CAMPAIGN FACT SHEET: UPDATED 2.7.26 WITH SOME NEW FACTS & INFORMATION
CAMPAIGN FACT SHEET: UPDATED 2.7.26
WESTER HERMISTON HYPERSCALE AI DATA CENTRE
Planning Reference: 25/05576/SCR (EIA Screening) / 25/03978/PAN (Pre-Application Notice)
Status: Environmental Impact Assessment (EIA) Screening Opinion issued – 6 May 2026 (Waived by Officers)
Campaign Group: West Edinburgh Against AI Data Centres
Petition Status: 2,580+ Signatories (Growing at an average rate of 65 signatures per week)
TABLE OF CONTENTS
1. Scale: A Development of Exceptional Industrial Scale
2. Energy & Climate: Exposing the 95% "Operational Carbon Bomb"
3. Diesel Standby & Public Health: The "Zero Fossil Fuel" Contradiction
4. Water Infrastructure & The "District Heating" Paper Tiger
5. HSE Statutory Law: Fire, Vapour Explosion, and Major Accident Risks
6. Genuine Renewable/Solar Energy "Greenwashing"
7. The Technical Acoustic Defence: "Metric Smoothing"
8. Prime Agricultural Land & Green Belt Degradation
9. The Unnassessed Hardware Lifecycle: E-Waste and Carbon Gap
10. Consistency, Policy Crisis & Public Confidence
11. The “Speculative Corporate Flip”
12. Our Position & Democratic Call to Action.
1. SCALE: A DEVELOPMENT OF EXCEPTIONAL INDUSTRIAL SCALE
The Council's screening opinion and the developer's architectural design specifications confirm the extraordinary, unprecedented industrial scale of this urban-fringe proposal:
Daily Power Demand: Approximately 213 Megawatts (MW) continuous, uninterrupted utility load. This is 18% more energy than the Ravenscraig Steelworks consumed at its peak operational output when it employed 20,000 workers.
Annual Electricity Demand: Approximately 1,752 GWh of electrical power.
Domestic Energy Equivalent: Equal to the continuous domestic electricity demand of well over 600,000 average homes. For context, the entire residential sectors of Glasgow and Edinburgh combined contain approximately 570,000 homes.
Physical Footprint: Three massive data halls covering approximately 54,690 square metres distributed across two identical two-storey 48MW buildings and one single-storey 36MW building.
Total Site Area: 30.5 hectares (77 acres, equivalent to 44 football pitches) adjacent to the Union Canal and M8 corridor.
Building Height: Structural heights up to 23 metres (75 feet) tall along the western edge approach corridor to Edinburgh, encircled by a proposed 7 to 10-metre earth mound.
Verification Addendum / Source: City of Edinburgh Council Portal (Ref: 25/05576/SCR); Developer Site Layout Masterplans (Doc Ref: WH-Z-S01). Household metrics calculated via UK Eurostat/DESNZ domestic consumption baselines averaging 2,900–3,100 kWh annually per household.
2. ENERGY & CLIMATE: EXPOSING THE 95% "OPERATIONAL CARBON BOMB"
Council Position: The screening opinion concludes that climate impacts are not significant, relying on broad, non-quantified assertions regarding Scotland's general renewable electricity supply.
The Developer's Internal Admission: In the hidden background papers (Greenhouse Gas Emissions Report, Doc Ref: 7022478-P01), the developer's own consultants openly admit that 95% of the campus's total whole-life greenhouse gas emissions arise purely from operational energy due to the heavy electricity demand of the IT servers and cooling loops.
The Immediate Carbon Shock: While the developer attempts to highlight a "smoothed out" 60-year average based on theoretical future grid trajectories of the late 2070s, their reports show that on Day 1 of operation (2029), the facility will hit the atmosphere with an immediate, concentrated shock of 139,147 tonnes of CO2e in Year 1 alone.
Contextual Comparison: According to Edinburgh Airport's latest Sustainability Report, the entire airport's total carbon footprint is approximately 174,000 tonnes of CO2 per year. Wester Hermiston's server load matches roughly 80% of an international airport's entire operational footprint on Day 1.
Verification Addendum / Source: Cundall Lifecycle Carbon Assessment (Job No: 1047041, Doc Ref: 7022478-P01). The physical atmosphere experiences localized carbon loading on Day 1 of operations, directly violating the absolute emissions reduction trajectories mandated under NPF4 Policy 1.
3. DIESEL STANDBY & PUBLIC HEALTH: THE "ZERO FOSSIL FUEL" CONTRADICTION
The Core Contradiction: In their Energy Statement (Doc Ref: 7002484-P01), the developer's consultants state that a fundamental step toward sustainable design is to "eliminate the use of fossil fuels on building projects" to prevent localised human health hazards like Nitrogen Oxide (NOx) and toxic diesel particulates.
