Investigations — Scottish Energy Compact

Scottish Futures Trust

Submitted: 18 June 2026

Response received: 6 July 2026

Response Received

Scottish Futures Trust is a Scottish Government company funded by approximately £8.2 million per year of public money. It established and ran the Host in Scotland programme, which identified and promoted 12 data centre sites across Scotland to international hyperscale operators — without any published cumulative assessment of the energy, water or grid impact of those developments.

Key Findings

No cumulative assessment of energy demand, water use, environmental impact, consumer cost or grid reinforcement was ever conducted — before or during the promotion of 12 sites to international operators.
£398,766 spent on consultancy (CBRE, Deloitte, Gartner, TechRe, Farrpoint) since 2018.
No correspondence with Scottish Ministers exists regarding the programme's establishment, funding or objectives.
Records were only searched from 1 April 2019 onwards — files from the programme's 2017 launch remain in unsearched archive storage.

Read full text of request submitted, 18 June 2026

To: Freedom of Information Officer
Scottish Futures Trust Limited
1 Atlantic Quay, 1 Robertson Street, Glasgow, G2 8JB
foi@scottishfuturestrust.org.uk

Subject: Freedom of Information (Scotland) Act 2002 — Request for Information: Host in Scotland Programme

Dear Freedom of Information Officer,

I write to request the following information under the Freedom of Information (Scotland) Act 2002.

1. Expenditure

Please provide a full breakdown of all expenditure relating to the Host in Scotland programme from its inception to the date of this request, including but not limited to:

Staff costs and time allocation
External consultancy fees, including those paid to FarrPoint and TechRE
Marketing and promotional activity
Site identification and assessment costs
Travel and hospitality
Any expenditure incurred in promoting identified sites to international operators

2. Impact Assessment

Please provide copies of all internal or commissioned assessments conducted prior to, or during, the promotion of identified data centre sites, relating to:

Cumulative energy demand on the Scottish grid
Water abstraction and consumption requirements
Environmental impact
Cost to Scottish electricity consumers
Grid reinforcement requirements and associated costs

3. Ministerial Direction

Please provide all correspondence between Scottish Futures Trust and Scottish Ministers relating to the establishment, funding and objectives of the Host in Scotland programme.

4. Due Diligence

Please confirm whether any cumulative impact assessment was conducted before the 12 shortlisted sites were publicly identified and promoted to the international data centre market. If such an assessment was conducted, please provide a copy. If no such assessment was conducted, please confirm this in writing.

I would be grateful to receive this information within the statutory 20 working days. If any information is withheld, please specify the exemption relied upon and confirm whether the public interest test has been applied.

Yours faithfully,
Michael Knox
Scottish Energy Compact
scottishenergycompact.co.uk

Read full text of response received, 6 July 2026, from Scottish Futures Trust

To: Michael Knox
mike.knoxy@icloud.com
6 July 2026

Re: Freedom of Information (Scotland) Act Request for Information Dated 18 June 2026

Dear Mr Knox

I refer to your request for information dated 18 June 2026 ("Your Request"). Information relevant to Your Request is as follows:

Host in Scotland was an initiative to represent and promote the interests of the Scottish datacentre and subsea sector industry. Host in Scotland was started in 2017 by Scottish Futures Trust and the initiative has not been active since 2023. Since the publication of the Scottish Government's Green Datacentre Vision and Action Plan in March 2021, any datacentre work has been run by the Scottish Government and Scottish Enterprise.

In March 2021, Scottish Futures Trust, together with Crown Estate Scotland and Scottish Enterprise, published a report listing sites across Scotland potentially suitable for datacentre locations. The site selection report was written and produced for SFT by consultancy firm TechRe, in parallel with the Scottish Government's Green Datacentres and Digital Connectivity Vision and Action Plan. The report identifies that datacentre operators and other interested parties would need to undertake their own site investigations and risk assessments to satisfy themselves of the suitability of a specific location.

