In February there were six planning applications, now there are 24!
So, we need to pull together and support the people of Auchtertool in their fight against Fife Council's plans for a 600MW Hyperscale AI Data Centre.
When you get a moment please go to the Fife Planning Website :
The application number is : 26/01243/PPP
Please see below some guidance on wording....
FORMAL PLANNING OBJECTION
Town and Country Planning (Scotland) Act 1997
Planning Permission in Principle for Data Centre Campus and Associated Infrastructure
Land North of Camilla Road, Auchtertool
Application Reference: 26/01243/PPP
Dear Sir/Madam,
I wish to submit this formal objection to the above application for Planning Permission in Principle (PPP) for the proposed "Cato" data centre campus at Auchtertool.
This representation builds upon concerns already raised by local residents and community organisations and focuses on the substantial conflicts between the proposal and the statutory development plan, National Planning Framework 4 (NPF4), and wider environmental and public interest considerations.
It is respectfully submitted that the applicant has failed to demonstrate that this proposal complies with the requirements of the development plan or that the significant environmental and infrastructure impacts arising from a development of this scale have been adequately assessed.
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# 1. Environmental Impact Assessment (EIA) Screening and Procedural Concerns
The proposed development represents an industrial complex of exceptional scale, involving a reported electrical demand of up to 600MW across a site extending to approximately 60 hectares.
Given:
* the scale of the proposed development;
* the associated energy infrastructure requirements;
* potential landscape and visual impacts;
* transport impacts;
* cumulative environmental effects; and
* the potential implications for national energy and water infrastructure,
serious questions arise as to whether the Screening Opinion issued under reference 25/03079/SCR remains appropriate.
The recent confirmation by First Minister John Swinney that the Scottish Government is reviewing the environmental assessment requirements applicable to hyperscale data centres demonstrates that this issue has become one of national planning significance.
In these circumstances, it is respectfully submitted that Fife Council should reconsider whether a full Environmental Impact Assessment is required before determination of this application proceeds. Failure to do so may expose the authority to unnecessary legal risk and could result in significant environmental effects not being properly identified or assessed.
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# 2. National Planning Framework 4 – Climate Change and Energy Impacts
The applicant's submitted documentation indicates that the proposed facility may require a continuous electrical load of approximately 600MW, equivalent to annual electricity consumption of approximately 4.2 TWh.
This level of energy demand is substantial and raises important questions regarding:
* national grid capacity;
* cumulative demand from proposed data centre developments across Scotland;
* energy system resilience;
* carbon impacts during periods of renewable generation shortfall; and
* the long-term allocation of strategic electricity infrastructure capacity.
NPF4 Policy 1 requires significant weight to be given to the global climate and nature crises, while Policy 2 requires development to contribute positively to climate mitigation and adaptation objectives.
The application does not appear to provide sufficient evidence demonstrating:
* the wider strategic implications of this level of electricity demand;
* the cumulative impact of large-scale data centre development across Scotland; or
* how the proposal aligns with Scotland's wider climate objectives and energy transition strategy.
In the absence of such information, it cannot be concluded that the proposal complies with the objectives of NPF4.
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# 3. Water Supply, Water Security and Public Utilities
The applicant's submissions indicate an annual operational water demand of approximately 34,000 cubic metres.
Whilst this may be relatively modest in isolation, the application does not adequately assess:
* cumulative impacts on regional water infrastructure;
* resilience during periods of drought;
* climate change impacts on future water availability; or
* the implications for public utility infrastructure.
NPF4 Policy 23 requires development proposals to demonstrate that infrastructure impacts can be satisfactorily accommodated.
At present, insufficient information has been provided to demonstrate that the proposed development can be supplied and serviced without adverse impacts on public utility infrastructure or long-term water resilience.
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# 4. Noise, Low Frequency Noise and Residential Amenity
The proposed development will require substantial mechanical cooling systems, air handling equipment, electrical infrastructure and emergency generation facilities operating continuously throughout the lifetime of the development.
While the submitted assessments rely principally on conventional A-weighted noise metrics, concerns remain regarding:
* low-frequency noise;
* tonal characteristics;
* cumulative operational noise;
* night-time noise impacts; and
* the potential effects of continuous industrial operations on nearby residential communities.
It is well recognised that standard A-weighted measurements may underrepresent low-frequency components associated with major industrial plant.
The application does not appear to provide a sufficiently detailed assessment of:
* low-frequency acoustic impacts;
* cumulative operational noise;
* vibration effects; or
* long-term residential amenity impacts.
This omission creates significant uncertainty regarding compliance with relevant environmental health standards and the requirements of NPF4.
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# 5. Emergency Generation, Air Quality and Public Safety
The proposed development will necessarily require substantial standby electrical generation capacity and associated fuel storage infrastructure to maintain operational resilience.
However, the application provides limited information regarding:
* the number and scale of standby generators;
* fuel storage capacity;
* operational testing regimes;
* air quality impacts;
* cumulative emissions;
* emergency planning requirements; and
* potential implications under relevant health and safety legislation.
Without detailed information concerning these matters, neither the planning authority nor the public can properly assess:
* air quality impacts;
* carbon emissions;
* noise impacts;
* operational resilience measures; or
* public safety considerations.
Given the scale of the proposed development, these matters require comprehensive assessment before any planning permission can properly be considered.
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# 6. Landscape Character, Rural Character and Prime Agricultural Land
The proposal would introduce a major industrial complex into an open rural landscape, with buildings reportedly reaching heights of up to 35 metres together with associated substations, infrastructure compounds, lighting columns, cooling equipment and security installations.
The proposed development raises substantial concerns regarding:
* landscape character;
* visual amenity;
* cumulative industrialisation of the rural environment;
* night-time light pollution;
* loss of rural character; and
* impacts upon the setting of cultural and historic assets.
Furthermore, the proposal would result in the permanent development of significant areas of agricultural land.
NPF4 Policy 5 places significant weight on the protection of soils and prime agricultural land, while the wider objectives of NPF4 seek to protect and enhance Scotland's natural and rural environments.
The applicant has failed to demonstrate that:
* there are no suitable alternative locations;
* the loss of agricultural land is justified;
* landscape impacts can be adequately mitigated; or
* the proposal accords with the spatial strategy objectives of the development plan.
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# 7. Socio-Economic Benefits and Planning Balance
While the proposal represents a significant capital investment, the operational employment benefits associated with hyperscale data centres are generally limited when compared to:
* their land requirements;
* their energy consumption;
* their infrastructure demands; and
* their environmental impacts.
The application has not demonstrated that the claimed economic benefits outweigh the substantial and unresolved concerns relating to:
* climate impacts;
* infrastructure capacity;
* landscape effects;
* environmental impacts;
* public amenity; and
* long-term sustainability.
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Conclusion
The proposed Cato data centre campus represents development of exceptional scale and intensity.
The applicant has failed to demonstrate that the proposal:
* accords with the Development Plan;
* complies with the objectives of National Planning Framework 4;
* has been subject to adequate environmental assessment; or
* can be delivered without significant adverse impacts upon the environment, public infrastructure and local communities.
Accordingly, I respectfully request that Fife Council:
1. Reconsider the need for a full Environmental Impact Assessment;
2. Undertake a comprehensive assessment of the cumulative impacts associated with large-scale data centre development;
3. Give substantial weight to the conflicts identified with National Planning Framework 4; and
4. Refuse Planning Permission in Principle for application 26/01243/PPP.
I request that this representation be formally registered as an objection and made available to all members of the determining committee.
Yours faithfully,
Your name & address