The Reality: Despite this narrative, the project infrastructure relies on a massive backup generation fleet consisting of up to 60 heavy industrial diesel generators. Standard 2.5MW to 3.0MW units are gigantic, measuring roughly 12.0m (40 ft) long, 2.4m (8 ft) wide, and 2.9m (9.5 ft) high, introducing an immense fossil fuel footprint directly into a rural-residential zone.
Fleet Fuel Consumption: Manufacturer specifications confirm that a single 2.5MW unit burns 659 litres of diesel per hour at full standby load (15,816 litres per day). In a prolonged grid failure scenario, this 60-generator fleet will use 39,540 litres of fuel per hour, dumping 2,544 tonnes of raw CO2 alongside concentrated particulate matter (PM2.5) directly over the West Edinburgh microclimate in a single 24-hour window.
Verification Addendum / Source: Cummins Inc. Commercial Power Generation Specification Sheets (Model QSK60-G22, Document Ref: DS391-CPGB). Bypassing an EIA allows the council to entirely escape evaluating ground-level particulate matter dispersion and toxic exhaust emissions under NPF4 Policy 23.
4. WATER INFRASTRUCTURE CANNIBALISATION & THE "DISTRICT HEATING" PAPER TIGER
The Scale of Consumption: Hyperscale data centres require immense, continuous volumes of water to control ambient facility temperatures. When outdoor temperatures rise or free-cooling thresholds are exceeded, these facilities switch to evaporative cooling mechanisms that draw thousands of litres of clean, treated drinking water daily from the municipal main.
The Public Utility Drain: By placing a continuous, high-volume demand on the local network, the facility risks lowering water pressure across West Edinburgh and actively cannibalises regional water security during increasingly frequent summer droughts.
The PR Promise vs. Internal Admission: The developer claims the project is a community asset because it includes masterplan allowances to export waste heat to a district heating network. However, in their official Energy Statement, the developers explicitly concede that there are currently no existing district heating networks in proximity to the site to connect to.
The Microclimate Threat: Scotland's official Heat Map proves that the surrounding Hermiston and South Gyle areas possess low to moderate heat demand. Until a multi-million-pound network is built by third parties, 100% of that massive sensible waste heat will be dumped into the local air, directly driving an estimated 2.2 degree Celsius urban microclimate thermal hazard and threatening the sensitive Union Canal eco-corridor.
Verification Addendum / Source: Scottish Water Network Capacity Assessments; National Heat Map Scotland (2024–2026). Bypassing the EIA means the Council has accepted this massive water drain and thermal plume without a transparent, quantified audit of its long-term impact on the city's utility infrastructure.
5. HSE STATUTORY LAW: FIRE, VAPOUR EXPLOSION, AND MAJOR ACCIDENT RISKS
Because this massive data centre requires millions of litres of bulk fuel storage to ensure continuous uptime, its infrastructure falls under strict UK Health and Safety Executive (HSE) hazardous safety thresholds. Bypassing an Environmental Impact Assessment (EIA) completely hides these severe industrial explosions and public safety hazards from the local community.
The COMAH Major Hazard Threshold
Under the Control of Major Accident Hazards (COMAH) Regulations, any facility storing over 2,500 tonnes of petroleum products (diesel/gas oil) is legally classified as a Lower-Tier COMAH site.
The Reality: To sustain a 213MW continuous load during a multi-day grid collapse, Wester Hermiston requires a massive bulk fuel tank farm.
Statutory Requirement: Once the 2,500-tonne threshold is crossed, the developer is forced by HSE law to implement a formal Major Accident Prevention Policy (MAPP). They must mathematically model worst-case disaster scenarios, including a catastrophic loss of primary containment and pool fire propagation.
DSEAR Vapour Explosion and Flash Fire Risks
Under the Dangerous Substances and Explosive Atmospheres Regulations 2002 (DSEAR), developers are legally required to assess and eliminate the risks of fire, explosions, and similar energetic events caused by dangerous substances.
Vapour Clouds: Large-scale diesel storage tanks vent volatile organic compounds (VOCs) and hazardous vapours into the air during tank refilling or thermal expansion. If a structural leak occurs under pressure, a compressed fuel mist or heavy explosive vapour cloud can form.
Ignition Hazards: Under DSEAR, developers must map out strict "Hazardous Area Zones" (Zones 0, 1, and 2) where flammable vapour and air mixtures can form. They must prove that the close proximity of heavy industrial cooling infrastructure, high-voltage substations, and local traffic routes will not spark a catastrophic flash fire or unconfined vapour cloud explosion.
Hazardous Substances Consent (HSC) Blindspot
Under the Town and Country Planning (Hazardous Substances) (Scotland) Regulations 2015, separate consent is required for large fuel volumes.