1. Expenditure

Staff costs and time allocation — In accordance with section 17(1) of the Freedom of Information (Scotland) Act 2002, SFT does not hold this information. The Host in Scotland initiative formed the majority of a full-time role for an employee from mid-2017 to mid-2023, supported by a part-time role from July 2021 to March 2023. Employees were at Associate Director grade, salary band (2022/23) £51,700–£86,700.

External consultancy fees, including FarrPoint and TechRE — Provided in full. See the consultancy expenditure breakdown below.

Marketing and promotional activity — 10 Host in Scotland in-person events were hosted in Edinburgh or Glasgow. Expenditure across these events (excluding consultancy already captured above) totalled £15,807.

Site identification and assessment costs — In accordance with section 17(1), SFT does not hold this information separately; costs incurred by external consultants relating to this are encompassed within the consultancy fees breakdown below.

Travel and hospitality — Travel and accommodation for attendance at datacentre and international connectivity meetings and conferences (including Dublin, London, Amsterdam, Monaco and New Orleans) totalled £12,602. All other incidental expenses totalled £3,931.

Expenditure promoting identified sites to international operators — In accordance with section 17(1), SFT does not hold this information.

SFT holds information falling within the scope of this request from 1 April 2019 onwards only. Information created prior to this date is held in archive storage and was not searched for the purposes of this response.

Description	Company	Cost
Pre-current financial system — reports produced:
Scottish DC Location Review, Jan 2018	CBRE	£45,000.00
Economic impact of international connectivity and data centre development, Sept 2018	Deloitte	£101,700.00
Economic impact of international connectivity and data centre development, Jan 2018	Gartner	£59,998.80
Financial records, 2019–2023 (TechRE were a sub-consultant to Farrpoint from Mar 2020–Jun 2023):
HIS workshop invoices	TechRe Consulting	£11,997.56
Data centre site consultancy, visits, review resource (20 invoices, Mar 2020–Nov 2023)	Farrpoint Limited	£180,069.78
Total consultancy expenditure		£398,766.14

2. Impact Assessment

SFT confirms that no internal or commissioned assessments were conducted relating to cumulative energy demand on the Scottish grid, water abstraction and consumption requirements, environmental impact, cost to Scottish electricity consumers, or grid reinforcement requirements and associated costs.

3. Ministerial Direction

SFT confirms that there is no such correspondence between itself and Scottish Ministers.

4. Due Diligence

SFT confirms that no cumulative impact assessments were conducted before the 12 shortlisted sites were publicly identified and promoted to the international data centre market.

If you are unhappy with this response, you may ask that Scottish Futures Trust carries out an internal review by writing to the Chief Executive, Peter Reekie. If you are unhappy with the outcome of the internal review, you have the right to appeal to the Scottish Information Commissioner.

Yours sincerely,
Paul Moseley
Senior Associate Director (Legal & Commercial), Scottish Futures Trust

Download full response letter (PDF) · Download consultancy expenditure breakdown (PDF)

Scottish Enterprise

Originally attempted: 18 June 2026 · Resubmitted: 25 July 2026

Response due: 21 August 2026

Resubmitted — Awaiting Response

Scottish Enterprise is Scotland's main economic development agency, funded by Scottish Government. It took over the Host in Scotland programme from Scottish Futures Trust and has actively marketed Scotland to international hyperscale data centre operators through Scottish Development International and Scotland IS — spending public money to attract developments whose cumulative impact on Scotland's energy system and household bills has never been publicly assessed.

Status

Our original 18 June submission and a 25 July follow-up were both sent to foi@scottishenterprise.com — an address that does not match Scottish Enterprise's published FOI contact. The follow-up failed to deliver outright; whether the original request was ever received cannot be confirmed.
The request has been resubmitted in full to the correct address, FOI@scotent.co.uk, on 25 July 2026. The statutory 20 working day clock now runs from that date, with a response due by 21 August 2026.
Key findings will be added here once a substantive response is received.

Read full text of request submitted, 18 June 2026

To: Freedom of Information Officer
Scottish Enterprise
Atrium Court, 50 Waterloo Street, Glasgow, G2 6HQ
foi@scottishenterprise.com

Subject: Freedom of Information (Scotland) Act 2002 — Request for Information: Data Centre Promotion and Inward Investment Activity

Dear Freedom of Information Officer,

I write to request the following information under the Freedom of Information (Scotland) Act 2002.

