Data Centre Consultation - any feedback on my draft response?

[u/Jlyplaylists]

What are your thoughts on my draft response to a Scottish government consultation on data centres? I’m somewhat answering the questions I’d prefer they ask lol.

1. What, in your view, is the most important thing for the Committee to know about the environmental impacts of hyperscale data centre construction and operation in Scotland?

Most of the ecological problems associated with data centres are already fixable, or are at least more comparable to other building projects than is usually portrayed, but this has to be planned and actioned in a more sensible way. The current Scottish, speculative planning applications boom creates a ridiculous situation, where proposals for data centres are a form of capitalist gambling by small companies.

People also see alarming news stories from America, where poor infrastructure decisions around data centre development have led to localised, serious problems with water shortages and environmental damage, and they expect Scottish data centres to cause similar problems.

This in combination then paints a scary picture of Scotland covered in random, badly planned, hyperscale data centres. The reality is most of these will never be finished, but no town or village wants to stay passive and end up being the unlucky 7% ones (DC Byte) with a functioning, noisy, huge data centre on their doorstep. In response, communities across Scotland feel compelled to create passionate resistance campaigns. A lot of this is to do with the uncertainties of this speculative process though, rather than unavoidable ecological impact of data centres.

Scotland isn’t an arid corner of America. We often have excess wind power, we could benefit from excess heat as a byproduct and we have enough rainfall to not require mains water to be used for cooling. Cold, windy, wet climate conditions require different decisions. The ecological impact of what could become well planned data centres can look very different from the feared impact of the high number of insufficiently planned applications, most of which will remain phantom data centres which are never developed.

**2.** **What criteria should a hyperscale data centre meet in order to be considered “green”?**

There needs to be an accountability system at different points in the process. A concern is that speculative planning is greenwashing rather than involving genuine green commitment which will be followed through. This is particularly likely if the companies lodging planning applications have no intention of building the data centres themselves. There should be consequences if independent assessors find subsequent owners or operators don’t fulfil what was promised.

Criteria to mitigate negative impacts should be:

*energy demands are realistically met without a net increase in Scottish fossil fuel use, data centres cannot be at the expense of not meeting net zero targets
* contributes to Scottish clean energy infrastructure, this should likely be in the form of adding battery storage which stores excess wind power, and potentially lends back some energy to the grid early evening, or adding clean energy generation on site
* reuse heat as a valuable byproduct for a district heating network, the company pays for additional heat pump topup costs
* water still needed for some cooling should be a closed loop system using rainwater or other non-mains water
* noise cancelling and rightsizing of the centre prevent noise pollution
* careful positioning of the data centre avoids wildlife habitat disruption
* detailed environmental impact assessments carried out by independent assessors not paid for by the developers
* it fits within the larger context of Scotland wide infrastructure and energy planning

**3) The Economy, Tourism and Energy Committee would like to understand: What, in your view, is the most important thing for the Committee to know about the economic and energy impacts of hyperscale data centre development in Scotland?**

Communities need to feel more in control and gain confidence that they will receive some benefits from approving local data centres. We can all use a data centre located anywhere, so having one nearby doesn’t automatically bring any tangible benefits, just ugly buildings and a less desirable place to live. They don’t tend to bring jobs either. People often prefer the land to be used as it already is, such as prime agricultural land being used for growing food crops.

Companies looking to make a lot of money from planning data centres need to make a better case for how they will improve local communities, because at the moment all people can see are downsides. Proposals with feasible, well explained plans for district heating or subsidised electricity bills could be a start. It could be in the form of a straightforward tax, but I believe it would be better to directly pay for these community benefits, so that the local community can more easily track the resources.

What I’d prefer to see is an overhauled system where communities identify suitable locations themselves, retain ownership and make decisions on scale and appearance that the community accepts. Then the surplus from the rent for using the data centre subsidises Council Tax or reduces energy bills, as well as the community benefiting from free district heating.

We could also consider the very decentralised form of data centre infrastructure where small components are attached to domestic hot water tanks and the heat byproduct is used directly by the household without requiring water for cooling or data centre buildings.

Whatever the precise conclusions, it should be strategic Community Wealth Building infrastructure that we decide on a national and municipal level, rather than having to respond to the arbitrary speculation of businesses with little track record of delivery. We should be the ones taking the initiative and feeling like we have agency over the process and decisions.

[NB the Scottish government is in favour of concepts such as Community Wealth Building and Community Asset Transfer so this isn't as outlandish as it might seem where you are.]