Article Masthead
- Category: Policy & Regulation
- Topic: Data Centre Environmental Review
- Region: Europe
- Signal Type: Planning and Environmental Regulation
- Published Date: 2026-09-17
- Original Source Date: 2026-09-16
01 What Happened
A new Scottish planning direction came into force on September 17, 2026 requiring an Environmental Impact Assessment (EIA) for applications for new data centres with power capacity exceeding 50 MW.
The Scottish Government published the direction on September 16. It states that artificial intelligence is increasing national considerations around energy use, water consumption and hardware needs, and notes that closed-loop cooling can significantly reduce water required for cooling. The direction also identifies water resources, biodiversity, soils, noise, landscape effects and potentially air quality from backup generators among the locational issues that may need assessment.
For developments below 50 MW, EIA is not automatically required under this direction. Those projects remain subject to case-by-case screening under Scotland’s existing EIA regulations.
The measure follows an August direction requiring planning authorities to notify Scottish Ministers within seven days when they validate applications for data centres above 50 MW, giving central government earlier visibility into the development pipeline and wider infrastructure implications.
02 Key Takeaways
01
Scotland has moved large data-centre environmental review from discretionary screening to a mandatory EIA requirement once proposed power capacity exceeds 50 MW.
02
Water is explicitly part of the policy rationale: the government identifies AI-related water consumption and water-resource impacts alongside energy, climate, biodiversity and other environmental issues.
03
The new rule does not prescribe a specific cooling or water-treatment technology, but it raises the documentation burden for developers at the planning stage.
03 Why It Matters
Data-centre water debates are increasingly moving upstream into planning and permitting rather than being addressed only after a site has been selected.
An EIA requirement changes when water questions must be answered. Developers may need to establish water-source availability, cooling demand, seasonal stress, abstraction constraints, wastewater pathways, stormwater effects and interactions with local water infrastructure before planning approval is secured.
The Scottish direction is also notable because it does not treat closed-loop cooling as equivalent to zero water impact. It recognizes that closed-loop systems can reduce cooling-water demand while still placing water resources within the environmental review.
For utilities and engineering teams, this creates a stronger incentive to define the water balance early. A project that reaches detailed design before confirming local water availability or discharge constraints can face redesign, infrastructure upgrades or permitting delays later.
04 ATLAS Engineering View
From an engineering perspective, the important threshold is not simply 50 MW of electrical capacity. The practical issue is that projects above that threshold now need a defensible environmental case that includes water.
A robust data-centre EIA should distinguish potable or utility supply, non-potable alternatives, cooling make-up, blowdown, process-water treatment residuals, sanitary flows, stormwater and emergency conditions. Seasonal and drought scenarios should be considered where local supply is sensitive.
Closed-loop cooling can materially reduce water demand, but system-level performance still depends on heat-rejection configuration, climate, concentration cycles, water quality and blowdown management. Dry or hybrid cooling may reduce water dependence further but can introduce energy, footprint or noise trade-offs.
The wider signal is that data-centre water strategy is becoming a front-end siting and planning issue. For large projects, a credible water balance and wastewater pathway are increasingly part of development risk management, not optional sustainability reporting.