1. Expenditure

Please provide a full breakdown of all expenditure by Scottish Enterprise relating to the promotion of Scotland as a data centre location, from 2020 to the date of this request, including:

Staff costs and time allocation
Marketing and promotional materials
Attendance at industry events and trade shows
Engagement with international data centre operators
Contributions to the Host in Scotland programme

2. Operators Engaged

Please provide a list of all hyperscale or large-scale data centre operators that Scottish Enterprise has formally engaged with, hosted, or provided information to as part of its data centre inward investment activity.

3. Impact Assessment

Please provide copies of all assessments conducted by Scottish Enterprise, or commissioned on its behalf, relating to:

The cumulative energy demand of data centres in the Scottish pipeline
The impact on Scottish electricity consumers of grid reinforcement required to serve data centre developments
Water consumption and abstraction requirements of promoted developments
Environmental impact assessments

4. Co-ordination with Other Bodies

Please provide all correspondence between Scottish Enterprise and the following bodies relating to data centre promotion and site identification:

Scottish Futures Trust
Scottish Development International
Scotland IS
The Scottish Government Directorate for Digital

5. Pipeline Knowledge

As of the date of this request, please confirm the total megawatt capacity of data centre developments in Scotland that Scottish Enterprise is aware of, whether consented, under construction or in planning.

Yours faithfully,
Michael Knox
Scottish Energy Compact
scottishenergycompact.co.uk

Read full text of chase-up email sent, 25 July 2026

To: foi@scottishenterprise.com
25 July 2026

Subject: Overdue Response — Freedom of Information Request Dated 18 June 2026

Dear Freedom of Information Officer,

I am writing to follow up on my Freedom of Information (Scotland) Act 2002 request submitted on 18 June 2026, regarding data centre promotion and inward investment activity by Scottish Enterprise (subject: "Data Centre Promotion and Inward Investment Activity").

Under Section 10 of the Act, a response was due within 20 working days, which fell on 16 July 2026. That deadline has now passed without a response or any acknowledgement of extension.

Please provide the requested information as a matter of urgency, or confirm the current status of my request. If a response is not received within 5 working days of this email, I will consider referring this matter to the Scottish Information Commissioner for a failure to respond within the statutory timescale.

For reference, my original request sought:

Expenditure on data centre promotion since 2020
A list of operators engaged
Impact assessments conducted
Correspondence with related bodies
Total known pipeline capacity

Yours faithfully,
Michael Knox
Scottish Energy Compact
scottishenergycompact.co.uk

Read full text of resubmission sent, 25 July 2026, to the correct address

To: FOI@scotent.co.uk
25 July 2026

Subject: Freedom of Information (Scotland) Act 2002 — Request for Information: Data Centre Promotion and Inward Investment Activity (Resubmission)

Dear Freedom of Information Officer,

I originally submitted this request under the Freedom of Information (Scotland) Act 2002 on 18 June 2026, sent to foi@scottishenterprise.com. I have since discovered that address does not accept mail, and both that request and a follow-up sent on 25 July 2026 were never delivered. I am therefore resubmitting the original request in full below, to this correct address.

Please provide the following information:

Expenditure — a full breakdown of all expenditure by Scottish Enterprise relating to the promotion of Scotland as a data centre location, from 2020 to the date of this request, including staff costs, marketing materials, industry event attendance, engagement with international operators, and contributions to the Host in Scotland programme.
Operators Engaged — a list of all hyperscale or large-scale data centre operators Scottish Enterprise has formally engaged with, hosted, or provided information to.
Impact Assessment — copies of any assessments relating to cumulative energy demand, consumer grid reinforcement costs, water consumption, or environmental impact of promoted developments.
Co-ordination with Other Bodies — correspondence with Scottish Futures Trust, Scottish Development International, Scotland IS, and the Scottish Government Directorate for Digital regarding data centre promotion.
Pipeline Knowledge — the total megawatt capacity of data centre developments in Scotland that Scottish Enterprise is aware of, as of the date of this request.

