We need to do everything to support our friends in Larbert and the surrounding area to fight their local planning dept. You don't have to live in Falkirk district to object.
Here is our objection. We hope it helps with your objection!
FORMAL PLANNING OBJECTION
Town and Country Planning (Scotland) Act 1997
Proposed Hyperscale Data Centre Campus with Associated Infrastructure, Energy Centre and Substation, Larbert
Application Reference: P/26/0237/FUL
Dear Sir/Madam,
I submit this formal objection to the above application for full planning permission for a hyperscale data centre campus at Larbert, submitted by Apatura.
The proposal represents a major industrial development requiring a continuous electrical demand of approximately 300 megawatts (MW), equivalent to around 2.6 terawatt hours (TWh) of electricity per annum. This scale of constant energy consumption is comparable to the output of a large power station and is among the largest ever single-site electricity demands proposed in Scotland.
Having reviewed the Environmental Impact Assessment (EIA) and supporting documentation, it is respectfully submitted that the applicant has failed to demonstrate that the proposal accords with National Planning Framework 4 (NPF4), the Falkirk Local Development Plan (LDP), or the wider public interest in relation to climate change, infrastructure resilience, environmental protection, and cumulative national impacts.
Accordingly, Falkirk Council is respectfully requested to refuse planning permission.
1. Strategic Energy Demand (NPF4 Policy 1 & 11)
The Environmental Impact Assessment confirms that the proposed development will operate at a continuous load of approximately 300MW, equating to annual electricity consumption of approximately 2.6TWh.
This level of demand raises significant strategic planning considerations, including:
cumulative impacts on Scotland’s electricity infrastructure;
energy system resilience and peak demand management;
carbon impacts during periods of constrained renewable generation;
the strategic allocation of national grid capacity; and
the cumulative effect of multiple hyperscale data centre proposals across Scotland.
National Planning Framework 4 requires development proposals to contribute to Scotland’s response to the climate emergency and support the transition to a net zero economy.
The applicant has not demonstrated:
how a continuous 300MW industrial electricity demand is consistent with Scotland’s climate objectives;
how cumulative national impacts of data centre expansion have been assessed; or
how the proposal supports long-term energy system resilience.
In the absence of such evidence, compliance with NPF4 cannot be concluded.
2. Standby Generation, Emissions and Air Quality (NPF4 Policy 23)
A development of this scale necessarily requires substantial standby generation infrastructure to maintain operational continuity in the event of grid failure or maintenance.
However, the application provides insufficient detail regarding:
total installed standby generation capacity supporting a 300MW facility;
fuel storage capacity and handling arrangements;
generator testing regimes and operational hours;
emissions profiles under testing and emergency conditions;
cumulative air quality impacts; and
greenhouse gas emissions associated with resilience operations.
Without this information, the environmental consequences of maintaining operational continuity for a 300MW hyperscale facility cannot be properly assessed.
The applicant has not demonstrated that:
emissions from standby generation will not adversely affect local air quality; or
the operational resilience strategy is compatible with climate mitigation objectives.
3. Fuel Storage, Safety and Emergency Planning
The proposed development will require significant fuel storage and associated infrastructure to support standby generation systems.
However, the application does not provide sufficient information on:
total fuel storage quantities;
containment and spill prevention measures;
fire risk assessment and mitigation strategies;
emergency response planning;
accident prevention and risk modelling; or
whether consultation with relevant statutory safety bodies is required.
Given the scale of a 300MW data centre campus, these matters are material considerations which must be fully understood before planning permission can be granted.
At present, the information provided is insufficient to properly assess public safety risks and emergency preparedness.
4. Water Supply and Climate Resilience (NPF4 Policy 23)
The operation of hyperscale data centres requires significant cooling infrastructure and associated water demand.
The applicant has not adequately demonstrated:
the long-term resilience of water supply arrangements;
the ability of local infrastructure to support sustained industrial-scale demand;
cumulative impacts on regional water resources;
implications of climate change and increased drought frequency; or
whether adequate mitigation measures are achievable.
NPF4 requires that infrastructure impacts are capable of being accommodated without unacceptable pressure on public services.
In relation to a 300MW facility, the absence of detailed resilience modelling is a significant omission.
5. Noise, Low-Frequency Effects and Residential Amenity
The proposed development will include large-scale mechanical cooling systems, electrical infrastructure and standby generation equipment operating continuously.
While noise assessments are provided, they rely primarily on standard A-weighted methodologies.
Concerns remain regarding:
low-frequency noise emissions;
tonal noise characteristics associated with large cooling plant;
cumulative noise from continuous 24/7 operations;
night-time noise impacts; and
long-term effects on residential amenity.
It is recognised that A-weighted metrics may not fully capture low-frequency acoustic characteristics associated with large industrial installations of this scale.
The applicant has not demonstrated that:
low-frequency noise impacts from a 300MW hyperscale facility have been fully assessed; or
mitigation measures will be effective over the operational lifetime of the development.
6. Landscape and Visual Impacts
The proposal constitutes a major industrial complex incorporating large-scale buildings, substations, cooling infrastructure, lighting and security installations.
The applicant has not demonstrated that the development would avoid significant adverse effects on:
landscape character and quality;
rural visual amenity;
night-time visual impacts and light spill;
cumulative industrialisation of the area; and
the setting of surrounding environmental and community assets.
The scale and intensity of a 300MW data centre campus represents a fundamental change to the character of the area, which has not been adequately justified or mitigated.
7. Cumulative Impacts and National Policy Context
Recent statements by the Scottish Government indicate increasing recognition of the strategic implications of hyperscale data centre development and the need for clearer national planning guidance.
The applicant has not demonstrated that the cumulative impacts of multiple large-scale data centre proposals across Scotland have been adequately assessed, particularly in relation to:
national electricity demand;
carbon emissions and climate targets;
infrastructure capacity;
environmental impacts; and
spatial planning policy.
In the context of a 300MW continuous-load development, cumulative assessment is a critical requirement of proper planning consideration.
Conclusion
The proposed Larbert Data Centre Campus represents a 300MW continuous industrial energy development of exceptional scale and national significance.
The applicant has failed to demonstrate that:
the proposal accords with National Planning Framework 4;
cumulative energy impacts have been adequately assessed;
environmental and public health impacts can be satisfactorily mitigated;
infrastructure capacity is sufficient to support the development;
public safety and emergency planning requirements are adequately addressed; or
the claimed benefits outweigh the significant environmental and planning concerns identified.
Accordingly, Falkirk Council is respectfully requested to refuse planning permission for application P/26/0237/FUL.
I request that this objection is formally recorded and presented to the Planning Committee in full.
Yours faithfully,
[Name]
[Address]
[Postcode]