The Loophole: Developers are frequently choosing to submit vague, split-up Planning in Principle (PPP) or Pre-Application filings to deliberately conceal the exact fluid volumes of their planned fuel storage facilities.
HSE Public Risk Contours: The HSE is a statutory consultee on these applications, independently mapping out three distinct public risk zones (inner, middle, and outer contours) around the storage tanks to evaluate the safety threat to local houses, schools, and workplaces. By waiving the EIA, the council allows the developer to defer this detailed air dispersion and explosion modeling to a later date, leaving the public completely blind to the true scale of the risk while the principle of development is quietly pushed through.
Verification Addendum / Source: UK Health and Safety Executive (HSE) Hazardous Installations Directorate (HID) Regulatory Guidelines; Control of Major Accident Hazards (COMAH) Regulations 2015 (Schedule 1, Part 1); Dangerous Substances and Explosive Atmospheres Regulations (DSEAR) 2002 Approved Code of Practice (L138).
6. GENUINE RENEWABLE/SOLAR-ENERGY "GREENWASHING"
The On-Site Solar Fallacy: The developer points to rooftop solar photovoltaic (PV) arrays covering 850 square metres on DC01/DC02 and 700 square metres on DC03 as evidence of on-site green generation.
The Mathematical Drop: This array is restricted purely to the small administrative office roofs. A few hundred square metres of solar panels is a mathematical drop in the ocean compared to the continuous 213 MW industrial load required to power the AI servers. It is cosmetic window-dressing designed to distract from a massive grid drain.
The Infrastructure Monopoly: While the statutory planning fee paid (172,000 pounds) to process the paperwork is entirely inconsequential to the developer, the long-term grid impact is severely lopsided. The developer locks down a multi-decade monopoly over 213 MW of West Edinburgh's grid capacity to secure massive global corporate revenues, while forcing the local community to "pay the bill" through heavily degraded public utilities and unmitigated climate loads.
Verification Addendum / Source: City of Edinburgh Council Financial Planning Registers; NPF4 Policy 11 (Support for genuine renewable energy infrastructure).
7. THE TECHNICAL ACOUSTIC DEFENCE: "METRIC SMOOTHING"
The Acoustic Loophole: Data centres feature hundreds of massive cooling fans which generate continuous low-frequency hums and environmental infrasound. Developers attempt to obscure this by measuring emissions using the A-weighted (dBA) scale, which artificially filters out low frequencies and renders harmful infrasound legally "invisible".
The Earth Mound Fallacy: The developer's proposal to create a 7 to 10-metre-high earth mound around the site is entirely insufficient. While dirt banks can deflect directional, high-frequency sound, they are completely useless against low-frequency acoustic energy. Ground-coupled infrasound passes directly through earthen mounds unimpeded, threatening nearby communities with chronic sleep disturbance and vibroacoustic fatigue.
The Policy Request: The Council must condition that all technical noise assessments utilize Z-weighting (dBZ)—which applies absolutely no frequency correction and captures true, raw acoustic energy—or G-weighting (dBG) for infrasound monitoring.
Verification Addendum / Source: Acoustic Engineering Noise Impact Assessment Technical Papers (Cundall Job No: 1047041); World Health Organization (WHO) Guidelines for Community Noise.
8. PRIME AGRICULTURAL LAND & GREEN BELT DEGRADATION
The Asset Destruction: The Council explicitly acknowledges that the development requires the permanent loss, excavation, and concrete capping of 30.5 hectares (77 acres) of Class 2 Prime Agricultural Land.
The Food Security Loss: This finite soil resource is capable of producing, in a single growing season, enough grain for 500,000 bread loaves.
NPF4 Policy 5 Violation: Prime Class 2 agricultural land is a nationally important, finite resource representing just 1.38% of Scotland's total landmass. The Council has accepted this loss without any public evidence assessing brownfield alternatives or proving why this specific food-producing location is essential. Once construction begins, the destruction of this Green Belt asset and the negative impact on the historic Union Canal rural setting becomes permanent and irreversible.
Verification Addendum / Source: James Hutton Institute Soil Survey of Scotland (Class 2 Classification Data); NPF4 Policy 5 (Development on Prime Agricultural Land).
9. THE UNASSESSED HARDWARE LIFECYCLE: E-WASTE AND CARBON GAP
Here is the ultra-condensed, punchy version designed to fit seamlessly into a single-page campaign flyer or factsheet section.
The 3-Year Burnout Loop: AI servers face extreme thermal stress running 24/7 at peak capacity. Combined with rapid chip evolution, this forces operators to completely strip out and discard the internal computing hardware every 3 to 5 years.