I would be grateful to receive this information within the statutory 20 working days from the date of this email. If any information is withheld, please specify the exemption relied upon and confirm whether the public interest test has been applied.

Yours faithfully,
Michael Knox
Scottish Energy Compact
scottishenergycompact.co.uk

Scottish Government Planning Hub

Submitted: 18 June 2026

Response received: 17 July 2026

Response Received

On 18 June 2026 at First Minister's Questions, John Swinney told Parliament that "The Government's planning hub has been working with planning authorities to ensure that there is a wide and consistent understanding" of how to assess data centre applications. On the same day Ross Greer MSP placed on the parliamentary record that six applications in the current pipeline have undergone no environmental impact assessment. This FOI asks the Planning Hub to produce the guidance that the First Minister described — and to confirm whether any definition of "green data centre" with measurable thresholds has ever been issued.

Key Findings

No formal guidance, circulars or briefing notes have been issued to planning authorities on data centre applications — at all, in over four years. Only one letter, to one council, was identified.
No guidance exists on when an Environmental Impact Assessment is required for a data centre — left to case-by-case authority judgement.
No assessment has ever been carried out on whether planning authorities are applying the policy consistently.
No internal document defines "green data centre" — the definition "remains under active consideration," with formal guidance not promised until 2027.

Read full text of request submitted, 18 June 2026

To: Freedom of Information Officer
Scottish Government
foi@gov.scot

Subject: Freedom of Information (Scotland) Act 2002 — Request for Information: Scottish Government Planning Hub — Data Centre Guidance

Dear Freedom of Information Officer,

I write to request the following information under the Freedom of Information (Scotland) Act 2002.

On 18 June 2026, at First Minister's Questions in the Scottish Parliament, the First Minister stated:

"The Government's planning hub has been working with planning authorities to ensure that there is a wide and consistent understanding of those factors when coming to those conclusions."

The factors referred to were renewable energy use, energy-efficient technologies, reduced water consumption and the reuse of excess heat, in the context of assessing applications for hyperscale data centre developments.

I request the following information:

1. Guidance Issued

Please provide all guidance, circulars, letters, briefing notes and communications issued by the Scottish Government Planning Hub to Scottish planning authorities relating to the assessment of hyperscale or large-scale data centre applications, from 1 January 2022 to the date of this request.

2. Environmental Impact Assessment

Please confirm whether the Planning Hub has issued any guidance to planning authorities on the circumstances in which an Environmental Impact Assessment is required for data centre applications. If such guidance exists please provide a copy. If no such guidance has been issued please confirm this in writing.

3. Recipients

Please provide a list of all planning authorities to which the Planning Hub has issued data centre guidance, and the dates on which that guidance was issued.

4. Consistency Assessment

Please provide any internal assessment, report or correspondence produced by the Planning Hub evaluating whether planning authorities are applying a consistent approach to the assessment of data centre applications.

5. Definition

Please provide any internal document in which the Scottish Government has defined the term "green data centre" for the purposes of National Planning Framework 4 Policy 24 or National Development 12, including any minimum thresholds, metrics or standards associated with that definition.

The public interest in disclosure is substantial. The First Minister made a positive factual assertion to Parliament about the Planning Hub's work. That assertion has been directly contradicted by evidence placed on the parliamentary record the same day. The public has a clear interest in establishing whether the guidance described by the First Minister exists, what it contains and whether it has been consistently applied.

Yours faithfully,
Michael Knox
Scottish Energy Compact
scottishenergycompact.co.uk

Read full text of response received, 17 July 2026, from the Scottish Government

To: Michael Knox
17 July 2026
Ref: 202600522802

Re: Environmental Information (Scotland) Regulations 2004 — Your Request Dated 19 June 2026

Thank you for your request. As the information requested is "environmental information," it has been handled under the EIRs rather than FOISA (a technical point with no material effect on the outcome).

