Evidence Series — Scottish Energy Compact — June 2026
Scotland is not dealing with a distant projection. The sites are named, the developers identified, the applications lodged. Combined electricity demand already in the planning system stands at 5,700MW — rising to 8,700MW when pre-application sites are included. Scotland’s entire winter peak consumption is 4,000MW. No cumulative impact assessment has been published.
Part One — The Sites
The table below lists every site currently identified in Scotland’s data centre planning pipeline, drawn from Action to Protect Rural Scotland’s analysis of Scottish planning portals (updated June 2026) and Foxglove’s investigation of November 2025. This is the complete picture that no planning authority has been asked to consider as a whole.
| Site | Local Authority | Developer | Capacity |
|---|---|---|---|
| Ravenscraig | North Lanarkshire | Apatura | 550MW |
| Drumshangie | North Lanarkshire | Apatura | 500MW |
| Killean | Argyll & Bute | Argyll Dev. / SambaNova | 100–600MW; option to 2,000MW |
| Auchtertool | Fife | ILI Group | 600MW |
| Hurlford | East Ayrshire | ILI Group | 540MW |
| Newhouse | North Lanarkshire | ILI Group | 400MW |
| Hunterston | North Ayrshire | Eneus Energy | ~450MW |
| South Gyle | Edinburgh | Shelborn Drummond | 212MW |
| Wester Hermiston | Edinburgh | Apatura | 200MW |
| Freeport | West Lothian | Apatura | 250MW |
| Westerhill | East Dunbartonshire | Apatura | 300MW |
| Ochiltree | East Ayrshire | Apatura | 200MW |
| Duns | Scottish Borders | Sunlaws / Roxburghe Estate | 225MW |
| Coldstream | Scottish Borders | Apatura | 300MW |
| Haspielaw | South Lanarkshire | Apatura | Unknown |
| Irvine | North Ayrshire | TBC | 1,000MW (pre-planning) |
| Cockenzie | East Lothian | TBC | Unknown (pre-planning) |
| Total confirmed pipeline | 5,700–8,700MW | ||
Source: Action to Protect Rural Scotland planning portal analysis, June 2026; Foxglove, November 2025. Capacity figures reflect planning applications and stated development options where formal applications are not yet lodged.
Part Two — The Clusters
The pipeline is not evenly distributed. Six geographic clusters concentrate enormous demand on the same grid infrastructure, water catchments, and communities — yet each application is processed independently, as if the others do not exist.
Ravenscraig (550MW, Apatura), Drumshangie (500MW, Apatura) and Newhouse (400MW, ILI Group) form a cluster centred on the AI Growth Zone announcement of January 2026. All three share the same regional grid infrastructure and draw on the same catchment systems. No cumulative assessment covers any of them.
Hurlford (540MW), Ochiltree (200MW), Hunterston (~450MW) and Irvine (1,000MW pre-planning) place over 2,190MW in Ayrshire. Hurlford and Ochiltree both draw on the River Irvine catchment. Hunterston and Irvine sit on the North Ayrshire coast with potential for seawater cooling — which carries its own Marine (Scotland) Act obligations, none of which have been assessed.
The Killean site is the pipeline’s single largest proposed facility, with an option to reach 2,000MW. At full build it would alone exceed Scotland’s entire recorded peak winter demand of 4,000MW by 50%. No hydrological impact assessment has been published for the full 2,000MW scenario. No grid connection route has been publicly assessed at scale.
South Gyle (212MW, Shelborn Drummond), Wester Hermiston (200MW, Apatura) and Freeport (250MW, Apatura) represent over 662MW in and around Edinburgh and West Lothian. These sites sit in areas of existing dense grid infrastructure but place new pressure on urban network capacity and community environments.
ILI Group’s Auchtertool site is Fife’s largest proposed development. At 600MW it sits within the River Ore catchment — a relatively small watercourse with low summer flows. No SEPA abstraction assessment has been published. No low-flow analysis has been required as a condition of any application stage to date.
Duns (225MW, Sunlaws / Roxburghe Estate) and Coldstream (300MW, Apatura) sit in the Scottish Borders close to the River Tweed system — a designated Special Area of Conservation and one of Scotland’s most ecologically important rivers. No abstraction or catchment impact assessment has been required or published for either site.
Part Three — Scale in Context
Scotland’s maximum recorded winter peak electricity demand is approximately 4,000MW. This is the highest point of consumption — the peak on the coldest winter evening when every home, business and industrial facility is drawing simultaneously.
The confirmed data centre pipeline represents 5,700MW of new demand already in the planning system — 43% more than that winter peak. Including pre-application sites, the total reaches 8,700MW — more than double Scotland’s entire peak consumption.
Unlike domestic and commercial consumption, hyperscale data centres draw at near-constant load, 24 hours a day, 365 days a year. They do not switch off at night, at weekends, or in mild weather. They represent a permanent new baseload demand on Scotland’s grid — not a peak, but a floor.
When the wind stops blowing — as it frequently does in winter — these facilities compete directly with Scottish households for expensive dispatchable generation. The claim that they will absorb only “surplus” renewable energy collapses on contact with their operational profile.
No government body — not the Scottish Government, not the UK Government, not National Grid ESO, not Ofgem — has published a cumulative impact assessment of this pipeline on Scotland’s grid capacity, energy prices, or household electricity bills. Every application is being determined in isolation as if the other sixteen do not exist. This is a structural failure of the planning and policy system.
Bar widths proportional to 8,700MW baseline. Scotland winter peak: National Grid ESO. Pipeline totals: APRS / Foxglove analysis, June 2026.
Apatura appears as developer on nine of the seventeen named sites — more than half the pipeline by number and a substantial share by capacity. Sites include Ravenscraig, Drumshangie, Wester Hermiston, Freeport, Westerhill, Ochiltree, Coldstream, Haspielaw and others. The concentration of one developer across multiple local authority areas — each processing applications independently — is a structural feature of the pipeline that the current consent process is not designed to scrutinise.
Part Four — The Planning Gap
National Planning Framework 4 (NPF4), adopted in 2023, designates “green” data centres as national developments — a status that streamlines consent. The designation was designed for a different era: facilities of 50–200MW being considered individually, in a grid context very different from the one Scotland now faces.
The consequences of applying that framework unchanged to this pipeline are now visible. Planning authorities process each application as a standalone development. There is no mechanism for any single authority to require cumulative impact data. There is no trigger for a national-level grid capacity assessment. There is no requirement for SEPA to publish a catchment-wide water assessment before consent is determined.
The result is a pipeline of historically significant scale being approved through a system calibrated for a problem that is one to two orders of magnitude smaller.
Environmental Impact Assessments for major developments; consultation with statutory consultees including SEPA, NatureScot, and Transport Scotland; community engagement. Each application assessed on its own merits against local development plan policies.
Cumulative grid impact assessment; standardised water abstraction disclosure; Water Use Effectiveness targets; SEPA pre-assessment before consent is determined; household bill impact analysis; binding employment obligations; community energy levy; or any reference to the existence of other applications in the same developer’s pipeline.
Sources: Action to Protect Rural Scotland planning portal analysis, June 2026; Foxglove, November 2025; National Planning Framework 4 (2023), Scottish Government; National Grid ESO Network Options Assessment 2024/25.