The Global Memory Monopoly: By 2026/2027, AI data centres are projected to swallow an unprecedented 70% of all high-end computing memory chips manufactured globally. Stacking these ultra-dense memory blocks (HBM3e/HBM4) onto server blades accelerates severe heat concentrations and thermal failure.
70,000 Tonnes of Toxic Waste: Populated server racks average 1.13 tonnes each. For a 213MW site like Wester Hermiston, a single tech refresh moves thousands of hardware-packed racks, instantly creating 2,500 to 5,500 tonnes of electronic waste (WEEE). Over a 60-year lifespan, this relentless 3-to-5-year replacement loop dumps 40,000 to 70,000+ tonnes of heavy-metal-laden e-waste into global disposal streams with zero local planning scrutiny.
The 20% Carbon Understatement: Developers focus solely on ‘operational energy’ to claim their sites are green. They entirely hide Scope 3 Supply Chain Emissions (mining, overseas chip fabrication, and international transport logistics). Peer-reviewed research from Harvard University (Hassel, W. J.) proves that omitting this hardware manufacturing loop hides a massive 20% underestimation in total whole-life carbon footprint projections.
Material Violations of NPF4: By concealing these massive electronic waste streams and manufacturing carbon blocks, the development directly violates National Planning Framework 4 (NPF4) Policy 1 (Climate Crisis), Policy 2 (Whole-Life Greenhouse Gases), and Policy 12 (Zero Waste). Bypassing a full Environmental Impact Assessment (EIA) means the Council has completely failed to audit cumulative lifetime waste impacts.
Verification Addendum / Source: Hassel, W. J., Harvard SEAS, "Liquid versus Air: Life Cycle Carbon of Cooling Down AI Data Centers"; Counterpoint Research / TrendForce Memory Reallocation Data; United Nations Global E-waste Monitor; National Planning Framework 4 (NPF4) Statutory Policy Guidelines.
10. CONSISTENCY, POLICY CRISIS & PUBLIC CONFIDENCE
The Holyrood Admission: The planning framework for hyperscale data infrastructure is currently in an active state of emergency. On 25 June 2026, First Minister John Swinney confirmed at FMQs that the Scottish Government is urgently drawing up priority planning guidance. The First Minister openly acknowledged that local planning authorities are being overwhelmed by a "proliferation of applications" and that the government must react to protect "national energy and climate goals."
The South Gyle Precedent: West Edinburgh is sitting at the absolute epicentre of this unmanaged infrastructure surge. In February 2026, the Development Management Sub-Committee (DMSC) unanimously rejected a major data centre application at 1 Redheughs Avenue (South Gyle) due to unmitigated grid, water, and sustainability conflicts.
Regulatory Asymmetry: It is completely illogical for Edinburgh Council officials to waive a full Environmental Impact Assessment (EIA) for a massive 213MW proposal at Wester Hermiston when the First Minister himself has warned that these assets threaten national climate targets and require urgent policy intervention. Proceeding with a screening waiver within a recognized national policy vacuum completely undermines public confidence in the planning system.
Verification Addendum / Source: Scottish Parliament Official Report, First Minister's Questions, 25 June 2026; City of Edinburgh Council DMSC Official Minutes (Ref: South Gyle Rejection, February 2026).
11. THE "SPECULATIVE CORPORATE FLIP”
The Drax Precedent: The document exposes Apatura’s true business model. Apatura has no history of semiconductor manufacturing, research, or large language model software development. In October 2025, Apatura bundled and sold off its battery storage sites straight to energy giant Drax (Turnover in 2025 £5.3bn). This proves the Wester Hermiston application is entirely speculative, they want to gain planning approval over public land, flip the package for a massive corporate profit, and leave the local community to deal with an unnamed operator. Apatura currently has
Before entering the data centre gold rush in late 2024, the company's background was strictly in property speculation and large-scale grid battery storage rather than operating data server farms.
12. OUR POSITION & DEMOCRATIC CALL TO ACTION
The Council has concluded that a full Environmental Impact Assessment is not required, and we respectfully disagree. We are calling on all 63 elected members of the City of Edinburgh Council to utilise their democratic powers to enforce the highest tier of evidence-based scrutiny and refuse the full planning application when it comes before the committee.
Councillors are bound by both the Local Development Plan and NPF4. Where our older local policies have gaps, the stricter, modern national NPF4 policies legally take precedence. This data centre utterly collapses under NPF4 Policies 1 (Climate Emergency), 5 (Agricultural Land), and 23 (Public Health).
The council has a clear legal mandate to protect our community and require a full environmental report. West Edinburgh deserves robust planning decisions based on evidence the public can see, test, and verify.
CAMPAIGN NETWORK & CONTACTS
Email: gfmountain@gmail.com
Our Petition (2,580+ Signatories): https://www.change.org/data-centre
Our Campaign Website: https://sites.google.com/foot-logic.co.uk/data-centre/home