1. Guidance Issued

The Scottish Government National Planning Hub (NPH) has not issued formal guidance, circulars, briefing notes or written communications to planning authorities collectively on assessing hyperscale or large-scale data centre applications between 1 January 2022 and the date of the request. One relevant document was identified: a letter from the Chief Planner to City of Edinburgh Council dated 13 May 2026, enclosed with the response. Beyond this, the NPH points to non-written engagement only — a webinar with planning authorities and stakeholders, and a roundtable co-organised with techUK on 18 March 2026 (slide deck enclosed) — describing both as intended "to support knowledge sharing and consistency of understanding, rather than to constitute formal guidance."

2. Environmental Impact Assessment

The NPH has not issued specific guidance on when an EIA is required for data centre applications. This is left to individual planning authorities to determine case-by-case under the Town and Country Planning (Environmental Impact Assessment) (Scotland) Regulations 2017.

3. Recipients

As no formal data centre-specific guidance has been issued, there is no list of planning authorities or issue dates to provide.

4. Consistency Assessment

The NPH has not produced any internal assessment, report or correspondence evaluating whether planning authorities are applying a consistent approach. The Government states the NPH's role is to support capacity and information-sharing, "rather than to monitor, assess or audit decision-making by planning authorities" — responsibility for consistency rests with individual authorities.

5. Definition

The Scottish Government does not hold any internal document defining "green data centre" for NPF4 Policy 24 or National Development 12, including any minimum thresholds, metrics or standards. The response states this work "remains under active consideration and has not yet been taken forward," and quotes the First Minister in Parliament on 25 June 2026: "I am giving active consideration to whether the Scottish Government should provide planning guidance to balance the rapid expansion of hyperscale data centres with national energy and climate goals, which are vital to our future prosperity."

Yours sincerely,
Scottish Government FOI Unit

Download full response letter (PDF) · Download enclosed Chief Planner letter to Edinburgh Council, 13 May 2026 (PDF) · Download enclosed techUK/Scottish Government roundtable slides, 18 March 2026 (PDF)

Analysis: This response confirms Question 3 of the Holyrood exchange below — see the "Swinney vs the Paper Trail" comparison further down this page. The enclosed Chief Planner letter confirms Edinburgh's own Planning Committee asked for exactly this clarity in March 2026 and was told the request would be "drawn to the attention of incoming Ministers in due course." The only firm commitment on record is the Scottish AI Strategy 2026-31's promise to publish "green" data centre guidance by 2027 — over a year after the current wave of applications is due to be decided.

Holyrood Evidence

First Minister's Question Time

Scottish Parliament — 18 June 2026 — Official Report (Draft)

Ross Greer MSP, co-leader of the Scottish Greens, questioned First Minister John Swinney on the Scottish Government's definition of a "green data centre" and called for a moratorium on approvals for hyperscale developments above 50MW. The full exchange is reproduced below in order. This is a matter of public parliamentary record.

Ross Greer MSP — Question 1

Scotland faces a wave of applications for hyperscale data centres. If all the applications that are currently in the pipeline were approved, they would consume up to 6,000MW of power, which is more than one and a half times our entire national power use at peak time and is obviously completely impossible. There is currently no clear Government strategy or guidance for councils on how to deal with those applications, which are for something completely different from the kind of data centres that already exist in Scotland. We are not talking about socially and economically useful projects such as the University of Edinburgh supercomputer. The Government's policy is to support what it refers to as "green" data centres, but that position was decided before ChatGPT existed, before Elon Musk launched Grok and before any of those hyperscale proposals came forward. So, what is the Scottish Government's definition of a "green" data centre?

John Swinney — First Minister — Reply 1

The Government's definition of a green data centre is one that has been approved with due account taken of the environmental implications of all required developments. That will, of course, cover a range of the issues that Mr Greer highlighted in his question.

In defining green data centres, it is for planning authorities to interpret and apply national planning policy to the circumstances of each case. They should consider factors such as renewable energy use, energy-efficient technologies, reduced water consumption and the opportunities to reuse excess heat. The Government's planning hub has been working with planning authorities to ensure that there is a wide and consistent understanding of those factors when coming to those conclusions.

