufus facility’s consumption would be equivalent to the annual water use of “a few hundred homes,” and that the precise configuration of any on-site rainwater harvesting facility will depend on the final design and selected cooling technologies.

The firm said it was not possible to provide definitive figures around projected CO2 emissions, but said its “driving ambition” was to operate with the lowest possible, and “potentially net zero” operational emissions. It said electricity will be supplied via the grid with “additional measures” being considered, such as long-term renewable power purchase agreements and connecting to nearby wind generation “where feasible.”

The spokesman said it was consulting with the public at a time when The Stoics was at a “very early design stage,” and said “more detailed and definitive information” will be provided ahead of planning submissions.

He added: “ILI Group does not accept the suggestion that it is avoiding key issues such as water use or environmental impact, and in fact these matters are central to the design process. These issues have been part of our consultation from the outset.”

It will ultimately be for East Ayrshire Council to determine whether the Rufus plans proceed. But that process in itself raises other questions around the way in which hyperscale data centres are being assessed.

Scotland’s fourth national planning framework (NPF4) designates “green data centres” as forming part of what is known as National Development 12, and they are described in the framework as a “fundamentally important utility.” But exactly what criteria is used to determine whether a data centre qualifies as green?

On Thursday, Gillian Martin, the cabinet secretary for climate action and energy, told Holyrood that where new data centre development proposals emerge, it was for planning authorities to “interpret and apply” NPF4 according to the circumstances of each case, considering factors such as whether it is powered by renewables, has energy efficient technologies, seeks to minimise water consumption, and supports the re-use of excess heat.

However, the problematic nature of interpretation was laid bare in February when the City of Edinburgh Council’s development management sub-committee was asked to approve a 210MW hyperscale centre on the site of the former Royal Bank of Scotland headquarters in South Gyle .

The applicant, Shelborn Drummond, described it as a “green” data centre, in spite of the fact its estimated CO2 emissions amounted to more than 200,000 tonnes a year. Planning officers recommended approval in principle, pointing out it had been designated a national development. In the end, however, the committee’s councillors rejected the project, partly on the basis that it did not adhere to policies addressing the climate crisis and lifecycle greenhouse gas emissions.

It is no coincidence that on Thursday, a full meeting of the City of Edinburgh Council agreed to ask officers if it is possible for it to implement a moratorium on data centre applications until a definition or guidance on what constitutes a data centre exists. It followed a motion brought forward by Scottish Green councillor, Alys Mumford, who said it was important the city could be reassured that such hyperscale centres “are more than simply green by name.” That decision could have wider ramifications. Ms Beacham said she hoped East Ayrshire Council would follow suit in considering such a moratorium, not least given the scale of the Rufus facility.

Elsewhere, APRS has written the Scottish government’s chief planner, Dr Fiona Simpson, and Barry Stalker, head of its national planning hub, expressing “extreme concern” at the ongoing lack of guidance and information, pointing out that local authority planners are having to a deal with a “whole new industrial sector” where there is a “huge gap of information and policy.”

According to Foxglove, an independent non-profit organisation which campaigns to make “tech fair for everyone,” the increase in demand posed by the hyperscale developments would lead to “huge, increased pressure” on the grid,” and warned it was “very hard to see” how Scotland could accommodate such a vast new source of electricity demand while still hitting its climate targets.

Donald Campbell, advocacy director at Foxglove, also said the ambiguous and incoherent approach taken by the Scottish government in setting out whether a large data centre is green or not does not provide for the kind of crucial environmental safeguards that should be built into the planning process.

“This alarmingly vague approach from the Scottish Government is, in effect, a greenwasher’s charter. Developers can say their facility will be ‘green’ on whatever grounds they like, then argue it should be treated as a priority development,” he explained. “This has to be changed, urgently, to ensure there are real, concrete environmental protections in place.

“Until the electricity grid is fully decarbonised, increased electricity demand means increased emissions. Unless developers are required to build new, renewable energy and storage equal to their data centre’s needs, at all times, then more data centres mean more climate pollution.”

Mr Campbell said there was a need for “more active transparency” from both governments in Edinburgh and London, and called for stronger measures to be put in place to ensure developments cannot proceed unless they demonstrate they will not increase climate emissions or harm water supplies.

A Scottish government spokesperson said: “The Scottish government’s new AI strategy for Scotland sets out the strategic and economic importance of data centres and digital infrastructure. Thanks to the abundance of renewable energy we generate in Scotland, we are able to build infrastructure and AI capability that is clean, efficient and globally competitive. The strategy also sets out the steps we will take to assess and mitigate potential risks, including in relation to environmental sustainability.

“Planning authorities have a responsibility to consider the environmental implications of all developments which require planning permission, and all proposed developments are considered on their own merits. In cases where a proposal is likely to have a significant environmental effect, these powers are further supplemented by the procedures set out in environmental impact assessment legislation.”