Compact note: The First Minister's definition contains no thresholds, no metrics and no enforceable standards. A green data centre is defined as one that has been approved as a green data centre — a circular statement. None of the four factors listed (renewable energy use, energy efficiency, reduced water consumption, heat reuse) carry a minimum standard or measurement requirement.

Ross Greer MSP — Question 2

The First Minister's response indicates that the Government expects each data centre to be approached individually, but we need a coherent national strategy. This is not an abstract issue: huge energy demands from these data centres will mean higher energy bills for everyone else and real problems for the communities that surround them. There are multiple reports of London boroughs putting a freeze on the building of new houses because of the impact of data centres on the grid. Those centres use so much power that, if additional homes were to be built in those areas, there would not be the grid capacity to supply them with electricity.

This is urgent because some applications are set to be decided perhaps before Parliament returns from summer recess. Data centres can play an important role in our economy, but not if we allow a free-for-all of unworkable applications to continue. Will the First Minister agree today to a moratorium on new data centres of above 50MW until we can agree on a clear national strategy and give councils the specific guidance that they need before they make decisions on individual applications?

John Swinney — First Minister — Reply 2

I understand the concerns that Mr Greer puts to me, but the detail of the planning policy addresses the issues that he is concerned about, particularly in relation to renewable energy use, to energy-efficient technologies and to water consumption and the generation of heat.

The planning policy is there to enable local authorities to make the determinations that they consider appropriate and necessary. There must, obviously, be extensive interaction and dialogue with individual communities before those applications are determined, but the criteria for the consideration and assessment of such developments are very clearly set out in planning policy.

Compact note: The First Minister declines to agree to a moratorium and instead restates that planning policy is sufficient. He does not address the claim that some applications are due to be decided before the summer recess, nor the evidence from London that grid constraints caused by data centres are preventing new housing connections.

Ross Greer MSP — Question 3

I cannot reconcile what the First Minister is saying about planning policy with how that operates in practice. He says that a green data centre is one where environmental considerations have been taken into account, but there is no requirement to do an environmental impact assessment on a data centre application.

In fact, six of the proposed hyperscale data centres that are in the pipeline have not undergone any environmental impact assessment, so they cannot possibly meet the definition that the First Minister has just set out. They have not undergone such an assessment because councils are dealing with the applications in the dark and have not been given the guidance that the First Minister is implying that they have been given.

One of the proposals that have not undergone an EIA is the one at Auchtertool in Fife. The data centre there would be the size of 100 football pitches, and its 600MW of energy need would be monumental. That is the same need, for just one private business, as that of 1.3 million households.

I am not asking the First Minister to comment on individual applications — he cannot do that — but I bring him back to the point that the 24 applications that have been announced so far would require, in total, 6,000MW, which is more than one and a half times our country's entire peak energy demand right now. The First Minister must recognise that that is not possible, so will he come back to the Parliament next week, before we suspend for the summer, to announce a pause on approvals for new hyperscale data centres until some kind of national plan is in place?

John Swinney — First Minister — Reply 3

Mr Greer raises an important issue that gets to the nub of how prescriptive planning policy should be in Scotland. It is a reasonable point, but members often argue in the Parliament for local decision making within a policy framework that is set by the Government. Mr Greer is asking me to do something much more specific, instructive and determinative than that. It is a perfectly reasonable point, but it is different from the prevailing mood in the Parliament in relation to how members have argued planning policy should be undertaken. Indeed, much of the content of national planning framework 4 is predicated on the basis of what I have just set out to the Parliament. Mr Greer will be familiar with the formulation of that document.

The Government will, of course, consider all emerging planning issues, and we must monitor the implications of local planning decisions. However, if the Parliament wishes there to be a fundamental change to the way in which we determine such issues, it will have to have an open discussion about whether such powers should be exercised nationally by the Government, not locally by individual local authorities, which has been the prevailing view in the Parliament until now. The Parliament is welcome to consider that issue.

Compact note: The First Minister does not address Greer's central point — that six developments in the pipeline have undergone no EIA, yet his own definition requires environmental implications to be taken into account. He declines to return to Parliament before the summer recess and offers no moratorium. The four conditions of the Scottish Energy Compact require no transfer of planning powers from local to national — they can be delivered through a Planning Circular and targeted NPF4 update within the existing devolved framework. Update, 17 July 2026: our FOI request to the Planning Hub (above) has since confirmed in writing that no EIA guidance and no consistent-application assessment exist — see the response and analysis in the Planning Hub card above.

Verdict

Swinney vs the Paper Trail

On 18 June 2026, the First Minister told Parliament the planning hub had already been ensuring a "wide and consistent understanding" of green data centre criteria, and that assessment criteria were "very clearly set out in planning policy." The Scottish Government's own written FOI response, dated 17 July 2026, says otherwise on every count below.

Swinney told Parliament

"The Government's planning hub has been working with planning authorities to ensure that there is a wide and consistent understanding of those factors when coming to those conclusions."

FMQs, 18 June 2026 — Reply 1

The FOI response says

The NPH has not issued formal guidance, circulars, briefing notes or written communications to planning authorities collectively — at all, in over four years. Only one letter, to one council, was identified. The webinar and roundtable relied on are described by the Government itself as intended "to support knowledge sharing... rather than to constitute formal guidance." No assessment of whether authorities are applying a consistent approach has ever been produced.

FOI 202600522802, 17 July 2026 — Q1 & Q4

Swinney told Parliament

"...the criteria for the consideration and assessment of such developments are very clearly set out in planning policy."

FMQs, 18 June 2026 — Reply 2

The paper trail says

No data centre-specific EIA guidance exists; authorities apply the generic 2017 EIA Regulations case by case. Five weeks earlier, the Chief Planner had written to Edinburgh Council conceding that "greater clarity on a definition would support consistent decision-making across Scotland" — and promising only to revisit the question with incoming ministers after the election.

FOI 202600522802, Q2 · Chief Planner letter, 13 May 2026

Swinney told Parliament

"...we must monitor the implications of local planning decisions."

FMQs, 18 June 2026 — Reply 3

The FOI response says

"The role of the NPH is to support capacity, capability and information sharing across the planning system, rather than to monitor, assess or audit decision-making by planning authorities." Responsibility for consistency rests entirely with each individual planning authority.

FOI 202600522802, 17 July 2026 — Q4

The Timeline That Contradicts the Claim

13 MAY 2026

Chief Planner to Edinburgh Council: concedes no single definition exists, notes stakeholder calls for a pause on consents, defers clarification until "early following on from the recent election."

18 JUN 2026

Swinney, FMQs: tells Parliament the planning hub has already been ensuring "a wide and consistent understanding" of green data centre criteria.

25 JUN 2026

First Minister, quoted in the FOI response: says he is "giving active consideration to whether" the Government should provide planning guidance at all — one week after claiming consistent understanding was already assured.

17 JUL 2026

FOI response confirms: the green data centre definition "remains under active consideration and has not yet been taken forward." No guidance, no monitoring, no definition exist in writing anywhere in Government.

Also on the record: at a techUK/Scottish Government roundtable on 18 March 2026 — three months before the FMQs exchange, in a session co-organised by the Government itself — Shoosmiths' planning partner listed "lack of established policy and practice" and "EIA approach can vary" among the sector's open challenges. Download the slides (PDF).

Can You Help?

If you have information relevant to these investigations — or believe there are questions we have not yet asked — we want to hear from you. This includes planning professionals, former public servants, energy industry insiders, academics, journalists and members of the public.

We are particularly interested in:

Internal assessments of data centre energy demand held by any Scottish public body
Correspondence between Scottish Ministers and data centre operators or their agents
Evidence of grid reinforcement costs being allocated to general consumer tariffs
Water abstraction applications or licences relating to proposed data centres
Any cumulative environmental impact assessment that has not been published

All sources are treated in confidence unless you indicate otherwise. This is an independent public interest campaign with no political or commercial funding.

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